Justia Civil Rights Opinion Summaries

The Illinois Department of Juvenile Justice, runs a number of youth detention facilities. Jamal, age 16, had a history of mental illness and was known to have attempted suicide at least three times when he arrived at one of those facilities in 2008. His intake assessment noted a history of Attention Deficit Hyperactivity Disorder, major depression, bipolar disorder, psychosis, behavior disorders, and anger and drug abuse counseling. His behavioral history included delinquency, gang affiliations, anger, aggression, setting of fires, cruelty to animals, putting a gun to a cousin’s head, threatening to kill teachers, learning disabilities, alcohol abuse, and cannabis use. Jamal denied that he had manic or depressive symptoms, that he was depressed, or that he had experienced suicidal thoughts since his June 2008 attempt; the intake doctor prescribed Prozac and lithium. Jamal was noncompliant, had disciplinary problems, and was periodically evaluated for suicide risk before he committed suicide by hanging himself from a bunk bed. In his mother’s suit, alleging deliberate indifference to Jamal’s serious mental illness, in violation of his Fourteenth Amendment rights, the district court granted summary judgment for the defendants. The Seventh Circuit affirmed. View "Miller v. Nordstrom" on Justia Law

Racine County Human Services Department caseworker Wagner removed Thor, a 12-year-old, from his parents’ home and placed him into protective custody. Thor suffers from cerebral palsy, global developmental delay, and is confined to a wheelchair. Wagner investigated after receiving a referral from personnel at Thor’s school concerning bruising on his arm and leg. A judge issued a probable cause order for removal, based on evidence of Thor’s injuries and that he had been left unattended. Thor suffered additional injuries as a result of accidents that occurred in foster care and at a rehabilitation facility. Thor’s mother and stepfather and Thor sued Wagner, his supervisor, another caseworker, and her supervisor, alleging violations of their constitutional rights under 42 U.S.C. 1983 and 42 U.S.C. 1985. The district court granted summary judgment to defendants on qualified immunity grounds and because plaintiffs failed to establish sufficient evidence of racial animus. The Seventh Circuit affirmed. Defendants are entitled to qualified immunity for any alleged violation of plaintiffs’ right to familial relations; for any alleged breach of Thor’s right to bodily security and integrity based on the decision to continue his placements; and for any alleged breach of Thor’s right to individualized treatment. View "Xiong v. Wagner" on Justia Law

Respondent was adjudicated delinquent and committed to a state facility. While there, he allegedly battered a group supervisor. The State charged him as an adult with battery by a prisoner under Nev. Rev. Stat. 200.481(2)(f), a felony. Citing relevant statutes and Robinson v. State, which broadly holds that "prisoner" as used in section 200.481(2)(f) was meant to only apply in the criminal setting, the district court dismissed the charge, holding that because Respondent's detention was civil, not criminal, he was not a "prisoner" to whom section 200.481(2)(f) could apply. The State appealed. The Supreme Court affirmed, holding that a juvenile detained for delinquency in a state facility is not a "prisoner" for purposes of section 200.481(2)(f). View "State v. Javier C." on Justia Law

The juvenile court adjudicated Ashley W. as a child within the meaning of Neb. Rev. Stat. 43-247(1) for possession of marijuana. Ashley appealed, and the court of appeals affirmed in a memorandum opinion. The court of appeals declined to address issues previously raised by Ashley in a motion to suppress, concluding she had failed to preserve the alleged errors. The Supreme Court reversed and remanded, holding that the juvenile court erred in denying Ashley's motion to suppress and in finding that she had waived her objection to the evidence at the adjudication hearing and that the court of appeals erred in affirming the order of adjudication. View "In re Ashley W." on Justia Law

Petitioner, a juvenile placed on juvenile probation, pleaded guilty to failing to follow an order of probation by violating curfew and failing to obey household rules. The circuit court then placed Petitioner in secure detention. Petitioner subsequently filed a petition for writ of habeas corpus, arguing that his sentence was illegal. The second district court of appeal denied Petitioner's petition for writ of habeas corpus and certified conflict with the fifth district court of appeal's decision in M.P. v. State. The Supreme Court (1) approved the decision of the second district court of appeal denying Petitioner's petition for writ of habeas corpus, and (2) disapproved the decision of the fifth district court of appeal in M.P. to the extent it was inconsistent with this opinion. View "J.M. v. Gargett" on Justia Law

At issue in this appeal was whether a juvenile has a statutory right to counsel during a police interrogation conducted before a complaint is filed or an appearance is made in juvenile court. The juvenile in this case was adjudicated delinquent of aggravated robbery with a three-year firearm specification. The juvenile appealed, arguing that the police sergeant violated Ohio Rev. Code 2151.352 in obtaining a written statement before giving the juvenile an opportunity to obtain counsel. The appellate court rejected the juvenile's claim, concluding that a juvenile proceeding does not commence until the filing of a complaint, and because no complaint had been filed against the juvenile at the time he was interrogated and gave the written statement, section 2151.352 did not apply. The Supreme Court affirmed, holding (1) pursuant to section 2151.352, a child is statutorily entitled to representation by legal counsel upon the filing of a complaint in juvenile court or upon initial appearance in the juvenile court; and (2) thus, the right of a juvenile to counsel pursuant to section 2151.352 attaches when the jurisdiction of a juvenile court is properly invoked. View "In re M.W." on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C. View "Hopkins v. State" on Justia Law

Plaintiff taught sixth-grade at a public school and met with a student’s parents about a threat the student had made against another student. He met the parents again after seeing the student beating another student. The father threatened a lawsuit and told plaintiff that an older son, who had assaulted the assistant principal, should have assaulted plaintiff. During a subsequent class, the student used an assignment to write a song with lyrics about stabbing plaintiff. The police liaison encouraged plaintiff to file criminal charges; under Illinois law declaring a knowing threat of violence against a person at a school is disorderly conduct, 720 ILCS 5/26-1(a)(13). School administrators feared a suit and were not supportive. After plaintiff filed charges, his evaluations went from satisfactory to unsatisfactory and administrators advised him that they would recommend that he not be rehired. Plaintiff resigned and filed suit, claiming retaliation for exercise of First Amendment rights. The district court granted summary judgment for defendants on the ground that the complaint was not protected by the First Amendment because it did not involve a matter of public concern. The Seventh Circuit reversed. Principles underlying the suit are well settled, which defeats claims of qualified immunity.

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case.