Justia Civil Rights Opinion Summaries

Nucera was charged with committing a hate crime, depriving another of his civil rights, and making false statements to the FBI, arising from actions he took as a police officer arresting Stroye. His jury engaged in heated deliberations with racial tensions playing a major role. Credibility determinations were crucial, and jurors were deeply divided over whom and what to believe.The Third Circuit rejected Nucera’s claims of jury misconduct. Nucera offers only post-verdict affidavits from jurors who say they experienced racial vitriol, intimidation, and other misconduct that occurred during the jury deliberations. When parties challenge a verdict, Federal Rule of Evidence 606(b) bars a court from considering a juror’s statement or affidavit unless it satisfies either an exception in the Rule or a constitutional exception created by the Supreme Court (Peña-Rodriguez, 2017), for evidence of racial bias. The latter exception is narrow and specific: it requires a clear statement that a juror voted for a conviction based on racial animus toward, or stereotypes about, the defendant. None of Nucera’s evidence satisfies the Rule 606(b) exceptions nor does it fit the Peña-Rodriguez exception. The court also affirmed a ruling that limited Nucera’s use of the victim’s out-of-court statement and the court’s jury instructions about unanimity. The court vacated Nucera’s sentence; the district court erred in applying the Sentencing Guidelines. View "United States v. Nucera" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant for possession with intent to distribute marijuana and failure to affix a tax stamp, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held that the district court (1) did not err by denying Defendant's motion to suppress evidence of marijuana found when law enforcement conducted a warrantless search of a duffel bag and suitcase on a passenger trial; (2) did not err in failing to suppress certain testimony at trial; (3) did not abuse its discretion in denying Defendant's motion for a mistrial; and (4) did not abuse its wide discretion in sentencing Defendant to four to six years of imprisonment for possession with intent to distribute marijuana. View "State v. Vaughn" on Justia Law

Ingram contends that, while confined in the Terre Haute Penitentiary, he was attacked and beaten by guards, after which the medical staff denied him necessary care. A magistrate concluded that Ingram failed to exhaust his administrative remedies, as required by 42 U.S.C.1997e(a), and granted the defendants summary judgment.The Seventh Circuit affirmed in part. Ingram filed three substantive grievances. Two he did not pursue to a conclusion; one. asserting that members of the staff failed to protect him from harm, was rejected because it lacked required attachments and Ingram did not resubmit a grievance or appeal. A second grievance asserted that staff retaliated against him by withholding necessary medical care. The prison rejected this grievance because Ingram had not attempted an informal resolution. An inmate cannot short-circuit the grievance process by filing in court while that process is ongoing.The court remanded in part. Ingram alleged that he never got a written decision on his remaining substantive grievance, complaining about the attack itself. If an appeal was blocked by the need to attach a document that the prisoner did not have, then that appeal is not “available” to the prisoner, and the statute allows the prisoner to turn to court. The district court should have held a hearing and taken testimony on subjects such as whether the Warden refused to provide the statement to Ingram or whether there was just a bureaucratic delay in handing it over. View "Ingram v. Watson" on Justia Law

A criminal complaint was filed against Appellant. On May 20, 2009, a certificate of mental disease or defect and dangerousness issued pursuant to 18 U.S.C. Section 4246. Appellant’s mental condition improved with treatment. The district court ordered his conditional discharge. Appellant returned home and lived with his mother after conditional discharge. The district court revoked the term and recommitted him. This appeal presents two consequential questions. Both relate to the continued involuntary commitment of those afflicted with a mental illness. A commitment wrongly perpetuated is an unwarranted restraint of liberty; a commitment errantly discontinued poses a danger to the committee and the public.   The Fourth Circuit vacated the district court’s order and remanded for further proceedings. The court explained that the record is unclear whether the district court’s findings were made by a preponderance of the evidence. It also appears from the record that the district court collapsed both inquiries of Section 4246(f) into a single question, focusing only on whether Appellant violated the conditions of his release and not explaining why “in light of” those violations his continued release created a substantial risk to other persons or property. Additionally, the record would benefit from further development respecting the violations alleged and the available, recent records from the facility. Further, the court wrote that the government should take note of its evidentiary burden, develop evidence on the point, and provide the district court a sound basis for making reasoned findings on the matter of dangerousness for that particular alleged violation. View "US v. Christopher Perkins" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

Courtney was sentenced to three years in state prison followed by one year of supervised release for violating an earlier term of parole by failing to register as a sex offender. Courtney’s supervised release was revoked before he left prison. The stated reason was not that he had acted wrongly but that he had no arrangements for a place to live that state officials deemed suitable. Courtney spent his year of supervised release in prison.Courtney brought suit under 42 U.S.C. 1983, alleging that the defendants failed to investigate his proposed living arrangements and ignored his grievances and that his release was revoked without evidence that he violated any terms of release and without adequate procedural protections. The district court dismissed Courtney’s claims as barred by the Supreme Court’s 1994 “Heck” decision, which forecloses civil litigation that would call into question the validity of a state criminal conviction or sentence that has not been set aside or that would call into question the validity of parole revocation, at least when the revocation is based on the parolee’s wrongdoing.The Seventh Circuit affirmed in part but remanded the claims based on the defendants’ failure to do their jobs. Courtney’s claims that the defendants, after his parole revocation, ignored his grievances and communications regarding possible host sites, if substantiated, would not necessarily imply that the Prison Review Board’s decision to revoke his parole was invalid. Courtney’s claims concerning the defendants’ inaction before that date are similar to seeking a writ of mandamus, not like seeking habeas corpus relief, and would not “necessarily demonstrate the invalidity of confinement or its duration.” View "Courtney v. Butler" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law

Howell received medical screenings from nurses employed by NaphCare, which contracts with the Jail to provide medical services. Nurses noted his sickle cell disease diagnosis. Howell returned to the medical unit after he started a fight. Video shows Howell repeatedly falling in the hallway. Officers placed Howell in a wheelchair. At the medical sallyport, Howell complained loudly of pain and stated that he could not feel his legs. Howell slid out of the wheelchair and was eventually left on the floor. Nurse Jordan reviewed Howell’s medical chart. Medical staff had previously sent Howell to a hospital for sickle cell pain. Jordan concluded Howell was in pain but was experiencing a psychiatric issue. Around 5:40 p.m., officers placed Howell in a restraint chair, transported Howell to the mental health unit, and placed him in a cell with a small window on its door. At 6:06 p.m., Nurse Arthur checked on Howell, who was still yelling. but decided that he did not need further medical treatment. No NaphCare employee checked on Howell again. Officers checked Howell approximately every 20 minutes by looking through the window, seeing only a side profile. Officers falsified log entries and failed to comply with regulations concerning removal, rotating Howell’s limbs, or providing water or the restroom. At 9:45 p.m., Officers went to remove Howell and found him dead. The coroner determined that Howell died from sickle cell crisis.In a suit under 42 U.S.C. 1983, the district court granted the defendants summary judgment. The Seventh Circuit reversed as to Nurse Jordan and Deputy Erwin on deliberate indifference claims; a reasonable jury could find that they recklessly failed to act to mitigate an unjustifiably high risk of harm to Howell that a reasonable official would have recognized. Erwin was not entitled to qualified immunity. View "Howell v. NaphCare, Inc." on Justia Law