Justia Civil Rights Opinion Summaries

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

Abdul Malik Muhammad was convicted of first-degree murder in 2001 for the 1999 shooting death of Damone Mims. Muhammad was interrogated by Chicago police detectives and allegedly made incriminating statements, which he later denied. He was sentenced to 50 years in prison. Muhammad's conviction and sentence were affirmed on direct appeal, and his subsequent postconviction petition and habeas corpus petition were denied.Muhammad later filed a claim with the Illinois Torture Inquiry and Relief Commission (TIRC), alleging he was tortured by police during his interrogation. The TIRC found sufficient evidence of torture to merit judicial review and referred the case to the Cook County Circuit Court. The court appointed the Office of the Special State’s Attorney, including Robert Milan, as special prosecutor. After two years of discovery, Milan moved to terminate the judicial review proceedings, arguing the TIRC acted outside its authority. The circuit court granted the motion to terminate and denied Muhammad's motions to rescind Milan's appointment as special prosecutor.Muhammad appealed, and the appellate court reversed the circuit court's orders, finding the TIRC's definition of "tortured confession" was reasonable and that Muhammad's statements qualified as such. The appellate court also found an actual conflict of interest with Milan's appointment and remanded the case for an evidentiary hearing.The Illinois Supreme Court reviewed the case and affirmed the appellate court's decision to reverse the termination of the proceedings under the TIRC Act, agreeing that the TIRC's definition of "tortured confession" was appropriate. However, the Supreme Court reversed the appellate court's decision regarding Milan's appointment, finding no actual conflict of interest. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Muhammad" on Justia Law

Plaintiff Jere Eaton sued the City of Stamford and police officer Steven Estabrook, alleging that Estabrook used excessive force during a protest on August 8, 2020. Eaton claimed that Estabrook lifted her by her bra strap, drove her backward several feet, and dropped her on the ground without warning, violating her Fourteenth Amendment rights and committing assault and battery under Connecticut state law. Estabrook and the City of Stamford moved for summary judgment on the grounds of qualified immunity and state governmental immunity.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants. The court found that while there were genuine disputes of material fact regarding whether Estabrook used excessive force, Estabrook was entitled to qualified immunity because it was not clearly established at the time that his actions were unconstitutional. The court also granted summary judgment on Eaton’s state law claims, concluding that Estabrook was entitled to state governmental immunity.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that there were genuine disputes of material fact regarding the use of excessive force. However, the appellate court concluded that Estabrook was not entitled to qualified immunity at this stage because the same factual disputes also affected whether his actions were clearly established as unconstitutional at the time. The court affirmed the district court’s judgment in part, vacated it in part, and remanded the case for further proceedings. The appellate court upheld the district court’s decision regarding state governmental immunity for the state law claims. View "Eaton v. Estabrook" on Justia Law

In 2002, Tracy Allen Hampton was convicted of killing Charles Findley, Tanya Ramsdell, and Ramsdell’s unborn child. A jury sentenced him to death. The Arizona Supreme Court affirmed Hampton’s convictions and sentences on direct appeal and denied his petition for state post-conviction relief. Hampton then filed a federal habeas petition under 28 U.S.C. § 2254, which the district court denied.Hampton raised four certified claims on appeal. The United States Court of Appeals for the Ninth Circuit held that each lacked merit. The court found that the State did not violate Brady v. Maryland or Napue v. Illinois in connection with the testimony of a jailhouse informant, George Ridley. Hampton was not prejudiced by his trial counsel’s alleged failure to obtain evidence that could have been used to impeach Ridley. The court also held that Hampton’s defense counsel were not constitutionally ineffective at the guilt or sentencing phases of his trial. Additionally, the district court acted within its discretion in denying Hampton’s request for evidentiary development on his Brady, Napue, and ineffective assistance of counsel claims. The court declined to expand the certificate of appealability to include Hampton’s uncertified claims.The Ninth Circuit affirmed the district court’s denial of Hampton’s federal habeas petition. The court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law, nor was it based on an unreasonable determination of the facts. The court also denied Hampton’s motion for reconsideration as moot. View "HAMPTON V. SHINN" on Justia Law

The case involves Justin Michael Wolfe, who was convicted of hiring Owen Barber to murder Daniel Petrole in 2001. Barber, the key witness, initially testified against Wolfe, implicating him in the murder-for-hire scheme. Wolfe was sentenced to death, but Barber later recanted his testimony, claiming he was coerced by the Commonwealth of Virginia with threats of the death penalty. Wolfe's conviction was vacated by the district court due to Brady violations and other prosecutorial misconduct, and the Commonwealth was ordered to retry Wolfe or release him.The United States District Court for the Eastern District of Virginia granted Wolfe habeas relief, finding that the Commonwealth had withheld exculpatory evidence and engaged in misconduct. The Fourth Circuit Court of Appeals affirmed this decision, but the Commonwealth continued to pursue charges against Wolfe. In a subsequent interview, Commonwealth officials again coerced Barber, leading him to invoke his Fifth Amendment rights, making him unavailable as a witness for Wolfe's retrial. Wolfe ultimately pled guilty to avoid the death penalty, receiving a 41-year sentence.Wolfe filed a new habeas petition in the Eastern District of Virginia, asserting claims of vindictive prosecution and due process violations based on the Commonwealth's intimidation of Barber. The district court dismissed the petition as untimely and found that Wolfe failed to present new, reliable evidence of actual innocence under the Schlup standard. Wolfe appealed to the Fourth Circuit Court of Appeals.The Fourth Circuit held that Barber's new declaration, which exculpated Wolfe and explained his previous invocation of the Fifth Amendment due to Commonwealth threats, constituted new, reliable evidence. The court found that Barber's declaration was credible and that no reasonable juror would have convicted Wolfe if they had heard Barber's recantation. The court vacated the district court's judgment and remanded for adjudication of Wolfe's substantive claims. View "Wolfe v. Dotson" on Justia Law

On September 1, 2016, law enforcement officers conducted narcotics raids at a home and shop in Pulaski County, Arkansas. During the raid, officers found contraband in both locations, and an officer shot and injured Lloyd St. Clair, who was holding a shotgun. Lloyd and other occupants of the home and shop filed a lawsuit under § 1983, alleging violations of their Fourth Amendment rights by the officers and the City of Little Rock.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The plaintiffs appealed the decision, arguing that there were genuine disputes of material fact regarding the existence of two separate search warrants and the justification for no-knock entries.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the record included two valid search warrants signed by a state judge, and there was no genuine dispute of material fact regarding their existence. The court also determined that the officers had reasonable suspicion to justify the no-knock entries based on videos of Amy St. Clair shooting firearms, which were seen by Officer Kalmer before the raids.Regarding Lloyd's excessive force claim, the court held that the use of deadly force by Officer Thomas was reasonable, as Lloyd admitted to pointing a gun at Thomas. The court also affirmed the district court's grant of summary judgment on the municipal liability claim, as there was no underlying constitutional violation by the city employees.The Eighth Circuit affirmed the judgment of the district court, upholding the summary judgment in favor of the defendants. View "Davenport v. City of Little Rock" on Justia Law

Detective Genaro Hernandez, a Dallas Police Department detective, was involved in a shooting investigation outside The Green Elephant bar in August 2019. Hernandez, who also worked for the Stainback Organization, allegedly pursued false charges against the bar's owner, Shannon McKinnon, and a security guard, Guadalupe Frias, to benefit his private employer. Despite the Special Investigation Unit finding no criminal offense by the plaintiffs, Hernandez bypassed standard procedures and directly sought prosecution from the Dallas County District Attorney’s Office, leading to the plaintiffs' indictment for tampering with evidence. The charges were later dropped when Hernandez's conflict of interest was revealed during Frias's trial.The plaintiffs filed a lawsuit against Hernandez, alleging federal claims under 42 U.S.C. § 1983 for false arrest and malicious prosecution, and state-law claims for malicious prosecution, false imprisonment, and civil conspiracy. The United States District Court for the Northern District of Texas dismissed the federal malicious-prosecution claim but allowed the federal false-arrest claim and the state-law claims to proceed. Hernandez appealed, arguing he was entitled to governmental immunity under the Texas Tort Claims Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Hernandez's actions, despite being motivated by personal interests, fell within the scope of his employment as a detective. The court held that Texas law provides broad immunity to state actors for actions within their employment scope, regardless of intent. Consequently, the court reversed the district court's decision denying dismissal of the state-law claims and remanded the case for further proceedings on the remaining federal claim. View "Frias v. Hernandez" on Justia Law

In March 1988, Isaiah Harris, a sheriff in Montgomery County, Alabama, was killed. His wife, Louise, was having an affair and conspired with her lover, Lorenzo McCarter, to have Harris killed for insurance money. McCarter recruited Michael Sockwell and Alex Hood to carry out the murder. Sockwell was later convicted of capital murder for pecuniary gain and sentenced to death.Sockwell appealed his conviction, arguing that the prosecution used peremptory strikes to exclude Black jurors in a discriminatory manner, violating Batson v. Kentucky. The Alabama Court of Criminal Appeals (ACCA) affirmed his conviction, finding no clear error in the trial court’s denial of the Batson challenge. The Alabama Supreme Court also affirmed, stating that the prosecutor’s identification of a juror’s race was merely descriptive and not a race-based reason for the strike.Sockwell then filed a habeas corpus petition in the United States District Court for the Middle District of Alabama, which was denied. The district court found the strike of a Black juror, Eric Davis, problematic but concluded that the Alabama Supreme Court did not unreasonably apply Batson. The district court granted a certificate of appealability on the Batson issue, and Sockwell appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit held that the Alabama Supreme Court unreasonably applied federal law by not properly considering all relevant circumstances under Batson’s third step. The court found that the prosecutor’s history of Batson violations, statistical evidence of disproportionate strikes against Black jurors, and the comparison of Davis to similarly situated white jurors indicated purposeful discrimination. The Eleventh Circuit reversed the district court’s ruling and directed it to issue a writ of habeas corpus, allowing Alabama the right to retry Sockwell. View "Sockwell v. Commissioner, Alabama Department of Corrections" on Justia Law