Justia Civil Rights Opinion Summaries

In 2000, Karl Roberts was convicted and sentenced to death in Arkansas state court for the rape and murder of his twelve-year-old niece. Roberts waived his right to challenge his conviction on direct appeal, in state postconviction proceedings, and in federal habeas corpus proceedings. Both the Arkansas state trial court and the Arkansas Supreme Court found the waiver to be knowing and voluntary. On the day of his scheduled execution in 2004, Roberts moved for a stay of execution, which was granted, and subsequently filed a petition for writ of habeas corpus, initiating two decades of litigation.The United States District Court for the Eastern District of Arkansas denied Roberts’s nineteen habeas corpus claims but granted a certificate of appealability (CoA) on three claims: whether Roberts was intellectually disabled, competent to be tried, and competent to waive his direct appeal. The Eighth Circuit expanded the CoA to include two ineffective assistance of counsel claims: failure to investigate and challenge Roberts’s competency to be tried and failure to investigate and present evidence of Roberts’s mental health as mitigating evidence at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s denial of Roberts’s habeas petition. The court held that the Arkansas courts’ findings that Roberts was not intellectually disabled, was competent to stand trial, and was competent to waive his direct appeal were reasonable and supported by the record. The court also found that Roberts’s trial counsel was not ineffective, as the counsel’s performance did not fall below an objective standard of reasonableness, and there was no prejudice to Roberts. The court concluded that Roberts failed to show that the outcome of his trial would have been different but for the alleged errors by his counsel. View "Roberts v. Payne" on Justia Law

Sha Kendrick Smith was convicted under 18 U.S.C. § 2422(b) for enticing a minor to engage in prostitution. The minor victim (MV) was a thirteen-year-old runaway who was a ward of the state. Smith provided MV with a cell phone and took her to various locations where she engaged in commercial sex with multiple men, with Smith keeping the money. MV initially told Smith she was eighteen, but he later learned she was underage. MV described Smith as always carrying a gun and being feared by those who knew him. Smith was eventually arrested after MV reported her situation to the police.The United States District Court for the Southern District of Texas sentenced Smith to 235 months of imprisonment and ten years of supervised release. The court applied two sentencing enhancements: one under U.S.S.G. § 2G1.3(b)(2)(B) for undue influence over the minor and another under U.S.S.G. § 3A1.1(b)(1) for MV’s status as a vulnerable victim. Smith objected to these enhancements, but the district court overruled his objections, adopting the presentence investigation report (PSR) and the government’s arguments.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s application of both sentencing enhancements. It found that the district court’s determination that Smith unduly influenced MV was plausible given the evidence of Smith’s control over MV, including his age, size, possession of a gun, and the fear he instilled in others. The court also upheld the vulnerable-victim enhancement, noting that MV’s age, status as a ward of the state, and economic desperation made her unusually vulnerable, and Smith knew or should have known of her vulnerabilities. The Fifth Circuit concluded that the district court did not commit clear error in its findings and affirmed Smith’s sentence. View "United States v. Smith" on Justia Law

Detective Frias of the Richmond Police Department observed an Instagram video showing known gang member J.S. and others brandishing firearms at the Belt Atlantic apartment complex. The video, posted shortly before the incident, depicted two men later identified as Anthony Cornelius Brown, Jr., and Dequane Aquil McCullers. Detectives accessed live surveillance footage showing individuals matching the video’s description at the same location. Upon arrival, the officers approached the men, who attempted to walk away. Brown and McCullers were detained and frisked, leading to the discovery of firearms.The United States District Court for the Eastern District of Virginia denied Brown and McCullers' motions to suppress the evidence of the firearms. The court found that the officers had reasonable suspicion to stop and frisk the defendants based on the video and their behavior. Brown and McCullers entered conditional guilty pleas, reserving the right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officers had reasonable suspicion to stop Brown and McCullers based on the Instagram video and their actions upon the officers' arrival. The court also found that the frisk of McCullers was justified as the officers reasonably believed he was armed. Additionally, the court ruled that the length of Brown’s detention was reasonable given the circumstances and the need to ensure officer safety. The Fourth Circuit affirmed the district court’s denial of the motions to suppress. View "US v. Brown" on Justia Law

Patrick Neiss was convicted in Montana state court of deliberate homicide and evidence tampering, based on circumstantial evidence. He filed a pro se federal habeas petition under 28 U.S.C. § 2254, claiming ineffective assistance of trial and appellate counsel. Neiss argued that his trial counsel failed to challenge the particularity of a search warrant, which led to the discovery of silencer-related internet searches on his computer, and that his appellate counsel failed to raise this issue on appeal.The United States District Court for the District of Montana dismissed Neiss’s habeas petition under Rule 4 of the Rules Governing Section 2254 Cases, which allows for preliminary screening of habeas petitions. The district court adjudicated the petition on the merits, concluding that Neiss’s trial counsel was not deficient because they had made multiple attempts to suppress the evidence, albeit not on the particularity grounds. The court did not find the petition procedurally defective or frivolous.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that the district court misapplied the Rule 4 standard, which is intended to screen out only those petitions that are procedurally defective or frivolous. The court emphasized that Rule 4 does not permit summary dismissal on the merits. The Ninth Circuit found that Neiss’s petition alleged a cognizable, non-frivolous claim of ineffective assistance of counsel, which should not have been dismissed summarily. The case was remanded for further proceedings consistent with this opinion. View "NEISS V. BLUDWORTH" on Justia Law

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

Tony Fisher, a federal inmate, filed a lawsuit against several prison officials, alleging they were deliberately indifferent to the risk of sexual assault by another inmate, resulting in his rape. Fisher entered federal prison in 2013 and was transferred to Fort Dix, where he reported past sexual assault and harassment by other inmates. Despite these reports, prison staff did not classify him as at high risk for sexual assault. Shortly after, Fisher was raped by another inmate. Fisher claimed that a prison official, Captain Fitzgerald, discouraged him from reporting the assaults and seeking legal help, warning him of potential retaliation.The United States District Court for the District of New Jersey dismissed Fisher’s complaint, ruling it was time-barred under New Jersey’s two-year statute of limitations for personal injury actions. Fisher appealed, arguing that the statute of limitations should be tolled due to the prison official’s threats and his mental health issues.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The court held that no Bivens cause of action exists for failure to protect an inmate from another inmate’s violence, following the Supreme Court’s decision in Egbert v. Boule. The court also ruled that even if such a claim were cognizable, Fisher’s complaint was untimely. The court found that Fisher did not qualify for equitable tolling because he was transferred away from the influence of the threatening official shortly after the assaults and did not exercise due diligence in pursuing his claims. Additionally, the court held that New Jersey’s revival statute for sexual assault claims did not apply to Bivens actions. View "Fisher v. Hollingsworth" on Justia Law

Two high school brothers, Kameron and Noah Evans, were arrested for disorderly conduct after wearing tactical vests to school. The brothers, who had faced racial bullying, wore the vests on a day when the school was screening an active-shooter video. They were searched by school resource officers, who found no weapons. The principal decided to have them arrested, and they were charged with disorderly conduct. The state court later acquitted them, and the brothers filed a lawsuit under § 1983 and state tort claims against the officers, alleging lack of probable cause and excessive force.The United States District Court for the Eastern District of Arkansas denied the officers' motion for summary judgment based on qualified immunity. The officers appealed, arguing they had probable cause or at least arguable probable cause to arrest the brothers for disorderly conduct under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the officers lacked probable cause to arrest the brothers, as their actions did not disrupt a lawful assembly or constitute threatening behavior. The court also determined that the officers did not have arguable probable cause, as the brothers were cooperative and their attire did not violate the school dress code. The court affirmed the district court's denial of qualified immunity on the unlawful arrest, malicious prosecution, and false imprisonment claims. However, the court reversed the denial of qualified immunity on the excessive force and abuse of process claims, as the plaintiffs failed to respond to these arguments on appeal. The case was remanded for further proceedings. View "Evans v. Dodd" on Justia Law

The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law

A Los Angeles County Sheriff’s Department deputy entered the curtilage of Harson Chong’s home without a warrant, leading to the discovery of drugs, guns, and money. Chong and Tac Tran, who was present at the home, were subsequently charged with federal drug and gun offenses. They claimed ineffective assistance of counsel because their attorneys did not object to the search on Fourth Amendment grounds.The United States District Court for the Central District of California initially denied their suppression motions, ruling the search justified by the parole-search exception. However, after the Ninth Circuit’s decision in United States v. Grandberry, the district court reversed, finding insufficient probable cause that Tran resided at Chong’s home. Despite this, the court upheld the search based on exigent circumstances. Chong and Tran were convicted, and their convictions were affirmed on direct appeal. They then filed post-conviction motions under 28 U.S.C. § 2255, which the district court denied, finding no ineffective assistance of counsel.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the deputy’s entry onto the curtilage without a warrant, consent, or exigency was unreasonable under the Fourth Amendment. The court found Chong’s counsel ineffective for not moving to suppress the evidence, as the search was clearly unlawful. However, Tran lacked standing to challenge the search, as he did not reside at Chong’s home and was merely a visitor. Consequently, the court reversed the district court’s denial of Chong’s § 2255 motion and remanded for relief, but affirmed the denial of Tran’s motion. View "Chong v. United States" on Justia Law

In 2015, Eddie Williams was prosecuted in Pennsylvania for crimes related to a drug dispute that resulted in one death and one serious injury. Williams, along with Rick Cannon and Akeita Harden, was implicated in the incident. Cannon pleaded guilty to twenty charges, including homicide and conspiracy, some of which named Williams as a coconspirator. During Williams's trial, his attorney misrepresented Cannon's plea, leading the judge to read Cannon's entire Criminal Information to the jury, which included references to Williams as a coconspirator.Williams was found guilty on all counts and sentenced to life imprisonment plus additional years. He filed a Post-Conviction Relief Act (PCRA) petition, arguing ineffective assistance of counsel due to his attorney's actions. The PCRA court denied relief, finding no Confrontation Clause violation and concluding that the attorney's strategy was reasonable. The Superior Court affirmed, and the Pennsylvania Supreme Court denied further appeal.Williams then filed a habeas corpus petition in the United States District Court for the Middle District of Pennsylvania, which granted relief, finding that the reading of Cannon's Criminal Information violated the Confrontation Clause and that Williams's counsel was ineffective for not objecting. The Commonwealth appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court held that the reading of Cannon's Criminal Information, which included references to Williams, was testimonial and violated the Confrontation Clause. The court also found that Williams's counsel was ineffective for failing to object to the reading, which prejudiced Williams's defense. The court concluded that these errors had a substantial and injurious effect on the jury's verdict, warranting habeas relief. View "Williams v. Greene" on Justia Law