Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its authority to grant extraordinary relief, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial judge erred in excluding evidence that law enforcement officers found illegal narcotics in a vehicle occupied by the victim and in the victim's clothing and that the judge's ruling "deprived the defense of the plausible alternative theory that rival drug dealers committed the murder." The Supreme Judicial Court disagreed and affirmed, holding (1) there was no evidentiary error in the proceedings below; (2) as to the firearm conviction, the trial court's failure to instruct the jury on licensure requirements was harmless beyond a reasonable doubt; and (3) the verdict of murder in the first degree was consonant with justice and should stand. View "Commonwealth v. Bookman" on Justia Law

Plaintiff alleged was assaulted by his daughter’s ex-boyfriend and the ex-boyfriend’s cousin outside his house in Camden County, Missouri, in December 2011. He reported the assault to the Camden County Sheriff’s Department the following May. After no charges were brought, Plaintiff filed a civil suit against the alleged assailants. While pursuing his civil suit, Plaintiff claimed he discovered that the sheriff’s department refused to investigate the assault because the assailants were related to the county’s clerk of court. This refusal meant that Plaintiff could obtain very little evidence of the assault. Plaintiff then filed an action against officials in the sheriff’s department for claims under 42 U.S.C. Section 1983 and the Missouri Constitution. He claimed that Defendants’ inadequate investigation deprived him of his equal protection and due process rights. Defendants moved to dismiss Plaintiff’s complaint for lack of standing. They also moved for summary judgment. The district court granted summary judgment to the Defendants and denied their motion to dismiss as moot. Plaintiff appealed.   The Eighth Circuit vacated the district court’s grant of summary judgment as to Plaintiff’s federal claims and remanded with instructions to dismiss these claims for lack of standing. The court affirmed to Plaintiff’s state law claims.  The court explained that it has not yet addressed whether a crime victim has standing to sue a government official for an inadequate investigation. However, the court has held that a crime victim cannot sue a government official for failing to prosecute his assailant. View "Jeffery Pratt v. Tony Helms" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of burglary in the second degree, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's constitutional rights to confrontation, to present a defense, and to a fair trial under the Sixth and Fourteenth Amendments to the federal constitution were not violated during the underlying proceedings; and (2) assuming, without deciding, that the trial court abused its discretion when it limited defense counsel's cross-examination of the victim on the ground that the proffered line of questioning was speculative, Defendant failed to satisfy his burden of proving harm. View "State v. Lanier" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for the City of Worcester and several of its officers and dismissing Plaintiff's constitutional and tort claims, holding that the individual defendants were entitled to qualified immunity and that neither they, nor the City, were liable for the alleged torts.The Worcester police used a SWAT team to execute a warrant at a residential apartment where they expected to find a rape suspect but instead found Plaintiff, who was nineteen years old, thirty-eight weeks pregnant, and not conversant in English. Plaintiff began experiencing contractions shortly after the entry, and gave birth the following day. Plaintiff, who was later diagnosed with post-traumatic stress disorder, brought this lawsuit. The district court granted summary judgment for Defendants, concluding that the officers did not violate Plaintiff's constitutional rights and that, even if they did, they were entitled to qualified immunity. The First Circuit affirmed, holding that Plaintiff's claims failed. View "Penate v. Sullivan" on Justia Law

Marvin’s mother called the police to perform a wellness check; she thought Marvin, age 21, was suicidal. St. Joseph County Sheriff’s Deputies arrived at Marvin’s home and found his mother in the driveway with a bleeding lip. She stated that Marvin had hit her with a chair. The officers approached the house to speak with Marvin, who declined to exit the house. During the confrontation, the deputies saw Marvin’s father remove a box cutter from Marvin’s pocket. They pulled him from the doorway and wrestled him to the ground. While he resisted, they tased him twice and struck him several times. Marvin sued the deputies for unlawful entry and excessive force. Marvin admitted that he was uncooperative but claimed he was not threatening or violent and that he suffered a concussion and a broken toe.Marvin brought claims under 42 U.S.C. 1983 against the deputies for unlawful entry and excessive force, in violation of his Fourth Amendment rights. The Seventh Circuit affirmed the dismissal of the unlawful entry claims against Officer Corban, who had not helped pull Marvin from his house, and the excessive force claims against Officer Lawson-Rulli, who was not involved in tasing or hitting Marvin. Corban and Holcomb’s use of force was reasonable as a matter of law. The court also affirmed a defense verdict on Marvin’s unlawful entry claims against Holcomb and Lawson-Rulli. View "Marvin v. Holcomb" on Justia Law

The City of Los Angeles (the “City”) brought an action against Plaintiffs for abatement, unfair competition, and public nuisance regarding their ownership of a motel. Plaintiffs appealed from the district court’s dismissal of their first amended complaint for failure to state a claim. After the Los Angeles County Sheriff’s Department (the “Sheriff’s Department”) seized $98,000 from Plaintiffs pursuant to a state court judgment, Plaintiffs brought this 42 U.S.C. Section 1983 action alleging that the failure to provide pre-seizure notice violated their constitutional rights.   The Ninth Circuit affirmed the district court’s judgment dismissing. The panel concluded that the district court correctly held that Plaintiffs failed to state a claim for violation of procedural due process. The panel considered the Mathews v. Eldridge, 424 U.S. 319 (1976), factors. First, the competing interests strongly weighed against a conclusion that Plaintiffs’ procedural due process rights were violated. The City as creditor had a clear interest in collecting the money judgment because it prevailed before the California trial court and on appeal, and Plaintiffs did not allege that the funds were exempt or were needed for subsistence. Second, the risk of erroneous deprivation under California’s procedures was small because the procedures required the clerk of the court only to transcribe the amount of the money judgment and take account of statutory defenses like the exemptions asserted by a judgment debtor. Finally, given the small risk of erroneous deprivation, the value of the substitute procedure proposed by Plaintiffs did not outweigh the strong interests of the City. View "NANUBHAI PATEL, ET AL V. CITY OF LOS ANGELES, ET AL" on Justia Law

In 2018, Plaintiff filed a federal Terry action against the City of Pasadena and several of its police officers seeking to recover for the death of Reginald Thomas, a father figure to Plaintiff. The Terry action, which included a section 1983 claim, was dismissed with prejudice for lack of Article III standing in 2019. Plaintiff then filed a nearly identical lawsuit in California state court, which the Defendants removed to federal court and successfully moved to dismiss based on issue preclusion.   The Ninth Circuit vacated the district court’s dismissal of Plaintiff’s Section 1983 action brought against Defendants. The panel held that a plain reading of the first district court’s judgment established that Article III standing was actually litigated and decided, although erroneously. However, erroneous, unappealed judgments are still owed preclusive effect. The panel concluded that issue preclusion was available, and Plaintiff was bound by the prior standing determination. While issue preclusion was available, the panel held that the Defendants waived issue preclusion by removing the refiled case to federal court because a removing defendant voluntarily invokes and acquiesces to the federal courts and bears the burden of establishing subject-matter jurisdiction and Article III standing. Accordingly, the panel vacated and remanded to the second and current district court to determine, in the first instance, whether jurisdiction lies in the federal courts and whether Plaintiff adequately stated a claim if the Defendants pursue such an argument on remand. View "SHANE LOVE V. AARON VILLACANA, ET AL" on Justia Law

The Fifth Circuit denied Plaintiff’s motion for leave to proceed IFP and dismissed his appeal failure to pay filing fees pursuant to 28 U.S.C. Sections 1911–14. The court barred Plaintiff from proceeding IFP in any civil action or appeal filed while he is incarcerated or detained in any facility unless he is in imminent danger of serious physical injury as defined by Section 1915(g).   The Fifth Circuit denied Plaintiff’s motion to proceed IFP and dismissed his appeal for failure to pay the required filing fees. The court held that that the district court did not abuse its discretion in denying Plaintiff’s motion to proceed IFP. He has accumulated more than three strikes and has failed to demonstrate imminent danger in this case. The court barred him from proceeding IFP in any civil action or appeal filed while he is incarcerated or detained in any facility unless he is in imminent danger of serious physical injury as defined by Section 1915(g). Alternatively, he may pay the appropriate fees. He may resume any claims dismissed under Section 1915(g), if he decides to pursue them, under the fee provisions of 28 U.S.C. Sections 1911–14. View "Prescott v. UTMB" on Justia Law

Tennessee enacted the Prohibition on Medical Procedures Performed on Minors Related to Sexual Identity, citing concerns that gender dysphoria treatments “can lead to the minor becoming irreversibly sterile, having increased risk of disease and illness, or suffering adverse and sometimes fatal psychological consequences” while less risky, non-irreversible treatments remain available. Prohibited procedures include surgically removing, modifying, or entering into tissues, cavities, or organs and prescribing or dispensing any puberty blocker or hormone with exceptions for treating congenital defects, precocious puberty, disease, physical injury, and continuation of ongoing treatment. It provides for professional discipline of healthcare providers and creates a private right of action.The district court entered a preliminary injunction, finding that the challengers lacked standing to contest the surgery ban but that the ban on hormones and puberty blockers infringes the parents’ “fundamental right” to direct their children’s medical care, improperly discriminates on the basis of sex, that transgender persons constitute a quasi-suspect class, and that the state could not satisfy the necessary justifications.The Sixth Circuit stayed the injunction, finding that Tennessee is likely to succeed on appeal. The district court erred in its facial invalidation of the law, as opposed to an as-applied invalidation. “Life-tenured federal judges should be wary of removing a vexing and novel topic of medical debate from the ebbs and flows of democracy by construing a largely unamendable federal constitution to occupy the field.” A right to new medical treatments is not “deeply rooted" in history and traditions. Tennessee could rationally exercise caution before permitting irreversible medical treatments of children. View "L. W. v. Skrmetti" on Justia Law

In 2012, Horton was convicted of multiple drug trafficking and firearm crimes. Horton had been convicted of four prior state drug felonies. The court imposed three concurrent life sentences. Horton’s direct appeal and collateral relief motion under 28 U.S.C. 2255, failed. Under 2255(h) a successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.” Horton filed a habeas petition under 28 U.S.C. 2241, citing the “saving clause,” 28 U.S.C. 2255(e); a 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit previously held (Davenport) that 2255 is “inadequate or ineffective”— and 2241 is available—when the limits on successive 2255 motions bar relief and the prisoner’s claim is based on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Horton's Davenport claim challenged his sentences based on the Supreme Court’s 2016 Mathis decision.In the interim, the Supreme Court decided Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy 2255’s conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all." The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Horton v. Lovett" on Justia Law