Justia Civil Rights Opinion Summaries

In the Harvard College admissions process, “race is a determinative tip for” a significant percentage “of all admitted African American and Hispanic applicants.” University of North Carolina (UNC) also considers the applicant’s race. SFFA challenged both systems.The Supreme Court held that both programs violate the Equal Protection Clause of the Fourteenth Amendment. The Court first held that SFFA complies with the standing requirements for organizational plaintiffs as a voluntary membership organization with identifiable members who support its mission and whom SFFA represents in good faith.Tracing the history of Fourteenth Amendment precedent, the Court acknowledged its "role in that ignoble history,” and subsequent efforts to eliminate racial discrimination. The core purpose of the Equal Protection Clause is to eliminate all governmentally-imposed discrimination based on race. Any exceptions must survive strict scrutiny. which asks whether the racial classification is used to advance compelling governmental interests and whether the use of race is narrowly tailored--necessary to achieve that interest. Previous holdings permitted race-based college admissions only in compliance with strict scrutiny and acknowledged that, eventually, they must end.The admissions programs at issue are not sufficiently measurable to permit strict scrutiny. The identified "compelling" interests include training future leaders, acquiring new knowledge based on diverse outlooks, promoting a robust marketplace of ideas, and preparing engaged and productive citizens. The question of whether a particular mix of minority students produces those results is standardless. The systems fail to articulate a meaningful connection between the means they employ and those goals; they use racial categories that are overbroad, arbitrary or undefined, or underinclusive.The systems also use race as a “negative” and employ stereotypes. College admissions are zero-sum. A benefit provided to some applicants is necessarily at the expense of others. The systems employ “the offensive and demeaning assumption" that students of a particular race think alike. The systems lack a “logical endpoint. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law

Plaintiff brought a lawsuit under 42 U.S.C. Section 1983, alleging that Isanti County, Minnesota (the “County”) violated his Fourth and Fourteenth Amendment rights when it unlawfully prosecuted him under the County’s solid waste ordinance (the “Solid Waste Ordinance”). Plaintiff also asserted Minnesota state law claims for false imprisonment, malicious prosecution, and abuse of process. The district court granted judgment on the pleadings as to the federal claims in favor of the County and declined to exercise supplemental jurisdiction on the remaining state law claims.The Eighth Circuit affirmed. The court explained that while Plaintiff’s opening brief lists 21 cases, which Plaintiff contends constitute proof the County used the Solid Waste Ordinance to wrongly prosecute property owners, none of these cases are properly before the court as they were not included in the complaint. Plaintiff’s complaint contains insufficient factual allegations to sustain a municipal liability claim. Accordingly, the court held that without a constitutional violation, there can be no Section 1983 liability. View "Keith Kiefer v. Isanti County" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to dismiss the case against him with prejudice after a mistrial was declared, holding that retrial would not violate Defendant's right against double jeopardy.Defendant was tried on one count of trafficking of a child. During trial, the trial court declared a mistrial on the basis that certain evidence was improperly admitted. Thereafter, Defendant filed a motion to dismiss, arguing that retrial would violate his right under the Fifth Amendment, as incorporated against the states by the Fourteenth Amendment, to be free against double jeopardy. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that the trial court exercised sound discretion in ordering a mistrial based on manifest necessity and that retrial will not violate Defendant's Fifth Amendment right against double jeopardy. View "State v. Green" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this interlocutory appeal of the denial of Defendant's motion to suppress calls made by Defendant on the Salt Lake County Jail's telephones and recorded by the jail, holding that Defendant impliedly consented to the conditions the jail had placed on the use of its phones.Defendant was charged with kidnapping and assaulting his wife and made hundreds of calls to his wife from the jail. The State moved to admit recording of several of those phone calls and filed new charges based on the recordings. Defendant filed a motion to suppress the recordings in both cases. The Supreme Court denied the motions, concluding that Defendant impliedly consented to the interception of the phone calls and that the calls were exempt under the law enforcement exception to Utah's Interception of Communications Act, Utah Code 77-23a-1 to -16. The Supreme Court affirmed, holding that Defendant impliedly consented to the jail's recording of his phone calls, and therefore, the interception of Defendant's calls was authorized under the Interception Act's consent exception. View "State v. Wood" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's demand for a jury trial before Walworth County extended his involuntary commitment for twelve additional months, holding that Waukesha County v. E.J.W., 966 N.W.2d 590 (Wis. 2021), applied retroactively to Appellant's case and that the denial of Appellant's jury demand was erroneous.Following a mental health crisis, Appellant was involuntarily committed and forcibly medicated for six months. Walworth County later sought to extend Appellant's commitment for twelve months. Appellant filed a jury demand at least forty-eight hours prior to his rescheduled final hearing date, but the circuit court denied the jury demand as untimely. Thereafter, the Supreme Court decided E.J.W., which held that a jury demand is timely filed if it is filed at least forty-eight hours before a rescheduled final hearing. Appellant appealed, arguing that E.J.W. applied retroactively. The Supreme Court reversed, holding (1) E.J.W. applies retroactively; and (2) under the circumstances of this case, the proper remedy for the circuit court's denial of Appellant's jury demand was not remand but reversal. View "Walworth County v. M.R.M." on Justia Law

Spectrum contracts with Michigan to house children who are ordered to be detained in facilities “similar to a prison setting.” The children are completely restricted in their movements. The state requires Spectrum to monitor them on a 24/7 basis. A court ordered the detention of 15-year-old Quintana at Spectrum’s facility on August 24, 2018. Quintana struggled with depression, anxiety, and difficulty sleeping, among other things. On September 11, 2018, Quintana took his life while alone in his bedroom. No one checked his room in the 45 minutes between the last time he was seen alive and when his body was found, violating a contractual requirement that Spectrum conduct “eye-on checks” every 15 minutes when the children are “outside of the direct supervision of staff.” Spectrum had a policy or custom of skipping many eye-on checks and falsifying supervision logs to reflect that the checks had been performed.Quintana’s estate sued Spectrum under 42 U.S.C. 1983, alleging that Spectrum functioned as a state actor and violated Quintana’s Eighth and Fourteenth Amendment rights. The Sixth Circuit reversed the dismissed the dismissal of the suit. The complaint contains adequate facts to establish that Spectrum is a state actor. Spectrum was allegedly engaged in a public function similar to a correctional institution, a traditionally exclusive state function. View "Nugent v. Spectrum Juvenile Justice Services" on Justia Law

Jenkins purchased a 1987 Oldsmobile and a 2001 Chevrolet and transferred the titles to his mother, Buchanan, retaining exclusive use of both vehicles. The DEA, investigating Jenkins for drug conspiracy crimes, seized the vehicles, which were towed to an impound lot. The DEA obtained a search warrant, which was executed in October 2012. In April 2013, Jenkins pled guilty and was sentenced to 252 months of imprisonment. In October, the impound lot sent letters to the address on file for Buchanan notifying her that the vehicles could be reclaimed upon payment of towing and storage charges. Buchanan did not receive the letters, having moved. No letter was addressed to Jenkins. Jenkins acknowledged that he “was informed" to pick up the vehicles. In February 2014, the impound lot sent final notices to Buchanan, who was incarcerated, then sold the vehicles, retaining the proceeds.In 2017, Jenkins moved in his criminal case for the return of the cars (FRCP 41(g)). The government responded that the cars “are available for return.” The court dismissed the motion. In 2019, Jenkins unsuccessfully sought monetary compensation in excess of $10,000, then filed a civil action under the Little Tucker Act, 28 U.S.C. 1346(a)(2), alleging a physical taking of his vehicles. The Sixth Circuit vacated summary judgment. While the government’s police power may preclude liability for an initial seizure, there is no police power exception that precludes takings liability for the period after the property is not needed for criminal proceedings. The court noted a factual issue of abandonment and affirmed the dismissal of the due process clause for lack of jurisdiction, without prejudice. View "Jenkins v. United States" on Justia Law

The Supreme Court vacated the decision of the circuit court sustaining Defendant's motions to suppress evidence obtained after his warrantless arrest for a felony, holding that to the extent the decision was based on Defendant's claim that the Fourth Amendment is violated when an arresting officer was outside of the officer's jurisdiction unless the officer personally observed the crime, the decision was clearly erroneous.Defendant was charged in two separate cases for his involvement in two robberies. Defendant moved to suppress evidence obtained after a warrantless arrest, arguing that his Fourth Amendment rights were violated because the officer was outside of his jurisdiction. The circuit court sustained the motions to suppress. The Supreme Court vacated the circuit court's decision, holding that while Moore v. State, 458 S.W.3d 822 (Mo. banc 2015), requires both probable cause and that the crime be committed in the officer's presence for an arrest to satisfy the Fourth Amendment, when a warrantless arrest is for a felony, the Fourth Amendment is satisfied if the arresting officer has probable cause for the arrest, even when the felony was not committed in the arresting officer's presence. View "State v. Barton" on Justia Law

Snowden, staying at a hotel, received a call asking him to visit the lobby to pay for the room. When Snowden arrived, DEA Agent Henning pushed him into a door and onto the ground. Snowden did not resist. Henning punched him several times. Snowden suffered two black eyes and a fractured left eye socket.Snowden sued Henning, alleging a Fourth Amendment excessive force claims. The court construed the complaint to allege a “Bivens” claim (an implied damages remedy against federal officers for certain constitutional violations), then dismissed that claim, noting factual distinctions between Snowden’s case and Bivens–the location of the arrest, the presence of a warrant, and the number of officers involved. Bivens involved allegations concerning the rights of privacy implicated in an unlawful warrantless home entry, arrest, and search, the court reasoned, while Snowden alleged excessive force incident to a lawful arrest, and special factors weighed against recognizing a new Bivens context, including the availability of an alternative remedy.The Seventh Circuit reversed. While the Supreme Court has declined to extend the Bivens remedy beyond specific Fifth and Eighth Amendment contexts, Snowden’s claim does not present a new context. Agent Henning operated under the same legal mandate as the Bivens officers and is the same kind of line-level federal narcotics officer. Like Bivens, Snowden seeks damages for violation of his Fourth Amendment rights. The legal landscape of excessive-force claims is well-settled. Nor does allowing a Bivens claim here risk a “disruptive intrusion” into the “functioning of other branches.” View "Snowden v. Henning" on Justia Law