Justia Civil Rights Opinion Summaries

Steven Catlin, a California state prisoner, appealed the district court’s denial of his 28 U.S.C. § 2254 habeas corpus petition challenging his 1990 conviction for the murders of his fourth wife, Joyce Catlin, and his adoptive mother, Martha Catlin, as well as his death sentence. Catlin was convicted of murdering three family members with paraquat, a poisonous herbicide. The habeas petition in this case relates to his convictions for the murders of Joyce and Martha and the death sentence for Martha’s murder.The California Supreme Court (CSC) summarily denied Catlin’s first state habeas petition on the merits in 2007 and rejected his second state habeas petition in 2013 as procedurally barred. The district court denied Catlin’s federal habeas petition and his motion for discovery and evidentiary development in 2019, granting a certificate of appealability on several claims.The United States Court of Appeals for the Ninth Circuit reviewed Catlin’s claims under the deferential standard set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Catlin’s habeas petition, concluding that the CSC reasonably rejected Catlin’s claims. The court held that the CSC acted reasonably in rejecting Catlin’s claims of error arising from the state trial judge’s ex parte discussion with a juror, concluding that there was no ineffective assistance of counsel at both the guilt and penalty phases of Catlin’s trial, and determining that there was no violation of due process rights under Brady v. Maryland and Napue v. Illinois.The Ninth Circuit also declined to issue a certificate of appealability for Catlin’s uncertified claim that the state violated his due process rights by withholding exculpatory evidence and presenting false evidence. The court found that no reasonable jurist could debate the district court’s resolution of this claim. View "CATLIN V. BROOMFIELD" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law

The appellant, Shawn Lee Perrot, was convicted in 2004 of multiple sexual offenses involving minors, including forcible rape, lewd acts on a child, and distribution of lewd material to a minor. After serving over 16 years of a 21-year sentence, he was paroled with specific conditions. Perrot violated three parole conditions: accessing and using computer devices, associating with known sex offenders, and possessing sexually stimulating devices. He challenged these conditions as unconstitutionally vague and overbroad.Upon his release, Perrot refused to sign parole conditions, leading to civil commitment proceedings, which were later dismissed. He was evaluated as high risk for reoffending. Perrot signed parole conditions, including prohibitions on computer access, associating with sex offenders, and possessing sexually stimulating devices. He filed grievances and a habeas corpus petition challenging these conditions, which were largely denied, though he was temporarily allowed limited computer use for legal research.The Department of Adult Parole Operations filed a petition for parole revocation, alleging Perrot violated the conditions. Evidence showed he possessed multiple unauthorized devices, operated a business assisting sex offenders, and had sexually stimulating devices. The court found probable cause and revoked his parole, sentencing him to a 60-day jail term, followed by reinstatement to parole.The California Court of Appeal, First Appellate District, reviewed the case. The court rejected Perrot's claims, holding that the parole conditions were not unconstitutionally vague or overbroad. The court found the conditions were sufficiently precise and narrowly tailored to address the state's compelling interest in preventing Perrot from reoffending. The order revoking Perrot's parole was affirmed. View "P. v. Perrot" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law

Jessie Grace was convicted of second-degree murder in 1994 and sentenced to life in prison without the possibility of probation or parole. The Louisiana Fifth Circuit affirmed his conviction. Over the next 18 years, Grace filed several post-conviction relief applications, all of which were denied until 2012, when he was granted leave to reopen his federal proceedings based on newly discovered evidence. Grace obtained state grand jury testimony that revealed discrepancies between the grand jury and trial testimonies of two key witnesses: Sergeant Snow and Michelle Temple. These discrepancies suggested that another individual, Darrick Hudson, might have been involved in the crime.In 2015, Grace filed a third application for post-conviction relief in state trial court, alleging Brady violations based on the grand jury testimony. The state trial court granted his application, vacated his conviction, and ordered a new trial. The State appealed, and the Louisiana Fifth Circuit reversed the trial court's decision, reinstating Grace's life sentence. The Louisiana Supreme Court denied Grace's subsequent writ application in 2019. Grace then filed a second supplemental application in federal district court, asserting a Brady claim. The district court granted relief, but the United States Court of Appeals for the Fifth Circuit vacated the order and remanded for further proceedings.On remand, the district court again granted Grace's habeas relief, finding that the state court erred in its consideration of the materiality of the suppressed evidence. The State appealed, and the Fifth Circuit reviewed the case. The Fifth Circuit determined that the state court's decision was not an unreasonable application of clearly established federal law and that the suppressed evidence was not material enough to undermine confidence in the verdict. The Fifth Circuit reversed the district court's decision and denied Grace's application for habeas relief. View "Grace v. Hooper" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

Nathan Wilson and Christopher Beasley were alleged to have set fire to a police car during a protest in Santa Monica, California, following the killing of George Floyd. They were federally indicted on one count of arson. The defendants moved to dismiss the indictment, arguing they were selectively prosecuted based on perceived anti-government views. Alternatively, they sought discovery on their selective-prosecution claim.The United States District Court for the Central District of California denied the motion to dismiss but granted discovery on the selective-prosecution claim. The government indicated it would seek appellate review rather than comply with the discovery order, leading the district court to dismiss the indictment without prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction under 18 U.S.C. § 3731, which allows for government appeals in criminal cases without requiring final decisions. The court found that the district court abused its discretion by granting discovery based on an erroneous view of the law. The district court had incorrectly defined the control group for determining discriminatory effect, failing to account for relevant factors beyond committing the same crime in the same location.The Ninth Circuit reversed the district court’s selective-prosecution discovery order and the dismissal of the indictment without prejudice. The case was remanded for further proceedings consistent with the opinion. The court did not address whether the defendants presented evidence of discriminatory intent. View "USA V. WILSON" on Justia Law

The defendant, Angelo Clark, was charged with multiple counts of attempted first-degree murder and aggravated battery following a gang-related shooting in 2013 that injured two people. Clark moved to quash his arrest, which was based on an investigative alert issued by the Chicago Police Department. The circuit court denied his motion, and Clark did not contest this denial further in the circuit court.In 2017, a jury in the Cook County Circuit Court convicted Clark of two counts of aggravated battery with a firearm under an accountability theory. He was initially sentenced to 46 years in prison, which was later reduced to 32 years upon reconsideration.Clark appealed, and the Appellate Court, First District, affirmed his conviction and sentence. The appellate court rejected Clark's argument that his arrest was unconstitutional because it was based on an investigative alert rather than a warrant. The court also found no plain error in the circuit court's consideration of sentencing factors for juvenile offenders, as Clark was 17 at the time of the offense.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that warrantless arrests based on probable cause do not violate the Illinois Constitution, even if communicated via an investigative alert. The court also found that the circuit court had considered the relevant factors for sentencing juvenile offenders, as required by section 5-4.5-105(a) of the Unified Code of Corrections, and thus, there was no clear or obvious error in the sentencing process. View "People v. Clark" on Justia Law

David Vincent was stopped by Officer David Robertson of the Edmonton Police Department based on a tip from a known informant and an alleged equipment violation. The informant reported that two individuals at a gas station appeared to be intoxicated. Officer Robertson observed a vehicle with red parking lights, which he believed violated a new law that had not yet taken effect. He followed the vehicle, observed no traffic violations, and stopped it. Vincent was found to have a suspended license, and a search of the vehicle revealed drugs and paraphernalia.The Metcalfe Circuit Court denied Vincent's motion to suppress the evidence obtained from the stop, ruling that the officer's belief about the equipment violation was an objectively reasonable mistake of law. The court also found the informant's tip provided a sufficient basis for the stop. Vincent entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The Court of Appeals affirmed the trial court's decision, holding that the stop was supported by reasonable suspicion and the subsequent search was lawful under the automobile exception to the warrant requirement.The Supreme Court of Kentucky reviewed the case and reversed the lower courts' decisions. The court held that the stop was not justified by the equipment violation because the law had not yet taken effect, and the officer's mistake of law was not reasonable. Additionally, the informant's tip did not provide reasonable suspicion for the stop, as it was based on observations that could be explained by innocent behavior and was not corroborated by the officer's own observations. The court remanded the case for the trial court to grant Vincent's motion to suppress the evidence obtained from the unlawful stop. View "VINCENT V. COMMONWEALTH OF KENTUCKY" on Justia Law

Tyler Story was charged with first-offense DUI after being observed driving at high speed with one headlight and failing field sobriety tests. He admitted to drinking and had a breathalyzer result of 0.178. Story requested an independent blood test, which was drawn but not tested immediately. The sample was stored by the police. Story was charged and sought to preserve the sample for independent testing. The District Court suppressed the breathalyzer results due to an error in administration, leaving the Commonwealth without evidence. The Commonwealth obtained a warrant to test the independent blood sample, which Story opposed.The Campbell District Court denied Story's motion to return the blood sample for independent testing, finding he had abandoned it. The Campbell Circuit Court denied Story's petition for a writ of prohibition against the search warrant. The District Court allowed the Commonwealth to test the sample, which showed a blood alcohol level above the legal limit. Story entered a conditional guilty plea and appealed. The Circuit Court and the Court of Appeals affirmed the District Court's decisions, with the Court of Appeals disagreeing on the abandonment but upholding the testing as evidence.The Supreme Court of Kentucky reviewed the case and found that Story's statutory right to an independent blood test was infringed, but the error was harmless since the breathalyzer test was suppressed. However, the Court concluded that the Commonwealth's testing of the blood sample was conducted under an invalid warrant and without Story's consent, violating his Fourth Amendment rights. The Court reversed the District Court's denial of Story's motion to suppress the test results, vacated his conviction, and remanded for further proceedings. View "STORY V. COMMONWEALTH OF KENTUCKY" on Justia Law