Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the trial court convicting Defendant of several crimes in connection with a murder in the city of Hartford in 2002, and remanded this case for a new trial, holding that Defendant's constitutional right to counsel was violated and that, therefore, he was entitled to a new trial on all counts.On appeal, Defendant argued that the State violated its obligation under Messiah v. United States, 377 U.S. 201 (Conn. 1964), to respect and preserve the invocation of his right to counsel under the Sixth Amendment by using a jailhouse informant deliberately to elicit incriminating statements from Defendant. The Supreme Court agreed and reversed Defendant's convictions, holding that the trial court's denial of Defendant's motion to suppress the informant's testimony was improper and that Defendant was entitled to a new trial. View "State v. Ashby" on Justia Law

Jesse Aquirre's family filed a 42 U.S.C. 1983 action alleging that the San Antonio Police Department violated Aguirre's constitutional rights by causing his death through the use of excessive force. The district court granted summary judgment to the individual officers based on qualified immunity and to the City of San Antonio.The Fifth Circuit reversed the district court's grant of summary judgment for the officers in regard to the excessive force claims. The court weighed the Graham factors and concluded that the first Graham factor—the severity of any crime of which Aguirre was suspected—weighs in favor of it being unreasonable and excessive for the officers to hold Aguirre in the dangerous maximal-restraint position for five and a half minutes, and there are at very least genuine disputes as to the second two Graham factors—whether Aguirre posed a safety threat to officers or others or was resisting the officer's efforts to remove him from the highway and hold him safely until the police wagon arrived. The court explained that these disputes of material facts alone are enough to preclude a finding of summary judgment that the force used by the officers in holding Aquirre in a hog-tie position was constitutionally reasonable. Under Graham and its progeny, the court concluded that it is unreasonable for an officer to use injurious force against a non-resisting, non-dangerous individual who is not suspected of a serious crime, which the court must assume occurred here under Aguirre's version of events. The court also concluded that the summary judgment evidence indicates that a reasonable officer in the officers' position would have known that applying the maximal-restraint position to Aguirre and holding him in this position for an extended period posed a substantial risk of causing his death or serious bodily injury. Therefore, a reasonable jury could find that the officers' use of force constituted "deadly force." Accordingly, the officers are not entitled to summary judgment based on qualified immunity.However, the court affirmed the district court's grant of summary judgment on plaintiffs' deliberate indifference claims. Finally, the court affirmed the district court's dismissal of plaintiffs' municipal liability claim; rejected plaintiffs' claims against the City under the Texas Tort Claims Act; and granted the motion to supplement the record and denied the motion to take judicial notice as moot. The court remanded for further proceedings. View "Aguirre v. City of San Antonio" on Justia Law

The Ninth Circuit affirmed the district court's denial of petitioner's habeas corpus petition challenging his California state conviction and death sentence for two first-degree murders. The panel granted a certificate of appealability (COA) on the claims related to ineffective assistance of counsel (IAC). In this opinion, the panel addressed the certified claims as well as the previously uncertified claim (Claim 48), namely whether trial counsel failed to present evidence of mental impairments at the penalty phase.The panel applied the deferential standards imposed by the Antiterrorism and Effective Death Penalty Act (AEDPA) and concluded that the California court's inferred conclusions were not an unreasonable application of clearly established Federal law or based on an unreasonable determination of the facts. The panel held that presenting the jailhouse informant's testimony would not have created a reasonable probability that petitioner would not have been convicted as an aider and abettor in two murders. Therefore, lead counsel at the guilt phase was not ineffective for failing to investigate and present evidence from the informant. Furthermore, counsel did not render deficient performance by failing to raise petitioner's mental impairments as mitigating evidence at the penalty phase; the panel did not review petitioner's argument that the state court made an unreasonable determination of the facts under 28 U.S.C. 2254(d)(2) because this claim rests on an issue of state law; and the panel upheld the district court's denial of habeas relief on petitioner's proportionality claim. View "Sanchez v. Davis" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, sexual battery of a person under twelve years old, and kidnapping, and the imposition of the death penalty, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error in failing to grant Defendant's motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial on account of the interruption to the testimony of the state's expert; (3) the trial court did not abuse its discretion in denying Defendant's motion to exclude autopsy photographs during certain testimony; (4) Defendant was not entitled to relief on his claim that the state made inappropriate comments in its opening statement and in closing argument; and (5) there was no cumulative error in this case. View "Smith v. State" on Justia Law

A Mississippi jury convicted Jones of murder for killing his grandfather when Jones was 15 years old. Under Mississippi law, murder carried a mandatory sentence of life without parole. That sentence was affirmed on appeal. The Supreme Court subsequently held, in Miller v. Alabama, that the Eighth Amendment permits a life-without-parole sentence for a defendant who committed homicide when he was under 18 only if the sentence is not mandatory and the sentencer has the discretion to impose a lesser punishment. The Mississippi Supreme Court ordered that Jones be resentenced. The judge at resentencing acknowledged that he had discretion under Miller to impose a sentence less than life without parole but determined that life without parole remained the appropriate sentence. The Supreme Court had recently held (Montgomery v. Louisiana) that Miller applied retroactively on collateral review. The Mississippi Court of Appeals rejected Jones’s argument that, under Miller and Montgomery, a sentencer must make a separate factual finding that a murderer under 18 is permanently incorrigible before sentencing the offender to life without parole.The Supreme Court affirmed. In the case of a defendant who committed homicide when he was under 18, Miller and Montgomery do not require the sentencer to make a separate factual finding of permanent incorrigibility before sentencing the defendant to life without parole; a discretionary sentencing system is both constitutionally necessary and constitutionally sufficient. The cases require consideration of an offender’s youth but not any particular factual finding nor an on-the-record sentencing explanation with an “implicit finding” of permanent incorrigibility before sentencing a murderer under 18 to life without parole. Jones's resentencing complied with Miller and Montgomery because the sentencer had discretion to impose a sentence less than life without parole in light of Jones’s youth. View "Jones v. Mississippi" on Justia Law

The Fifth Circuit affirmed the district court's grant of qualified immunity and summary judgment to defendant on plaintiff's 42 U.S.C. 1983 claims, alleging that defendant, an off-duty sheriff's deputy at the time, used excessive force when he shot her several times. Plaintiff had emerged from a stopped vehicle and would not follow defendant's demands, and when she reached behind her waist, defendant feared that she might be reaching for a weapon and shot her. The court concluded that defendant made a split second decision to use deadly force against a non-compliant person who made a movement consistent with reaching for a weapon, and plaintiff failed to identify clearly established law prohibiting defendant's use of deadly force.Plaintiff also alleged that defendant shot her in retaliation for engagement in activity protected by the First Amendment. The court agreed with the district court that plaintiff did not present evidence that her speech and expressive conduct was a but-for cause of the shooting. In this case, defendant did not discharge his firearm at plaintiff when she began shouting expletives at him or when she was walking towards him. Rather, he shot her when she reached her hand behind her back towards the waistband of her pants. Finally, plaintiff has not shown that defendant responded to her medical needs with deliberate indifference. View "Batyukova v. Doege" on Justia Law

After the University dismissed plaintiff from its medical residency program, plaintiff filed suit for wrongful termination and alleged that the University discriminated against her based on age and disability, as well as retaliated against her.The Eighth Circuit affirmed the district court's grant of summary judgment for the University, concluding that the University established a legitimate, non-discriminatory reason for plaintiff's termination. In this case, assuming that plaintiff made a prima facie case for age discrimination, the University produced a legitimate, nondiscriminatory reason for terminating plaintiff by explaining that she made an egregious error affecting patient safety despite supervisor and attending efforts. Furthermore, plaintiff failed to show evidence of pretext. The court also concluded that plaintiff failed to make a prima facie case of discrimination under the Americans with Disabilities Act because there are no genuine issues of material fact as to whether the University regarded her as disabled at the time before her termination. View "Canning v. Creighton University" on Justia Law

The Supreme Judicial Court reversed Defendant's conviction of two counts of assault and battery by means of a dangerous weapon resulting in serious injury, holding that the trial court judge erred in excluding one of Defendant's experts, and this error was prejudicial.At trial, Defendant argued that he acted in self-defense and that the two men involved in the altercation were motivated to attack him by racial animus. To support his theory, Defendant sought to introduce the testimony of two experts who would testify that the tattoo found on one of the men was affiliated with a group that espoused white supremacist beliefs. The judge excluded both efforts on reliability grounds. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that the trial judge abused his discretion in excluding the testimony of one of the experts, and this error was prejudicial. View "Commonwealth v. Hinds" on Justia Law

The Supreme Court affirmed Defendant's convictions for three felony counts of privacy in communications, in violation of Mont. Code Ann. 45-8-213(1)(a), holding that there were no prejudicial errors in the proceedings below.Specifically, the Supreme Court held (1) the Privacy in Communications statute, Mont. Code Ann. 45-8-213(1)(a), is not facially overbroad, nor does it constitute a content-based restriction on speech in violation of the "freedom of speech" clauses of the Montana and United States Constitutions; (2) the district court correctly interpreted the Privacy in Communications statute; (3) there was insufficient evidence to conclude that there was jurisdiction when the threatening communication was made to a person located outside of Montana; and (4) the district court fully and fairly instructed the jury in accordance with the charges and evidence presented. View "State v. Lamoureux" on Justia Law

Plaintiff filed suit against defendant, a deputy in the sheriff's office, under 42 U.S.C. 1983, alleging that plaintiff's Fourth Amendment rights were violated when the deputy seized his iPhone after plaintiff took photos and videos of a car accident crash scene from an interstate median. The district court granted summary judgment on all of plaintiff's claims except for one, which plaintiff prevailed at trial.The Eleventh Circuit affirmed the district court's order, holding that plaintiff's First Amendment claim is barred by qualified immunity because defendant did not violate clearly established law at the time; plaintiff's false-arrest claims fail because defendant had probable cause to arrest him because plaintiff's car was parked on a limited-access facility in violation of Florida law; and plaintiff's excessive-force claim fails on the merits and, in any event, is barred by qualified immunity. The court noted that, whether it analyzed plaintiff's excessive-force claim under the Fourteenth or Fourth Amendment, the court would reach the same result. View "Crocker v. Beatty" on Justia Law