Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Hamilton County Common Pleas Court Judge Tom Heekin for failure to file an affidavit of prior civil actions as required by Ohio Rev. Code 2969.25(A), holding that Appellant filed the required affidavit.Appellant, an inmate, filed a petition for a writ of mandamus seeking an order compelling Judge Heekin to vacate a judgment entry dismissing a malpractice case Appellant had filed against his criminal defense attorney. The court of appeals sua sponte dismissed the petition based on Appellant's purported failure to comply with section 2969.25(A). The Supreme Court reversed, holding that the affidavit Appellant filed with his petition supported his claim that he complied with section 2969.25(A). View "State ex rel. Woods v. Heekin" on Justia Law

In 2012, Horton was convicted of multiple drug trafficking and firearm crimes. Horton had been convicted of four prior state drug felonies. The court imposed three concurrent life sentences. Horton’s direct appeal and collateral relief motion under 28 U.S.C. 2255, failed. Under 2255(h) a successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.” Horton filed a habeas petition under 28 U.S.C. 2241, citing the “saving clause,” 28 U.S.C. 2255(e); a 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit previously held (Davenport) that 2255 is “inadequate or ineffective”— and 2241 is available—when the limits on successive 2255 motions bar relief and the prisoner’s claim is based on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Horton's Davenport claim challenged his sentences based on the Supreme Court’s 2016 Mathis decision.In the interim, the Supreme Court decided Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy 2255’s conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all." The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Horton v. Lovett" on Justia Law

Sanders was convicted in 2006 of firearms offenses. The court imposed an enhanced sentence under the Armed Career Criminal Act, based on three prior convictions, including one for Illinois residential burglary. His direct appeal and 28 U.S.C. 2255 motion for collateral relief failed. Sanders has three times unsuccessfully sought permission to file a successive 2255 motion. A successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.”Sanders filed a 28 U.S.C. 2241 habeas petition, citing the “saving clause.” 28 U.S.C. 2255(e); A federal prisoner’s 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.” Seventh Circuit precedent (Davenport) applied the saving-clause gateway to habeas claims premised on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Sanders’s Davenport claim challenged his ACCA-enhanced sentence based on the Supreme Court’s 2016 Mathis decision.The district judge denied relief. The Supreme Court held, in Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy the 2255 conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all. The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Sanders v. Joseph" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

While serving a 55-year sentence for murder, Love assaulted a correctional officer, resulting in state convictions for felony battery. The Indiana Department of Correction also found Love guilty of violating prison rules and imposed sanctions including revocation of 5,700 days of his accrued good time credit, which extended Love’s release date by more than 15 years. Love unsuccessfully pursued prison appeals. The district court denied his 28 U.S.C. 2254 petition. The Seventh Circuit affirmed. Love procedurally defaulted his constitutional claims and forfeited them by failing to present them in administrative proceedings or the district court.One argument concerned Executive Directive 17-09, under which the Department must revoke all accrued good time credit from inmates found guilty of qualifying offenses. There is no additional hearing; the inmate is not provided an opportunity to argue why revocation of less time is appropriate. Love argued that the Department cannot, consistent with due process, predetermine how it will use its discretionary power over sanctions without first considering arguments in mitigation. Love also argued that Directive 17-09 is facially arbitrary in tying punishment to the amount of good time credit an inmate has rather than the severity of his misconduct. Love offered two examples where other inmates presumably should have been punished in accordance with the Directive but were allegedly shown leniency instead. View "Love v. Vanihel" on Justia Law

In 2007, Hogsett was convicted of crimes, including being a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The court found that Hogsett was an armed career criminal, with three prior convictions for violent felonies, and sentenced him to 295 months. In 2021, the Supreme Court (Borden) interpreted “violent felony” in 924(e) to exclude crimes that can be committed with a mens rea of recklessness. Hogsett sought to challenge his sentence under Borden. To collaterally attack a conviction or sentence, a federal prisoner files a 28 U.S.C. 2255 motion, not a habeas petition, 28 U.S.C. 2241. Hogsett had filed a 2255 motion in 2010. A prisoner can only file another 2255 motion in two circumstances: newly discovered evidence sufficient to establish innocence or a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court. Hogsett argued that he was eligible to file under 2255(e), the “saving clause,” which applies when “the remedy by motion is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit ordered the dismissal of Hogsett’s petition for lack of jurisdiction. The court cited the Supreme Court’s intervening Jones holding: “The inability of a prisoner with a statutory claim to satisfy” 2255(h)’s requirements “does not mean that he can bring his claim in a habeas petition under the saving clause … he cannot bring it at all.” Borden is a statutory interpretation decision. View "Hogsett v. Lillard" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his pleas of no contest to voluntary manslaughter, attempted voluntary manslaughter, two counts of aggravated robbery, and four counts of interference with a peace officer, holding that the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest pleas.Defendant pleaded no contest to the charges against him pursuant to a plea agreement with the State. Before he was sentenced, Defendant moved to withdraw his pleas, arguing that his right to a speedy trial was violated and that defense counsel did not provide effective assistance of counsel. The district court denied the motion and sentenced Defendant according to the plea agreement. That Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion to withdraw his pleas. View "McHenry v. State" on Justia Law

As a Chicago gang member, States participated in drug trafficking and kidnappings. Officers went to his apartment to arrest him. States fired five shots through the door and hit an officer in the finger. A jury convicted him on 12 counts. The court sentenced him to life in prison, plus 57 years in consecutive sentences under 18 U.S.C. 924(c)—two for carrying a firearm during and in relation to a crime of violence, and one for carrying a firearm during and in relation to a drug trafficking crime. States subsequently moved to vacate his sentence, 28 U.S.C. 2255. The Seventh Circuit affirmed the reimposition of his sentence.The Supreme Court subsequently held (Johnson) that the ACCA residual clause, 18 U.S.C. 924(e)(2)(B), was unconstitutionally vague. Section 924(c) has an analogous residual clause (later struck down). States filed a successive 2255 motion to vacate his 924(c) convictions. His predicate crimes of violence were Hobbs Act extortion and attempted murder of a federal officer, 18 U.S.C. 1113–1114. The court vacated the extortion-predicate conviction but denied the motion with respect to the conviction predicated on attempted murder; then-controlling circuit precedent established that an attempt to commit a crime of violence is a crime of violence under 924(c)'s elements clause. The Seventh Circuit affirmed his sentence--concurrent 20-year terms plus two consecutive five-year sentences for the 924(c) convictions. The district court correctly held that attempted murder of a federal officer is a crime of violence and that drug trafficking and kidnapping offenses could not be grouped. View "United States v. States" on Justia Law

Officers discovered Brewer’s naked body tied to his bed frame; he had been shot twice. The case went cold for several years before an inmate told officers that Miller and Hall and two women had set up a threesome with Brewer in order to rob him. DNA found at the scene did not implicate either woman. The women implicated Martin. Officers knew the story was false but nonetheless interviewed Martin; the interview was not recorded. Martin, who claimed to have been "very high" on the night of the murder, waffled between denying any involvement and other stories. Officers falsely told her that her DNA was found at the scene and implied her children could be taken away. Martin failed a polygraph examination. Martin was told that “she’[d] walk” if she revealed the killer but that if she did not implicate anybody else, she would “go down.” Eventually, with a plea agreement, she implicated Miller. Martin repeatedly attempted to recant. Kentucky indicted Miller but eventually dropped the charges.Miller filed suit (42 U.S.C. 1983) for malicious prosecution, fabrication of evidence, destruction of exculpatory evidence, due process violations, and conspiracy. The Sixth Circuit affirmed summary judgment for the defendants. Because the conduct at issue was in furtherance of genuine prosecutorial interests, the prosecutor has absolute immunity for his actions, including ordering the destruction of evidence and purported thwarting of a court order. The other defendants were entitled to qualified immunity. View "Price v. Montgomery County" on Justia Law

On August 31, 2012, in San Bernardino County Superior Court, Appellant entered a no-contest plea to one count of assault by means likely to produce great bodily injury. He was placed on three years formal probation. Shortly after being placed on probation, Appellant was deported. He later illegally reentered the country. In 2014, his probation was reinstated, and on June 25, 2015, the sentencing court transferred probation supervision and jurisdiction from San Bernardino County to Los Angeles County, where Appellant permanently resided, pursuant to section 1203.9. On April 6, 2021, Appellant filed a motion in Los Angeles County Superior Court to vacate his plea pursuant to section 1473.7. By then, he had already completed his probationary sentence. On August 23, 2021, the trial court concluded it lacked jurisdiction to hear Appellant’s motion and directed him to refile the motion in San Bernardino County Superior Court.   The Second Appellate District affirmed. The court concluded that Appellant should have filed his motion to withdraw his plea in the county where he was prosecuted, convicted, and sentenced. The question was whether the phrase “full jurisdiction” is meant to remove the authority of the original sentencing court from everything associated with the case or whether “full jurisdiction” refers only to matters relating to the probationary sentence. The court held that section 1203.9 was enacted solely to effectuate more streamlined and effective supervision of probationers statewide by ensuring that the court of their county of residence is empowered to supervise and adjudicate issues arising as a result of the probationary grant. View "P. v. Hernandez" on Justia Law