Justia Civil Rights Opinion Summaries

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

The defendant was originally convicted in 2011 of felony possession of child pornography, which required him to register as a sex offender. In 2015, he was convicted of failing to register a change of address, an offense classified as a felony because his registration requirement was based on his prior felony conviction. Years later, after his child pornography conviction was reduced to a misdemeanor and dismissed, he sought to have his 2015 failure to register conviction likewise reduced to a misdemeanor and dismissed, citing his rehabilitation, lack of subsequent offenses, and support from family and associates.The Santa Cruz County Superior Court had previously granted the defendant’s motion to reduce his 2011 conviction to a misdemeanor and dismissed that case. However, when the defendant petitioned to reduce and dismiss his 2015 felony registration offense, the court denied the motion, finding that the offense was a straight felony, not a wobbler, and that it was not appropriate to dismiss the case. The defendant appealed, arguing that the later reduction of his underlying offense should retroactively affect the status of his 2015 conviction, or that the court should have exercised discretion to reduce or dismiss it in the interest of justice.The California Court of Appeal, Sixth Appellate District, affirmed the trial court’s order. The court held that the 2015 failure to register conviction was a straight felony under Penal Code section 290.018(b), and not subject to reduction under Penal Code section 17(b), which only applies to wobblers. The reduction of the underlying 2011 offense did not retroactively convert the 2015 conviction to a misdemeanor. The court also found no substantive due process violation, as the legislative scheme had a rational basis. Finally, the court found no abuse of discretion in denying dismissal under Penal Code section 1203.4. View "People v. Woodward" on Justia Law

In this case, the defendant was charged following two shootings in Buffalo, New York, that occurred about an hour apart on August 4, 2016, resulting in one death and three injuries. Key evidence included witness accounts and surveillance footage showing a shooter in distinctive clothing matching what the defendant wore earlier that day. Forensic testimony linked the fatal weapon to an individual depicted in the videos. After trial, the jury convicted the defendant of murder in the second degree, assault in the first degree, and criminal possession of a weapon in the second degree, while acquitting him of two counts of attempted murder.During jury deliberations, a juror raised concerns that another juror had made a racially biased remark. The trial judge questioned both the reporting juror and the accused juror individually, with input from counsel, but did not question other jurors. Defense counsel moved for a mistrial based on alleged racial bias affecting up to six jurors but declined to request further inquiry or substitution of jurors, relying solely on the mistrial request. The trial judge denied the motion, finding no convincing evidence of grossly unqualified jurors or racial animus affecting deliberations, and subsequently denied a post-verdict motion to set aside the verdict.The Appellate Division, Fourth Department, reviewed the trial court’s response and concluded that the judge had conducted an appropriate inquiry into the allegations and did not abuse discretion by denying the mistrial request. Upon further appeal, the New York State Court of Appeals held that the trial court’s inquiry was sufficient, that the record did not convincingly demonstrate a lack of impartiality among the jurors, and that the denial of the motion for a mistrial was not an abuse of discretion. The Court of Appeals therefore affirmed the order of the Appellate Division. View "People v Wiggins" on Justia Law

Three men were prosecuted for their roles in the fatal shooting of Ahmaud Arbery, a Black man, in the Satilla Shores neighborhood of Glynn County, Georgia. On February 23, 2020, Arbery was running through the neighborhood and stopped at a house under construction, which he had visited before. Gregory and Travis McMichael, who lived nearby, saw Arbery and, suspecting him of recent burglaries, armed themselves and pursued him in a truck. William Bryan, a neighbor, joined the chase in his own vehicle. The men used their trucks to block and pursue Arbery through public streets, ultimately leading to a confrontation in which Travis McMichael shot and killed Arbery.After being convicted of murder and other charges in Georgia state court and sentenced to life imprisonment, the defendants were tried in the United States District Court for the Southern District of Georgia. There, they were convicted of interference with rights under 18 U.S.C. § 245(b)(2)(B), attempted kidnapping under 18 U.S.C. § 1201(a)(1), and, for the McMichaels, firearm offenses under 18 U.S.C. § 924(c)(1)(A)(iii). The district court denied their motions for acquittal, finding sufficient evidence that the defendants acted because of Arbery’s race and his use of public streets, that the streets were provided or administered by the county, and that the attempted kidnapping was for a benefit and involved an instrumentality of interstate commerce.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the sufficiency of the evidence de novo. The court held that substantial evidence supported the jury’s findings on all challenged elements, including racial motivation, use of public facilities, and use of an automobile as an instrumentality of interstate commerce. The Eleventh Circuit affirmed all convictions. View "USA v. Bryan" on Justia Law

An 18-year-old individual was convicted of second degree felony murder and sentenced to 300 months in prison, with an offender score that included a prior drug possession conviction. The court also imposed over $7,000 in restitution to the Crime Victims Compensation fund, covering part of the victim’s funeral expenses. Years later, following the Washington Supreme Court’s decision in State v. Blake, which invalidated certain drug possession convictions, the individual’s prior conviction was vacated, reducing his offender score and lowering his sentencing range. At the resentencing hearing, the individual specifically requested that the court consider his youth at the time of the offense as a mitigating factor. The resentencing judge declined to do so, stating that the issue of youthfulness was not relevant to the hearing and could be raised elsewhere, and imposed a sentence within the new standard range as recommended by defense counsel.The Washington Court of Appeals reviewed the case and held that, although the resentencing judge had discretion to consider youth as a mitigating factor, any error in failing to do so was harmless because the sentence imposed matched the defense’s request. The Court of Appeals also found that the restitution order was not constitutionally excessive, as it was compensatory rather than punitive.The Supreme Court of the State of Washington reversed the Court of Appeals in part. It held that the resentencing court abused its discretion by failing to meaningfully consider the individual’s youthfulness when specifically asked, as required by precedent. The court clarified that while a judge is not required to impose a lower sentence due to youth, the judge must at least consider it as a mitigating factor. The Supreme Court affirmed the Court of Appeals’ ruling that the restitution was not excessive, as it was solely compensatory. The case was remanded for a new resentencing hearing. View "State v. Ellis" on Justia Law

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law

In 2004, Clemente Javier Aguirre-Jarquin was arrested and later convicted for the murders of his neighbors, Cheryl Williams and Carol Bareis, in Altamonte Springs, Florida. The investigation by Seminole County Sheriff’s Office (SCSO) focused on Aguirre after bloody clothing and a knife were found near his residence, and forensic analysis by Donna Birks, a latent print examiner, identified Aguirre’s palm print on the murder weapon. Aguirre was tried and sentenced to death in 2006. Over the next decade, new evidence emerged: a 2007 investigation revealed misconduct in the SCSO Latent Print Unit, undermining the reliability of the fingerprint identification, and post-conviction DNA testing failed to link Aguirre to the crime scene but implicated Samantha Williams, the victims’ daughter and granddaughter, who later confessed to involvement in the murders.The Seminole Circuit Court denied Aguirre’s initial motion for a new trial, finding the evidence against him overwhelming. The Supreme Court of Florida affirmed this denial. However, after further post-conviction investigation and new DNA evidence, the Supreme Court of Florida vacated Aguirre’s convictions and ordered a new trial. In 2018, the State dropped all charges against Aguirre.Aguirre then filed suit in the United States District Court for the Middle District of Florida against Birks, lead investigator Robert Hemmert, crime scene analyst Jacqueline Grossi, and the Seminole County Sheriff, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and state law claims. The District Court denied qualified immunity to Birks, Hemmert, and Grossi on several counts and denied state-law immunity to Hemmert and Grossi.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of qualified immunity to Birks on the fabrication of evidence claim and affirmed the denial of state-law immunity to Hemmert and Grossi for intentional infliction of emotional distress. However, the court reversed the denial of qualified immunity to Birks and Hemmert on the malicious prosecution claim and to Hemmert and Grossi on the claim of inadequate investigation, finding no clearly established law requiring the investigation to eliminate all doubts. The case was remanded for further proceedings. View "Aguirre-Jarquin v. Hemmert" on Justia Law

In this case, the defendant was stopped by police officers in Aurora, Colorado, for speeding. During the stop, the officers observed the defendant make a dramatic movement toward the passenger side of his vehicle, to the extent that he was no longer visible to them. The officers recognized the defendant as a member of a local violent gang and learned from him that he was on parole for robbery. After asking the defendant to exit the vehicle and conducting a pat-down that revealed no weapons, the officers searched the passenger seat area and found a firearm. The defendant was subsequently charged with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).The United States District Court for the District of Colorado held an evidentiary hearing on the defendant’s motion to suppress the firearm evidence, which argued that the warrantless vehicle search violated the Fourth Amendment. The district court denied the motion, finding that the officers had reasonable suspicion to believe the defendant was armed and dangerous, based on his furtive movement, gang affiliation, and parole status for a violent crime. The defendant entered a conditional guilty plea, reserving his right to appeal the suppression ruling, and was sentenced to thirty-seven months in prison.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the motion to suppress de novo, considering the totality of the circumstances. The court held that the combination of the defendant’s dramatic movement, his recognized gang membership, and his parole for robbery provided reasonable suspicion that he was armed and dangerous, justifying the protective vehicle search under the officer safety exception to the Fourth Amendment. The court also rejected the defendant’s constitutional challenge to § 922(g)(1), finding it foreclosed by circuit precedent. The Tenth Circuit affirmed the district court’s judgment. View "United States v. McGregor" on Justia Law

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

A Black man was charged with multiple offenses, including felony false imprisonment, after a domestic violence incident in which his girlfriend alleged he struck her and prevented her from leaving his car. Witnesses observed the girlfriend attempting to exit the moving vehicle and heard shouting. The girlfriend initially told police that the defendant hit her and threatened her if she tried to leave, but later recanted, claiming she fabricated the story out of anger. The prosecution introduced both her initial statements and her recantation at trial. The jury found the defendant guilty of felony false imprisonment and other related charges, but acquitted him of attempted robbery. He admitted a prior conviction, and the trial court imposed a total sentence of nine years and four months, including time for an unrelated prior case.During trial, the defendant’s counsel raised concerns under the California Racial Justice Act (RJA) regarding the racial composition of the jury venire and the prosecution’s peremptory challenge of a Black prospective juror. The Santa Clara County Superior Court denied these motions, finding no evidence of bias or violation of the RJA. At sentencing, the court made comments referencing the defendant’s race and background, but defense counsel did not object to these statements under the RJA.The California Court of Appeal, Sixth Appellate District, reviewed the case. It held that the defendant forfeited his RJA claims on appeal by failing to object to the trial court’s statements at the appropriate time. The court also found no merit in the claim of ineffective assistance of counsel, as there was a conceivable tactical reason for not objecting. Additionally, the appellate court determined that the trial court did not err in failing to instruct the jury on misdemeanor false imprisonment, as there was no substantial evidence to support that lesser offense. The judgment of conviction and sentence was affirmed. View "People v. Wagstaff" on Justia Law