Justia Civil Rights Opinion Summaries

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

The defendant was indicted by a federal grand jury in Massachusetts on three counts: being a prohibited person in possession of a firearm and ammunition, and two counts of possession with intent to distribute controlled substances. The first drug count was based on drugs found during his arrest, and the second on drugs found at his residence during a search. He moved to suppress evidence seized from his home, arguing the search violated the Fourth Amendment, but the district court denied the motion, finding the search was conducted under a valid warrant and in good faith. He also sought dismissal of the firearm charge, claiming the statute was unconstitutional under the Second Amendment, but that motion was denied. He then pleaded guilty to all counts.The United States District Court for the District of Massachusetts grouped the convictions for sentencing under the United States Sentencing Guidelines. The presentence report applied several enhancements, including one for being a career offender based on prior convictions. The defendant objected, arguing he had only one qualifying conviction and that a 2008 Massachusetts conviction for possession with intent to distribute cocaine should not count, because the definition of “controlled substance” had changed under federal law. The district court rejected his objections, but stated it would have imposed the same sentence even if it had accepted his arguments. The court ultimately imposed a below-Guidelines sentence of 96 months.The United States Court of Appeals for the First Circuit held that the district court erred in applying the career offender enhancement because the relevant Massachusetts conviction did not qualify as a “controlled substance offense” under the Guidelines at the time of federal sentencing, since the substance at issue was no longer federally controlled. Nevertheless, the error was harmless because the district court made clear it would have imposed the same sentence regardless. The court affirmed the convictions and sentences. View "US v. Fulcar" on Justia Law

W.W., an incarcerated person, died after experiencing a severe medical crisis while in Bureau of Prisons custody. Shronda Covington was the highest-ranking official on duty at the time and had the authority to call a physician or send W.W. to the hospital; evidence showed that she was informed of W.W.’s distress but allegedly failed to intervene. Tonya Farley, a BOP nurse, examined W.W., observed troubling symptoms, but instead of seeking appropriate medical attention, contacted a psychologist and submitted a report stating no signs of acute distress. Both Covington and Farley later made statements to investigators that were allegedly false regarding their actions during the crisis.After an investigation, Covington and Farley were charged in the United States District Court for the Eastern District of Virginia. Covington was convicted by a jury of violating 18 U.S.C. § 242 (willfully depriving W.W. of his constitutional rights, with the jury finding bodily injury but not death resulted), as well as making false statements under 18 U.S.C. § 1001. Farley was convicted of making false statements under 18 U.S.C. § 1001 but acquitted of the Section 242 charge and another false report charge. Both defendants were sentenced to terms of incarceration and home detention. Farley contested the inclusion of her acquitted conduct in calculating her Guidelines range.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Section 242’s “bodily injury results from” language requires proof of both but-for and proximate causation. The district court erred by not instructing the jury on proximate cause for Covington’s Section 242 conviction, so that conviction and both defendants’ sentences were vacated and remanded for further proceedings. The court affirmed both defendants’ convictions for making false statements under Section 1001, rejecting all other challenges. View "US v. Covington" on Justia Law

After serving a prison sentence for conspiracy to manufacture methamphetamine, the defendant began a term of supervised release, which included a condition that he refrain from any use of alcohol. The defendant, who is a practicing Messianic Jew, asked the court to modify this condition to allow him to drink a glass of wine during religious ceremonies on his Sabbath, arguing that the complete alcohol ban violated his rights under the Religious Freedom Restoration Act (RFRA) and imposed a greater deprivation of liberty than necessary under 18 U.S.C. § 3553(a). The defendant had a lengthy history of alcohol abuse intertwined with criminal behavior, including prior convictions related to intoxication and repeated violations of probation and supervised release conditions. Medical reports and court findings noted his inability to control alcohol consumption and recommended complete abstinence.The United States District Court for the Central District of Illinois denied the defendant’s motion to modify the supervised release condition. The court found that the government had a compelling interest in prohibiting the defendant from consuming alcohol entirely, given his history of rapid escalation from initial drinking to dangerous behavior. The court also found that alternatives—such as monitoring with breathalyzers—were not feasible for ensuring compliance and public safety, and therefore, a total ban was the least restrictive means to further the government’s interests.Reviewing the case, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that, under RFRA, the complete alcohol ban was the least restrictive means to further the government’s compelling interests in public safety, rehabilitation, and preventing recidivism, given the defendant’s history. The court also held that the condition did not involve a greater deprivation of liberty than necessary under § 3553(a). The district court’s denial of the motion to modify supervised release was affirmed. View "USA v Broadfield" on Justia Law

A lawyer and parents’ rights activist assisted her client in evading a Tennessee juvenile court’s order that awarded temporary custody of the client’s child to the Department of Children’s Services. The client, a single mother, fled with her daughter after being investigated for suspected child neglect. The lawyer joined the client and child at a hotel, and when they received a missing child alert, they disabled their phones and went to the lawyer’s home to avoid authorities. The police located them the following day, and the state took custody of the children. After an extended custody dispute, the state returned the children and dismissed its petition.While the custody case was ongoing, the Department of Children’s Services and local police investigated and eventually indicted both the lawyer and her client on charges related to custodial interference. Both were convicted by juries, but on appeal, the Tennessee Court of Criminal Appeals vacated the convictions. The appellate court concluded that the statute at issue required proof that the alleged interference occurred after a period of lawful visitation, an element not present in this case.The lawyer and her client then filed a federal suit in the United States District Court for the Middle District of Tennessee, alleging malicious prosecution, conspiracy, and other claims against various officials and the City of Brentwood. The district court dismissed all claims, holding that the defendants were entitled to qualified or absolute immunity and that the Monell claim against the city failed because the officers lacked final policymaking authority.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The Sixth Circuit held that the individual defendants were entitled to immunity and that the Monell claim failed as a matter of law. The court confirmed that the law provides no recourse against prosecutors and officers acting within their respective protected functions under these circumstances. View "Reguli v. Hetzel" on Justia Law

The defendant entered the United States in 1999 and remained without legal status after his tourist visa expired in 2000. He applied for and received a Washington concealed pistol license in 2019, falsely claiming to be a U.S. citizen. He also submitted Bureau of Alcohol, Tobacco, Firearms, and Explosives forms indicating citizenship to register handguns. A series of domestic violence incidents led to multiple restraining orders against him, each including a prohibition on owning or possessing firearms. Law enforcement seized firearms, ammunition, and a silencer from his residence in 2022. The defendant admitted to being a Brazilian citizen and acknowledged that he was not permitted to possess firearms due to his immigration status and domestic violence convictions.The United States District Court for the Western District of Washington denied the defendant’s motions to dismiss charges on Second Amendment, materiality, and vagueness grounds. The defendant was convicted in a bench trial based on stipulated facts for unlawful possession of firearms and ammunition as a noncitizen and as a person under a domestic violence restraining order, making false statements during firearm purchases, falsely claiming U.S. citizenship, and unlawful possession of a firearm silencer.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed all convictions. The court held that precedent from United States v. Vazquez-Ramirez controlled challenges to 18 U.S.C. § 922(g)(5)(A), confirming the constitutionality of prohibiting firearm possession by noncitizens unlawfully present. Materiality challenges to false statement convictions failed because the Second Amendment does not protect firearm possession by such individuals. The court found that United States v. Rahimi and United States v. VanDyke foreclosed challenges to convictions based on domestic violence restraining orders. The court held that the National Firearms Act’s silencer regulations do not violate the Second Amendment or the Fifth Amendment’s vagueness doctrine. The panel affirmed the district court’s judgment. View "USA V. DEBORBA" on Justia Law

Two individuals, both members of the Lincoln Park Bloods gang, were convicted in San Diego County Superior Court of two murders, conspiracy to commit murder, and attempted murder, with special circumstance and gang-related enhancements, for their roles in two gang-related shootings that occurred in 2011 and 2013. The prosecution’s theory was that higher-ranking gang members directed the killings, and a rap song performed by an uncharged coconspirator was introduced as evidence of gang motive and hierarchy. The jury found the defendants guilty on all counts and enhancements, and the trial court sentenced each to consecutive life terms without parole plus additional years.On prior appeal, the California Court of Appeal, Fourth Appellate District, Division One, vacated the gang and gang-related firearm enhancements and remanded for further proceedings. On remand, the prosecution did not retry those enhancements. The defendants moved for a new trial under the California Racial Justice Act (RJA) and newly enacted Evidence Code section 352.2, also seeking discovery under the RJA. The trial court denied all motions, finding the rap song admissible and concluding that the defendants had not demonstrated a miscarriage of justice or substantiated their claims that the song’s introduction—allegedly containing prejudicial, racially charged language—was played for the jury.The California Court of Appeal, Fourth Appellate District, Division One, held that while the trial court properly denied the new trial motions based on section 352.2, it erred by not recognizing that the defendants had established a prima facie RJA violation and by applying an overly restrictive standard to the discovery request. The Court conditionally reversed the judgments and remanded for an evidentiary hearing on the RJA claims and for reconsideration of the discovery motion in accordance with correct legal standards. If relief is denied on remand, the judgments are to be reinstated. View "People v. Haddock" on Justia Law

Two black teenagers carried out a robbery at a grocery store in Mississippi, during which one of them shot and killed the white store owner. The shooter accepted a plea deal for a 20-year sentence. The other participant was charged with capital murder, and the state sought the death penalty. During jury selection, the prosecutor used peremptory strikes on four out of five black prospective jurors. Defense counsel objected under Batson v. Kentucky, alleging that these strikes were racially motivated. The trial court asked the prosecutor for race-neutral explanations and accepted them but did not allow the defense to rebut or argue that the reasons were pretextual, effectively ending the Batson analysis at the second step. Attempts by defense counsel to revisit the issue were cut off by the court. The jury ultimately consisted of eleven white jurors and one black juror, and the defendant was convicted and sentenced to death.On direct appeal, the Mississippi Supreme Court found that the defendant had waived his Batson objection by not specifically arguing pretext at trial. In subsequent federal habeas proceedings, the U.S. District Court for the Northern District of Mississippi determined that the state court’s finding of waiver was unreasonable, noting the trial court had not conducted the required three-step Batson process and had prevented defense counsel from making a pretext argument. The District Court granted relief, but the U.S. Court of Appeals for the Fifth Circuit reversed, holding that the Mississippi Supreme Court’s waiver finding was reasonable.The Supreme Court of the United States held that the Mississippi Supreme Court unreasonably applied Batson and unreasonably determined that the defendant waived his opportunity to rebut the prosecution’s race-neutral reasons for peremptory strikes. The Court reversed the Fifth Circuit’s judgment and remanded the case for further proceedings. View "Pitchford v. Cain" on Justia Law

A man lived with his girlfriend in an apartment in Pierre, South Dakota, where they invited a teenage girl to spend time with them. On the evening in question, the group played cards and drank alcohol, but tensions arose, particularly between the man and the girl. After two friends left the apartment, the girlfriend became ill and went to the bathroom, followed by the girl to assist her. The man entered the bathroom, argued with the girl, and the girlfriend fled to seek help. Police responded to 911 calls shortly thereafter, encountered the man at the apartment, and noticed blood on him. Upon entry, police discovered the girl’s body in the bathroom, having suffered multiple stab wounds. The man was arrested, and forensic evidence linked him to the crime scene and the murder weapon.The Circuit Court of the Sixth Judicial Circuit, Hughes County, presided over the trial. During jury selection, the State used a peremptory strike to remove a Native American juror, prompting a Batson challenge from the defense. The circuit court accepted the State’s race-neutral justifications—prior negative interactions with law enforcement and criminal history—as valid reasons for the strike and allowed it to stand. At trial, the man testified, offering conflicting accounts of the events. The jury acquitted him of first-degree murder and aggravated assault but convicted him of second-degree murder, resulting in a life sentence.The Supreme Court of the State of South Dakota reviewed the appeal. It held that the circuit court did not clearly err in allowing the State’s peremptory strike, finding the reasons provided to be race-neutral and not pretextual. It also concluded that the State’s closing argument comments did not constitute improper vouching or prosecutorial misconduct. The conviction and sentence were affirmed. View "State v. Shangreaux" on Justia Law

A law enforcement officer conducted a traffic stop of an individual suspected of participating in a series of armed robberies. During the stop, the suspect, D’Juantez Mitchell, did not comply with police orders and drove his vehicle into the officer and toward another officer. In response, the officer shot and killed Mitchell. Mitchell’s estate and children challenged the officer’s use of deadly force, alleging violations of constitutional rights and Kentucky law.The United States District Court for the Western District of Kentucky granted the officer qualified immunity on federal claims brought under 42 U.S.C. § 1983, concluding there was no violation of clearly established federal law. However, the district court denied the officer’s motion for summary judgment on the state-law claims, finding a genuine dispute as to whether the officer acted in subjective good faith, and thus denied Kentucky qualified official immunity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified official immunity under Kentucky law de novo. The appellate court held that the officer’s use of deadly force constituted a discretionary act under Kentucky law and that the plaintiffs failed to provide evidence sufficient to rebut the presumption that the officer acted in good faith. The court found that neither purported inconsistencies in the officer’s testimony nor affidavits concerning his general racial animus created a genuine issue of material fact regarding his subjective intent during the incident. The court emphasized that the video evidence showed the officer and another were in imminent danger when the vehicle moved, supporting the officer’s stated belief that deadly force was necessary.The Sixth Circuit reversed the district court’s denial of qualified official immunity, holding that the officer was entitled to immunity from the state-law claims. View "Mitchell v. Conrad" on Justia Law