Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the grant of summary judgment in favor of the YMCA in plaintiff's public accommodation suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff argued that the YMCA's blanket policy of requiring a child's individualized education program (IEP) before admitting the child to its summer camp programs was discriminatory because the IEP in effect serves to screen out children with disabilities from the YMCA summer camp programs. The district court correctly determined that the YMCA took no adverse action against plaintiff's child. Assuming that plaintiff's request to provide less information than the entire IEP was a request for an accommodation, plaintiff failed to establish that the YMCA failed to unreasonably accommodate the child where the YMCA offered to modify the policy as long as it obtained the information it deemed necessary to accommodate the child. View "Koester v. Young Men's Christian Assoc." on Justia Law

The Eighth Circuit reversed and remanded the district court's grant of summary judgment in a suit against employees of a juvenile home, concluding that the district court erred by holding as a matter of law that defendants were entitled to qualified immunity. Plaintiff alleged that defendants violated his constitutional rights by housing him in prolonged solitary confinement, failing to educate him, and allowing him to be sexually abused. In this case, the district court addressed only the fact of juvenile court supervision in determining that defendants were entitled to qualified immunity, and its opinion did not contain sufficient detail to allow the court to review whether defendants were entitled to qualified immunity. View "Bradford v. Avery" on Justia Law

In three consolidated cases, the court concluded that the motion for relief and the petition for writ constitute second or successive habeas applications, and denied authorization for the district court to consider them; petitioner's claim that his counsel was ineffective for failing to undertake an investigation into juror bias or misconduct was sufficiently similar to a habeas corpus application; and, even if the court were to conclude that the motion was not a second or success habeas petition, petitioner has not shown extraordinary circumstances that would justify relief. The court denied petitioner's application for a certificate of appealability as moot; petitioner's protective application to file a second or successive habeas petition; and motions for stay of execution that were currently pending in each of the three cases. View "Williams v. Kelley" on Justia Law

Mark Moore and two others filed suit against the Arkansas Secretary of State, challenging certain Arkansas statutes that set the filing deadline for individuals who wish to appear on the general election ballot as independent candidates. Plaintiffs sought a declaratory judgment that the filing deadline is unnecessarily early and thus violates the First and Fourteenth Amendments, as well as 42 U.S.C. 1983. Plaintiffs sought to enjoin the Secretary from enforcing this deadline against Moore. The district court granted the Secretary's motion for summary judgment and denied Moore's motion for reconsideration. The court concluded that the district court correctly noted that the March 1 filing deadline for independent candidates imposes a burden "of some substance" on Moore's First and Fourteenth Amendment rights and that Arkansas has a compelling interest in timely certifying independent candidates for inclusion on the general election ballot. The court concluded, however, that the district court erred in determining that there was no genuine dispute of material fact whether the March 1 deadline is narrowly drawn to serve that compelling interest. In this case, there exists a genuine factual dispute whether the verification of independent candidate petitions would conflict with the processing of other signature petitions under the former May 1 deadline. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Moore v. Martin" on Justia Law

Marcel Williams filed suit under 42 U.S.C. 1983, challenging the Arkansas lethal injection execution protocol. After the district court denied Williams' motion for a preliminary injunction, he moved for a stay of execution pending appeal. Williams' as-applied challenge alleged that due to his medical conditions, there was a substantial and unjustifiable risk that the execution method would cause him severe pain and serious harm in violation of the Eighth Amendment. The court concluded that Williams failed to offer evidence establishing a significant likelihood of success on the merits. In this case, the State produced testimony that the execution protocol would succeed despite Williams' health conditions; Williams failed to identify a known and available alternative method of execution that would substantially reduce a significant risk of pain; and Williams unreasonably delayed in bringing this as-applied challenge. Accordingly, the court denied the motion for a stay of execution pending appeal. View "Williams v. Kelley" on Justia Law

Marcel Williams, convicted of capital murder, kidnapping, rape, and aggravated robbery, moved for a stay of execution. Williams wanted to re-open the denial of federal habeas relief in 2009, renewing his claims of ineffective assistance of counsel at the guilt and penalty phases of his trial. The court concluded that Williams lacked a reasonable likelihood of success on his claims for Rule 60(b) relief based on ineffective assistance of counsel during either the penalty phase or the guilt phase of his trial. Therefore, Williams was not entitled to an extraordinary stay of execution. View "Williams v. Kelley" on Justia Law

Jack Harold Jones, Jr. appealed the district court's denial of a preliminary injunction, and moved for a stay of execution. Jones argued that, because of his specific medical conditions, the administration of the ADC's lethal-injection protocol will inflict cruel and unusual punishment on him in violation of the Eighth Amendment. The court concluded that Jones's delay in bringing his as-applied claim was sufficient reason to deny a stay; Jones failed to establish a significant possibility that he could show that, as applied to him, the State's lethal injection protocol creates a demonstrated risk of severe pain; and Jones failed to establish that there was a significant possibility that he could identify an alternative method of execution that is feasible, readily implemented, and in fact significantly reduces a substantial risk of severe pain. Therefore, the court affirmed the district court's order and denied a stay of execution. View "Jones, Jr. v. Kelley" on Justia Law

Two appeals were filed before this court five hours before Ledell Lee's scheduled execution. Lee challenged the district court's alleged denial of his motion requesting funds under 18 U.S.C. 3599(f) for "ancillary services to assist in the preparation of clemency and potential additional litigation." The court denied Lee's motion for stay of execution, concluding that Lee has failed to make a showing that there is a significant possibility that he will succeed on the merits of a claim that would deprive Arkansas of the authority to execute him. The court explained that, even if he succeeded on his section 3599(f) claim, Arkansas would still have the authority to execute him. View "Lee v. Kelley" on Justia Law

Four Arkansas death-row inmates appealed the denial of their motions for a preliminary injunction prohibiting their executions and moved the court for a stay of execution. The court concluded that, to the extent the inmates argued that Arkansas law, regulations, and policy during the clemency process violated the Due Process Clause of the Fourteenth Amendment, this argument failed under well-established law; even if the inmates are correct that the Board failed to comply with Arkansas law, regulations, and policy, this in and of itself is insufficient to demonstrate a significant possibility of success on the merits; the district court was correct in determining that, despite the procedural shortcomings in the clemency process, the inmates received the minimal due process guaranteed by the Fourteenth Amendment; and the court rejected the inmates' claim that the district court abused its discretion in determining that their procedural impossibility claim "evaporated" at the moment the Board recommended against granting clemency. Accordingly, because the inmates have failed to show a significant possibility of success on the merits, the court denied the motion for a stay. View "Lee v. Hutchinson" on Justia Law

The district court entered stays of execution in an action brought by nine Arkansas prisoners under 42 U.S.C. 1983. The prisoners were all convicted of murder and sentenced to death. The court granted the State's motion to vacate the stays, concluding that the prisoners could have brought their section 1983 method-of-execution claim much earlier and intentionally declined to do so; the district court's conclusion concerning the use of midazolam in the Arkansas execution protocol did not apply the governing standard; the district court's factual findings would not support a conclusion that the prisoners have a likelihood of success in showing that the execution protocol is sure or very likely to cause severe pain; the court disagreed with the legal standard that the district court applied in determining whether alternative methods of execution are known and available; and, even assuming a risk of pain from the current method, the availability of the several methods cited by the district court is too uncertain to satisfy the rigorous standard under the Eighth Amendment. Accordingly, the court vacated the stays of execution. View "McGehee v. Hutchinson" on Justia Law