Justia Civil Rights Opinion Summaries

The Supreme Court denied a petition for writ of certiorari and/or prohibition requesting relief from the Court after the circuit court denied Petitioner's motions to dismiss the charges against him, holding that an extraordinary writ was not necessary in this case.Petitioner, who was charged with aggravated robbery and other charges, moved to dismiss the charges for a violation of his right to a speedy trial pursuant to Ark. R. Crim. P. 28.1, asserting that he was not brought to trial within twelve months from the date of his arrest. Petitioner also filed a motion to dismiss for lack of jurisdiction, alleging that the juvenile division retained exclusive jurisdiction. The circuit court denied both motions. The Supreme Court denied Petitioner's ensuing petition for writ of certiorari and/or prohibition, holding that the circuit court did not err in denying Petitioner's motions to dismiss for lack of jurisdiction and for violation of his speedy-trial rights. View "Tilson v. State" on Justia Law

In 2020, Lafayette City Councilmember and former Mayor, Burks, and his wife, Ackley, hosted an open house in their home in support of a school bond measure. The invitation stated Burks was “hosting this event as an individual resident of Lafayette and a father of school-aged children.” Peterson attended and had an “odd” and “stilted” conversation with Ackley in which Peterson referred to Ackley's birthday. Peterson later reposted on his Facebook page a family photo from Ackley’s public Facebook page. In the comments, Peterson wondered where they hid the girls during the open house. He mused, “They live near Burton Valley School … Burks, has a different name than his wife, I wonder what their daughters’ last name is?” Burks felt Peterson “could be a threat” to his wife and daughters. Later, Ackley received a “confusing” letter and check in the mail from Peterson, again mentioning the daughters. The rambling letter was a screed against local politics.Peterson was convicted of stalking and sentenced to two years of probation, with one year of home confinement. The court of appeal reversed. Peterson’s speech acts were constitutionally protected activities. A reasonable listener would not have found Peterson’s speech or speech-related acts a true threat of violence. View "People v. Peterson" on Justia Law

Plaintiff brought both a Section 1983 false arrest claim and a state law false arrest claim against two Huntsville, Alabama, police officers and the City itself. The district court concluded that the officers were entitled to qualified immunity, and Plaintiff appealed.   The Eleventh Circuit reversed the district court’s grant of qualified immunity. The court explained that, in general, when government officials are performing discretionary duties, as all parties concede they were in this case, they are entitled to qualified immunity. A plaintiff may rebut this entitlement by showing that the government officials (1) committed a constitutional violation; and (2) that this violation was “clearly established” in law at the time of the alleged misconduct.   The court explained that it has been clearly established for decades that the police are free to ask questions, and the public is free to ignore them. It has been clearly established prior to Plaintiff’s arrest that any legal obligation to speak to the police and answer their questions arises as a matter of state law. And the state statute itself, in this case, is clear and requires no additional construction: police are empowered to demand from an individual three things: “name, address and an explanation of his actions.” It was thus clearly established at the time of Plaintiff’s arrest that Defendant could not demand he produce physical identification. Thus, no reasonable officer could have believed there was probable cause to arrest Plaintiff for obstructing governmental operations. And this theory cannot support the grant of qualified immunity to the officers. View "Roland Edger v. Krista McCabe, et al" on Justia Law

Plaintiff pled guilty to two counts of first-degree murder in 2012 and received a life sentence at the Louisiana State Penitentiary (“LSP”). Plaintiff claims Defendants should be personally liable under 42 U.S.C. Section 1983 for his conditions of confinement from August 2012 to June 2017, which he alleges violated the Fourteenth and Eighth Amendments. On remand, the district court directed the parties to file supplemental memoranda addressing qualified immunity and prescription and referred the matter to a magistrate judge. The magistrate judge recommended dismissal for failure to state a claim. The district court adopted the magistrate judge’s recommendation and dismissed Plaintiff’s claims. Plaintiff appealed.   The Fifth Circuit affirmed. The court explained that as to the Fourteenth Amendment, the magistrate judge correctly stated that restrictive confinement, like Plaintiff’s grounds for a due process claim, only if it “imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.” Applying that standard, the judge properly considered the severity and duration of the confinement. Further, as to Plaintiff’s Eighth Amendment claim, the magistrate judge correctly stated that such a claim requires showing both that a prisoner faces conditions so dire as to deprive him of “the minimal civilized measure of life’s necessities” and that the responsible prison officials were “deliberately indifferent” to the inmate’s health or safety. Finally, the court wrote that confinement to a cell for twenty-three hours per day did not violate the Eight Amendment, where the inmate nonetheless could converse with other inmates, receive visitors, and engage in some form of exercise or other recreation. View "LaVergne v. Stutes" on Justia Law

=O.B. who was attending the University on a football scholarship, repeatedly and violently assaulted Plaintiff, his fellow student, in an off-campus house where O.B. was living with other university football players. At the time of the assault, university officials knew that O.B. had repeatedly and violently assaulted two other female undergraduates the previous year. Plaintiff sued the University under Title IX. The district court granted summary judgment to the University.   The Ninth Circuit reversed the district court’s summary judgment. The en banc court held that to obtain damages under Title IX for student-on-student harassment, a plaintiff must show (1) that the educational institution had substantial control over both the harasser and the context in which the known harassment occurs; (2) that the harassment was so severe, pervasive, and objectively offensive that it denied its victims the equal access to education that Title IX is designed to protect; (3) that a school official with authority to address the alleged discrimination and to institute corrective measures has actual knowledge of the discrimination; (4) that the school acted with deliberate indifference to the harassment; and (5) that the school’s deliberate indifference must cause students to undergo harassment. The en banc court held that evidence in the record would support a conclusion by a reasonable factfinder that University officials had actual knowledge or notice of O.B.’s violent assaults and that Erika Barnes, the University’s Title IX liaison within the Athletics Department, was an official who had authority to address O.B.’s assaults and to institute corrective measures. View "MACKENZIE BROWN, ET AL V. STATE OF ARIZONA, ET AL" on Justia Law

MyPillow, Inc. and Chief Executive Officer Michael Lindell (collectively, “Lindell”) appealed the district court’s denial of their motions for a preliminary injunction and for the return of property—Lindell’s cell phone that was seized by federal agents on September 13, 2022. The basis of Lindell’s action arises from an ongoing federal investigation into the individuals responsible for publishing forensic images of election software used in the 2020 election in Mesa County, Colorado. He argued on appeal that the federal investigation violates his First Amendment rights of freedom of speech, freedom of association, freedom of the press, and the right to petition for the redress of grievances. He also contended the search warrant for his phone violates the Fourth Amendment’s prohibition against general warrants.   The Eighth Circuit affirmed the district court’s denial of Lindell’s motion for a preliminary injunction. The court reversed the district court’s decision not to exercise equitable jurisdiction over Lindell’s motion for the return of property as it relates to the continued retention of the cell phone itself and all its data. The court explained that it is unable to determine from the record whether the government can reasonably justify its continued refusal to return Lindell’s cell phone, which at this point was seized nearly a year ago, or the data on it, which is entirely unrelated to the offenses the government is investigating. Accordingly, the court remanded for the district court to hold a prompt hearing and balance the government’s interest in retaining Lindell’s cell phone and all its data against Lindell’s right to get the property back. View "Michael Lindell v. United States" on Justia Law

Plaintiff is a black female educator and school administrator who works for the Brookhaven School District (the “School District”). Plaintiff sought to attend the Mississippi School Board Association Prospective Superintendent’s Leadership Academy, a training program for prospective superintendents. According to Plaintiff, the School District “established a precedent of paying for every employee’s fees after the employee was accepted to attend the program.” Plaintiff asked the Deputy Superintendent, if the School District would pay for her to attend the Leadership Academy. Once the program accepted Plaintiff, the School District’s Superintendent reneged and refused to pay for her to attend at that time. But Plaintiff’s spot was for the upcoming class, so she paid the fees herself. Plaintiff sued, alleging that the School District violated Title VII and 42 U.S.C. Section 1981 by refusing to pay for her to attend the Leadership Academy but agreeing to pay for similarly situated white males to attend. The district court dismissed Plaintiff’s claims under Federal Rule of Civil Procedure 12(c).   The Fifth Circuit reversed. The court held that Plaintiff set forth a plausible Title VII claim under Rule 12 because plausibly alleged facts that satisfy both adverse employment action prongs and the adverse employment action element was the only element in dispute. The court explained, taking Plaintiff’s allegations as true—that the School District (1) agreed to pay for similarly situated white males’ fees to attend the Leadership Academy; (2) promised to pay her fees (a promise she relied on); and (3) reneged on that promise—Plaintiff plausibly stated a Title VII disparate treatment claim. View "Harrison v. Brookhaven Sch Dist" on Justia Law

Plaintiffs’ neighbor petitioned for a civil harassment restraining order against Plaintiffs and was granted a temporary restraining order. As a result of the TRO, Plaintiff was ordered to surrender his firearms to a California licensed firearms dealer. Certain California laws make it unlawful for any person subject to a “civil restraining order” issued by a California state court (including temporary restraining orders) to possess firearms or ammunition. Plaintiffs claim these laws violate the Second Amendment and the Due Process Clause of the United States Constitution as applied to them. Though Plaintiffs were subject to civil restraining orders when they filed their suit, the orders against them have expired, and in January 2023, a California court denied the latest request to extend them.   The Ninth Circuit dismissed Plaintiffs’ action as moot. The panel rejected Plaintiffs’ argument that, although they were no longer subject to any firearm restrictions, the case fell within the “capable of repetition, yet evading review” exception to mootness. The panel noted that this doctrine is to be used sparingly, in exceptional situations, and generally only where (1) the challenged action is in its duration too short to be fully litigated prior to cessation or expiration, and (2) there is a reasonable expectation that the same complaining party will be subject to the same action again. The panel held that this case was moot because the relevant restraining orders have expired, a three-year-long restraining order is not too brief to be litigated on the merits, and there was no reasonable expectation that Plaintiffs will be subject to the same action again View "MIRANDA WALLINGFORD, ET AL V. ROBERT BONTA, ET AL" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree manslaughter and aggravated assault and sentencing him to life imprisonment, holding that Defendant's sentence did not violate the Eighth Amendment.Defendant pled guilty to first-degree manslaughter and aggravated assault. The circuit court sentenced Defendant to life without the possibility of parole for first-degree manslaughter and to a term of fifteen years for aggravated assault to run concurrently with his life sentence. Defendant appealed, arguing that his life sentence constituted cruel and unusual punishment and that the circuit court abused its discretion by imposing a life sentence without the possibility of parole. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion. View "State v. Caffee" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying the claims in Michael Duane Zack, III's fourth successive postconviction motion and denied Zack's motion for stay of execution and request for oral argument, holding that Zack was not entitled to relief.Defendant was sentenced to death for the murder of Ravonne Smith and was scheduled for execution on October 3, 2023. In his successive postconviction motion Defendant claimed that his execution should be barred under the Eighth Amendment. The postconviction court summarily denied the claims as untimely, procedurally barred, and meritless. The Supreme Court affirmed and denied Zack's motion for stay of execution and request for oral argument, holding that the postconviction court did not err by summarily denying Defendant's claims as untimely, procedurally barred, and meritless. View "Zack v. State" on Justia Law