Justia Civil Rights Opinion Summaries

The petitioner was convicted by an Arizona jury of child molestation after he helped bathe young girls who were in his and his wife’s care through the foster system. The relevant Arizona statute defined child molestation as any direct or indirect touching of a child’s private parts, and, at the time, allowed a defendant to raise an affirmative defense by proving he was not motivated by sexual interest. The petitioner admitted to the touching but argued he lacked sexual motivation.After his first trial ended in a mistrial, the Arizona Supreme Court decided State v. Holle, which held that sexual motivation was not an element of the crime and that the lack of sexual interest was an affirmative defense the defendant must prove by a preponderance of the evidence. At the petitioner’s second trial, the court instructed the jury accordingly, and he was convicted on some counts. The Arizona Court of Appeals affirmed, relying on Holle, and the Arizona Supreme Court denied review. The United States Supreme Court also denied certiorari. The petitioner then sought federal habeas relief in the United States District Court for the District of Arizona, arguing that the statutory scheme unconstitutionally shifted the burden of disproving an essential element of the crime to him. The district court denied relief, finding the state courts’ application of federal law was not objectively unreasonable.The United States Court of Appeals for the Ninth Circuit reversed. It held that Arizona’s statutory scheme violated the Due Process Clause of the Fourteenth Amendment by shifting to the defendant the burden of disproving sexual motivation, which is the critical fact distinguishing criminal from innocent conduct. The court concluded that the Arizona Court of Appeals’ decision upholding the conviction was an objectively unreasonable application of clearly established Supreme Court precedent. The Ninth Circuit ordered the district court to grant the writ of habeas corpus. View "BIEGANSKI V. SHINN" on Justia Law

A woman was stopped by a county deputy in Texas around 2:00 AM after the officer claimed to observe multiple traffic violations, including speeding and failing to maintain a single lane. The woman, who had just left a family event with her husband, denied any wrongdoing and began recording the encounter on her phone. The officer reported smelling alcohol and observing signs of intoxication, such as slurred speech and glossy eyes. The woman refused to answer certain questions or perform field sobriety tests, leading to her arrest. Body camera footage later showed her being uncooperative and verbally abusive during the arrest and subsequent blood draw at the jail. A blood test revealed a low blood alcohol content, and the criminal charge was later dismissed for insufficient evidence.The United States District Court for the Western District of Texas granted summary judgment in favor of the county and the arresting officer on all claims. The court found that the officer was entitled to qualified immunity and that there was probable cause for the arrest based on the totality of the circumstances, including the officer’s observations and the woman’s refusal to cooperate. The court also rejected claims of First Amendment retaliation, malicious prosecution, and excessive force, as well as Monell claims against the county for alleged unconstitutional policies.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s evidentiary rulings and summary judgment de novo. The appellate court affirmed the district court’s judgment, holding that the officer had probable cause to arrest for driving while intoxicated, that the woman failed to show a constitutional violation necessary for her claims, and that the county could not be held liable under Monell without an underlying constitutional violation. The court also found no abuse of discretion in the district court’s evidentiary decisions. View "Wood v. Bexar County" on Justia Law

Rodney Owen Skurdal, who is not a licensed attorney, attempted to represent Ronald Trow during Trow’s initial appearance in a criminal case in Yellowstone County Justice Court. Judge Jeanne Walker, presiding over the case, ordered Skurdal to vacate the defendant’s table and did not permit him to represent Trow, as Skurdal was not a member of the bar. Trow subsequently entered a plea of not guilty, and a public defender was appointed. Skurdal then filed a lawsuit in the Thirteenth Judicial District Court for Yellowstone County against Judge Walker, later joined by Yellowstone County as a defendant, alleging violations of his and Trow’s rights and advancing various arguments, including those associated with the “Sovereign Citizen” movement.The Thirteenth Judicial District Court dismissed Skurdal’s complaint with prejudice, holding that Judge Walker and Yellowstone County were protected by absolute judicial immunity for actions taken in the course of judicial duties. The court also found that Skurdal, as a non-lawyer, had no statutory or constitutional right to represent another individual in a criminal proceeding in Montana. The court denied leave to amend the complaint, finding that any amendment would be futile due to the immunity defense.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that Montana law does not permit non-lawyers to represent others in criminal cases, and that Judge Walker’s actions were judicial acts performed within her jurisdiction, entitling her and Yellowstone County to absolute immunity from suit. The Court also concluded that the District Court did not err in denying leave to amend, as further amendment could not overcome the immunity bar. View "Skurdal v. Walker" on Justia Law

Kenin Edwards was sentenced to 21 months’ imprisonment for tax fraud after a series of procedural complications. Edwards, who was represented by four different attorneys throughout the process, delayed his trial multiple times before pleading guilty. After his guilty plea, he fired his final attorney, decided to represent himself, recanted his admission of guilt, sought to vacate his plea, and filed numerous frivolous motions. The government, which had initially agreed to recommend a five-month split sentence, sought a 21-month sentence due to Edwards's conduct.The United States District Court for the Central District of Illinois handled the case. Edwards's initial attorneys withdrew due to a breakdown in strategy, and his subsequent attorney was disqualified due to a conflict of interest. Edwards then retained a fourth attorney, with whom he eventually reached a plea agreement. However, Edwards later discharged this attorney as well and chose to represent himself. The district court conducted a Faretta hearing to ensure Edwards's waiver of counsel was knowing and intelligent. Despite Edwards's numerous pro se filings and attempts to withdraw his guilty plea, the district court denied his motions and sentenced him to 21 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. Edwards argued that his Sixth Amendment rights were violated when the district court disqualified his attorney and allegedly forced him to proceed pro se at sentencing. He also claimed the government breached the plea agreement by recommending a higher sentence. The Seventh Circuit dismissed Edwards's appeal, finding that he had waived his right to appeal in his plea agreement. The court held that Edwards's claims did not fall within the exceptions to the appeal waiver and that the government did not breach the plea agreement. View "United States v. Edwards" on Justia Law

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

In this case, the applicant was convicted of capital murder for the 2004 killing of an elderly man, James Tomlin, during a robbery. The applicant and his girlfriend, Leketha Allen, were implicated in the crime, with the applicant providing statements to the police detailing their involvement. The medical examiner, Dr. Nizam Peerwani, testified that Tomlin's death was caused by smothering with positional asphyxia, which was critical in proving the applicant's intent to kill.The Texas Court of Criminal Appeals previously affirmed the applicant's conviction and death sentence. The applicant's first post-conviction application for a writ of habeas corpus was denied. In his subsequent application, the applicant raised claims that his due process rights were violated by the presentation of false or misleading testimony by Dr. Peerwani and that new scientific evidence contradicted the evidence presented at trial.The Court of Criminal Appeals remanded the case to the lower court to review the merits of these claims. The habeas court held evidentiary hearings and considered testimony from various experts, including Dr. Peerwani, who reaffirmed his trial testimony. The habeas court recommended granting relief based on the new evidence and alleged false testimony.Upon review, the Texas Court of Criminal Appeals found that the habeas court considered evidence beyond the scope of the claims raised in the application. The court determined that the applicant failed to demonstrate that Dr. Peerwani's testimony was false or misleading and that the new scientific evidence did not meet the requirements for relief under Article 11.073. Consequently, the court denied the applicant post-conviction habeas relief. View "EX PARTE CARTER" on Justia Law

In 2024, Carlos Huerta filed a petition for a writ of habeas corpus in the superior court, seeking relief under the Racial Justice Act (RJA). The superior court denied the petition without appointing counsel, concluding that Huerta had failed to establish a prima facie claim for relief. Huerta then filed a petition in the Court of Appeal of the State of California, Fifth Appellate District, alleging racial discrimination in his charges and sentence, supported by statistical data.Previously, in 2010, Huerta was convicted of three counts of premeditated attempted murder and other felonies, with gang enhancements, and sentenced to 53 years to life plus 14 years. In 2022, he was resentenced to a determinate term of 26 years following changes in the law concerning attempted murder, retaining multiple gang enhancements. The RJA was not addressed during the resentencing.The Court of Appeal issued an order to show cause (OSC) in October 2024, appointing counsel for Huerta and directing the parties to address the legal showing required for the appointment of counsel in an RJA petition. The respondent initially argued that a prima facie showing was necessary for counsel appointment but later conceded that the McIntosh decision correctly interpreted section 1473, subdivision (e), which requires the appointment of counsel if the petition alleges facts that would establish an RJA violation.The Court of Appeal held that the superior court misapplied the statutory sequence by requiring a prima facie showing before assessing the lower pleading threshold for appointing counsel. However, the Court of Appeal concluded that Huerta's petition was facially defective as it failed to allege facts showing a qualifying offense under the RJA. The petition relied solely on gang enhancements, which do not fall within the scope of the relevant statutory provisions. Consequently, the Court of Appeal denied the petition for writ of habeas corpus. View "In re Huerta" on Justia Law

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