Justia Civil Rights Opinion Summaries

The Supreme Court dismissed this interlocutory appeal in which Defendant argued that the trial court erred in denying his motion to dismiss because the State intentionally had delayed the prosecution in violation of his right to a speedy trial, holding that the denial of Defendant's motion to dismiss did not constitute a final judgment.Defendant filed a motion to dismiss criminal charges the State had reinstitute against him after the trial accepted a nolle prosequi on the ground that the State was unable to locate material witnesses, arguing that the State had violated his right to a speedy trial by intentionally delaying the prosecution, and consequently, he lost the ability to have the counsel of his choice represent him at trial. The trial court denied the motion, and Defendant appealed. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that Defendant failed to satisfy either prong of the test established in State v. Curcio, 463 A.2d 566 (Conn. 1983). View "State v. Malone" on Justia Law

The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

Rutherford County, Tennessee law enforcement officers raided 23 stores selling cannabidiol (CBD) products because they falsely believed that such products were illegal under state law. The charges were dropped; the products were legal under both state and federal law. The shop owners sued the responsible law enforcement agencies, asserting violations of their constitutional rights and conspiracy to violate those rights. All but one of the shop owners ultimately settled. The district court then granted summary judgment to the County and Sheriff Fitzhugh.On interlocutory appeal, the Sixth Circuit reversed. The plaintiff presented evidence to support a claim of 42 U.S.C. 1983 civil conspiracy. Fitzhugh’s alleged behavior reflects interdependent decision-making with the Smyrna Police Department (SPD) and the DA’s office through the planning and execution of the raids, calculated to achieve an unconstitutional outcome. Although SPD’s raid of the plaintiff’s business was the overt act that directly caused the plaintiff’s alleged injury, holding the county defendants liable for their alleged involvement in the overall plan that led to that raid is the kind of conspiratorial behavior at the heart of section 1983 civil conspiracy claims. A jury could reasonably conclude that there was a “single plan” in which Fitzhugh participated. View "Rieves v. Smyrna, Tennessee" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

Plaintiff was detained beyond the expiration of his sentence because Department officials gave him credit for time served in pre-trial detention but only for one (rather than both) of his two consecutive sentences. That was the right thing to do under the law, then in effect. But Plaintiff was entitled to the more generous provision in effect at the time his sentence was entered. As a result, he served over a year longer than he should have. After his release, Plaintiff brought suit against various Louisiana officials under 42 U.S.C. Section 1983, among other claims. This appeal concerns only one of those claims: Plaintiff’s claim against the head of the Department, Secretary James LeBlanc (“Defendant”). Defendant appealed the denial of qualified immunity, arguing that his conduct wasn’t objectively unreasonable in light of clearly established law.   The Fifth Circuit reversed. The court explained that while the right to timely release is clearly established, Plaintiff does not show how Defendant’s conduct was objectively unreasonable in light of clearly established law. Plaintiff contends that Defendant was objectively unreasonable because he failed to assign the task of calculating release dates to an attorney. But nothing in the Constitution requires that such actions be undertaken by a member of the bar. View "Taylor v. LeBlanc" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's convictions and reinstated the judgments of the trial court, holding that the intermediate court erred when it stated that an involuntary confession claim is "inextricably linked" to a Miranda waiver claim such that the two inquiries can be considered together.Defendant, a juvenile at the time of the offenses, was convicted of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. Defendant was sentenced to life in prison for the murder conviction. On appeal, the court of criminal appeals reversed the denial of Defendant's motion to suppress pretrial statement to detectives, concluding that the statement was not voluntary. The Supreme Court reversed, holding (1) Defendant's overall statement was voluntary, and his Miranda waiver was both knowing and voluntary; and (2) the evidence presented by the State was sufficient to support Defendant's conviction for premeditated first-degree murder. View "State v. McKinney" on Justia Law

The Supreme Court reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" on Justia Law

Howard was charged as a felon in possession of a weapon. Before his trial, the government struck the only three Black jurors on the 39-person venire panel. The judge had admonished the jurors that they could not use the internet for any purpose related to or surrounding the case and asked the jurors to “[r]aise your number if you don’t use the internet.” Jurors 9, 13, and 24 each raised their numbers. Jurors 9 and 24 were two of the three Blacks. The prosecutor struck each of them, explaining: “I do not believe people when they say they don’t use the Internet.” In response to the defendant’s subsequent Batson challenge, the court applied the three steps of the Batson inquiry. At the third step—that the defendant established purposeful discrimination by the government—the court summarized Howard’s counsel’s argument, stating: “Your sole justification and your persuasiveness is that the government attorney, who does happen to be African-American, has struck every single African-American on the panel.”The Seventh Circuit affirmed Howard’s conviction, rejecting arguments that the district court erred by injecting the prosecutor’s race into the Batson inquiry, improperly evaluating the peremptory strike, and failing to make required demeanor findings. The prosecutor’s theory was not so “implausible or fantastic” as to require a conclusion that the justification was “pretext[] for purposeful discrimination.” View "United States v. Howard" on Justia Law