Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree for the killing of Brandy Waryasz on theories of premeditation and felony-murder and murder in the first degree for the killing of Dane Anthony Hall, on a theory of felony-murder, but reversed his conviction for armed robbery, holding that the conviction must be dismissed as duplicative of the felony-murder conviction.Defendant attacked Waryasz while she was working at a gas station by tightly wrapping a ligature around her neck. Waryasz, who was seven months pregnant with Hall, died from a constricted airflow, killing her son within minutes of his mother. Defendant was indicted for two murders and armed robbery and convicted on all charges. Defendant later filed a motion for a new trial, which the superior court denied. The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree but vacated and set aside the armed robbery conviction, holding (1) as to Defendant's murder convictions, he was not entitled to relief on his allegations of error, and there was no ground for granting relief pursuant to Mass. Gen. Laws ch. 278, 33E; and (2) the armed robbery conviction was duplicative of the felony-murder conviction for the killing of Hall and therefore must be dismissed. View "Commonwealth v. Bateman" on Justia Law

Plaintiff filed a Section 1983 civil rights suit in Louisiana state court against Louisiana Department of Public Safety and Corrections Secretary James LeBlanc. Among other claims, Plaintiff argued that LeBlanc violated his constitutional rights by misclassifying him as a sex offender and thereby illegally extending his detention in prison for 337 days past his release date. LeBlanc sought dismissal based on qualified immunity, but the district court denied the motion. LeBlanc argued that this complaint did not adequately allege the requisite “pattern” of constitutional violations by untrained employees “ordinarily necessary” under Connick to establish deliberate indifference for purposes of failure to train.   The Fifth Circuit affirmed. The court agreed with Plaintiff that his complaint sufficiently alleges the requisite “pattern” of constitutional violations by untrained employees to establish deliberate indifference for purposes of failure to train. Further, the court held that there is sufficient clearly established law regarding the constitutional right to a timely release from prison and that Plaintiff has sufficiently argued a violation of the right. Accordingly, construing the allegations in the light most favorable to Plaintiff, the court agreed they are sufficient to support the argument that LeBlanc had fair warning’ that his failure to address this delay would deny prisoners like Plaintiff their immediate or near-immediate release upon conviction. View "Parker v. LeBlanc" on Justia Law

Coopwood has bipolar disorder and schizophrenia. She was institutionalized several times from 2010-2017. On August 13, 2017, Coopwood (six months pregnant) stopped taking her antipsychotic medications because of concerns about potential effects on the fetus. Coopwood fatally stabbed her mother and was ultimately found “guilty but mentally ill.”In pretrial custody, Coopwood, not taking her antipsychotic medications, was repeatedly screened and denied any history of mental health treatment. Employees, aware of Coopwood’s history of inpatient psychiatric care, did not raise concerns. Coopwood alleges that, in August 2017, Jailer Watts dragged her to her cell and kicked Coopwood in the stomach, after which she suffered cramping with a bloody discharge from her vagina. She was hospitalized several times in August and September. On October 19, she was seen by a psychiatrist, Haddad, who determined that Coopwood had been psychotic for an unknown period and seemed unaware of her circumstances. On October 22, Coopwood, exhibiting bizarre behavior, was forcibly given antipsychotic medications. She was readmitted on November 8, reporting contractions. Labor was induced. Coopwood’s baby was stillborn. Coopwood contends that she attempted to file a grievance but that her verbal requests were ignored.Coopwood’s suit, alleging excessive force and deliberate indifference to her medical needs, was dismissed. The Sixth Circuit reversed. Defendants failed to establish the absence of a genuine dispute of material fact as to whether the Jail’s staff thwarted Coopwood’s attempts to exhaust her administrative remedies. View "Coopwood v. Wayne County, Michigan" on Justia Law

Plaintiff argues that former Broward County Public Defender Howard Finkelstein fired her from her position as a public defender in violation of her First Amendment rights. Finkelstein fired Plaintiff after she made public comments during her campaign to replace Finkelstein, who was not seeking reelection. Specifically, Plaintiff claimed on a political podcast that Finkelstein played golf rather than work, did not hire racial minorities or support black social justice organizations, and had used illegal drugs while practicing law earlier in his career. Based on these comments, Finkelstein terminated Plaintiff's employment after the primary election, which Plaintiff had lost to another employee of the office. The district court granted summary judgment to Finkelstein. It concluded that many of Plaintiff’s statements about Finkelstein were eligible for First Amendment protection because they were made on matters of public concern. But, balancing Plaintiff’s interests against her employer’s interests, the district court concluded that her interest in making these statements did not outweigh the government’s interest in the effective management of the public defender’s office.   The Eleventh Circuit affirmed. The court concluded that Plaintiff’s termination cannot support a claim for retaliation in violation of the First Amendment. The court wrote that it is yet to consider whether and how a public employee’s political campaign to replace her supervisor impacts her interest in criticizing that supervisor. Although the court recognized that an employee seeking public office has a strong interest in criticizing the elected official currently holding that position, the court believes the employer’s interest in effective management outweighs the employee’s interest when the employee’s criticisms are likely to frustrate the employer’s mission. View "Ruby Green v. Howard Finkelstein, et al" on Justia Law

Hunter was housed in a general-population wing of “Unit H” at Redgranite Wisconsin state prison. Patterson, Hunter’s cellmate March-December 2017, was regarded as a “lifer” and a “violent individual.” On multiple occasions, Patterson told Hunter that he would beat him while he slept. Hunter communicated Patterson’s threats to Mueske, the Unit H supervisor with authority over housing assignments. Hunter told Officer Walker about Patterson’s threats. At Walker’s suggestion, Hunter filled out an Inmate Complaint form, dated August 9. Walker typically notifies his superiors and drafts an incident report when he learns of threats between inmates, but he did not do so. Wilcox decided to move Patterson out of Unit H on December 6, 2017, but not due to Hunter’s complaints.On the day of Patterson’s move, Hunter approached Patterson, purportedly to say goodbye. Hunter claims that Patterson flew into a rage, accusing Hunter of causing Patterson’s reassignment. Patterson testified that Hunter called him various derogatory terms, including the N-word. Patterson violently battered Hunter and stomped on his head, causing Hunter permanent injuries and triggering his PTSD from his time in the military. The altercation was captured on video. In Hunter’s suit under 42 U.S.C. 1983, the district court granted Mueske and Walker summary judgment. Hunter offered no facts from which a reasonable jury could find that Walker acted with deliberate indifference or that Mueske’s conduct caused his injury. View "Hunter v. Mueske" on Justia Law

The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

Plaintiff brought a Section 1983 claim against prison officials for their conduct during an electrical fire at Sing Sing Correctional Facility. Meanwhile, the prison officials claim that Plaintiff received a denial but failed to appeal. The district court determined that Plaintiff had not exhausted his administrative remedies and granted summary judgment to the officials. Plaintiff claimed that he received a denial and then appealed through the second and third stages of review.The Second Circuit vacated. The court explained that drawing all reasonable inferences in Plaintiff’s favor, there is a genuine dispute of material fact as to whether Plaintiff exhausted his administrative remedies. The prison officials may have mistakenly failed to consolidate Plaintiff’s grievance with those of the other inmates who were affected by the electrical fire—in a possible violation of state regulations requiring full consolidation. Plaintiff’s declaration is consistent with a belief that his grievance was denied as part of the consolidated group of grievants. He may have appealed that denial, but the prison system might not have a record of his appeal because it failed to record the denial of his initial grievance in the first place. Plaintiff’s declaration—combined with (1) the undisputed evidence that he filed an initial grievance, (2) the absence of documentary evidence that his complaint was ever denied, and (3) the apparent failure of the prison officials to consolidate his complaint with those of the other inmates—creates a dispute of material fact as to whether Plaintiff actually did pursue all administrative remedies that were “available” to him. 42 U.S.C. Section 1997e(a). View "Garcia v. Heath" on Justia Law

Defendants Cpl. John Lee and Cpl. Derek Barker appealed the district court’s denial of their motion for summary judgment seeking qualified immunity from Plaintiffs’ unlawful entry and excessive force claims. The Fifth Circuit unanimously concluded that Lee and Barker are not entitled to qualified immunity from Plaintiffs' unlawful entry claims. However, the court held that Lee is entitled to qualified immunity for any force employed from the moment he entered Plaintiffs' house. The court explained that, including the significant fact that the dog was deployed as a wholly duplicative means of detention, no precedent establishes under analogous circumstances how long a bite is too long. Thus, a jury could not find that every reasonable officer would have known that a K9-trained dog had to be released more quickly. Even if Officer Lee mistakenly permitted Dice to bite Plaintiff for a minute, qualified immunity shields him from suit as well as liability. View "Smith v. Lee" on Justia Law

A kitchen supervisor directed Balle, an Illinois state prisoner, to carry near-boiling water across a wet, damaged floor in a plastic five-gallon bucket. His foot caught in a hole, and he fell down. The water splashed on him and caused severe burns. Balle sued several prison officials, claiming they violated the Eighth Amendment by being deliberately indifferent to the dangerous kitchen conditions. The district court dismissed some of Balle’s claims at the pleading stage and granted summary judgment on the others.The Seventh Circuit affirmed in part. The record lacks sufficient evidence to create a genuine dispute as to the subjective knowledge of two defendants. Viewing the record in the light most favorable to Balle, a reasonable jury could conclude that the kitchen conditions represented an objectively serious danger to inmates, but gaps in the record prevent a jury from inferring that the two actually knew about the conditions that made the kitchen seriously dangerous–that inmates had to carry scalding water across the damaged floor. The court reversed in part, reinstating the claim against the kitchen supervisor, who required the inmates to carry the scalding water. The court affirmed the denial of a motion to recruit counsel. View "Balle v. Kennedy" on Justia Law

Miller, who describes himself as “an active wine consumer,” asserts that he wants to order wine from out-of-state retailers and would like to be able to buy wine in other states and transport that wine back into Ohio for his personal use. House of Glunz is an Illinois wine retailer and alleges that it wishes to ship wine directly to Ohio consumers but cannot. Miller and Glunz challenged the constitutionality of Ohio liquor laws preventing out-of-state wine retailers from shipping wine directly to Ohio consumers and prohibiting individuals from transporting more than 4.5 liters of wine into Ohio during any 30-day period.The district court held that the Direct Ship Restriction is constitutional under binding Sixth Circuit precedent; the Director of the Ohio Department of Public Safety is entitled to Eleventh Amendment immunity from the claims; and the plaintiffs lack standing to challenge the Transportation Limit. The Sixth Circuit affirmed the Director of the Ohio Department of Public Safety’s Eleventh Amendment immunity, reversed with respect to the Direct Ship Restriction and the plaintiffs’ standing to challenge the Transportation Limit. On remand, the district court shall determine whether the challenged statutes “can be justified as a public health or safety measure or on some other legitimate nonprotectionist ground,” and whether their “predominant effect” is “the protection of public health or safety,” rather than “protectionism.” View "Block v. Canepa" on Justia Law