Justia Civil Rights Opinion Summaries

The case revolves around Mr. Lyndell Daniels, who was detained by law enforcement officers who linked him to a stolen Glock firearm based on his name. Daniels was charged with being a felon in possession of a firearm. Daniels moved to suppress his name as the fruit of an unlawful investigative detention, arguing that the officers had no reasonable suspicion to detain him. The district court agreed with Daniels and granted his motion. The government appealed this decision, arguing that the district court erred because there was reasonable suspicion to detain Daniels.The case originated from a near-anonymous call to the Aurora Police Department, expressing concern about three Black men, wearing dark hoodies and jeans, intermittently taking guns in and out of their pockets and getting in and out of a dark SUV. The caller believed they were “getting ready to do something,” but reported no illegality. The police arrived at the scene and detained Daniels, who was standing near the SUV. The officers did not observe any illegal activity or firearms when they arrived.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the totality of the circumstances known to the officer when he detained Daniels did not amount to reasonable suspicion. The court noted that the 911 call, the presence and actions of the SUV, the time of the encounter, and the location of the encounter were not sufficient to establish reasonable suspicion. The court concluded that Daniels' detention was unreasonable under the Fourth Amendment, and the district court's grant of Daniels' motion to suppress was proper. View "United States v. Daniels" on Justia Law

The case revolves around an incident involving Corey Fisherman, an inmate at Minnesota’s maximum-security prison, and David Launderville, a prison guard. Fisherman was being transferred to a more restrictive area after a shank was found in his cell. During the transfer process, Fisherman initially refused to undergo a strip search, leading to the intervention of the A-Team, a group of guards trained to handle noncompliant inmates, which included Launderville. After the search, Fisherman objected to kneeling and placing his hands through a small opening in his cell door. Once he complied, he was handcuffed. Fisherman alleges that Launderville kneed him six times, three times each in the face and body, while another guard kneeled on his legs. Launderville, however, claims he struck Fisherman twice in the leg because he was resisting.The case was initially heard in the United States District Court for the District of Minnesota. The magistrate judge identified a potential jury issue: whether Launderville struck a restrained inmate six times in the face and body or a partially unrestrained one just twice in the leg. The district court adopted the report and recommendation, leading to an appeal to the United States Court of Appeals for the Eighth Circuit.The Court of Appeals affirmed the district court's decision, denying Launderville's claim of qualified immunity. The court found that a reasonable jury could conclude that the repeated blows to Fisherman's head and body were "malicious and sadistic." The court also determined that the law was clearly established that repeatedly striking a fully restrained inmate violates the Eighth Amendment. Therefore, the court concluded that every reasonable official in Launderville's position would have understood that kneeing a restrained inmate several times in the face and body violated that right. View "Fisherman v. Launderville" on Justia Law

The plaintiff, John Deaton, was arrested and charged with assault, battery, and disorderly conduct following an altercation at a youth football game. Although the charges were later dismissed, Deaton filed state and federal claims against the Town of Barrington and several individuals, including police officers and the town manager. The case was removed from state court to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of the defendants on most counts and remanded three counts to the state court for resolution. Deaton appealed, arguing that the district court improperly found that probable cause to arrest him existed, improperly denied his post-judgment motion, and should have abstained and remanded to state court to allow the state claims to be resolved.The district court had granted summary judgment in favor of the defendants, finding that there was probable cause for Deaton's arrest. The court also denied Deaton's post-judgment motion for relief. Deaton appealed these decisions, arguing that the district court had improperly found probable cause for his arrest, improperly denied his post-judgment motion, and should have abstained from hearing the case and remanded it to state court.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that the district court had correctly determined that there was probable cause for Deaton's arrest. The court also found that the district court had not erred in denying Deaton's post-judgment motion for relief. Finally, the court determined that abstention was not appropriate in this case, as resolution of the state law question would not avoid the need to resolve a significant federal constitutional question. View "Deaton v. Town of Barrington" on Justia Law

The case involves a defendant who was convicted of first-degree murder with special circumstances and an enhancement for personally and intentionally discharging a firearm causing great bodily injury or death. The defendant appealed his conviction, arguing that his trial counsel exhibited racial bias towards him in violation of the California Racial Justice Act of 2020 (RJA) by advising him to use Ebonics and slang when he testified. He also contended that the trial court erred in imposing two sentence enhancements and a parole revocation restitution fine after sentencing him to life without the possibility of parole.The Court of Appeal of the State of California, First Appellate District, Division Five, found that the defendant's trial counsel did not exhibit racial bias. The court noted that the counsel's advice to the defendant to "speak how you speak" when testifying was a valid tactical decision aimed at ensuring the defendant appeared authentic and genuine before the jury. The court also found that the defendant had not demonstrated by a preponderance of the evidence that his counsel's advice indicated racial animus or bias towards him. Therefore, the court concluded that there was no violation of the RJA.The court also found that the defendant's claim that his enhancements should have been stricken was forfeited for failure to request that the trial court strike the enhancements under section 1385. However, the court agreed with the defendant and the People that the trial court improperly imposed a parole revocation restitution fine. The court modified the judgment to strike the parole revocation restitution fine and affirmed the judgment in all other respects. View "P. v. Coleman" on Justia Law

In May 2019, police officers detained Marlon Flores in a Los Angeles neighborhood known for narcotics and gang activity. The officers observed Flores standing alone near a parked car, ducking behind it as they approached. The officers suspected Flores was involved in narcotics activity due to his behavior and the area's reputation. During a pat-down search, the officers found a drug pipe in Flores's car and methamphetamine in his wallet. Flores was subsequently charged with carrying a loaded firearm and armed possession of methamphetamine.The trial court denied Flores's motion to suppress the evidence, reasoning that his behavior was suspicious enough to warrant detention and subsequent questioning. Flores pleaded no contest to the firearm charge, and the methamphetamine charge was dismissed. He was sentenced to three years' probation. The Court of Appeal affirmed the judgment, concluding that Flores was not detained until he was ordered to stand and put his hands behind his head, and that reasonable suspicion justified the detention.The Supreme Court of California reversed the lower courts' decisions. The court held that the officers' observations of Flores's behavior, combined with his presence in a high crime area at night, did not provide a particularized and objective basis for suspecting that Flores was engaged in illegal activity. The court emphasized that a person's mere presence in a high crime area cannot transform them into a suspect. The court concluded that the officers lacked reasonable suspicion to detain Flores, and thus, the evidence obtained during the pat-down search should have been suppressed. The case was remanded to the trial court to allow Flores to withdraw his no contest plea and for the court to grant Flores's suppression motion. View "P. v. Flores" on Justia Law

The defendant, Jason Pederson, was found guilty of one count of terrorizing following a jury trial. The charge was based on two emails Pederson sent to her former employer, threatening to retrieve damages through the taking of physical assets and warning employees to stay out of the way to avoid unnecessary deaths. These emails were sent after Pederson had filed an employment discrimination lawsuit against her former employer. After receiving the emails, the employer contacted law enforcement, leading to Pederson's arrest.The case was first heard in the District Court of Cass County, East Central Judicial District. During the trial, Pederson, who represented herself, argued that the State had violated her rights under Brady v. Maryland by failing to provide her with a recording of a conversation she had with Officer Tanner Anderson, who had informed her that she was trespassed from her former employer's property. The State argued that the recording was not relevant to the terrorizing charge and had been filed under a civil trespass file, not the criminal case. The court ruled that the State's failure to disclose the recording was not intentional and that the State must provide it before Officer Anderson was called as a witness.The case was then appealed to the Supreme Court of North Dakota. The Supreme Court affirmed the lower court's decision, concluding that Pederson did not establish a Brady violation. The court found that although the State had possessed the recording and did not disclose it to Pederson, Pederson had not demonstrated that the recording was favorable to her or plainly exculpatory. The court also concluded that Pederson did not preserve the issue of insufficient evidence because she failed to move for acquittal under N.D.R.Crim.P. 29 and did not argue obvious error. View "State v. Pederson" on Justia Law

The case revolves around an incident where Colorado Springs Police Officers Robert McCafferty and Christopher Pryor responded to a 911-call placed by Sasha Cronick reporting a drug overdose. During the incident, Officer Pryor questioned Cronick, which escalated into an argument, leading to her arrest for failure to desist and disperse in violation of Colorado Springs Code § 9.2.103. Cronick filed a claim under 42 U.S.C. § 1983, alleging the officers violated her constitutional rights. The officers asserted qualified immunity, but the district court denied their claim.The district court found several disputes of fact, including whether Officer Pryor issued an order for Cronick to leave the scene, whether Cronick was obstructing the scene, and whether Officer Pryor grabbed Cronick's arm to escort her away or after she had already turned to walk away. The court concluded that these disputes prevented it from finding that the officers had probable cause to arrest Cronick.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court concluded that a reasonable officer under these circumstances would not have arguable probable cause to arrest Cronick for failure to desist or disperse. The court also found that the officers did not have probable cause to conduct a search incident to arrest. The officers failed to articulate specific facts that led them to believe Cronick posed a threat and offered nothing beyond conclusory references to safety. Therefore, the officers were not entitled to qualified immunity because they violated Cronick's clearly established constitutional rights. View "Cronick v. Pryor" on Justia Law

Two former police officers, John Powell and Brian Scott, were indicted for violating their oaths of office under OCGA § 16-10-1. The indictment alleged that they failed to uphold the Constitution of the United States as interpreted by Brady v. Maryland by not conducting investigations into allegations of police misconduct. The officers filed a general demurrer, arguing that the indictment failed to adequately charge them with any offense against the laws of Georgia, and that the oath-of-office statute was unconstitutionally vague as applied to the facts of the case. The trial court denied the demurrer, concluding that the allegations would constitute conduct violative of the oaths of office taken by the officers.The Supreme Court of Georgia reviewed the trial court's ruling on the general demurrer de novo. The court agreed with the officers that the trial court's ruling regarding the sufficiency of the indictment was erroneous, and their general demurrers should have been granted. The court found that the indictment alleged that the officers committed the crimes in a specific way that was legally impossible. The court concluded that the indictment against the officers could not withstand a general demurrer and reversed the trial court's denial of the general demurrers to the indictment. The court did not reach the officers' constitutional challenge or the speedy-trial issue also before them on appeal. View "POWELL v. STATE" on Justia Law

The case involves David Thurston, a registered sex offender, who moved to Avery County, North Carolina, where Kevin Frye served as Sheriff and Lee Buchanan was the Deputy in charge of sex-offender registrations. Thurston informed Sheriff Frye that he had been invited to his nephew’s wedding in Spokane, Washington, and sought advice on how to comply with the law and asked for permission to attend the wedding. Sheriff Frye gave Thurston permission to travel and instructed him to email a copy of his Washington visitor-registration form within ten days of his arrival. However, while Thurston was away, the Sheriff’s Office mailed his verification form. Thurston contacted Sheriff Frye for guidance, but Sheriff Frye never responded. Deputy Buchanan began investigating Thurston and obtained a warrant alleging three different criminal violations. Thurston was arrested upon his return to North Carolina.The United States District Court for the Western District of North Carolina denied the officers' motion for summary judgment, arguing that they were entitled to qualified immunity because their arrest of Thurston did not violate his Fourth Amendment rights. The officers appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision. The court found that Thurston’s arrest was unconstitutional and that the officers failed to prove that they acted objectively reasonably in seeking Thurston’s arrest warrant. The court also concluded that the officers were not entitled to qualified immunity because Thurston’s right to be free from unlawful arrest was clearly established. View "Thurston v. Frye" on Justia Law

The case involves Victor Hill, the former Sheriff of Clayton County, Georgia, who was convicted under 18 U.S.C. § 242 for using his position to deprive detainees in his custody of their constitutional rights. Hill ordered individual detainees, who were neither violent nor uncontrollable, into a restraint chair for at least four hours, with their hands cuffed behind their backs and without bathroom breaks. Each detainee suffered injuries, such as “open and bleeding” wounds, lasting scars, or nerve damage.Hill was convicted by a jury in the United States District Court for the Northern District of Georgia. He appealed his conviction to the United States Court of Appeals for the Eleventh Circuit, arguing that he lacked fair warning that his conduct was unconstitutional, that the evidence was insufficient to support his conviction, and that the district court improperly handled allegations of juror misconduct.The Eleventh Circuit rejected Hill's arguments and affirmed his conviction. The court found that case law provided Hill with fair warning that his actions violated constitutional rights. The court also found that the evidence was sufficient to support the jury's conclusion that Hill's conduct had no legitimate nonpunitive purpose, was willful, and caused the detainees’ injuries. Lastly, the court found that the district court did not abuse its discretion in investigating and responding to alleged juror misconduct. View "United States v. Hill" on Justia Law