Justia Civil Rights Opinion Summaries

In the midst of a group contacted by officers for smoking cannabis on the street, 16-year-old T.F.-G. witnessed first one and then another of his companions be restrained, searched, and made to sit on the curb as the officers worked their way through the group. T.F.-G. ran. Chased, tackled, and punched, he was arrested for resisting or delaying a peace officer (Pen. Code 148(a)). In a search incident to that arrest, the police found a loaded handgun in his pocket, which T.F.-G. was not licensed to carry.The court of appeal affirmed his convictions. The totality of the circumstances, establishing the existence of probable cause for his arrest for resisting or delaying a peace officer—the asserted basis for the eventual search that revealed his possession of a loaded handgun in public–indicated that a reasonable person in T.F.-G.’s position would have understood he was not free to leave. The court also rejected a Second Amendment facial challenge to the prohibition on the unlicensed public carrying of loaded firearms. Although California’s “good cause” licensing requirement is undisputedly unconstitutional under the Supreme Court’s 2022 “Bruen” decision, the unconstitutionality of a discrete licensing requirement does not render section 25850 facially unconstitutional. View "In re T.F.-G." on Justia Law

Plaintiff was brutally beaten by three Maryland corrections officers because they believed he had taken part in an assault on another officer. He sued their warden along with the officers who attacked him and their direct supervisors. A federal jury awarded Plaintiff $700,000. The warden appealed. He argued that this case should never have proceeded to trial because Plaintiff failed to exhaust his administrative remedies before suing. He also believes the district court should have found that the evidence failed to support the jury’s verdict and that he was entitled to qualified immunity.
The Fourth Circuit affirmed the district court. The court held that Plaintiff was not required to exhaust because no administrative remedies were available, the evidence supports the jury’s verdict, and the warden was not entitled to qualified immunity based on the facts found by the jury. The court explained that this case was properly tried before a jury because inmates cannot receive any relief through Maryland’s administrative grievance proceedings when the Intelligence and Investigative Division is investigating the subject matter of the grievance. And the jury’s role in trials is enshrined in the Seventh Amendment for good reason. Resolving factual disputes, weighing the evidence, and determining whom to believe is within its province. When a jury performs these functions, the court will not disturb its conclusions based on a cold record unless those conclusions lack evidentiary support. Here, the evidence was sufficient to support the jury’s conclusions. And based on how the jury resolved these issues, the warden’s conduct violated clearly established law. View "Kevin Younger v. Tyrone Crowder" on Justia Law

The Supreme Court reversed the judgment of the court of appeal that a Department of Insurance regulation prohibiting bail bond agents from entering into agreements with jail inmates to be notified when individuals have recently been arrested and thus may be in need of bail bond services was facially invalid under the First Amendment, holding that the court of appeal erred in holding that the regulation was unconstitutional on its face.In declaring the regulation constitutionally invalid the court of appeal concluded that the regulation imposed burdens on the free speech rights of bail bond agents that were not adequately justified by the State's interests in deterring abusive bail solicitation practices. The Supreme Court reversed, holding that the regulation burdened a protected speech right, that intermediate scrutiny applied, and that the regulation passed constitutional muster. View "People v. Martinez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the trial court's judgment concluding that the at-large method of electing city council members in the City of Santa Monica diluted Latino voters' ability to elect their preferred candidates and their ability to influence the outcome of council elections, holding that the court of appeals misconstrued the California Voting Rights Act of 2001, Cal. Elec. Code 14025 et seq. (CVRA).The superior court ruled in favor of Plaintiffs on their claims that the racially polarized voting in the City violated the CVRA. The superior court ruled in favor of Plaintiffs and ordered the City to conduct a special election using a seven-district map drafted by an expert who testified at trial. The court of appeal reversed, concluding that there had been no dilution of Latino voters' ability to elect their preferred candidates or their ability to influence the outcome of the election. The Supreme Court reversed, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) because the court of appeal did not evaluate the dilution element of the CVRA under the proper standard, remand was required. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

Plaintiff sued Defendant, a corrections officer, under 42 U.S.C. Section 1983, alleging a violation of his constitutional rights while Plaintiff was a detainee at a jail in Minnesota. Defendant moved for summary judgment based on qualified immunity. The district court denied the motion.   The Eighth Circuit affirmed. The court explained that qualified immunity protects governmental officials from suit under 42 U.S.C. Section 1983 unless a plaintiff shows that the official’s alleged conduct violated a clearly established right of the plaintiff. The court wrote that because Plaintiff was a detainee at the time of the incident, his relevant constitutional rights arise under the Due Process Clause of the Fourteenth Amendment. Defendant argued that he did not violate Plaintiff’s clearly established right under the Fourteenth Amendment. He maintains that no constitutional violation occurred because “manual contact with a detainee’s genitals may be necessary as part of a search.” The court explained that as a general proposition, it is clearly established that “the sexual assault of an inmate by a guard violates the inmate’s constitutional rights.” The court explained that right is violated when a government official’s conduct is so egregious “that it may fairly be said to shock the contemporary conscience.” Plaintiff asserts that Defendant subjected him to a strip search and, without legitimate penological justification, grasped his naked penis, squeezed it hard, and gestured. Viewing the facts in the light most favorable to Plaintiff, a jury could find that the alleged conduct constituted sexual abuse or assault. View "Wilbert Glover v. R. Paul" on Justia Law

Petitioner the Freedom Foundation requested the identities and workplace contact information for Washington state public employees. To prevent disclosure of this information, affected employees sought declaratory and injunctive relief through the Washington State Federation of State Employees and other labor unions (Unions). The Unions alleged their members, who were victims of domestic violence, sexual abuse, stalking, and harassment, possessed a constitutional liberty interest in personal security that the government would violate by releasing the requested information. The courts below agreed. On appeal, the Foundation argued no such fundamental right existed, the Unions lacked standing, and the Unions failed to bring justiciable claims. During the course of this case, the Washington State Legislature enacted a law exempting the requested information from disclosure under the Public Records Act (PRA), ch. 42.56 RCW. The Washington Supreme Court held the Unions had standing and brought justiciable claims on behalf of their members. However, the Unions did not demonstrate particularized harm to affected public employees; therefore, they did not satisfy the PRA injunction standard. The Court thus affirmed the Court of Appeals on these grounds. The Supreme Court reversed the Court of Appeals’ ruling on declaratory relief because this matter could be resolved on nonconstitutional grounds. Accordingly, the Court remanded this case to the superior court to apply the new statutory exemption. View "Wash. Fed'n of State Emps., Council 28, v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction of one count of possession of synthetic drugs, holding that the circuit court did not err in denying Defendant's motion to suppress evidence recovered from his backpack.In his motion to suppress, Defendant argued that the warrantless search of his backpack violated the Fourth Amendment of the federal constitution and section ten of the state constitution. The circuit court denied the motion, finding that the search of Defendant's backpack was lawful as a search incident to his lawful arrest. The court of appeals reversed, holding that the underlying search was unconstitutional. The Supreme Court reversed, holding that the trial court properly concluded that the search was a lawful search incident to Defendant's arrest. View "Commonwealth v. Bembury" on Justia Law

In this interlocutory appeal the First Circuit affirmed the decision of the district court granting Defendant's motion to suppress items seized during a traffic stop, holding that the government was not entitled to relief on its allegations of error.Defendant was stopped by a New Hampshire police officer for failing to use a turn signal on a road that narrowed from two lanes to one lane. After the officer discovered that Defendant had outstanding arrest warrants the officer arrested Defendant and seized a bag from him containing narcotics. Defendant moved to suppress the evidence on the grounds that New Hampshire law did not require use of a turn signal at the merge point on the roadway at issue. The district court agreed and granted the motion to suppress. The First Circuit affirmed, holding (1) it was not objectively reasonable for the officer to rely on a yield sign in the roadway to govern the factual situation he was encountering; and (2) it was not a reasonable mistake of law for the officer to believe that a turn signal was required at the merge point. View "United States v. Potter" on Justia Law

The First Circuit vacated Appellant's conviction for willfully violating 18 U.S.C. 922(n) - the federal prohibition on the receipt of a firearm by someone "under indictment for a crime punishable by imprisonment for a term exceeding one year" - and vacated Appellant's sentence, holding that an instructional error and the application of a "trafficking of firearms" enhancement were in error.Appellant was convicted of violating 18 U.S.C. 922(n) and 18 U.S.C. 922(a)(1)(A), the federal prohibition on "dealing in firearms" without a license. The First Circuit vacated the judgment in part, holding (1) the trial court erred in instructing the jury as to the "willfully" element of the section 922(n) offense; (2) remand was required for an evidentiary hearing on Appellant's claim of actual conflict of defense counsel under the Sixth Amendment; and (3) the trial court erred in applying the "trafficking" enhancement, and the error was not harmless. View "United States v. Daniells" on Justia Law

Over 20 years ago, taxpayers sued Kentucky and Sunrise, a religiously affiliated organization, for alleged violations of the Establishment Clause by paying for religious services that Sunrise allegedly imposed on children in state custody. The Sixth Circuit remanded the approval of a 2013 settlement. In 2015, the parties replaced monitoring provisions that mentioned Sunrise with general language about “any Agency.” The Third Circuit held, for the third time, that the plaintiffs had standing to bring their Establishment Clause claim but that the 2015 Amendment required new regulations or modifications to existing regulations for implementation, which meant the Amendment violated Kentucky law. In 2021 Kentucky and the plaintiffs jointly moved to dismiss the case with prejudice. Kentucky agreed to pursue new regulations in good faith; certain provisions of the Agreement would not take effect unless those regulations were adopted. The Settling Parties did “not” seek to have the court retain jurisdiction for enforcement, nor to incorporate the Agreement in the order of dismissal.Noting that the motion was filed by “the parties to the sole remaining claim,” the Establishment Clause claim against Kentucky, the district court dismissed the case. The court refused to address the terms of the 2021 Agreement, which was not properly before it. The Sixth Circuit affirmed. “Sunrise no doubt is frustrated to find itself unable to vindicate the legality of its program” but federal courts do not decide constitutional issues in the abstract. View "Pedreira v. Sunrise Children's Services, Inc." on Justia Law