Justia Civil Rights Opinion Summaries

Illinois’s Sexually Dangerous Persons Act authorizes the commitment and indefinite detention of individuals who are charged with a crime and found to suffer from a mental disorder "coupled with criminal propensities to the commission of sex offenses.” The Act requires care and treatment for the committed person, "designed to effect recovery.” Once detainees are deemed “no longer dangerous,” the state must discharge them. The Supreme Court held, in 1986, that the Act, on its face, complies with the Due Process Clause, noting the lack of punitive intent, the availability of treatment, and the realistic possibility of release.Every Big Muddy River Program detainee participates in a weekly core therapy group. Only detainees who have acknowledged their prior sexual misconduct participate in offense-specific and didactic groups. Big Muddy does not provide individual therapy. Therapists evaluate detainees semiannually and provide them with copies of their evaluations and treatment plans. Detainees may discuss their evaluations with the therapists only in group therapy, not one-on-one. The state contracts with Wexford to evaluate detainees for release. The plaintiffs alleged that Big Muddy’s treatment program was run in a constitutionally deficient manner.The district court concluded that the disparity between Big Muddy’s treatment program and professional standards amounted to a constitutional violation and issued an injunction, requiring that Big Muddy provide the plaintiffs a minimum of 7.5 hours of core group therapy per week; reinstate inactive groups; and use independent evaluators for discharge evaluations.The Seventh Circuit reversed, acknowledging concern about whether Illinois is complying with its Fourteenth Amendment obligations. Detainees receive minimal treatment, raising serious questions about whether rehabilitation and release are realistically available. The district court, however, issued too broad an injunction under the Prison Litigation Reform Act, 18 U.S.C. 3626(a)(1)(A), which requires the least intrusive means available to correct the constitutional violation. View "Howe v. Hughes" on Justia Law

Plaintiffs sued police officers under Sec. 1983 after the officers made warrantless entry into their apartment. The district court granted summary judgment to Plaintiffs and Defendants appealed.On appeal, the Eighth Circuit reversed. While warrantless searches are presumptively unreasonable, there is an exception when officers act with probable cause to believe that a crime has been committed and an objectively reasonable basis to believe that exigent circumstances exist.Here, the officers were dispatched to the scene in response to a report of domestic violence. The report received by the officers explained that the 911 call came from a neighbor who thought “abuse” was occurring and heard a “verbal argument,” “someone being thrown around,” and “yelling and screaming” in the upstairs apartment. The neighbor stated that a woman, her boyfriend, and a child lived in the apartment. This created anm exigency, justifying warrantless entry. View "Benedda Cotten v. Ryan Miller" on Justia Law

Johnsonburg, Pennsylvania Officer Cuneo learned that the St. Marys Police Department had a search warrant to obtain a DNA sample from Perez. Cuneo knew Perez, a local with a history of illegal drug use. A log entry instructed officers who saw Perez to “hold” him and call St. Marys. Cuneo knew that Perez’s DNA had been found at the scene of a recent drug house burglary. Cuneo inferred—mistakenly—that a “body” warrant also had been issued. Later, sitting in his cruiser, Cuneo spotted Perez. The men stood on the sidewalk, having a “friendly conversation.” When Cuneo mentioned the DNA warrant and told Perez he needed to take him into custody. Perez said he was going home and sprinted away.Cuneo pursued Perez. Perez says he was tased from behind without warning. Cuneo says he warned Perez to stop before tasing him. Perez fell forward, breaking his nose. Cuneo radioed for backup and medical assistance. Perez recovered; a physical altercation ensued. Cuneo repeatedly tased and struck Perez with his baton, then shot Perez in the back.In a suit under 42 U.S.C. 1983, Cuneo asserted qualified immunity in defense. The court denied Cuneo’s summary judgment motion as to his use of his firearm and the unlawful seizure claim. The Third Circuit reversed in part. Cuneo did not seize Perez during their initial encounter. The court remanded so Perez’s excessive force claim for Cuneo’s use of his firearm can proceed. View "Perez v. Borough of Johnsonburg" on Justia Law

When police responded to a shooting outside a casino, the victim was dead. They found Grady’s cell phone, which they used, along with surveillance video, to track him down and arrest him. They searched Grady’s apartment and discovered a gun. An expert witness later testified that it was the weapon that was used in the shooting. Grady and his roommate, Bronson, gave different accounts of what happened that night.A state-court jury convicted Grady of first-degree murder. In response to a special verdict form, the jury found that the prosecution had not proved that Grady was the triggerman. Bronson was sentenced to 24 years, Grady to 60 years. Grady’s direct appeal focused on his sentence. The Illinois Appellate Court affirmed the dismissal of his ineffective assistance post-conviction petition, concluding that the evidence presented against Grady was “overwhelming” and Grady could not demonstrate the necessary prejudice under Strickland.Contending that the special-verdict finding negated the prosecution’s sole theory of guilt, Grady sought a writ of habeas corpus under 28 U.S.C. 2254(a), alleging ineffective assistance of counsel, because his direct-appeal lawyer raised only two issues on appeal, both of which Grady regards as significantly weaker than the inconsistent-verdict argument. The Seventh Circuit affirmed the denial of relief. The state court’s rejection of this contention was not an unreasonable application of Strickland. View "Grady v. Truitt" on Justia Law

At around 4:36 AM, Washington’s cellmate, Simmons, awoke to the sound of Washington, a pretrial detainee, gasping for breath. Simmons tried to shake Washington; he did not respond. At 4:37, Simmons pressed the intercom button, which triggers an audible ping and a flashing light at the control desk. Valentine, the control deck officer, did not answer for over one minute. Valentine claims he had trouble understanding Simmons and thought Simmons was referring to a plumbing issue. Valentine ended the call. For 30 seconds. Simmons tried to wake Washington. He used the intercom again around 4:47. Valentine did not answer for about 90 seconds. Other officers had joined him at the desk. This time, Valentine understood Simmons was reporting an emergency. The other officers ran to Washington’s cell, arriving at 4:50, issued an alert for medical assistance, and began CPR. A nurse with a defibrillator arrived around 4:52 and administered an electrical shock. At 5:00, EMTs arrived and continued CPR. Washington was pronounced dead at the hospital. An autopsy concluded that sleep apnea caused Washington to go into cardiac arrhythmia, which caused Washington’s death.In a suit under 18 U.S.C. 1983, alleging that Valentine’s delay in obtaining treatment harmed Washington, the Seventh Circuit affirmed summary judgment in favor of Valentine for lack of sufficient evidence to show causation. View "Jackson v. Sheriff of Winnebago County, Illinois" on Justia Law

The Supreme Court affirmed the orders of the superior court granting motions to suppress filed by Defendants Jerome Joseph and Voguel Figaro, holding that the hearing justice did not err in granting Defendants' suppression motions.Figaro moved to suppress physical evidence seized as the result of a motor vehicle stop, arguing that the officer unconstitutionally prolonged the stop to perform a dog sniff. Joseph also filed a motion to suppress and joined the memorandum supporting Figaro's suppression motion. The hearing justice granted the motions to suppress, holding that reasonable suspicion did not support the prolonged traffic stop of Figaro's vehicle. The Supreme Court affirmed, holding that the hearing justice properly found that the state police lacked reasonable suspicion to detain Defendants. View "State v. Joseph" on Justia Law

Plaintiff is an Alabama death row inmate scheduled to be executed by lethal injection on July 20, 2023. Plaintiff filed a Section 1983 complaint asserting that the manner in which Alabama executes its lethal injection protocol violates the Eighth Amendment. Specifically, he takes issue with the manner in which the execution team attempted to secure IV access in the inmates during the preceding three executions that occurred in 2022. Relatedly, Plaintiff filed a motion for a preliminary injunction seeking to enjoin Alabama from executing him by any method other than nitrogen hypoxia. Plaintiff appealed the denial of that motion.   The Eleventh Circuit affirmed.  The court focused its analysis on whether the district court clearly erred in determining that Plaintiff did not show that he faces a “substantial risk of serious harm” if executed by lethal injection. Plaintiff argued that Nance does not control and that the court should instead follow its unpublished decision in Smith. The court explained that the evidence established that since the allegedly “botched” executions, ADOC conducted a full review of its execution processes and procedures, and determined that no deficiencies existed with the protocol itself. Accordingly, based on the evidence presented, the district court did not clearly err in finding that the intervening changes made by the ADOC “have disrupted the pattern discussed in Smith,” rendering Plaintiff’s claim that the same pattern would continue to occur purely speculative. Accordingly, the district court did not abuse its discretion in determining that Plaintiff did not have a substantial likelihood of success on the merits of his Eighth Amendment claim. View "James Edward Barber v. Governor of the State of Alabama, et al" on Justia Law

Mata fired shots, killing two men and injuring another. Chicago police arrested Mata that evening. The following day, after receiving his Miranda rights and saying that he understood them, Mata gave a videotaped statement: Mata explained that he heard Mares calling his name. He turned around and saw two men holding Mares while other men surrounded him. Mata took out his gun and fired. The men backed away, but one man reached for his pocket. Mata fired five more shots toward the group, then ran toward his car. The men were walking with their backs to him when he fired; he never saw any of them with a weapon. An officer read Mata his Miranda rights again on tape. Mata said he understood his rights and wanted to make the statement; the police had treated him “well and fairly,” and he gave the statement “freely and voluntarily” without threats or promises by the police.Defense counsel moved to suppress Mata’s statements, claiming that Mata was subjected to abuse by the police for two days before being given any Miranda warnings. No hearing was held on the motion. Convicted on two counts of first-degree murder and one count of aggravated battery with a firearm, Mata sought habeas relief, arguing counsel provided ineffective assistance by failing to pursue a hearing on the motion. The Seventh Circuit affirmed the denial of the petition. Mata procedurally defaulted his claim and did not show cause to excuse the default. View "Mata v. Baker" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree for the killing of Brandy Waryasz on theories of premeditation and felony-murder and murder in the first degree for the killing of Dane Anthony Hall, on a theory of felony-murder, but reversed his conviction for armed robbery, holding that the conviction must be dismissed as duplicative of the felony-murder conviction.Defendant attacked Waryasz while she was working at a gas station by tightly wrapping a ligature around her neck. Waryasz, who was seven months pregnant with Hall, died from a constricted airflow, killing her son within minutes of his mother. Defendant was indicted for two murders and armed robbery and convicted on all charges. Defendant later filed a motion for a new trial, which the superior court denied. The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree but vacated and set aside the armed robbery conviction, holding (1) as to Defendant's murder convictions, he was not entitled to relief on his allegations of error, and there was no ground for granting relief pursuant to Mass. Gen. Laws ch. 278, 33E; and (2) the armed robbery conviction was duplicative of the felony-murder conviction for the killing of Hall and therefore must be dismissed. View "Commonwealth v. Bateman" on Justia Law

Coopwood has bipolar disorder and schizophrenia. She was institutionalized several times from 2010-2017. On August 13, 2017, Coopwood (six months pregnant) stopped taking her antipsychotic medications because of concerns about potential effects on the fetus. Coopwood fatally stabbed her mother and was ultimately found “guilty but mentally ill.”In pretrial custody, Coopwood, not taking her antipsychotic medications, was repeatedly screened and denied any history of mental health treatment. Employees, aware of Coopwood’s history of inpatient psychiatric care, did not raise concerns. Coopwood alleges that, in August 2017, Jailer Watts dragged her to her cell and kicked Coopwood in the stomach, after which she suffered cramping with a bloody discharge from her vagina. She was hospitalized several times in August and September. On October 19, she was seen by a psychiatrist, Haddad, who determined that Coopwood had been psychotic for an unknown period and seemed unaware of her circumstances. On October 22, Coopwood, exhibiting bizarre behavior, was forcibly given antipsychotic medications. She was readmitted on November 8, reporting contractions. Labor was induced. Coopwood’s baby was stillborn. Coopwood contends that she attempted to file a grievance but that her verbal requests were ignored.Coopwood’s suit, alleging excessive force and deliberate indifference to her medical needs, was dismissed. The Sixth Circuit reversed. Defendants failed to establish the absence of a genuine dispute of material fact as to whether the Jail’s staff thwarted Coopwood’s attempts to exhaust her administrative remedies. View "Coopwood v. Wayne County, Michigan" on Justia Law