Justia Civil Rights Opinion Summaries

Plaintiff, the owner of a chain of pharmacies in Maryland and nearby states, was the subject of a Medicaid fraud prosecution. After the district court dismissed the charges against plaintiff, he filed suit seeking compensatory and punitive damages from multiple defendants. At issue on appeal are two of the district court's preliminary rulings.The Fourth Circuit affirmed the district court's dismissal of the federal constitutional claims, concluding that these claims would extend the Bivens remedy into a new context, and that special factors counsel against an extension to cover intertwined allegations of wrongdoing by prosecutors and criminal investigators in plaintiff's prosecution. However, the court reversed the district court's determination that the state-law claims can move forward against Prosecutor Pascale. Rather, the court found that absolute prosecutorial immunity bars the claims against her. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Annappareddy v. Pascale" on Justia Law

After Eli Gauna, Jr. committed suicide while being held in the Bell County jail as a pretrial detainee, his mother filed suit against the licensed clinical social worker who was the mental health professional that evaluated Gauna and took him off suicide watch. The district court granted summary judgment for the social worker, concluding that she was entitled to qualified immunity and had not acted with deliberate indifference to Gauna's serious medical needs.The Fifth Circuit reversed, concluding that the social worker, as an employee of a private organization systematically organized to perform a major administrative task, is not entitled to qualified immunity. Furthermore, plaintiff provided sufficient evidence regarding whether the social worker knew about Gauna's suicide risk to raise a genuine dispute of material fact over whether the social worker was deliberately indifferent to Gauna's medical needs. In this case, the social worker knew of Gauna's suicidal ideations and chose to have him taken off suicide watch, placing him into the general population where he would have access to tie-off points and ligatures, including the bedsheets with which he eventually hanged himself. Accordingly, the court remanded for further proceedings. View "Sanchez v. Oliver" on Justia Law

After defendants were charged with attempting to enter the United States illegally, the government prosecuted them on the normal criminal docket. Defendants moved to dismiss the charges, arguing that the government should have prosecuted them through the Central Violations Bureau (CVB) process, but the district court denied the motion.The Ninth Circuit held that the government did not violate defendants' right to equal protection by prosecuting illegal border crossings on the normal criminal docket. The panel explained that the policy does not discriminate against a protected class or infringe a fundamental right. Instead, it distinguishes between defendants based on their criminal conduct—in this case, illegally entering the United States. And since criminal defendants are not a protected class, at most the rational basis test applies. Applying the rational basis test, the panel concluded that the government's decision to prosecute first-time illegal entry separately from other petty offenses passes constitutional muster. In this case, defendants have not carried their burden to negate "every conceivable basis" which might support the government’s decision to prosecute them on the normal criminal docket. Therefore, the government's policy is supported by a rational basis and does not violate equal protection. View "United States v. Ayala-Bello" on Justia Law

The Ninth Circuit reversed the district court's denial of a stay and abeyance pending exhaustion of unexhausted claims under Rhines v. Weber, 544 U.S. 269 (2005). In this case, petitioner filed a 28 U.S.C. 2254 petition challenging the constitutionality of his conviction and capital sentence. The district court concluded that petitioner lacked good cause under Rhines for his failure to exhaust because his state postconviction counsel's ineffective assistance of counsel (IAC) was not sufficiently egregious. However, the panel subsequently held in Blake v. Baker, 745 F.3d 977 (9th Cir. 2014), that IAC by a petitioner's state-court counsel satisfies the good cause standard under Rhines. Therefore, the district court erred in applying the standard the panel later rejected in Blake and the panel remanded for the district court to apply the proper standard. View "Bolin v. Baker" on Justia Law

An Alaska jury convicted Wright of 13 counts of sexual abuse of a minor. Wright finished serving his sentence and moved to Tennessee. Once there, he failed to register as a sex offender as required by the Sex Offender Registration and Notification Act, 34 U.S.C. 20913. Wright pleaded guilty to failure to register and received a sentence of time served plus supervised release. During those federal proceedings, Wright filed a petition for a writ of habeas corpus in Alaska under 28 U.S.C. 2241 and 2254, arguing that the Alaska Supreme Court had unreasonably applied clearly established federal law when it denied his Sixth Amendment claims and affirmed his 2009 state conviction and sentence. The district court denied the motion, reasoning that Wright was not in custody pursuant to the judgment of a state court. The Ninth Circuit reversed, reasoning that Wright’s state conviction was “ ‘a necessary predicate’ ” to his federal conviction. The Supreme Court vacated. Section 2254(a) permits a federal court to entertain an application for a writ of habeas corpus on behalf of a person “in custody pursuant to the judgment of a State court.” A habeas petitioner does not remain “in custody” under a conviction “after the sentence imposed for it has fully expired, merely because of the possibility that the prior conviction will be used to enhance the sentences imposed for any subsequent crimes.” That Wright’s state conviction served as a predicate for his federal conviction did not render him “in custody pursuant to the judgment of a State court.” If Wright’s second conviction had been for a state crime, he independently could have satisfied section 2254(a)’s “in custody” requirement, though his ability to attack the first conviction would have been limited. View "Alaska v. Wright" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2254 habeas corpus petition in a case where petitioner was convicted of two murders and sentenced to death.The court concluded that petitioner's trial attorneys were not prejudicially ineffective by failing to further investigate and present to the jury evidence of his mental illness, cognitive deficits, and brain damage, and by failing to investigate and present evidence of additional mitigating family background and social history. The court concluded that the state court's rejection of these claims was neither contrary to nor an unreasonable application of clearly established Supreme Court law, nor was it based on an unreasonable determination of the facts in light of the evidence presented. The court was similarly unpersuaded regarding petitioner's procedural and substantive claims of incompetency to stand trial. Furthermore, petitioner's due process rights were not violated when he was required to wear a stun belt at trial. The court rejected petitioner's several claims of prosecutorial misconduct. Finally, the court concluded that it was not contrary to or an unreasonable application of clearly established law for the Georgia Supreme Court to have concluded, on direct review, that the prosecutor's violation of petitioner's Fifth Amendment rights by commenting on his failure to testify was harmless beyond a reasonable doubt. View "Raheem v. GDCP Warden" on Justia Law

Plaintiff and his son filed suit against three officers under 42 U.S.C. 1983, alleging violations of the Fourth Amendment, violation of the Iowa Constitution, and common law invasion of privacy. The district court denied summary judgment, but reversed in part and remanded for trial. On remand, the district court held a trial on the state law claims, as well as the federal excessive force claim. On the state claims for invasion of privacy and Iowa illegal search or seizure, the district court granted judgment as a matter of law. The jury found in favor of defendants on the excessive force claims.In Wilson I, the Eighth Circuit ruled that defendants' acts were reasonable as a matter of law. The court explained that the substantive standard for search and seizure does not vary between Iowa and federal law. Therefore, any error was harmless, since it would not change the result: regardless of who theoretically must show the officers' conduct was reasonable, defendants did show their conduct was reasonable. Accordingly, the district court did not err in granting judgment as a matter of law and denying plaintiff's motion for a new trial on the state search and seizure claims. The court also concluded that the district court did not err in granting judgment as a matter of law and denying plaintiff's motion for a new trial on the invasion of privacy claim. In this case, plaintiff cannot state a claim for intrusion upon seclusion because the officers' conduct was not a highly offensive intrusion on the private affairs or concerns of plaintiffs, and the stop of plaintiff's vehicle was lawful. The court also concluded that the district court properly instructed the jury on the elements of Fourth Amendment and Iowa Constitution excessive force claims. Because the Iowa Supreme Court's standard for excessive force does not materially differ from the federal standard, the court explained that the district court did not need to separately instruct the jury. Accordingly, the court affirmed the judgment. View "Wilson v. Lamp" on Justia Law

Petitioner, an inmate on death row in Texas, filed a federal habeas application under 28 U.S.C. 2254, arguing that his counsel was constitutionally ineffective in numerous ways at trial and sentencing. Petitioner's convictions stemmed from his murder of his wife, son, and step-daughter. The Fifth Circuit granted a certificate of appealability on four of petitioner's issues.As a preliminary matter, the court concluded that petitioner's notice of appeal was timely and thus the court has jurisdiction. The court affirmed the district court's denial of habeas relief, concluding that the state court's decision was not contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court, or was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. In this case, the court concluded that petitioner is not entitled to relief on the basis that the state court improperly resolved the claim that any partial jurors were seated; on the basis of the claim involving the jurors who expressed opposition to interracial marriage; and on the basis of ineffective assistance of counsel for failing to challenge petitioner's competency to stand trial, in rebutting the voluntary-intoxication theory, and in presenting a mitigation defense. View "Thomas v. Lumpkin" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court denying Defendant's motion to suppress, holding that, under the circumstances presented in this case, the police had reasonable suspicion to conduct a brief investigatory detention of Defendant, and the stop did not violate the parameters of the Fourth Amendment.In response to an anonymous 911 call that provided the location and license plate of a vehicle driven by a possibly intoxicated driver, the responding police officer located he vehicle in a parking lot, knocked on the window, and spoke to Defendant, who admitted to having had multiple drinks and that his driver's license was revoked. Defendant was arrested after he was unable to successfully complete a field sobriety test. On appeal, Defendant argued that the anonymous call could not support a finding of reasonable suspicion. The Supreme Court affirmed, holding that, under the totality of the circumstances, the stop at issue comported with the reasonable suspicion requirement of the Fourth Amendment. View "Trott v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant's motion to suppress evidence seized during the search of his home, holding that a waiver of the "right against search and seizure" clearly informs the defendant that a search may be conducted without reasonable suspicion.When a defendant is processed for home detention, he normally signs an agreement in which he forgoes many of his rights. The agreement typically includes consent to allow community corrections to search the defendant's person or home to ensure compliance with the rules. Defendant in this case argued that the search of his home violated his Fourth Amendment rights because the contract he signed when he was placed on home detention didn't include a waiver of searches without reasonable suspicion. The trial court granted the motion to suppress. The Supreme Court reversed, holding that the contract unambiguously informed Defendant that he waived his right against search and seizure absent reasonable suspicion. View "State v. Ellis" on Justia Law