Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's claims against Activate Healthcare, LLC under W. Va. R. Civ. P. 12(b)(6), holding that the circuit court did not err in concluding that Plaintiff's factual allegations against Activate were insufficient to establish a claim of aiding and abetting under the West Virginia Human Rights Act.Plaintiff was working at Constellium Rolled Products Ravenswood, LLC when she requested a change in her duties to accommodate her medical condition. Plaintiff was directed to Activate, Constellium's on-site medical provider, for a physical activity report, but Activate issued more than one report. Constellium terminated Plaintiff based on one of the reports and later returned to work. After Plaintiff unsuccessfully filed a grievance seeking lost wages during her break in employment she sued Constellium, Activate, and other defendants, alleging retaliation and discrimination. The circuit court dismissed Plaintiff's aiding and abetting claim against Activate for failure to state a claim. The Supreme Court affirmed, holding that nothing in the complaint could be construed to establish the elements of an aiding and abetting claim. View "Boone vs. Activate Healthcare, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting and sentencing Defendant for first-degree robbery, holding that Defendant's assignments of error did not merit relief.Defendant and his girlfriend were indicted for robbing a gambling parlor. Before trial, the girlfriend agreed to testify against Defendant. After Defendant made a series of jailhouse phone calls to his girlfriend, she withdrew her plea agreement and declared she would not testify against Defendant. The circuit court granted the State's motion to admit the girlfriend's recorded statement into evidence. The Supreme Court affirmed, holding (1) the circuit court did not err in granting the State's motion to admit the girlfriend's out-of-court statement under the forfeiture-by-wrongdoing doctrine; (2) the circuit court properly found that Defendant had engaged in wrongdoing that would support the admission of the girlfriend's out-of-court statement; (3) Defendant did not receive ineffective assistance of trial counsel; and (4) the court's answer to a jury question was not in error. View "State v. Jako" on Justia Law

The Supreme Court reversed Defendant's conviction and sentence for manufacturing a controlled substance, holding that the circuit court erred in denying Defendant's motion to suppress evidence that Defendant argued was the fruit of an illegal entry and search of his home.Law enforcement went to Defendant's home to serve a domestic violence emergency protective order (EPO) that prohibited Defendant from possessing firearms and provided for the surrender of firearms to the officer serving the EPO. The officers concluded that the EPO served as a search warrant permitting them to enter and search Defendant's home for weapons. When the officers stepped into the residence, they smelled marijuana and performed a protective sweep, including a pat down of Defendant. Defendant filed a motion to suppress the evidence, which the circuit court denied. The Supreme Court reversed, holding (1) an EPO is not a de facto search warrant, and no exception to the warrant requirement applied to otherwise validate the entry into and search of Defendant's home; and (2) therefore, the circuit court erred in denying Defendant's motion to suppress. View "State v. Snyder" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of driving under the influence causing serious bodily injury and sentencing him to life in prison, with mercy, holding that there was no error.After the jury returned a guilty verdict, the State filed a recidivist information alleging that Defendant had previously been convicted of two prior felony offenses. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motions for a mistrial; (2) the State provided sufficient evidence of Defendant's prior Maryland conviction; and (3) the sentence imposed by the trial court was not an unconstitutionally disproportionate punishment under W. Va. Const. art. III, 5. View "State v. Costello" on Justia Law

The Supreme Court granted a writ of prohibition sought by the prosecuting attorney of Monongalia County to prohibit the circuit court from enforcing its order suppressing Cesar Felix's statement to Morgantown police and certain DNA evidence, holding that the circuit court committed clear legal error.Cesar Felix worked at a restaurant where a woman claimed that she was sexually assaulted upon leaving. When police interviewed him, Defendant denied any involvement in the crime and consented to a DNA search by cheek swab. The DNA evidence linked Felix to the crime, and he was subsequently charged with two counts of sexual assault. Defendant filed a motion to suppress his statement and the DNA evidence, claiming that he was not given Miranda warnings or advised of his right to refuse his consent to the DNA search. The circuit court granted the motion. The Supreme Court reversed, holding (1) Defendant was not in custody when he gave his statement, and therefore, no Miranda warnings were required; (2) Defendant's Fifth Amendment privilege against self-incrimination and due process rights were not violated; and (3) Defendant's Fourth Amendment protection against unreasonable searches was not violated. View "State ex rel. DeChristopher v. Gaujot" on Justia Law

The Supreme Court reversed the order of the circuit court that denied Petitioner's appeal of an order of the family court modifying an infant guardianship order to prohibit Petitioner from having any contact with his child, J.B., holding that Petitioner's due process rights were violated.On appeal, Petitioner argued that the family court erred by failing to give him adequate notice or the opportunity to be heard at the final hearing in this matter. The Supreme Court agreed and reversed the circuit court's final order, holding that Petitioner was not afforded his due process rights as the father of J.B. when he was not afforded the opportunity to refute the family court's assumption that he was unfit to have contact with his child. The Court remanded this case for a full evidentiary hearing before the family court. View "David C. v. Tammy S." on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's complaint claiming failure to accommodate, gender discrimination, hostile work environment, and retaliation, holding that the circuit court did not err.In dismissing the complaint, the circuit court found that Plaintiff's claims were barred by the doctrine of res judicata because they could have been raised in an earlier lawsuit between the same parties. Plaintiff appealed, arguing (1) she was foreclosed from raising her claims during the earlier proceeding because the deadline for amendments to the pleadings had passed, and (2) the claims were different from those raised in the earlier lawsuit. The Supreme Court affirmed, holding that the circuit court properly found that res judicata was a bar to the litigation of Plaintiff's claims. View "Baker v. Chemours Co. FC, LLC" on Justia Law

The Supreme Court vacated the order of the circuit court modifying the disposition of this case to terminate Petitioners' parental rights under W. Va. Code Ann. 49-4-604(c)(6), holding that the circuit court erred in modifying the disposition absent a motion under section 49-4-606 and that the parties were deprived of due process when they were not notified that the circuit court intended to take up a motion to modify disposition.In 2017, the circuit court ordered a "section 5" disposition, concluding that Petitioners were unwilling or unable to provide for B.W.'s needs and that there were no parenting services available specifically tailed to Petitioners' need for reasonable accommodation under the Americans with Disabilities Act, 42 U.S.C. 12101 through 12213. The court did not terminate Petitioners' parental rights at that time but dismissed the case from its docket. In 2019, the circuit court held a status hearing and sua sponte modified the case's disposition to terminate Petitioners' parental rights. The Supreme Court vacated the order, holding that termination of Petitioners' parental rights violated the procedure required by section 49-4-606 to modify disposition and denied Petitioners due process. View "In re B.W." on Justia Law

The Supreme Court granted a writ of prohibition prohibiting the circuit court from enforcing its order denying Petitioners' motion to dismiss or, in the alternative, to compel arbitration, holding that the circuit court erred in finding that the arbitration agreement put forth by Petitioners was not authentic.After her employment ended, Respondent filed a lawsuit alleging wrongful and discriminatory discharge. Petitioners filed a motion to dismiss/compel arbitration, asserting that this matter was subject to a valid and binding arbitration agreement. The circuit court denied the motion, concluding that significant questions existed with regard to the authenticity of the arbitration agreement. Petitioners then filed the instant petition for a writ of prohibition seeking to prevent enforcement of the circuit court's order. The Supreme Court granted the requested writ, holding that the circuit court committed clear legal error in denying Petitioners' motion to dismiss or, in the alternative, to compel arbitration by finding the arbitration agreement was not authentic. View "State ex rel. Troy Group v. Honorable David J. Sims" on Justia Law

The Supreme Court reversed the orders of the circuit court in favor of Rosa Lee Butcher in the suit Butcher filed against Defendants, a police officer and the Clarksburg City Police Department, holding that in a claim filed pursuant to 42 U.S.C. 1983 a plaintiff cannot obtain a finding of liability or receive a judgment for damages against a John Doe defendant.The circuit court upheld the jury's finding of liability against the John Doe defendants, as well as the judgment rendered against the John Doe defendants in favor of Butcher. The court then awarded costs and attorney's fees to Butcher. The Supreme Court reversed, holding (1) a government official can be held liable only for his or her own misconduct, and Butcher failed to establish that any of the John Doe defendants were personally and directly responsible for the conduct giving rise to her section 1983 claim; and (2) because Butcher did not prevail in her section 1983 action she was not entitled to receive an award of her costs or attorney's fees. View "Vinson v. Butcher" on Justia Law