Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of second degree murder, unlawful discharge of a firearm, and two counts of use of a weapon to commit a felony, holding that there was no error in the trial judge's evidentiary rulings.On appeal, Defendant argued that the district court erred in admitting evidence of his character, specifically that he conducted drug deals after the murder, he was the victim of a robbery, and he owned firearms. Defendant also challenged cellular telephone information obtained from a "tower dump." The Supreme Court affirmed, holding (1) there was no error in the admission of the challenged evidence; and (2) even if the cell phone tower dump was not a search and subject to Fourth Amendment protections, the order under 18 U.S.C. 86-2,106 allowing the dump was executed in good faith. View "State v. Elias" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for five counts of trafficking a person for sexual servitude and a second and subsequent offense of possession of a class A substance with intent to distribute, holding that the conflict of interest inherent in counsel's bigotry against persons of Defendant's faith and race deprived Defendant of his right to effective assistance of counsel.Defendant, a Black man of the Muslim faith, was appointed counsel who openly shared his hatred of and bigotry against people of the Muslim faith and his racism against Black persons. Counsel advised Defendant to accept a plea deal, which Defendant did. Defendant later filed a motion to withdraw his guilty plea and for a new trial, arguing that his counsel had an actual conflict of interest. The motion judge denied the motion. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that Defendant met his burden to establish that counsel's representation of him was impaired by an actual conflict of interest. View "Commonwealth v. Dew" on Justia Law

Plaintiff, a convicted sexually violent predator, was held in the Lubbock County Detention Center as a pre-trial detainee for approximately one month from December 2017 to January 2018. Soon after his arrival, he was placed in administrative segregation away from the facility’s general population, where he was held for most of the remainder of his time there. He subsequently brought suit under 42 U.S.C. Section 1983 against Lubbock County and several law enforcement officials, asserting a series of claims regarding his alleged mistreatment there. The district court entered an order dismissing the claims against the county and all but one of the officials, which he now appeals in the first of the consolidated cases. Plaintiff challenged the process by which he was placed and remained in administrative segregation. After the district court subsequently dismissed the remaining named official, Plaintiff moved to reconsider that dismissal and the dismissal of several of his other claims. The district court rejected both motions for lack of new evidence, which Plaintiff appealed in the second of the consolidated cases. The Fifth Circuit affirmed, finding no reversible errors. View "Welsh v. Lubbock County" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress evidence showing that Defendant was carrying heroin with the intent to distribute it, holding that the district court did not err in denying Defendant's motion to suppress the evidence found during the underlying traffic stop.Defendant was stopped for unsafe operation of a vehicle. The stop resulted in more than an hour of questioning and in Defendant relinquishing thirty-seven grams of heroin that he was carrying on his person. Defendant filed a motion to suppress, arguing that the traffic stop was illegal and that the ensuing questioning violated his Fourth and Fifth Amendment rights. The district court denied the motion, after which Defendant pleaded guilty. The First Circuit affirmed, holding that there was no error in the denial of Defendant's motion to suppress. View "United States v. Fagan" on Justia Law

Plaintiff, a lieutenant in the Kankakee Fire Department (“KFD”)—was attacked by another firefighter while responding to a fire at a senior living facility. The City suspended the other firefighter for twenty-four hours without pay, ordered him to complete an anger management course, and directed him to avoid working on the same shift as Plaintiff for three months. Plaintiff experienced ongoing physical and mental injuries from the incident, causing her to take leave from work and apply for workers’ compensation. She returned to work six months later but permanently left her position shortly after. She then filed a lawsuit, alleging that Defendants, among other things, retaliated against her for certain protected activities under Title VII and condoned aggressive and inappropriate behaviors as part of a “code of silence” that resulted in her attack. The district court granted summary judgment for Defendants, and this appeal followed.   The Seventh Circuit affirmed. The court explained that on the merits, Plaintiff’s claim fails because none of her evidence, separately or taken together, creates a genuine dispute regarding whether Defendants had a practice of condoning aggressive behavior, resulting in a constitutional injury. Further the court wrote that the record does not support Plaintiff’s contention that there was such a high risk of constitutional injury from the other firefighter that the “single incident” theory of municipal liability applies here. The court held Plaintiff failed to create a genuine dispute of material fact precluding summary judgment regarding her Fourth Amendment Monell claim and her Title VII retaliation claim. The district court, therefore, properly granted summary judgment to Defendants. View "Michelle Giese v. City of Kankakee" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had not been lawfully arrested without a warrant and thus reversing the decisions of the West Virginia Division of Motor Vehicles (DMV) to revoke Defendant's driver's license, holding that the circuit court did not err.A law enforcement officer arrested Defendant in his home without a warrant for a misdemeanor committed elsewhere. Rhe officer articulated no urgent need to arrest Defendant and admitted that he could have obtained a warrant from an impartial magistrate. The DMV applied evidence suggesting that Defendant might have driven while intoxicated from the scene of the misdemeanor to his home in three separate decisions revoking Defendant's driver's license. The circuit court reversed the revocation decisions, concluding that they were clearly wrong in light of the now-repealed W. Va. Code 17C-5A-2(f)(2). The Supreme Court affirmed, holding that the circuit court did not err in concluding that the DMV's suspension orders were founded upon an unlawful arrest. View "Frazier v. Briscoe" on Justia Law

Not long after getting a new boss at the Priority Automotive Honda dealership, Plaintiffs effectively resigned from their jobs. They then sued, alleging racial discrimination—claiming that the new boss and the company fostered a hostile work environment and demoted them because they are Black—along with various state torts. Plaintiffs lost at summary judgment and appealed.   The Fourth Circuit largely affirmed but remand their state-law conversion claims for further proceedings. First, the court explained that a reasonable person might conclude that the employee’s alleged “white side” was race-based harassment. But the statement, on its own, does not create a severe or pervasive hostile work environment. Next, the court held that, since Plaintiff failed to support a reasonable inference of unlawful intentional discrimination, the magistrate judge rightfully rejected his disparate-treatment claim. Further, the court held that no reasonable jury could find that Defendants’ alleged conduct “rises to the level of ‘outrageous and extreme’ as the term has been interpreted and applied” in North Carolina. The court reasoned that courts do not weigh the evidence when ruling on a motion for summary judgment. So when both parties raise facts sufficient for a reasonable jury to find for them at trial, the claim must survive. But discrimination claims need more than neutral facts, an adverse action, and speculation about discriminatory motives to make it past this stage. As such, on the current record, a reasonable juror could find for Plaintiffs on their conversion claim. View "Kenneth Robinson v. Priority Automotive Huntersville, Inc." on Justia Law

The Court of Appeals affirmed the order of the appellate division reversing Supreme Court's conclusion that the application of the Sexual Assault Reform Act (SARA) to Petitioner violated the Ex Post Facto Clause of the federal Constitution when applied to offenders whose crimes predated the 2005 amendments to the Act, holding that the effect of SARA's school grounds condition, as codified in N.Y. Exec. Law 259-c(14), was not punitive.In 1986, Petitioner was convicted of two counts of murder in the second degree and other crimes. Petitioner was unable to locate SARA-compliant housing before his open release date and therefore remained in custody until he could locate suitable housing under SARA's school grounds condition prohibiting him from living within 1,000 feet of a school. Petitioner filed a petition for a writ of habeas corpus arguing that SARA's residency restriction violated ex post facto principles. Supreme Court granted Petitioner's application and ordered his release. The appellate division reversed. The Court of Appeals affirmed, holding that the condition does not violate the Ex Post Facto Clause. View "People ex rel. Rivera v. Superintendent, Woodbourne Correctional Facility" on Justia Law

The Court of Appeals reversed the conclusion of the appellate division that the Sex Offender Registration Act (SORA) court acted within its discretion by upwardly departing to level three in determining Defendant's risk level classification, holding that the SORA court deprived Defendant of basic due process protections of notice and an opportunity to be heard.Defendant's convictions required him to register under SORA. At the SORA hearing, the court noted that Defendant would normally be required to register as a level two sex offender but upwardly departed to level three due to Defendant's "extensive prior disciplinary history." The appellate division affirmed. The Court of Appeals reversed, holding that the proceeding failed to comport with due process because Defendant was provided no notice or meaningful opportunity to be heard in response to the District Attorney's request for an upward departure. View "People v. Worley" on Justia Law

Smith was indicted in the Northern District of Florida for theft of trade secrets from StrikeLines’ website. Smith moved to dismiss the indictment, citing the Constitution’s Venue Clause and the Vicinage Clause. Smith argued that he had accessed the website from his Alabama home and that the servers storing StrikeLines’ data were in Orlando, Florida. The Eleventh Circuit determined that venue was improper and vacated Smith’s conviction, but held that a trial in an improper venue did not bar reprosecution.The Supreme Court affirmed. The Constitution permits the retrial of a defendant following a trial in an improper venue conducted before a jury drawn from the wrong district. Except as prohibited by the Double Jeopardy Clause, when a defendant obtains a reversal of a prior, unsatisfied conviction, he may be retried. Nothing in the Venue Clause suggests that a new trial in the proper venue is not an adequate remedy for its violation. The Vicinage Clause—which guarantees the right to “an impartial jury of the State and district wherein the crime shall have been committed,” concerns jury composition, not the place where a trial may be held, and concerns the district where the crime was committed, rather than the state. The vicinage right is one aspect of the Sixth Amendment’s jury-trial rights and retrials are the appropriate remedy for violations of other jury-trial rights.The Double Jeopardy Clause is not implicated by retrial in a proper venue. A judicial decision on venue is fundamentally different from a jury’s verdict of acquittal. Culpability is the touchstone; when a trial terminates with a finding that the defendant’s criminal culpability had not been established, retrial is prohibited. Retrial is permissible when a trial terminates on a basis unrelated to factual guilt. The reversal of a conviction based on a violation of the Venue or Vicinage Clauses, even when called a “judgment of acquittal,” does not resolve the question of criminal culpability. View "Smith v. United States" on Justia Law