Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the circuit court granting summary judgment in favor of Dunn County on Plaintiff's claim filed under 42 U.S.C. 1983, holding that Plaintiff's section 1983 claim against Dunn County failed.On appeal, Plaintiff argued that she presented evidence sufficient for a reasonable jury to find that Dunn County violated her rights under the Eighth and Fourteenth Amendments when a correctional officer sexually assaulted her. The Supreme Court affirmed, holding (1) under Monell v. Department of Social Services, 436 U.S. 658 (1978), no reasonable fact finder could conclude that Dunn County was the causal, moving force behind the sexual assault; and (2) there was insufficient evidence demonstrating that Dunn County acted with deliberate indifference to a known or obvious consequence that the correctional officer would sexually assault Plaintiff. View "Slabey v. Dunn County" on Justia Law

In 2006, Watkins confessed to killing Varner. In jail, he refused to eat and urinated on himself. After four pretrial psychological evaluations, Watkins’s problematic behavior continued at trial; the judge removed him to a secured room. Watkins was convicted. In 2008, Watkins filed a pro se habeas petition but did not pay the filing fee or seek to proceed in forma pauperis. His petition was dismissed. In 2010, Watkins filed a “motion for equitable tolling,” alleging sentencing errors, ineffective assistance of counsel, and prosecutorial misconduct. The court stayed the federal case, pending exhaustion of his claims in state court.In 2014, after state courts rejected his claims, Watkins filed a “supplemental” federal petition, with additional claims. The district court construed Watkins’s petition as a motion to amend his 2010 petition and awarded habeas relief based on counsel’s failure to request another competency evaluation after his trial outbursts. The court reasoned that the claim related back to Watkins’s 2010 petition under Federal Rule 15 because both petitions raised ineffective-assistance claims and equitably tolled the limitations period due to Watkins’s mental-health struggles. The Sixth Circuit reversed, finding that the ineffective-assistance claim in the amended petition did not “relate back” to the generic 2010 ineffective-assistance claim and that Watkins was not entitled to equitable tolling.On remand, Watkins argued, for the first time, that his amended petition related back to the 2008 petition. The Sixth Circuit affirmed the denial of relief. Under Rule 15(c)(1)(B), an amended petition will “relate[] back to the date” of the original petition if the new claims arose from the same “conduct, transaction, or occurrence” as the old ones. A subsequent new suit does not “relate back to the date” of the petition in a dismissed suit. View "Watkins v. Stephenson" on Justia Law

Jail personnel search inmate mail for contraband. To preserve confidentiality, mail from an inmate to an attorney is opened in front of the inmate; the contents are visually inspected but not read. An officer noticed an envelope from Cortez addressed to his attorney; with a “bulk in the center.” It smelled of feces. Suspecting the envelope contained contraband, he opened it but not in front of Cortez. The envelope contained another envelope fashioned from the lined yellow paper, marked “do not read.” The officer opened it and found multiple "kites," each made from different colored paper and with different writing. Kites are clandestine notes, written by inmates on small pieces of paper in very small print, then rolled up to minimize their size and facilitate concealment. The officer informed his supervisor.A magistrate conducted an in-camera examination and concluded: The messages have “the teeny tiny writing ... indicative of a gang-related kite…. I did not read the substance … none of them were addressed to [Cortez’s attorney]. None of them ... appeared to even be written by Cortez…. I do not find the attorney-client privilege applies.” The court of appeal agreed. The magistrate’s findings were supported by substantial evidence. Even if the jail violated the regulation requiring legal mail to be opened in the inmate’s presence, the remedy would not automatically render everything inside the envelope—including communications intended for people other than an attorney—subject to attorney-client privilege. View "People v. Superior Court of Santa Cruz County" on Justia Law

The Supreme Judicial Court affirmed the final judgment and order of the district court in Husband's divorce from Wife and imposed sanctions, holding that Husband's appeal was frivolous and contumacious within the meaning of M. R. App. P. 13(f).On appeal, Husband contended that the trial court both violated his rights to due process by failing to hold a trial and made impermissible changes to the parties' mediation agreement. The Supreme Judicial Court affirmed, holding (1) there was no violation of Defendant's due process rights; (2) the final divorce judgment accurately incorporated the terms of the parties' agreement; and (3) Husband should be sanctioned for this frivolous and contumacious appeal. View "Aubuchon v. Blaisdell" on Justia Law

Behning, an Illinois prisoner, claims that prison guards violated his constitutional rights while responding to his altercation with a prison guard. After the incident Behning was taken to the emergency room, was charged with assaulting an officer, and was put in solitary confinement at another institution. While he was in solitary confinement, Behning allegedly timely mailed a grievance over the altercation, inadequate medical care, and procedural defects in his disciplinary hearing to the Illinois Department of Corrections Administrative Review Board. He sent a copy to his attorney, who also forwarded it to the Board. The Board returned it, asserting that only offenders themselves could submit grievances. Behning mailed another grievance, which the prison rejected as untimely.Behning filed suit under 42 U.S.C. 1983.The district court granted summary judgment based on Behning’s failure to exhaust available administrative remedies under the Prison Litigation Reform Act. 42 U.S.C. 1997e. The Seventh Circuit vacated in part. Behning, through his attorney, submitted most of his grievances to the appropriate administrative office, on time. Nothing in the regulation prohibits an offender from submitting a grievance through an attorney. Regardless of how Behning’s grievance arrived, it apprised the Board of the nature of his complaints. View "Behning v.Johnson" on Justia Law

The Supreme Court affirmed Defendant's nineteen convictions for first degree sexual assault, incest, and intentional abuse of a vulnerable adult, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) Defendant failed to raise his arguments that the district court violated his constitutional due process and double jeopardy protections in the district court and thus waived the issues for appeal; (2) there was sufficient evidence to support Defendant's convictions for first degree sexual assault; and (3) there was sufficient evidence to support Defendant's convictions for intentional abuse of a vulnerable adult. View "State v. Bershon" on Justia Law

The Supreme Court reversed the order of the court of appeals reversing the judgment of the circuit court convicting Defendant of first-degree child sexual assault and denying his motion for postconviction relief, holding that the circuit court did not err.On appeal from the denial of Defendant's motion for postconviction relief, the court of appeals concluded that the State suppressed evidence favorable to Defendant's defense, in violation of his right to due process under Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court reversed, holding (1) the State did not violate Defendant's due process rights by filing to disclose a certain report; (2) Defendant's ineffective assistance of counsel claims failed; and (3) there were no errors at trial that prevented the real controversy from being tried. View "State v. Hineman" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion and that the Commission's findings were supported by substantial evidence.On appeal, Appellant challenged the Commission's decision to overrule his motion to conduct additional discovery and submit additional evidence after the Supreme Court's decision in Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019) interpreting Mo. Rev. Stat. 287.220 and the Commission's finding that Appellant failed to show any medically documented qualifying preexisting disabilities that qualified him for benefits. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in overruling Appellant's motion to conduct additional discovery and submit additional evidence; and (2) the Commission's findings were supported by substantial and competent evidence. View "Dubuc v. Treasurer of State of Missouri Custodian of Second Injury Fund" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of conspiracy to commit export violations, visa fraud, making false statements to federal agents, money laundering, and smuggling, holding that the search of Defendant's laptop and cellular phone was a constitutional search.Defendant, a Chinese national, was stopped by Customs and Border Patrol agents upon his arrival to the United States after a trip to China. Agents seized Defendant's electronic devices for a further search. Defendant was indicted based on evidence during the warrantless search of his devices. The First Circuit affirmed, holding that neither probable cause nor a warrant was required for the search in this case to be lawful. View "United States v. Qin" on Justia Law

Philadelphia officers Kling and Nestel stopped Gallman for running a stop sign and recovered a firearm from Gallman’s passenger. Officer Rosinski moved Gallman to the patrol car. Kling discovered a firearm near Gallman's driver’s seat. Gallman, previously convicted of first-degree robbery, was charged with possession of a firearm by a felon, and unsuccessfully moved to suppress the evidence. During the hearing, the government informed the court that there was an open Internal Affairs Division (IAD) investigation about Rosinski’s failure to call a supervisor to a traffic stop. The government also supplied an IAD memorandum regarding a racial profiling complaint against Rosinski and Stout, who was also present at the Gallman stop. That matter was closed before Gallman’s arrest; the allegation was unfounded.Following COVID-19 protocol, Gallman's trial was conducted in one courtroom and video-streamed to another where the public and Gallman’s family were seated. Outside the presence of the jury, the court asked Gallman whether he wanted to stipulate his prior conviction and discussed the pending Rosinski IAD investigation.The Third Circuit affirmed Gallman’s conviction. Closing the video stream during the sessions away from the jury did not constitute reversible error; it was not “clear under current law” that the Sixth Amendment public-trial right applied to those proceedings. The closures here were brief and resulted from pandemic protocol challenges rather than any substantive decision. Some of the topics discussed were also discussed in open court. Nor did the court abuse its discretion in admitting evidence of Gallman’s prior conviction. View "United States v. Gallman" on Justia Law