Justia Civil Rights Opinion Summaries

At issue in these two consolidated appeals was whether the district court properly calculated the time period in which to file a motion for substitution of district judge in youth court and on an appeal from justice court. Petitioners, two youths who appeared in court or detention hearings and a defendant who pled guilty in justice court to driving under the influence, petitioned for writ of supervisory control, claiming that the district court incorrectly denied as untimely their motions for substitution of district court judge in those cases. The Supreme Court reversed in part and affirmed in part, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court properly calculated the time period in which to file a motion for substitution of district court on the appeal from justice court.

C.P. was fifteen years old when he was charged with two counts of rape and one count of kidnapping with sexual motivation. The juvenile court found C.P. to be a delinquent child and designated him a serious youthful offender in relation to each offense. Further, the court classified C.P. a public-registry-qualified juvenile-offender registrant (PRQJOR) and a Tier III sex-offender/child-victim offender pursuant to Ohio Rev. Code 2152.86. At issue on appeal was the constitutionality of section 2152.86, which created the new class of juvenile sex-offender registrants, PRQJORs, who are automatically subject to mandatory, lifetime sex-offender registration and notification requirements without the participation of a juvenile judge. The Supreme Court reversed, holding that to the extent that it imposes such requirements on juvenile offenders tried with the juvenile system, section 2152.86 violates the constitutional prohibition against cruel and unusual punishment and the due process clauses of the state and federal Constitutions.

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings.

A disabled child, born in 1996, was a student in the Sutton public school system from 1999 until 2005, when his parent were dissatisfied with the individualized education program developed under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1491, and the services he was receiving. They removed him from the school and enrolled him in a private learning center. The Massachusetts Bureau of Special Education Appeals determined that the 2005 IEP complied with the IDEA. The district court upheld the decision on summary judgment. The First Circuit affirmed, rejecting an argument that the court could not determine compliance without first determining the child's potential for learning and self-sufficiency. The district court properly concluded that the child's potential was unknowable and that the IEP was reasonably calculated to confer educational benefits. The parents did not raise triable claims under the First Amendment, the Rehabilitation Act of 1973, Titles II and V of the Americans with Disabilities Act, or 42 U.S.C. 1983 and 1985; plaintiffs “cannot disguise an IDEA claim in other garb.”

When he was fifteen years old, E.C. pled guilty to breaking and entering and rape. After E.C. was released from custody and placed under parole supervision, a team of attorneys filed a petition for a writ of habeas corpus on E.C.'s behalf alleging that E.C.'s guilty plea was neither knowing nor voluntary and was unconstitutionally invalid because of ineffective assistance of counsel. Six days after his petition was filed, E.C. was released from parole supervision. The circuit court dismissed the petition, concluding that it had no jurisdiction to consider the petition and that the habeas corpus proceeding was moot. The Supreme Court reversed, holding (1) the circuit court had active jurisdiction over the proceeding because E.C. was detained for purposes of habeas corpus when the petition was filed; and (2) E.C.'s release from probation during the pendency of the habeas corpus proceeding did not automatically render the proceeding moot, as the collateral consequences imposed on E.C. by the convictions he challenged were sufficient to sustain a continued controversy.

S.L. was charged with one count of rape in the juvenile division of the circuit court. Before the adjudication hearing, S.L. filed a motion to dismiss for violation of his right to a speedy trial, which the circuit court denied. S.L. then filed another motion to dismiss for lack of a speedy trial, which the circuit court granted. The State appealed. After noting that the State's appeal under these circumstances required the Supreme Court's review for the correct and uniform administration of the criminal law under Ark. R. App. P.-Crim. 3(d) instead of relying on facts unique to the case, the Court dismissed the appeal, as it did not have at issue the correct and uniform administration of justice and, instead, involved the application of the Court's speedy-trial rules to the unique facts of the case.

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute.

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California.

T.M.L. was seventeen when he pled guilty to felony burglary and misdemeanor criminal trespass to vehicles. The youth court entered a dispositional order providing that T.M.L. be placed on probation until he reached age eighteen, after which supervision was to be transferred to the district court and adult probation and parole department. After T.M.L. turned eighteen, the youth court transferred T.M.L.'s matter to district court and transferred T.M.L.'s supervision to adult supervision under the department of corrections. The Supreme Court (1) affirmed the youth court's denial of T.M.L.'s motion to dismiss where the youth court had jurisdiction over T.M.L.; and (2) remanded the matter for the limited purpose of striking the condition that T.M.L. register as a sexual offender as a condition of T.M.L.'s sentence, as the youth court did not have the power to require T.M.L. to register as a sexual offender.

The State filed a delinquency petition alleging that a seventeen-year-old girl had engaged in criminal solicitation to commit murder after she asked a stranger to punch her in the stomach to terminate her pregnancy. The juvenile court (1) held that an assault of a woman by punching her in the stomach was a "procedure" intended to terminate her pregnancy and therefore qualified as an abortion under statute; and (2) dismissed the State's petition against the minor because a woman cannot be held criminally liable for seeking an abortion. The Supreme Court reversed, holding that the solicited assault of a woman to terminate her pregnancy was not a "procedure" as contemplated by statute and therefore did not constitute an abortion. Remanded.