Justia Civil Rights Opinion Summaries

Ajay, a recent immigrant from India with limited English proficiency, was investigated for alleged sexual assault and attempted sexual assault against a child under 14 in Reno, Nevada. The accusations stemmed from an incident involving a 13-year-old boy, A.P., whom Ajay met at his workplace and with whom he allegedly engaged in sexual acts. During a custodial police interrogation, Detective DeSantis read Ajay his Miranda rights in English. Ajay repeatedly expressed confusion, stated he was not good in English, and requested to speak in Hindi or have an interpreter. Despite this, DeSantis continued explaining the rights in English, using props and hypotheticals, until Ajay acquiesced and the interrogation proceeded, resulting in a confession.Ajay moved to suppress his statements before the Second Judicial District Court, Washoe County, arguing he had not knowingly and intelligently waived his Miranda rights due to his limited English proficiency. At a pretrial hearing, Ajay testified through an interpreter, detailing his lack of formal English education and unfamiliarity with the American legal system. The district court denied his motion, finding the waiver valid and voluntary, citing DeSantis’s efforts to clarify the warnings and Ajay’s apparent understanding.On appeal, the Supreme Court of Nevada reviewed whether Ajay’s Miranda waiver was knowing and intelligent. The court found that Ajay's limited English skills and explicit requests for an interpreter demonstrated he did not understand his rights. The court held that law enforcement must recognize when a language barrier prevents meaningful waiver and provide an interpreter as necessary. The district court’s admission of Ajay’s confession was not harmless beyond a reasonable doubt given its significance at trial. Therefore, the Supreme Court of Nevada reversed the conviction and remanded for further proceedings. View "Ajay v. State" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law

Enrique Aguilar was involved in a shootout with San Diego Police Department officers after leading one officer on a foot chase during which he brandished a gun. Although Aguilar was wounded, none of the officers were hit, and a bullet fired from Aguilar’s direction struck a nearby store door. Aguilar was charged with multiple offenses, including attempted voluntary manslaughter, assaulting peace officers with a semiautomatic firearm, shooting at an occupied building, possessing methamphetamine while armed, and being a felon in possession of a firearm. At trial in September 2023, a jury convicted him of all charges and the court sentenced him to a lengthy prison term.During jury selection in the Superior Court of San Diego County, the prosecutor used a peremptory challenge to strike a Latina juror (Juror 1), claiming she struggled to understand the concept of intent, as revealed by her responses to a hypothetical question. Aguilar objected, arguing that the prosecutor was improperly excluding Hispanic and Latina jurors. The trial court accepted the prosecutor’s explanation, found Juror 1’s answers equivocal and overruled Aguilar’s objection, determining that ethnicity was not a factor in the challenge.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of Aguilar’s objection de novo, as required by Code of Civil Procedure section 231.7. The appellate court found no substantial evidence supporting the trial court’s finding that Juror 1 was confused about intent; her answers were clear and consistent. The court held that “juror confusion” is a presumptively invalid reason for a peremptory challenge under section 231.7, and that the prosecution failed to rebut this presumption. The judgment was reversed and the case remanded for a new trial. View "P. v. Aguilar" on Justia Law

Kelsey Fitzsimmons, a North Andover police officer, was indicted in Essex County on one count of assault by means of a dangerous weapon. The Commonwealth alleged that during the service of an abuse prevention order, Fitzsimmons deceived officers regarding firearms in her home, drew a firearm, pointed it at an officer, and pulled the trigger, though the gun did not discharge. She then allegedly attempted to chamber a round before being shot by an officer. The Commonwealth presented further evidence of Fitzsimmons’s prior alcohol-related violence, mental health struggles, and a 2019 misdemeanor conviction for intoxicated and disruptive behavior. Fitzsimmons relied on medical and psychological evidence suggesting she was suitable for outpatient care and posed no credible risk of harm.Initially, the District Court ordered Fitzsimmons held on dangerousness grounds. A Superior Court judge subsequently found her dangerous but released her subject to strict conditions, including house arrest, GPS monitoring, and alcohol abstinence monitored by SCRAM testing. When Fitzsimmons claimed she could not physically comply with SCRAM testing due to injuries, the judge vacated the release order and detained her pretrial. Fitzsimmons moved for reconsideration, proposing urine testing as an alternative, but the judge denied the motion, finding that urine testing would interfere with house arrest requirements.Fitzsimmons then petitioned a single justice of the Supreme Judicial Court of Massachusetts for extraordinary relief under G. L. c. 211, § 3, arguing the judge erred in refusing less restrictive alternatives and in her conduct. The single justice denied the petition, concluding there was no error or abuse of discretion. On appeal, the Supreme Judicial Court affirmed, holding that neither the hearing judge nor the single justice abused their discretion in ordering detention when Fitzsimmons could not comply with the least restrictive conditions necessary for community safety. The Court also found no requirement for de novo review and rejected Fitzsimmons’s arguments under the Americans with Disabilities Act and other statutes. Judgment was affirmed. View "Fitzsimmons v. Commonwealth" on Justia Law

Three business entities and individuals associated with the operation of a retail store in Cedar Park, Texas, were subject to enforcement under a city ordinance banning “head shops”—stores selling items commonly used to ingest or inhale illegal substances. After receiving notices from the City, two of the appellants were charged in municipal court and fined for violating the ordinance, while the third appellant, a related business entity, was not charged. Following the municipal court’s judgment, the two charged parties appealed for a trial de novo in the county court, which annulled the municipal court’s judgment and began new criminal proceedings. They also pursued state habeas relief, which was still ongoing at the time of this appeal.Separately, the appellants filed a lawsuit in the United States District Court for the Western District of Texas, challenging the ordinance’s validity and constitutionality under federal and state law, and seeking declaratory and injunctive relief. The district court dismissed all claims as barred by the doctrine announced in Heck v. Humphrey, which precludes certain civil claims that would imply the invalidity of existing criminal convictions. The district court also dismissed a distinct claim related to termination of utility services.On appeal, the United States Court of Appeals for the Fifth Circuit held that because the municipal court’s judgments were annulled by the trial de novo and criminal proceedings were still pending under Texas law, there were no outstanding convictions to trigger the Heck bar. Thus, the Fifth Circuit reversed the district court’s dismissal of the claims challenging the ordinance and remanded for further proceedings. The court affirmed the district court’s dismissal of the standalone water termination claim, as the appellants had disclaimed any intent to pursue it. View "Kleinman v. City of Cedar Park" on Justia Law

Fernando Rodriguez died following a confrontation with law enforcement officers from the Hampton Police Department and the Henry County Police Department, who responded to a disturbance call. Rodriguez, found nude on a roadway, resisted officers’ attempts to restrain and handcuff him. The officers subdued him by holding him in a prone position and applying pressure to his body while waiting for emergency medical services. When EMS arrived, Rodriguez was not breathing sufficiently and later died at the hospital.The officers were indicted in Henry County on several charges, including malice murder, felony murder predicated on aggravated assault, felony murder predicated on violation of oath by public officer, aggravated assault, and individual counts of violation of oath by public officer. The trial court, Superior Court of Henry County, granted the officers’ general demurrer to the felony murder count predicated on violation of oath by public officer (Count 3). The trial court ruled that violation of oath by public officer was not an inherently dangerous felony and could not serve as a predicate for felony murder, referencing Wilson v. State and distinguishing Eubanks v. State.The Supreme Court of Georgia reviewed the trial court’s ruling de novo. The Supreme Court held that although violation of oath by public officer is not inherently dangerous per se, it may be considered inherently dangerous depending on the circumstances of its commission, specifically if those circumstances create a foreseeable risk of death. The indictment alleged facts that could allow a jury to find such risk. Therefore, the Supreme Court vacated the trial court’s order granting the general demurrer to Count 3 and remanded the case for the trial court to consider other grounds for demurrer that had not yet been ruled upon. View "THE STATE v. PHILLIPS" on Justia Law

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