Justia Civil Rights Opinion Summaries

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

Plaintiff-Appellee Brandon Blackmon brought a 42 U.S.C. 1982 action against various members of the juvenile detention center in Sedgwick, Kansas, alleging they violated his Fourteenth Amendment rights as a pre-trial detainee when he was taken there as an eleven-year-old. He claimed that the staff regularly used a "Pro-Straint Restraining Chair, Violent Prisoner Model" sometimes as a legitimate effort to stop him from committing suicide, but mostly, as plaintiff contended, to punish him. The chair is equipped with wrist, chest and ankle restraints; as a juvenile detainee, plaintiff was 4'11' and 96 pounds. The district court denied defendants' motion for dismissal based on qualified immunity grounds. Defendants appealed to the Tenth Circuit, maintaining that the district court erred in holding that the facts, when viewed in a light favorable to plaintiff, suggested that defendants sometimes exceeded the scope of qualified immunity. After its review of the district court record, the Tenth Circuit affirmed in all respects except one: the Court directed the district court to grant qualified immunity to defendant Sutton on plaintiff's "failure to transfer" claim. View "Blackmon v. Sutton, et al" on Justia Law

Petitioner was a juvenile charged as an adult with attempted first-degree murder with a deadly weapon. After the U.S. Supreme Court issued its decision in Graham v. Florida, Petitioner filed a motion to have a bond set. The trial court denied the motion. Petitioner filed a second petition for writ of habeas corpus, arguing (1) the Florida Constitution provides for pretrial release as a matter of right for a noncapital offense or an offense that does not carry the possibility of a life sentence, and (2) because Graham prohibits the State from sentencing him to life without an opportunity for parole, he was entitled to bond under the provisions of the State Constitution. The court of appeal denied the petition, concluding that Graham does not impact a juvenile defendant's entitlement to bond because the Florida Constitution considers only the classification of the offense, not a defendant's eventual sentence. The Supreme Court quashed the decision below, holding that juvenile offenders such as Petitioner were entitled to bond under the Florida Constitution because they cannot be charged with a crime punishable by life imprisonment under Florida's current statutory scheme and Graham. View "Treacy v. Lamberti" on Justia Law

In 2010 the Supreme Court held, in Miller v. Alabama, that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment prohibition on cruel and unusual punishments. Three individuals, each serving a mandatory sentence of life without the possibility of parole for offenses committed as juveniles, sought authorization to file successive habeas corpus petitions under 28 U.S.C. 2254 and 2255 to raise Miller claims. The parties agreed that Miller states a new rule of constitutional law, but Pennsylvania (the state in which two petitioners were convicted) argued that Miller was not retroactive; the federal prosecutor claimed that Miller was retroactive but that the other petitioner’s sentence satisfied the new Miller rule. The Third Circuit found that the petitioners had made a prima facie showing that Miller is retroactive and authorized successive habeas petitions. View "In re: Grant" on Justia Law

Following the denial of her motion for new trial, Chanell Pitts appealed her convictions and misdemeanor sentences for 2011 violations of OCGA 20-2-690.1(the "mandatory education statute"). Her sole challenge was to the constitutionality of the statute. Finding no error in the trial court’s denial, the Supreme Court affirmed. View "Pitts v. Georgia" on Justia Law

Michael and April are the biological parents of Avalyn, born out of wedlock in 2002. A court ordered Michael to pay child support but did not order visitation. In 2005, the state took temporary emergency custody of Avalyn after April attempted suicide. The county sought an adjudication under Neb. Rev. Stat. 43-247(3)(a), but did not give Michael notice. Avalyn was placed in foster care with her maternal grandmother in April’s home. Michael claims that because he was paying support through the state, caseworkers knew or should have known how to contact him. About six months after the disposition he received notice and intervened. The court placed Avalyn with Michael until November 2007, when the parties stipulated that Avalyn should be placed with April but divide her time between her parents. In a suit under 42 U.S.C. 1983, Michael alleged that in failing to notify him of the juvenile proceedings, the defendants interfered with constitutional rights to familial integrity, substantive due process, and equal protection and that the Nebraska statutes were unconstitutional. The Nebraska Supreme Court held that claims against state defendants for monetary damages were barred by sovereign immunity; qualified immunity shielded employees from liability in their individual capacities because they did not violate a clearly established right. Claims for declaratory and injunctive relief were not barred. In a juvenile proceeding alleging abuse, neglect, or dependency, due process requires notice and an opportunity to be heard for a child’s known adjudicated or biological father who is providing substantial and regular financial support; the statutes at issue are not facially unconstitutional, but cannot be constitutionally applied to avoid notification. View "Michael E. v. State" on Justia Law

After her child was murdered by his father, the mother sued employees of county and state Child Protective Services (CPS) and others,, alleging negligence; violations of constitutional rights (42 U.S.C. 1983); and violation of the Adoption Assistance and Child Welfare Act--Adoption and Safe Families Act, 42 U.S.C. 670, and of the Child Abuse Prevention and Treatment Act, 42 U.S.C. 5106. The complaint alleged that from 1998-2007, CPS received numerous complaints about the father’s abuse and neglect of the child and his siblings. The district court rejected a defense of qualified immunity. The Sixth Circuit reversed. The contours of the substantive due process right to be free from government action increasing the risk of harm was not sufficiently clear that a reasonable official would understand that pursuing the father for use of a cattle prod, while failing to immediately remove the child, would violate the child’s substantive due process rights. Given previous cases, it is not clear that a reasonable CPS official would understand that failure to seek termination of parental rights would constitute denial of procedural due process. Without ignoring the father’s role in causing the child’s death, CPS employees’ conduct cannot be said to be the “most immediate, efficient, and direct cause” of the injury. View "Jasinski v. Tyler" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded. View "State v. Null" on Justia Law

In December, 2005, Chicago police officers Malaniuk and Shields arrested then-14-year-old Barber. Barber claims that the arrest was without probable cause and that Malaniuk used excessive force in shoving him into a holding cell, causing him to strike his head on a hard surface. The officers deny those allegations and say that the head injury occurred because Barber was intoxicated and fell over his own feet. In Barber’s suit under 42 U.S.C. 1982, a jury sided with the defendants. The Seventh Circuit reversed and remanded, finding merit in Barber’s claims that the district court erred when it allowed defense counsel to cross-examine him about a subsequent arrest for underage drinking and about his intervening felony conviction. View "Terrence Barber v. City of Chicago, et al" on Justia Law

Six-year-old D.B. and five-year-old twins C.C. and her brother W.C., were “playing doctor” in D.B.’s backyard when the twins’ mother arrived. She interpreted D.B.’s conduct as a sexual assault of her daughter and reported to the Department of Social Services. The Sheriff’s Department also responded. After an aggressive investigation, the District Attorney filed a petition alleging that D.B. had committed first-degree sexual assault and was in need of public protection or services. The petition was not adjudicated; the case was closed by consent decree. D.B.’s parents filed a civil-rights suit, alleging that county officials overzealously investigated and maliciously prosecuted D.B. They asserted a “class of one” equal-protection claim, noting that the twins engaged in the same behavior as D.B., but the twins’ father is a “high-ranking local political figure.” The district court dismissed. The Seventh Circuit affirmed. Allegations of improper subjective motive are not enough to state a class-of-one equal-protection claim; a complaint must allege sufficient facts to plausibly show that the plaintiff was treated differently from others similarly situated and that the discriminatory treatment was wholly arbitrary and irrational. Here, there was an objective rational basis for disparate treatment. The twins’ mother witnessed D.B.’s conduct and reported it; there was no adult witness to the twins’ behavior. View "Kurtis B. v. Kopp" on Justia Law