Justia Civil Rights Opinion Summaries

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

Chicago police arrested Lozano, who was subsequently charged with burglary and possession of burglary tools. Lozano moved to suppress evidence (a car radio, a wallet, and two screwdrivers) arguing that when the officers stopped, detained, and searched him, they neither possessed a warrant nor saw him committing any crimes and could not reasonably suspect that he had committed or was about to commit any crimes or that he was armed and dangerous. Officer Rodriguez testified that he and his partner were driving in an unmarked car, on patrol, and saw Lozano “running at a fast rate of speed” and holding his front pocket. It was raining and wet outside. Rodriguez made a U-turn and approached Lozano, who fled up the stairs of an apparently abandoned building. Rodriguez pursued Lozano and saw a “big bulge” in Lozano’s pocket. Rodriguez handcuffed Lozano, then touched his hooded sweatshirt and felt a rectangular box. He reached inside Lozano’s front pocket and recovered a wallet, two screwdrivers, and a radio. The wallet and radio had been taken from a parked car.The Illinois Supreme Court reversed the trial and appellate courts and held that the officers lacked reasonable suspicion to stop Lozano. The act of running in the rain while holding the front of his pocket did not provide a reasonable suspicion of criminal activity to justify an investigatory stop consistent with the Fourth Amendment and the Illinois Constitution. View "People v. Lozano" on Justia Law

Plaintiff was sitting on a bus when police officers boarded the bus, removed him, and arrested him on a misdemeanor bench warrant. Plaintiff, then 67 years old, was a resident of the City of Elmira (the "City"), in Chemung County (the "County"), New York. Plaintiff was taken to the County Jail, where an officer subjected him to a visual body cavity strip search. In addition, although Plaintiff’s girlfriend promptly posted his bail, his release was delayed about two hours. Plaintiff sued the County, the City, and officers in the County Sheriff's Department and City Police Department in the Western District of New York pursuant to 42 U.S.C. Section 1983. The district court dismissed the claims against the City and County at the outset of the case and eventually granted summary judgment dismissing the claims against the individual defendants as well.  Plaintiff appealed the dismissal of the claims against the individual defendants.   The Second Circuit affirmed in part, vacated in part, and remanded. The court explained that on the record, a reasonable jury could find that, instead of simply following the orders of a superior officer, the corrections officer was a party to harassment and demeaning conduct culminating in the search -- conduct that he, and other reasonable officers, should have known had no legitimate penological purpose and was therefore unconstitutional. The court explained that a jury may find otherwise, but in light of these disputed material facts, the district court erred when it granted summary judgment on Plaintiff’s strip search claim. View "Murphy v. Hughson et al." on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

The United States commenced an investigation of Mississippi’s mental health system. This investigation was not prompted any individual instance of discrimination against a person with serious mental illness. The United States filed suit against the state of Mississippi, alleging that its entire mental health care system violated the “integration mandate” prescribed by 28 C.F.R. Section 35.130(d) and reified in the Supreme Court’s decision, Olmstead v. L.C. ex rel. Zimring. The district court conducted a trial, upheld the federal government’s theory of liability, and ordered not only sweeping modifications to the state’s system but also the indefinite appointment of a monitor who would oversee the system. Mississippi contends that (1) the federal government has not proved a cause of action for discrimination in violation of the ADA (2) the court erred in rejecting its defense that remediation would require an impermissible “fundamental alteration” of its existing programs and (3) the court’s remedial order vastly exceeds the scope of claimed liability   The Fifth Circuit reversed. The court explained that the possibility that some un-named individual with serious mental illness or all such people in Mississippi could be unjustifiably institutionalized in the future does not give rise to a cognizable claim under Title II. The court further wrote that nor does such a vague and standardless theory license courts under the ADA to rework an entire state’s mental health system. Accordingly, the court held that the government did not prove that the state of Mississippi violated Title II pursuant to the statute, regulations, or Olmstead as properly construed. View "USA v. State of Mississippi" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated kidnapping, sexual intercourse without consent, and partner or family member assault, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) Mont. Code Ann. 45-5-303(2) is not facially unconstitutional because it permits a judge, rather than a jury, to apply factors that reduce the maximum penalty; (2) Defendant's level three offender designation was objectionable, not illegal, and Defendant did not properly reserve his objection to the designation during sentencing; and (3) Defendant's counsel was not ineffective for failing to argue that the maximum sentence for kidnapping was ten years based on mitigating factors and failing to object to Defendant's level-three sex offender designation. View "State v. Pine" on Justia Law

Creighton Preparatory School expelled Plaintiff after he made lewd remarks about a teacher. Plaintiff sued Creighton under Title IX of the Education Amendments of 1972 on the theory that the school had discriminated against him by failing to perform an “adequate and impartial investigation.” The district court granted Creighton’s motion to dismiss. It first dismissed the Title IX claim because Plaintiff had failed to “allege [that] his sex played any part in the disciplinary process at all.” Then, with the federal question gone, it declined to exercise supplemental jurisdiction over Plaintiff’s breach-of-contract claim.The Eighth Circuit affirmed. The court explained that Plaintiff does not allege that Creighton faced external pressure to punish male students, much less gave in by expelling him. The court reasoned that without an allegation of that kind, the complaint fails to plausibly allege the sort of “causal connection between the flawed outcome and gender bias” required to make an erroneous outcome theory work.Further, the court wrote that treating men and women differently can support an inference of sex discrimination, but it requires identifying a similarly situated member of the opposite sex who has been “treated more favorably.” For Plaintiff, he had to find “a female accused of sexual harassment” who received better treatment. There are no female students at Creighton, an all-boys school, let alone any who have faced sexual-misconduct allegations. The court explained that to the extent that Plaintiff argues that believing them over him raises an inference of discrimination, there is nothing alleged that the school did so because of his sex. View "Elijah Wells v. Creighton Preparatory School" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree, criminal possession of a firearm, and possession of a weapon in a motor vehicle, holding that the evidence was insufficient to support Defendant's conviction of possessing a weapon in a motor vehicle.Specifically, the Supreme Court held (1) any claimed error on the part of the trial court in violating Defendant's right to confront the witnesses against him under the Sixth Amendment by allowing the chief medical examiner to testify about the results of the victim's autopsy, which the chief medical examiner had not performed himself, was harmless; and (2) the evidence was insufficient to support Defendant's conviction of possessing a weapon in a vehicle in violation of Conn. Gen. Stat. 29-38(a). View "State v. Robles" on Justia Law