Justia Civil Rights Opinion Summaries

Appellant Attorney Kezhaya represented The Satanic Temple, Inc., in its lawsuits against the City of Belle Plaine, Minnesota. The Temple sued the City, claiming that the City opened a limited public forum for a Christian monument, but closed the forum to exclude a Satanic monument. The City sought $33,886.80 in attorney’s fees incurred by responding to the complaint in the second lawsuit and preparing the motion for sanctions. The court determined that the rates charged by the City’s counsel were reasonable but observed that a portion of the work was duplicative of the first lawsuit and that the issues unique to the second lawsuit were not complex, novel, or difficult. The court thus reduced the requested amount by fifty percent and ordered the Temple’s counsel to pay the City $16,943.40 under Rule 11(c). Kezhaya appealed the sanctions order. He argues that the district court abused its discretion by (i) imposing sanctions, (ii) failing to consider non-monetary sanctions, and (iii) granting an arbitrary amount of sanctions.   The Eighth Circuit affirmed. The court explained that under the circumstances, it disagreed with Kezhaya’s contention about the righteousness of a second lawsuit. For the claims dismissed “without prejudice” in the first lawsuit, Kezhaya and the Temple made a strategic choice to seek leave to amend the complaint to correct the deficiencies identified in the dismissal order. Further, the court found that even if the City’s insurance carrier ultimately paid the fees, the fees were “incurred” for the motion and could be awarded under Rule 11(c)(2). View "Matthew Kezhaya v. City of Belle Plaine" on Justia Law

McElhaney’s daughter, L.M., played high school softball. The school's “Parent–player Information” sheet stated: “Playing time is a non-negotiable for coaches to talk directly with parents about.” L.M.’s playing time decreased. McElhaney texted Coach Williams to express his displeasure. Williams responded, indicating McElhaney should reconsider either his tactics or his participation. McElhaney texted a conciliatory reply but Williams forwarded the messages to Principal Stepp, who banned McElhaney from a week’s worth of softball games. McElhaney unsuccessfully challenged but did not honor the suspension. Stepp spotted McElhaney and asked him to leave. Fearing arrest, McElhaney left. He filed suit (42 U.S.C. 1983), asserting that his communications with Williams constituted First Amendment-protected speech and that the school officials had impermissibly retaliated against him for exercising those speech rights and did not afford him due process before infringing on his property right to his season tickets. The district court held that the right to attend games after criticizing the coach was not clearly established, meaning any purportedly retaliatory acts did not violate McElhaney’s settled constitutional rights and that McElhaney did not experience a due process violation because any alleged injury could be remedied through a breach of contract action.The Sixth Circuit reversed. It is clearly established at a low level of generality that when a school employee interacts with a student, speech by the student’s parent about those interactions enjoys First Amendment protection. On remand, the court must resolve whether retaliation occurred. View "McElhaney v. Williams" on Justia Law

Hill and Combs kidnapped 12-year-old Fife, beat Fife, raped him in multiple ways, strangled him, bit his genitals, sodomized him, and burned him. Fife’s father found him in a field. Fife died days later. Several witnesses testified that Hill was around the crime scene. The state introduced Hill’s confession that he had watched Combs beat and rape Fife. There was physical evidence. One witness testified that Hill had raped her in the same wooded area and another testified that Hill had raped her multiple times. Hill was sentenced to death in 1986. Ohio courts rejected Hill’s appeal and state habeas petition.Hill’s 1996 federal habeas petition challenged the denial of expert assistance on bitemark evidence. While an appeal was pending, the Supreme Court decided “Atkins.” On remand, the state court determined that Hill was not intellectually disabled; his death sentence stood. Following a remand by the Supreme Court and various Sixth Circuit decisions, Hill sought a new trial based on “newly discovered evidence,” a report from the American Board of Forensic Odontology that suggested using bitemarks to identify a specific individual might not be reliable. Ohio courts held that there was “no probability” that a new trial would lead to a “different outcome” because the state had proffered so much other evidence of guilt.Hill’s second federal habeas petition argued that the state trial court violated his due process rights by not properly conducting a materiality review of the bitemark evidence. The Sixth Circuit characterized Hill’s petition as “second or successive,” so Hill was required to meet the gatekeeping provisions of 28 U.S.C. 2244(b)(2). Under Hill's interpretation, "Hmost convictions involving forensic evidence would never be final." View "In re: Hill" on Justia Law

The Supreme Court affirmed as modified Defendant's convictions for two counts of first degree murder and two counts of use of a firearm to commit a felony, holding that the record was insufficient to address certain claims, and there was otherwise no merit to his arguments on direct appeal.Specifically, the Supreme Court held (1) there was no plain error in the admission of evidence regarding a prior shooting; (2) there was no plain error in the prosecution's remarks; (3) the record was insufficient to address several of Defendant's numerous claims of ineffective assistance of trial counsel, and there was no merit to Defendant's remaining ineffective assistance of counsel claims; and (4) the sentencing order must be modified to reflect a sentence of life imprisonment for each of Defendant's convictions for first degree murder. View "State v. Mabior" on Justia Law

Plaintiff sued two Texas state officials, asserting that they violated his right to procedural due process when they notified him that he was required to register as a sex offender under Texas law. After a bench trial, the district court entered judgment in Plaintiff’s favor.   The Fifth Circuit vacated and remanded. The court concluded that Plaintiff’s suit is barred by sovereign immunity. The court explained that Sovereign immunity under the Eleventh Amendment precludes suits by private citizens against states in federal court. This bar extends not only to the state itself, but also to claims against “state officials” in their official capacity when the state is the real party in interest. The court explained that here, Plaintiff is suing state officials who have not waived sovereign immunity. Accordingly, his claims are barred in federal court unless an exception to sovereign immunity applies. Moreover, the court explained that because the district court’s order invalidated a federal statute—instead of affirming it—invoking the exception here would not advance Ex parte Young’s aim of “promoting the vindication of federal rights.” View "Tawakkol v. Vasquez" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Appellants' return-of-property motion and Appellants' request to quash and unseal search warrants, holding that Nevada's return-of-property statute, Nev. Rev. Stat. 179.085, allows a property owner to seek the return of privileged materials that were seized pursuant to a valid search warrant even when the government has an ongoing investigation.Appellants moved under section 179.085 for the return of the various documents and electronic devices seized at Appellants' business establishments on the basis that the property contained privileged materials. Appellant also sought to quash and unseal the warrants. The district court denied the motion, determining that it was not unreasonable for LVMPD to retain the property during an ongoing investigation and that the search protocol proposed by LVMPD was a reasonable resolution of the privilege issue. The Supreme Court reversed in part, holding that the district court (1) properly denied Appellants' request to quash and unseal the warrants; (2) erred when it denied Appellants' return-of-property motion without giving Appellants an opportunity to demonstrate privilege; and (3) erred by adopting LVMPD's proposed search protocol. View "In re Search Warrants re Seizure of Documents" on Justia Law

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