Justia Civil Rights Opinion Summaries

In 1998, Rimmer was convicted and sentenced to death for the murder of Ellsworth. Rimmer later learned that the federal government had conducted a joint investigation of Ellsworth’s murder with the Memphis Police Department, which, he claims, produced exculpatory evidence. Rimmer instituted state post-conviction proceedings, and obtained some, but not all, of the allegedly exculpatory evidence from the police department. Rimmer submitted a FOIA request that sought all relevant FBI documents. The FBI released 189 full or partially redacted pages from a total of 616 pages. The U.S. Department of Justice upheld the limited release. Rimmer filed claims under the APA, 5 U.S.C. 702, the Mandamus Act, 28 U.S.C. 1361, and FOIA, 5 U.S.C. 552(a)(4)(b). The FBI then determined that relevant files contained 786 pages and released them, but 704 pages were partially redacted. The district court dismissed Rimmer’s APA and mandamus claims as precluded by an adequate remedy under FOIA and granted the government summary judgment on Rimmer’s FOIA claim, holding that the redactions were proper under FOIA Exemptions 7(C) and 7(D) and that, in the case of the 7(C) redactions, there was not a “countervailing public benefit” to support disclosure of otherwise protected information. The Sixth Circuit affirmed. View "Rimmer v. Holder" on Justia Law

In 1985 Moreland lived with his girlfriend Glenna and seven others. After arguing with Glenna, Moreland left, returned with a rifle, and killed Glenna and four others. An 11-year-old child and another were injured but survived. When Moreland was arrested, he told officers that it was “too late” and was uncooperative. At trial, Moreland presented expert testimony that he would have had a blood alcohol level between .30 and .36 around the time the murders were committed, suggesting that he was too intoxicated to carry out the acts as described. Other witnesses reported seeing Moreland that night and called into question his intoxication defense. A three judge panel convicted Moreland and sentenced him to death. The Ohio Court of Appeals and Ohio Supreme Court affirmed; the U.S. Supreme Court denied certiorari. State courts denied relief in state post-conviction proceedings. The district court denied a petition for habeas corpus (28 U.S.C. 2254), rejecting claims of insufficient evidence, that the court did not conduct an adequate evidentiary hearing on a child eyewitness’s competence to testify, that the court wrongly excluded expert testimony concerning the child, and that Moreland was denied effective assistance of counsel. The Sixth Circuit affirmed. View "Moreland v. Bradshaw" on Justia Law

In 2004 a jury convicted Middlebrook of assault with intent to murder, felony firearm possession, and unlawful driving away of a motor vehicle in connection with the shooting of his former girlfriend. On appeal, Middlebrook argued that he was denied a fair trial when the jury was exposed to extraneous influences and engaged in premature deliberations. The Michigan Court of Appeals determined that there were no extraneous influences; the Michigan Supreme Court denied leave to appeal. The district court denied federal habeas relief without addressing the issue of premature deliberations. The Sixth Circuit affirmed. The trial court conducted the necessary inquiry into the allegation of extraneous influences on the jury and the Supreme Court has not entertained a case involving premature deliberations. This is not a case where the state court unreasonably refused to extend a legal principle to a new context in which it should apply. View "Middlebrook v. Napel" on Justia Law

On October 29, 1994, people, including Gover, congregated at a house from which Ratliff and Hunter sold marijuana to discuss a robbery. Ratliff believed that “Ricky” and the stolen items could be found nearby. Ratliff and Hunter got in the front seat of a vehicle. Witnesses testified that the backseat occupants were Catchings and Gover. The car traveled to a house where people on the porch said that Ricky was not there. As the car left, a gun fired from the rear passenger window. Two people sustained non-fatal injuries, but a bullet killed nine-year-old Michelle. Witnesses testified that Gover said that he shot because someone laughed at him. The Lannette house was later fired upon. Officers detained Hunter and Ratliff. Ratliff implicated Gover. Officer Johnson testified to Ratliff’s statement. Officer Jamison testified to what he observed and what occupants told him about the shooting. Gover was sentenced to 60-100 years and unsuccessfully appealed and challenged rulings in Michigan courts. He filed a 28 U.S.C. 2254 habeas petition. The district court held that, while its introduction violated Gover’s Sixth Amendment rights, Johnson’s testimony relaying Ratliff’s statement was harmless and that Jamison’s testimony did not violate the Sixth Amendment. The Sixth Circuit affirmed. View "Gover v. Perry" on Justia Law

Following a 2000 shooting death in Nashville, Robins was convicted of first-degree, premeditated murder in state trial court. The appellate court affirmed. Robins filed a habeas corpus petition, claiming ineffective assistance. The state trial court found that counsel’s representation was not deficient or prejudicial, and the state appellate court affirmed. Robins filed a pro se habeas corpus petition in the district court, which was amended and then dismissed. The Sixth Circuit affirmed, concluding that Robins did not demonstrate that the state appellate court’s decision was unreasonable or improper under Antiterrorism and Effective Death Penalty Act of 1996 deference. View "Robins v. Fortner" on Justia Law

A 1998 neighborhood shooting in Detroit resulted in the death of an 18-year-old male bystander and injury to two other bystanders, a 21-year-old male and a nine-year-old female. A year later, a Michigan state court convicted 22-year-old Blackmon of second-degree murder, using a firearm during the commission of a felony, and two assaults with intent to do great bodily harm. The court sentenced him to 40 to 60 years on the murder count, concurrent three-to-10 year terms on the assault counts, and a consecutive two-year term on the firearm count. Eleven years later, a federal district court on collateral review (28 U.S.C. 2254) held that Michigan had deprived Blackmon of a fair trial in violation of the Due Process Clause and granted a conditional writ of habeas corpus and told Michigan to retry him. The Sixth Circuit reversed. The prosecution’s elicitation of, and comment upon, testimony regarding Blackmon’s gang affiliation did not render his trial so unfair as to result in a denial of federal due process; it did not result in a decision that “involved an unreasonable application of clearly established Federal law, as determined by the Supreme Court of the United States.” View "Blackmon v. Booker" on Justia Law

In 1994 Nathan was discovered in a hotel room, having suffered severe trauma to her head. Her jewelry was missing. Nathan died that afternoon. Police investigated three hotel employees who had prior criminal histories, eventually focusing on Jones. Police discovered that Jones had injured his hand on the day Nathan was killed and had filed a claim for workers’ compensation for an injury classified as a fist-to-mouth injury. Jones stated that he hurt his hand cleaning a banquet room. A search of Jones’s car produced Nathan’s pendant and a master key to the hotel. A jury convicted Jones on aggravated felony murder, aggravated burglary, and aggravated robbery, and recommended the death penalty. The Ohio Court of Appeals and Supreme Court affirmed the convictions and death sentence. Jones unsuccessfully sought state post-conviction relief and, in 2001, filed an unsuccessful habeas petition in federal district court. The Sixth Circuit affirmed, rejecting claims that the state trial court improperly admitted evidence that Jones exercised his right to counsel; that the prosecution failed to disclose exculpatory evidence, and counsel provided ineffective assistance by failing to discover the withheld evidence; and that counsel provided ineffective assistance by failing to investigate a history of crime at the hotel.View "Jones v. Bagley" on Justia Law

Clay was appointed as public records coordinator for the City of Memphis. The volume of public-record requests increased substantially during an FBI investigation into awards of city contracts. Clay claims that her efforts to comply with requests were thwarted by delays in response from city employees and even delays in requests for office supplies and a place for the public to review documents. Clay was also concerned with the conduct of various other employees, such as not reporting absences, and “issues regarding nepotism and favoritism based upon personal relationships.” Clay repeatedly raised her concerns to various officials. When a new mayor was sworn in, she began to suspect the new city attorney of abuse of policies and sought records concerning employees in that office. Clay’s employment was terminated and she sued, asserting violations of the Tennessee Public Protection Act, common law retaliatory discharge and wrongful termination, tortious interference with at-will employment, breach of the duty of good faith and fair dealing, deprivation of constitutional rights in violation of 42 U.S.C. 1983, and violation of the Tennessee Governmental Tort Liability Act. The district court dismissed. The Sixth Circuit reversed with respect to a First Amendment retaliation claim, but otherwise affirmed. View "Handy-Clay v. City of Memphis, TN" on Justia Law

In 2001, Bridges was convicted of misdemeanor domestic violence; the court did not impose a term of incarceration, but sentenced him to one year of probation. In 2010, Bridges was indicted for possessing a firearm after being convicted of a misdemeanor crime of domestic violence, 18 U.S.C. 922(g)(9). Bridges moved to dismiss, arguing that he qualified for one of the exceptions to the firearm restriction, listed in 18 U.S.C. 921(a)(33)(B)(ii). The district court denied the motion and sentenced Bridges to 21 months in prison. The Sixth Circuit affirmed. An individual who has been convicted of a misdemeanor crime of domestic violence is prohibited from possessing a firearm, except that a “person shall not be considered to have been convicted of such an offense . . . if the conviction . . . is an offense for which the person . . . has had civil rights restored.” Under Michigan law, misdemeanants lose their civil rights only while confined in a correctional facility, Mich. Comp. Laws 168.758b.The Supreme Court has held that the “civil rights restored” clause in an analogous provision does not apply to an offender such as Bridges who lost no civil rights. View "United States v. Bridges" on Justia Law

In 1997, 19-year-old Franklin beat his grandmother, grandfather, and uncle, set the house on fire and left them to die of blunt-force injuries or smoke inhalation. Franklin fled the scene in his grandfather’s car, taking his grandfather’s gun and his grandmother’s jewelry. The trial court found him competent; the jury found Franklin guilty on: seven aggravated arsons, two aggravated robberies, and six aggravated murders. The trial court sentenced Franklin to death and 91 years of imprisonment. On direct appeal, the Ohio Supreme Court merged the escaping-detection aggravator into the aggravated-robbery and aggravated-arson aggravators then independently reweighed aggravation and mitigation before determining that death was the appropriate sentence. The district court denied a petition for habeas corpus. The Sixth Circuit affirmed, rejecting claims: challenging the pretrial competency hearing and determination of competency; alleging ineffective assistance; challenging denial of a continuance after a defense arson expert died before testifying; challenging admission of “gruesome” photographs; that execution would constitute cruel and unusual punishment and would violate his Equal Protection and Due Process rights because he committed the crimes when he was mentally ill; and that the definition of “reasonable doubt” given in the guilt-phase jury instructions was constitutionally inadequate. View "Franklin v. Bradshaw" on Justia Law