Justia Civil Rights Opinion Summaries

Arthur Lee Burton was convicted of capital murder and sentenced to death in June 1998 for kidnapping, sexually assaulting, and strangling a woman in Houston, Texas. His conviction was affirmed by the Texas Court of Criminal Appeals, but his sentence was vacated and remanded for a new trial on punishment. Upon retrial, he was again sentenced to death, and this sentence was affirmed. Burton pursued state and federal habeas relief, which were all denied.Burton recently filed three challenges to his scheduled execution in Texas state court, including motions to withdraw his execution order and a habeas petition alleging constitutional violations. These challenges were rejected by the Texas Court of Criminal Appeals. Subsequently, Burton sought authorization from the United States Court of Appeals for the Fifth Circuit to file a successive federal habeas petition under 28 U.S.C. § 2244(b) and moved to stay his execution.The United States Court of Appeals for the Fifth Circuit denied both motions. The court held that Burton's petition was untimely, as it was filed well beyond the one-year limitation period prescribed by § 2244(d). Burton's reliance on Atkins v. Virginia and Moore v. Texas was insufficient to excuse the delay, as both cases were decided long before his current motion. The court also rejected Burton's arguments for equitable tolling and actual innocence, finding that he had not pursued his rights diligently and that his claims were not supported by extraordinary circumstances. Consequently, the court concluded that Burton failed to meet the requirements of § 2244 and denied his motion to stay execution. View "In re Burton" on Justia Law

A twelve-year-old boy named Maxwell was abused and killed by his father and stepmother. His mother, Sara Coon, sued Lebanon County and several county officials, alleging that the county knew about the abuse and had a state-law duty to protect Maxwell. The complaint stated that the county's Children and Youth Services agency failed to act despite multiple warnings about the abuse.The United States District Court for the Middle District of Pennsylvania dismissed the federal claims brought under 42 U.S.C. § 1983, concluding that Pennsylvania’s Child Protective Services Law did not create a property interest in having the county agency protect Maxwell from child abuse. The court also remanded the state-law claims to state court.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that due process protects interests in life, liberty, or property, and to state a claim for violating procedural due process, a plaintiff must show a legitimate claim of entitlement to a protected property interest. The court found that Pennsylvania law did not create such a property interest in having a county agency protect a child from abuse. The court compared this case to Town of Castle Rock v. Gonzales and Burella v. City of Philadelphia, where similar statutory language did not create a property interest. Consequently, the Third Circuit affirmed the District Court’s order dismissing the federal claims and remanding the state claims to state court. View "Coon v. County of Lebanon" on Justia Law

Carl Langston was convicted of possessing a firearm in violation of 18 U.S.C. § 922(g)(1), the felon-in-possession statute. Langston argued that this statute is unconstitutional under the Second Amendment as applied to him, given his prior convictions for theft and drug trafficking under Maine law. He also challenged the district court's denial of his motion to suppress evidence obtained during a police stop and several sentencing decisions.The United States District Court for the District of Maine denied Langston's motion to suppress, finding that the police stop was based on reasonable suspicion. Langston then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. At sentencing, the district court applied a four-level enhancement for possessing a firearm during a felony assault on an officer and denied Langston a reduction for acceptance of responsibility, citing his conduct during pretrial release.The United States Court of Appeals for the First Circuit reviewed Langston's claims. The court held that Langston's Second Amendment challenge failed under the plain-error standard because it was not "clear" or "obvious" that § 922(g)(1) is unconstitutional as applied to him. The court noted that the Supreme Court has consistently referred to felon-in-possession laws as "presumptively lawful."The court also upheld the district court's denial of the motion to suppress, agreeing that the totality of the circumstances gave rise to reasonable suspicion for the police stop. Additionally, the court found no plain error in the application of the sentencing enhancement for felony assault on an officer and ruled that the district court did not abuse its discretion in relying on hearsay evidence to conclude that Langston violated his pretrial release conditions. Finally, the court affirmed the denial of the acceptance-of-responsibility credit, noting the similarities between Langston's conduct at the time of his arrest and during his pretrial release.The First Circuit affirmed Langston's conviction and sentence. View "US v. Langston" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law

Four condemned inmates challenged the constitutionality of a South Carolina statute that provides three methods of execution: electrocution, lethal injection, and firing squad. They argued that the statute violates the South Carolina Constitution's prohibition against cruel, corporal, or unusual punishment.The Richland County Circuit Court ruled in favor of the inmates, declaring the statute unconstitutional. The court found that electrocution and firing squad methods violate the state constitution's prohibition on cruel, corporal, or unusual punishment. It also found the statute's provision allowing inmates to choose their method of execution unconstitutionally vague and an improper delegation of authority. The court further ruled that the retroactive application of the amended statute violated ex post facto prohibitions.The South Carolina Supreme Court reversed the lower court's decision. The court held that the statute does not violate the South Carolina Constitution. It found that electrocution is not unconstitutionally cruel, corporal, or unusual, noting that the inmates did not meet their burden of proving that electrocution causes unnecessary and excessive pain. The court also held that lethal injection, as conceded by the inmates, is constitutional if properly administered. Regarding the firing squad, the court found it to be a relatively quick and painless method of execution, thus not cruel or unusual.The court also addressed the inmates' claims about the statute's vagueness and improper delegation of authority, finding that the term "available" is not unconstitutionally vague and that the statute does not unlawfully delegate authority to the Director of the Department of Corrections. The court emphasized that the statute's provision allowing inmates to choose their method of execution is a constitutional innovation aimed at making the death penalty less inhumane. The court concluded that the statute is constitutional in its entirety. View "Owens v. Stirling" on Justia Law

Roy Scott, who was unarmed and in mental distress, called the police for help. Officers Kyle Smith and Theodore Huntsman from the Las Vegas Metropolitan Police Department responded. Despite Scott complying with their orders and not being suspected of a crime, the officers used force to restrain him. Scott lost consciousness shortly after and was later pronounced dead. Scott’s daughter Rochelle and a representative of Scott’s estate sued the Department and the two officers, alleging violations of Scott’s Fourth Amendment right to be free from excessive force and Rochelle’s Fourteenth Amendment right to familial association.The United States District Court for the District of Nevada denied the officers' motion for summary judgment on the basis of qualified immunity for both the Fourth and Fourteenth Amendment claims. The officers appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on the Fourth Amendment claim, holding that the officers violated Scott’s Fourth Amendment right to be free from excessive force. The court found that Scott was mentally ill, not suspected of a crime, and did not present a risk to officers or others, making the use of severe or deadly force constitutionally excessive. The court also held that Scott’s Fourth Amendment rights were clearly established at the time of the violation, referencing Drummond ex rel. Drummond v. City of Anaheim.However, the Ninth Circuit reversed the district court’s denial of qualified immunity on Rochelle’s Fourteenth Amendment claim. The court held that while the officers violated Rochelle’s right to familial association, that right was not clearly established at the time of the officers’ conduct, entitling the officers to qualified immunity on this claim. The case was remanded for further proceedings consistent with the opinion. View "SCOTT V. SMITH" on Justia Law

Courtney Ealy, an inmate in the Illinois prison system, spent five consecutive months in segregation starting in 2019. During this period, he experienced cold temperatures, dirty cells, and faulty plumbing, which he claimed negatively affected his mental and physical health. Ealy sued several prison officials, alleging violations of his Fourteenth Amendment right to due process. He also filed multiple motions for recruitment of counsel during the litigation.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants, Cameron Watson, David D. Frank, and Angela McKittrick, and denied Ealy's motions for recruitment of counsel. The court found that Ealy had received due process before being placed in disciplinary segregation and that the conditions of his confinement did not constitute an atypical and significant hardship. The court also determined that Ealy was competent to represent himself despite his claims to the contrary.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Ealy received all the due process he was entitled to, including advance written notice of the charges, an opportunity to be heard, and a written statement of the evidence and reasons for the disciplinary action. The court also found that the district court did not abuse its discretion in denying Ealy's motions for recruitment of counsel, noting that Ealy's case was not complex and that he appeared competent to represent himself based on his filings. View "Ealy v. Watson" on Justia Law

Marc Susselman received a traffic ticket from a Washtenaw County Sheriff’s deputy for failing to yield to a police cruiser with flashing lights. This ticket was later dismissed, but Susselman received another citation for failing to obey a police officer directing traffic. The Michigan circuit court ultimately dismissed the second ticket as well. Susselman then filed a federal lawsuit asserting constitutional and state law claims against Washtenaw County, the Washtenaw County Sheriff’s Office, the sheriff’s deputy, and Superior Township, Michigan.The United States District Court for the Eastern District of Michigan granted the defendants' motions to dismiss all claims. Susselman appealed the decision. The district court had found that the Washtenaw County Sheriff’s Office could not be sued under 42 U.S.C. § 1983 and that Susselman had waived certain state-law claims. The court also dismissed Susselman’s federal claims, including First Amendment retaliation and Fourteenth Amendment malicious prosecution, as well as state-law claims for malicious prosecution and intentional infliction of emotional distress.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Susselman failed to plausibly allege a constitutional violation or behavior by the deputy that would support his claims. Specifically, the court found that the issuance of the second ticket did not constitute a violation of substantive due process or First Amendment rights. Additionally, the court determined that Susselman did not establish a civil conspiracy or meet the requirements for his state-law claims. The court also concluded that Susselman did not identify any municipal policy or custom that resulted in a constitutional violation, thus dismissing his claims against Washtenaw County and Superior Township. View "Susselman v. Washtenaw County Sheriff's Office" on Justia Law

In September 2018, Bryana Baker was arrested and taken to Butler County Jail, where she began experiencing drug withdrawal symptoms. After attempting to escape, she was placed in disciplinary isolation. Despite multiple mental health assessments indicating she was not suicidal, Baker was placed on suicide watch due to erratic behavior. On September 24, she was removed from suicide watch but was not cleared for single-celling. The next day, after a series of altercations with her cellmate, Officer April Riahi closed Baker’s cell door. Shortly thereafter, Baker was found hanging in her cell and later died.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants, including Officer Riahi, Sheriff Richard Jones, and Butler County. The court found no evidence of deliberate indifference or constitutional violations by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that Officer Riahi was entitled to qualified immunity because no clearly established law indicated her actions were unconstitutional. The court also found that Sheriff Jones could not be held liable under supervisory liability since there was no underlying constitutional violation by Riahi. Additionally, the court ruled that Butler County was not liable under municipal liability theories because there was no deliberate indifference to a clearly established right. Lastly, the court determined that Riahi and Jones were entitled to Ohio statutory immunity on the state-law claims, as their actions did not amount to recklessness under Ohio law.The Sixth Circuit affirmed the district court’s judgment, granting summary judgment to the defendants on all claims. View "Campbell v. Riahi" on Justia Law

A civilian, Clarissa Gilmore, was strip-searched while visiting her incarcerated husband at Smith State Prison in Georgia. During the search, officers manipulated her breasts, ordered her to bend over, and felt between her buttocks with a gloved hand. The officers did not inform her of the reasons for the search, and no contraband was found. Gilmore sued the officers and the Georgia Department of Corrections, claiming the search violated her Fourth Amendment rights.The United States District Court for the Southern District of Georgia granted summary judgment to the officers, finding that the search did not violate clearly established law and that the officers were entitled to qualified immunity. The court concluded that the officers acted within the scope of their discretionary authority and that there was no clearly established requirement for reasonable suspicion to conduct a strip search of a prison visitor.The United States Court of Appeals for the Eleventh Circuit reviewed the case and agreed that the strip search violated Gilmore’s Fourth Amendment rights. The court held that correctional officers must have at least reasonable suspicion that a visitor is concealing contraband before conducting a strip search. However, the court also found that no Supreme Court or Eleventh Circuit precedent expressly prohibited suspicionless strip searches of prison visitors at the time of the search. As a result, the law was not clearly established, and the officers were entitled to qualified immunity. The Eleventh Circuit affirmed the district court’s grant of summary judgment. View "Gilmore v. Georgia Department of Corrections" on Justia Law