Justia Civil Rights Opinion Summaries

A Virginia statute required the automatic suspension of residents’ driver’s licenses if they failed to pay certain court fines and fees. in 2016, a group of indigent Virginians who lost their licenses when they were unable to pay court debts initiated a putative class action against the Commissioner of the Virginia Department of Motor Vehicles (“Commissioner”), alleging that the Commonwealth’s license-suspension scheme was unconstitutional. The plaintiffs raised several claims under the Fourteenth Amendment: that the statute’s requirement of automatic suspension without notice or a hearing violated their procedural due process rights; and that the statute’s enforcement against those who were unable, not unwilling, to pay violated both their substantive due process rights and their equal protection rights. As relief, the plaintiffs sought preliminary and permanent injunctions preventing the statute’s enforcement and requiring license reinstatement to the “hundreds of thousands of Virginians” with suspended licenses. Plaintiffs then petitioned for attorney’s fees under 42 U.S.C. Section 1988(b), which provides that the district court, “in its discretion, may allow the prevailing party” in Section 1983 actions “a reasonable attorney’s fee as part of the costs.”   The Fourth Circuit vacated the district court’s denial of attorney’s fees and remanded. The court held that Plaintiffs here prevailed” in every sense needed to make them eligible for a fee award. The court explained that the named plaintiffs sought not only reinstatement of their own licenses but also class certification, a declaratory judgment that Section 46.2-395 was unconstitutional, and hence permanent license reinstatement for hundreds of thousands of Virginians. Those are precisely the kinds of considerations that bear on the “extent of a plaintiff’s success” – a critical factor in assessing a reasonable fee award in any fee litigation under Section 1988. View "Damian Stinnie v. Richard Holcomb" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

Prude, serving an 80-year sentence, helped a friend and fellow inmate file a successful civil rights lawsuit against their Wisconsin prison. According to Prude, his friend, grateful for the help, sent him $10,000 of his $40,000 damages award to help Prude retain an attorney for his own appeal. The prison’s Security Director, Meli, characterized the check as the product of an illegal business arrangement, seized the funds as contraband, and launched an investigation, after which he charged Prude with violations of the Wisconsin Administrative Code, including lying, unauthorized use of the mail, threats, and enterprises and fraud. Prude had a disciplinary hearing and was found guilty; the $10,000 was permanently seized. Although Meli was an investigating officer who should have recused himself from the hearing process, Prude claims he controlled the hearing and directed the actions of the hearing officer, Westra, to ensure a finding of guilt and to prevent Prude from ever getting his money.“Despite statements from Meli and Westra before and during the hearing suggesting a predetermined outcome,” the district court dismissed Prude's claims against Westra at the screening stage and later granted Meli summary judgment on all remaining claims. The Seventh Circuit reversed; the evidence in the record plausibly supports a due process violation. View "Prude v. Meli" on Justia Law

High-level officials in the California prison system transferred 122 inmates from the California Institution for Men, where there was a widespread COVID-19 outbreak, to San Quentin State Prison, where there were no known cases of the virus. The transfer sparked an outbreak of COVID-19 at San Quentin that ultimately killed one prison guard and over twenty-five inmates. The guard’s family members sued the prison officials, claiming that the officials violated the guard’s due process rights. The officials moved to dismiss, arguing that they were entitled to qualified immunity. The district court denied the motion with respect to some of the officials, who then filed an interlocutory appeal.   The Ninth Circuit affirmed the district court’s denial of Defendants’ motion to dismiss. The panel held that based on the allegations in the complaint, Defendants were not entitled to qualified immunity. Plaintiffs sufficiently alleged a violation of the guard’s substantive due process right to be free from a state-created danger, under which state actors may be liable for their roles in creating or exposing individuals to danger they otherwise would not have faced. The panel held that the unlawfulness of defendants’ alleged actions was clearly established by the combination of two precedents: L.W. v. Grubbs, 974 F.2d 119 (9th Cir. 1992), which recognized a claim under the state-created danger doctrine arising out of a prison’s disregard for the safety of a female employee who was raped after being required to work alone with an inmate known to be likely to commit a violent crime if placed alone with a woman; and Pauluk v. Savage, 836 F.3d 1117 (9th Cir. 2016). View "PATRICIA POLANCO, ET AL V. RALPH DIAZ, ET AL" on Justia Law

In 2017, Elion pleaded guilty to three counts of distributing methamphetamine, 21 U.S.C. 841(a)(1) and (b)(1)(C). The Probation Office classified him as a career offender, U.S.S.G. 4B1.1(a), 4B1.2(b), yielding a heightened Guidelines range, 151–188 months, rather than 70-87 months. Elion’s attorney did not challenge the enhancement. Elion appealed his 167-month sentence, but his attorney moved to withdraw. Elion voluntarily dismissed his appeals. Months later, Elion filed a pro se motion to vacate, set aside, or correct his sentence, 28 U.S.C. 2255. Elion argued that had trial counsel objected to the career offender designation, he would have received a lower Guidelines range and a much-reduced sentence. Elion’s prior convictions were a 1999 Illinois conviction for unlawful delivery of a look-alike substance within 1,000 feet of public housing property, a 2000 Illinois conviction for unlawful delivery of a look-alike substance, and a 2006 federal conviction for distribution of a cocaine base.The Seventh Circuit reversed the denial of Elion’s motion. The Illinois look-alike statute punishes conduct more broadly than the Guidelines controlled substance offense, and it is indivisible. Elion should not have been sentenced as a career offender. The district court must examine whether his attorney’s performance was deficient under the Strickland standard. View "Elion v. United States" on Justia Law

Plaintiff appealed the district court’s judgment dismissing her claims of age, race, and gender discrimination and retaliation under the Age Discrimination in Employment Act, 29 U.S.C. Section 621 et seq., Title VII of the Civil Rights Act of 1964, 42 U.S.C. Section 2000e et seq., and the Civil Rights Act of 1866, 42 U.S.C. Section 1981. On appeal, Plaintiff argued that the district court applied an incorrect legal standard to her retaliation claim and that it erroneously concluded that she had failed to demonstrate that Defendants’ race-neutral explanations for not selecting her for two internal promotions were pretextual.   The Second Circuit affirmed. The court held that Plaintiff has not demonstrated that Defendants’ explanations for her non-promotions were pretextual. Second, the court held that although the district court applied an incorrect standard to her retaliatory hostile work environment claim, Plaintiff has nevertheless failed to make out a prima facie case of retaliation and did not demonstrate that her employer’s non-retaliatory explanations were pretextual. The court explained that Defendant’s evidence supporting summary judgment established that Plaintiff received negative performance evaluations because she was not adequately or timely completing her duties and had become increasingly challenging to work with. The court wrote that Plaintiff has not rebutted this showing with evidence demonstrating that the reasons the NYCTA provided for the poor performance reviews were pretextual. Instead, she argues that the performance reviews must have been retaliatory due to their temporal proximity to her complaints. But she offers nothing more to establish causation. View "Carr v. New York City Transit Authority" on Justia Law

In 2015, McBride was charged with first-degree murder, assault with intent to commit murder, carrying a concealed weapon, and carrying a firearm during the commission of a felony. After two trials, a jury convicted McBride on all charges. The Michigan Court of Appeals rejected his argument that the court erred in failing to admit his full police interview, that the evidence could not support his convictions, and that his counsel was ineffective. While his appeal was pending, McBride filed unsuccessful motions requesting a “Ginther” hearing to present evidence of his counsel’s ineffectiveness.In a brief to the Michigan Supreme Court, McBride first alleged that his due process rights were violated during his pretrial detention. That court returned this brief because McBride was represented by counsel. In a federal habeas claim, 28 U.S.C. 2244(d)(1), McBride alleged his due process and Miranda rights were violated during his arrest and detention; his trial counsel was ineffective; and the Michigan courts erred in various evidentiary rulings. The district court dismissed claims without prejudice, citing the unexhausted first claim. A year later, McBride moved for reconsideration, arguing for the first time that his exhausted claims should be allowed to proceed under the Supreme Court’s “Rhines” decision which gives courts facing both exhausted and unexhausted claims two options besides dismissal. The Seventh Circuit affirmed the denial of the motion, rejecting McBride’s argument that the district court should have sua sponte considered alternatives to dismissal. View "McBride v. Skipper" on Justia Law

John Telly King was murdered by a fellow inmate. King’s estate sued the South Carolina Department of Corrections prison guards on duty and their supervisors, alleging that they were deliberately indifferent to King’s safety and medical needs and, therefore, responsible for his death. A magistrate judge disagreed, granting summary judgment to the defendants, and King appealed.   The Fourth Circuit affirmed. The court explained that the prison guards on duty failed to violate a clearly established right so are entitled to qualified immunity. And Plaintiff failed to allege, or raise a disputed material fact of, any individual involvement by the supervisor Defendants. The court explained that nowhere does Plaintiff identify how each defendant violated the constitution. This is a prerequisite to a supervisory-liability claim. Nor does Plaintiff present a material dispute about any individual Defendant’s knowledge. Instead, Plaintiff only claims that Defendants “either maintained actual or constructive knowledge of the risk” (whatever that risk may be). The court wrote that this boilerplate conclusion—lacking defendant specificity and factual support— does not state a claim for relief or allow a plaintiff to get past summary judgment. View "David King v. Timothy Riley" on Justia Law

Plaintiff received his third citation for Driving While Intoxicated (“DWI”). As a term of his probation, Plaintiff, an alcoholic, was required to attend weekly substance abuse classes. Some of these classes conflicted with shifts that Plaintiff was scheduled to work as an operator at a plant owned by Defendant La Grange Acquisitions, L.P. Plaintiff informed his supervisors that he was an alcoholic and that several of the court-ordered substance abuse classes would conflict with his scheduled shifts. When Plaintiff was unable to find coverage for these shifts, La Grange, citing this scheduling conflict, terminated Plaintiff. After exhausting his administrative remedies, Plaintiff sued La Grange under the Americans with Disabilities Act (“ADA”), 42 U.S.C. Sections 12112 et seq., for intentional discrimination, failure to accommodate, and retaliation. The district court granted summary judgment in favor of La Grange on all three claims.   The Fifth Circuit affirmed. The court explained that here, the facts suggest only that a reasonable employer might have found that Plaintiff might have been seeking accommodation for his disability. To hold that La Grange was required to determine whether Plaintiff had a disability and needed accommodation in this situation would place the initial burden of identifying an accommodation request on the employer, not the employee. We cannot find that Plaintiff’s terse references to his struggles with drinking and self-identification as an alcoholic, made while discussing the legal implications of a recent DWI, were enough to place a legal responsibility on La Grange to probe whether Plaintiff was requesting a disability accommodation. View "Mueck v. La Grange Acquisitions" on Justia Law

In 1985, Clark and Devose assaulted and kidnapped a postal worker at gunpoint, stripped him of his uniform, and restrained him in his truck. Disguised in the uniform, Devose gained entry to a banker’s home, where they held the banker’s 85-year-old mother-in-law and 19-year-old daughter at gunpoint and called the banker to demand ransom. Clark raped the girl. They saw police outside and fled. Devose pleaded guilty and agreed to testify against Clark.In 1990, Clark was convicted of two conspiracy offenses, attempted extortion, assault of a postal worker, kidnapping, theft of a postal vehicle, and using a firearm during a crime of violence--kidnapping (18 U.S.C. 924(c)). Clark was sentenced to life imprisonment plus five years for the firearm count, to be served consecutively, as section 924 required. The Sentencing Guidelines did not then apply. Clark filed an unsuccessful appeal and numerous unsuccessful collateral attacks. In 2019, the Supreme Court held that part of section 924(c)’s definition of “crime of violence” is unconstitutionally vague.In Clark’s successive 28 U.S.C. 2255 motion, the parties agreed that kidnapping does not qualify as a section 924(c) crime of violence. The district court vacated Clark’s 924 conviction but declined to conduct a full resentencing. The Third Circuit dismissed an appeal for lack of jurisdiction. As a matter of first impression, the court held that a certificate of appealability is required for a prisoner in federal custody to appeal a district court’s choice of remedy in a 28 U.S.C. 2255 proceeding. View "Clark v. United States" on Justia Law