Justia Civil Rights Opinion Summaries

Justin Johnson, a pretrial detainee at Jefferson County Jail, was attacked by two other inmates while in protective custody. Johnson sued correctional officers Jacob Schurman and Christopher Taylor under 42 U.S.C. § 1983 for failure to protect him and for negligence under Missouri law. The district court granted summary judgment in favor of the officers, finding that qualified immunity barred the § 1983 claims and that official immunity and the public duty doctrine barred the negligence claims.The United States District Court for the Eastern District of Missouri determined that Johnson could not show a constitutional violation necessary to overcome qualified immunity. The court found no evidence that the officers were deliberately indifferent to a substantial risk of serious harm, as the attackers were not known to be violent, and Johnson had no prior relationship with them. The court also dismissed the negligence claims, ruling that the officers were protected by official immunity because their actions were discretionary, not ministerial. Additionally, the court found that the public duty doctrine applied, as the officers owed no particular duty to Johnson beyond that owed to the general prison population.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the officers were entitled to qualified immunity, as Johnson failed to show that they were deliberately indifferent to a known risk. The court also upheld the dismissal of the negligence claims, concluding that the officers' actions involved discretionary decisions protected by official immunity. The court did not address the public duty doctrine, as the official immunity finding was sufficient to resolve the negligence claims. View "Johnson v. Schurman" on Justia Law

From 1990 to 1999, Patrick Rose, Sr., a Boston Police Department (BPD) officer, sexually abused two children, John and Jane Doe. Rose pled guilty to 21 counts of child rape and sexual assault in April 2022. The Does, now adults, sued Rose, the BPD, and other defendants involved in the investigation and response to their abuse allegations, claiming the defendants deprived them of their Fourteenth Amendment right to bodily integrity by enhancing the danger from Rose's abuse.The United States District Court for the District of Massachusetts dismissed the case before discovery, concluding that the defendants could not be held responsible under the state-created danger doctrine because the Does did not sufficiently allege that the defendants' actions enhanced Rose's abuse and caused them harm. The court also dismissed the Does' remaining claims.The United States Court of Appeals for the First Circuit vacated the district court's decision regarding the Does' Fourteenth Amendment claims. The appellate court concluded that the Does plausibly alleged that some of the defendants' actions enhanced the danger to them, meeting the first requirement of the state-created danger test. The court remanded the case for the district court to evaluate those actions under the test's remaining requirements. The appellate court also vacated the dismissal of the claims against the City of Boston and the DCF defendants, allowing the Does to address those claims. However, the appellate court affirmed the dismissal of the Does' § 1985 claims, agreeing with the district court that the Does failed to allege membership in a protected class or class-based discrimination. View "Doe v. City of Boston" on Justia Law

Police identified the defendant as a suspect in a violent assault and rape after DNA evidence linked him to the crime. During a custodial interview, the defendant denied involvement and offered an implausible explanation for the DNA match. The victim died three days later, and the State charged the defendant with capital murder and rape. A jury convicted him on both counts, and the district court merged the rape conviction into the capital murder conviction at sentencing.Prior to trial in the Sedgwick District Court, the defendant moved to suppress his statements to police, arguing he could not knowingly and intelligently waive his Miranda rights due to cognitive impairments. The court heard testimony from expert witnesses for both sides and ultimately found the defendant had sufficient cognitive ability to understand his rights and denied the motion to suppress. The defendant also objected to the racial composition of the jury pool, requested an implicit bias instruction, and challenged the court’s refusal to remove a juror for cause. The district court overruled these objections and denied a motion for a new trial.On direct appeal, the Supreme Court of the State of Kansas reviewed the case. The court held that the defendant knowingly and intelligently waived his Miranda rights, finding substantial evidence supported the district court’s conclusion. The court also held that the defendant failed to demonstrate systematic exclusion of a distinctive group from the jury pool or substantial underrepresentation of Black jurors. The court found no error in the district court’s refusal to give an implicit bias instruction, as the requested instruction was not legally appropriate. Finally, the court held that the defendant was not prejudiced by the denial of a for-cause juror challenge because the juror was removed by peremptory strike. The convictions were affirmed. View "State v. McNeal " on Justia Law

Mariano Albert Valdez was sentenced to life without the possibility of parole (LWOP) for a murder he committed at age 17. In 2018, Valdez petitioned for resentencing under Penal Code section 1170(d)(1), which allows juvenile offenders sentenced to LWOP to seek resentencing after 15 years of incarceration. The trial court granted the petition and resentenced Valdez to 50 years to life.In 2024, Valdez petitioned for resentencing again, arguing that his 50-year-to-life sentence was the functional equivalent of LWOP, citing People v. Heard, which held that denying resentencing relief to juvenile offenders sentenced to the functional equivalent of LWOP violates equal protection. The trial court construed Valdez's filing as a petition under section 1170(d)(10), which allows for resentencing after 20 years of imprisonment if the defendant was resentenced to LWOP or its functional equivalent. The trial court granted the petition, reasoning that Valdez's 50-year-to-life sentence was the functional equivalent of LWOP and that excluding him from resentencing relief would violate equal protection.The People petitioned for a writ of mandate to compel the trial court to deny Valdez's resentencing relief. The California Court of Appeal, Fourth Appellate District, Division Two, granted the petition. The court clarified that the reasoning in Heard does not apply to section 1170(d)(10) if the defendant was eligible for youth offender parole under the sentence imposed at resentencing under section 1170(d)(1). Valdez was eligible for youth offender parole under his 50-year-to-life sentence, making it not the functional equivalent of LWOP. Therefore, Valdez was not entitled to relief under section 1170(d)(10). The court directed the trial court to vacate its order granting resentencing relief and to deny Valdez's petition for resentencing. View "People v. Superior Court (Valdez)" on Justia Law

Eugene Hollow Horn Bear was convicted by a jury of two counts of abusive sexual contact and pled guilty to one count of failure to register as a sex offender. He was sentenced to 108 months’ imprisonment followed by a 5-year term of supervised release. Hollow Horn Bear appealed, arguing insufficient evidence for his convictions, a violation of the Double Jeopardy Clause, and that his sentence was substantively unreasonable.The United States District Court for the District of South Dakota initially handled the case. Hollow Horn Bear was indicted on multiple counts, including sexual abuse and failure to register as a sex offender. The district court severed the SORNA counts, and Hollow Horn Bear was tried on the sexual abuse counts. He was acquitted of sexual abuse of a person incapable of consent but convicted of two counts of abusive sexual contact. He later pled guilty to failure to register as a sex offender, and the court dismissed the remaining count. At sentencing, the court considered his criminal history and mitigating factors but imposed a total term of 108 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support the convictions, as the jury was entitled to believe the testimony of the witnesses despite their intoxication. The court also found no Double Jeopardy violation, as each act of sexual contact constituted a separate offense under the relevant statutes. Finally, the court determined that the sentence was substantively reasonable, given the serious nature of the offense and the district court’s consideration of the mitigating factors. The Eighth Circuit affirmed the judgment and sentence of the district court. View "United States v. Hollow Horn Bear" on Justia Law

Adam Urda attended a gathering where he attempted to start a bonfire with motor oil and racecar fuel, resulting in an explosion that injured him, another adult, and a four-year-old girl. The girl was severely injured and required extensive medical treatment. Trooper Jeffrey Sokso investigated the incident, interviewed witnesses, and filed a criminal complaint against Urda for aggravated assault, risking a catastrophe, and recklessly endangering another person. The charges were approved by an assistant district attorney. However, a magistrate judge dismissed the first two charges, and the Court of Common Pleas dismissed the third charge, finding no probable cause.Urda then sued Sokso in federal court for unlawful seizure, false arrest, malicious prosecution, abuse of process, and intentional infliction of emotional distress under 42 U.S.C. § 1983. The United States District Court for the Middle District of Pennsylvania granted summary judgment for Sokso on the abuse of process and intentional infliction of emotional distress claims but denied it on the remaining claims, rejecting Sokso's qualified immunity defense.The United States Court of Appeals for the Third Circuit reviewed the case and held that qualified immunity protects Sokso. The court found that Urda did not provide any precedent showing that Sokso's actions violated clearly established law. The court emphasized that qualified immunity shields officers unless it is clear to a reasonable officer that their conduct was unlawful. The court concluded that Sokso's actions did not rise to the level of an obvious constitutional violation and that the District Court had defined the right too abstractly. Consequently, the Third Circuit reversed the District Court's denial of summary judgment on the remaining claims, granting Sokso qualified immunity. View "Urda v. Sokso" on Justia Law

Kristopher Birtcher, experiencing a mental health crisis, was reported to law enforcement by a Hobby Lobby manager. Birtcher, unarmed and not threatening anyone, was detained by sheriff’s deputies. During the detention, Birtcher attempted to flee but was subdued by multiple deputies who restrained him in a prone position, applying bodyweight pressure to his back. Despite Birtcher’s pleas that he could not breathe, the deputies maintained the restraint, and Birtcher eventually stopped moving and died from asphyxiation and sudden cardiac arrest.In the Superior Court of San Diego County, the trial court granted summary judgment in favor of the defendants, finding no triable issues of material fact regarding the excessive force claim. The court concluded that the deputies’ actions were in accordance with their training and that Birtcher’s restraint was proper. The court also ruled that plaintiff failed to establish a legal basis for the negligent training claim against Sheriff William D. Gore.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court reversed the trial court’s decision, holding that there were indeed triable issues of material fact regarding the excessive force used by the deputies. The appellate court found that the evidence, including expert testimony, suggested that the deputies’ use of bodyweight pressure on Birtcher while he was restrained in a prone position could be considered excessive force. The court also held that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as there was a statutory basis for the claim and evidence suggesting his involvement in the training policies.The appellate court reversed the judgment in favor of all defendants and remanded the matter for further proceedings. View "A.B. v. County of San Diego" on Justia Law

Richard Walker was arrested at his girlfriend Ramona Paulette's residence, where he was staying overnight. Officers conducted a protective sweep of the residence and found a loaded firearm under the mattress in Walker Jr.'s bedroom. Later, with consent from Paulette's mother, Laverne Shipp, officers conducted a second search and found drugs in Paulette's bedroom. Walker was indicted for being a felon in possession of a firearm and possession with intent to distribute fentanyl. He moved to suppress the evidence, arguing the searches violated the Fourth Amendment.The United States District Court for the Southern District of Illinois denied Walker's motion to suppress, finding the protective sweep and subsequent search justified. Walker entered a conditional guilty plea, reserving the right to appeal the denial of his suppression motion. He was sentenced to 51 months' imprisonment and three years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Walker argued that the firearm and drugs were discovered through an unconstitutional search. The court found that Walker had standing to challenge the search and that the protective sweep was unlawful in scope when officers lifted the mattress in Walker Jr.'s bedroom. The court also determined that the district court erred in applying the attenuation exception to the exclusionary rule and did not address the inevitable discovery exception.The Seventh Circuit reversed the district court's denial of Walker's suppression motion and remanded the case for further proceedings to determine if the inevitable discovery exception applied and to reassess whether Shipp's consent justified the second search. View "United States v. Walker" on Justia Law

Perrie Thompson was sentenced to 50 years to life for a homicide he committed at age 17. Fifteen years later, he petitioned for relief under Penal Code section 1170(d), which allows juvenile offenders sentenced to life without parole to seek resentencing. Thompson argued that his sentence was effectively life without parole and cited cases like People v. Contreras and People v. Heard to support his claim. He presented evidence of his rehabilitation efforts while incarcerated. The trial court denied his petition, stating that his sentence was not equivalent to life without parole since he would be eligible for parole within his life expectancy.Thompson appealed the decision. The Attorney General initially opposed the appeal but later conceded that a 50-years-to-life sentence is functionally equivalent to life without parole and that denying relief to such offenders violates equal protection. However, the court independently reviewed the merits of Thompson's arguments.The California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court's order. The court held that Thompson's 50-years-to-life sentence is not the functional equivalent of life without parole for equal protection purposes. The court reasoned that the legislative intent behind section 1170(d) was to address the most severe punishments, specifically life without parole, and that the Legislature could rationally distinguish between life without parole and lengthy term-of-years sentences. The court concluded that Thompson failed to demonstrate that the exclusion of his sentence from section 1170(d) relief was irrational or unconstitutional. View "People v. Thompson" on Justia Law

Malcolm Wilson, an inmate at Indiana State Prison, was involved in an altercation where he grabbed another inmate's cane to defend himself, causing the other inmate to fall and require medical attention. Wilson was charged with battery and, after a disciplinary hearing conducted by Lieutenant Angelita Castaneda, was found guilty. Castaneda imposed a sentence that included 90 days in restrictive housing, a demotion in credit class, and up to $100,000 in restitution for medical costs.The United States District Court for the Northern District of Indiana dismissed Wilson's pro se complaint at the screening stage under 28 U.S.C. § 1915A, finding that there was sufficient evidence to support the restitution order. Wilson's motion for reconsideration was also denied. Wilson appealed the dismissal, arguing that the restitution amount was not supported by any evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, accepting the factual allegations in Wilson's complaint as true. The court found that the evidence presented at the disciplinary hearing, including Wilson's statements, video footage, and staff conduct reports, constituted "some evidence" to support the restitution order. The court held that the procedural requirements of due process were met, as Wilson received notice of the charges, an opportunity to defend himself, and a written statement of the evidence and reasons for the disciplinary action. The court affirmed the district court's judgment, concluding that Wilson received the process he was due. View "Wilson v. Castaneda" on Justia Law