Justia Civil Rights Opinion Summaries

At issue was whether the county court erred in overruling Defendant’s motion to suppress. The county court overruled Defendant’s motion after finding that the community caretaking exception to the Fourth Amendment applied. The district court and court of appeals affirmed. The Supreme Court affirmed the decision of the court of appeals, albeit on different grounds, holding (1) because the initial police-citizen encounter did not amount to a seizure, it was not necessary to invoke the community caretaking exception; but (2) the circumstances clearly established reasonable suspicion that a crime was being committed, and therefore, the detention that followed the stop of Defendant’s vehicle was constitutionally permitted. View "State v. Rivera" on Justia Law

The Supreme Court affirmed the district court’s order dismissing with prejudice Plaintiff’s complaint for failure to state a claim upon which relief could be granted. Plaintiff, which operated commercial grain warehouses and elevators and owned trading businesses through Nebraska, filed a complaint alleging that several defendants engaged in a pattern of behavior with the intent to deprive it of information, an opportunity to be heard, and due process of law. The district court concluded that Defendants were entitled to immunity under Nebraska’s Consumer Protection Act and the Noerr-Pennington doctrine and that Plaintiff’s claims of conspiracy and aiding and abetting required an underlying tort to be actionable. The Supreme Court affirmed, holding (1) Plaintiff failed to state a claim upon which relief could be granted because Defendants were entitled to immunity under the Noerr-Pennington doctrine and Plaintiff alleged only underlying statutory violations; and (2) any amendment to Plaintiff’s petition would be futile. View "Salem Grain Co. v. Consolidated Grain & Barge Co." on Justia Law

The Supreme Court affirmed the orders of the district court sustaining Defendants’ motion for summary judgment and overruling Plaintiff’s motion to alter or amend the judgment in this action brought by Plaintiff against the Board of Regents of the University of Nebraska and Kevin Ruser. In her complaint, Plaintiff asserted claims of discriminatory wage and employment practices based on her sex, as well as claims of employment retaliation arising from occurrences while she was a supervising attorney for the civil clinic law program at the University of Nebraska College of Law. The district court concluded that Plaintiff failed to establish a prima facie case of wage discrimination, failure to promote because of sex, retaliation, and retaliation in violation of public policy. The Supreme Court affirmed, holding that the district court did not err when it sustained Defendants’ motion for summary judgment with respect to Plaintiff’s claims and did not abuse its discretion when it overruled Plaintiff’s subsequent motion to alter or amend the judgment. View "Knapp v. Ruser" on Justia Law

Defendant pled no contest to first degree murder and was sentenced to life imprisonment. Defendant was sixteen years old at the time of the murder. Defendant’s life sentence was later vacated pursuant to Miller v. Alabama, 567 U.S. 460 (2012), and Defendant was granted a resentencing. The district court resentenced Defendant to imprisonment for eighty years to life after a hearing. The Supreme Court affirmed Defendant’s resentencing, holding (1) the sentencing court did not impose a de facto life sentence in violation of the Eighth Amendment and Neb. Const. art. I, 9 and 15; (2) the district court did not err when it did not make specific findings of fact regarding age-related characteristics; and (3) Defendant’s sentence of eighty years’ to life imprisonment with parole eligibility at age fifty-six was not unconstitutionally disproportionate. View "State v. Jones" on Justia Law

The Supreme Court affirmed the denial of Defendant’s motion to suppress evidence seized during the detention and search of a vehicle in which she was a passenger, as well as the sentence imposed for Defendant’s possession of a controlled substance conviction. In regard to her motion to suppress, Defendant argued that the initial encounter with the lead law enforcement officer amounted to a seizure when she was detained after the officer determined that the wanted individual was not in the vehicle and that the investigatory stop was not supported by reasonable suspicion. The Supreme Court held (1) the lead officer had reasonable suspicion of illegal activity to justify the detention of the vehicle’s passengers after the officer determined that the wanted individual was not in the vehicle; and (2) the sentence imposed did not constitute an abuse of discretion. View "State v. Rogers" on Justia Law

The Supreme Court affirmed the order of the district court that overruled Defendant’s motion for postconviction relief without an evidentiary hearing. Defendant pled guilty to five counts of first degree murder and five counts of use of a deadly weapon to commit a felony. Defendant’s motion for postconviction relief raised numerous claims of ineffective assistance of trial and appellate counsel. The Supreme Court held (1) with respect to each of Defendant’s ineffective assistance of counsel claims, the district court did not err when it concluded that Defendant failed to allege sufficient facts to demonstrate a violation of his constitutional rights and that the record affirmatively showed that Defendant was not entitled to relief; and (2) the district court did not err when it overruled Defendant’s motion for postconviction relief without holding an evidentiary hearing. View "State v. Vela" on Justia Law

In Hike I, Leo and Joanna Hike filed a petition of appeal seeking compensation after the State exercised its power of eminent domain in 2008 to acquire a parcel of the Hikes’ property for an expansion of a highway. The Supreme Court affirmed the jury verdict rendered in the case. In 2011, before the trial in Hike I, the State’s independent contractor began construction on the property taken from the Hikes. That same month, Leo noticed damage to the brick veneer of his and Joanna’s residence. The court precluded the Hikes from offering any evidence concerning the structural damage. In 2015, the Hikes filed the instant action claiming the same structural damage that they attempted to offer as evidence in Hike I. The trial court dismissed the complaint, finding that the claim was barred by the relevant statute of limitations. The Supreme Court affirmed, holding (1) the two-year statute of limitations period set forth in section 25-218 governs inverse condemnation actions against the State; and (2) the district court did not err in determining that the Hikes’ claim is barred by the two-year statute of limitations. View "Hike v. State" on Justia Law

Defendant appealed his conviction, rendered after a jury trial, for possession of methamphetamine with intent to deliver. Defendant argued, among other things, that the trial court erred in denying his motion to suppress evidence found during a search with a warrant that was obtained as a result of observing defaced firearms during a prior warrantless search for a possible intruder at the request of a houseguest. The Supreme Court affirmed, holding (1) the facts reasonably warranted an immediate intrusion of a residence into areas where a burglar might be hiding, and therefore, the trial court did not err in overruling Defendant’s motion to suppress; (2) Defendant was not prejudiced by the admission, without a limiting instruction, of evidence of his drug use around the time specified in the information; and (3) the prosecutor did not commit misconduct during closing arguments. View "State v. Rodriguez" on Justia Law

Defendant, who was convicted of violating Neb. Rev. Stat. 28-1212.04 and other offenses, appealed the district court’s denial of his motion for postconviction relief, arguing that he should have received an evidentiary hearing on his allegations. Defendant’s arguments were premised on the constitutionality of section 28-1212.04. The Supreme Court affirmed the denial of postconviction relief, holding (1) the district court properly found that Defendant’s allegations raising direct constitutional challenges to section 28-1212.04 were procedurally barred; and (2) Defendant’s ineffective assistance of counsel claim did not entitle him to an evidentiary hearing because the allegations could not support a finding of deficient performance. View "State v. Ross" on Justia Law

After a stipulated bench trial, Defendant was convicted of possession of a firearm by a prohibited person. Defendant was sentenced to three to five years’ imprisonment. Defendant appealed, arguing that the evidence against him should be suppressed because there was no probable cause to support the issuance of a search warrant. The Supreme Court affirmed, holding (1) Defendant’s Fourth Amendment rights were not violated when his house and vehicle were searched because the application and warrant established probable cause; and (2) officers did not exceed the scope of the search warrant when they searched a vehicle parked outside the house described in the search warrant. View "State v. Hidalgo" on Justia Law