Justia Civil Rights Opinion Summaries

In 1987, John Bejarano shot and killed Roland Wright, a cab driver, during a robbery. Bejarano was convicted of first-degree murder, robbery, and other felonies. During the penalty phase, Bejarano made threatening statements to the jury, which contributed to his death sentence. The Nevada Supreme Court dismissed his direct appeal and Bejarano filed several unsuccessful post-conviction petitions in state and federal courts.The United States District Court for the District of Nevada denied Bejarano’s habeas corpus petition. Bejarano argued that the district court wrongly denied him an evidentiary hearing and that his trial counsel was ineffective for not presenting additional mitigation evidence. The district court found that Bejarano failed to exercise due diligence in developing the factual basis for his claims and denied the evidentiary hearing. It also concluded that even if trial counsel’s performance was deficient, Bejarano was not prejudiced.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The court held that Bejarano was not diligent in presenting his evidence in state court, and thus, the district court did not abuse its discretion in denying an evidentiary hearing. The court also found that Bejarano’s trial counsel’s performance was not deficient and that Bejarano was not prejudiced by any alleged deficiencies. Additionally, the court concluded that the Nevada Supreme Court provided appropriate appellate scrutiny of Bejarano’s death sentence.The Ninth Circuit denied Bejarano’s request for a certificate of appealability on three other issues, as he did not make a substantial showing of the denial of a constitutional right. The court ultimately affirmed the district court’s denial of Bejarano’s habeas corpus petition. View "Bejarano v. Reubart" on Justia Law

Kevin Niedzialek died after being restrained by Riverside County Sheriff’s Department deputies. The deputies responded to a 911 call reporting a man having a psychotic episode. Upon arrival, they found Niedzialek bleeding from the head and acting erratically. After he advanced towards one of the deputies, they used a taser to subdue him and handcuffed him while he was prone. Niedzialek continued to struggle but eventually became unresponsive. The deputies did not move him into a recovery position or perform CPR before paramedics arrived. Niedzialek died the next day.In the United States District Court for the Central District of California, a civil jury found that the deputies did not use excessive force under the Fourth Amendment but acted negligently under California law. The jury awarded $1.5 million to Niedzialek’s successor-in-interest, Tracy Alves. The defendants moved for judgment as a matter of law, arguing that the jury’s mixed verdicts were irreconcilable because the legal standard for reasonableness was the same for both claims. The district court denied the motion, stating that California’s negligence standard is broader than the Fourth Amendment’s reasonableness standard.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the jury’s verdicts were reconcilable because California’s “reasonable care” standard considers the totality of circumstances more broadly than the Fourth Amendment’s reasonableness standard. The jury could have found that the deputies did not use excessive force but still breached their duty of care by failing to monitor Niedzialek’s condition or place him in a recovery position. The court concluded that it was possible to reconcile the jury’s verdicts based on the evidence and theories presented at trial. View "Alves v. Riverside County" on Justia Law

Three criminal defendants in San Francisco, on behalf of themselves and a putative class, challenged the constitutionality of the San Francisco Sheriff's Office (SFSO) Pre-Trial Electronic Monitoring program (PTEM). They specifically contested Rule 5, which requires enrollees to submit to warrantless searches, and Rule 11, which allows SFSO to share participants’ location data with other law enforcement agencies without a warrant and to retain the data. The plaintiffs were divided into two subclasses: those enrolled in the program before May 2023 ("original rules subclass") and those enrolled after May 2023 ("revised rules subclass").The United States District Court for the Northern District of California granted a preliminary injunction in favor of the plaintiffs, finding that the Program Rules likely violated their rights under the United States and California constitutions. The court enjoined the enforcement of the challenged Program Rules for both subclasses. The Sheriff appealed the injunction, particularly the prohibition on enforcing the location sharing provision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction over the appeals and that abstention was not warranted. The court found that the plaintiffs were unlikely to succeed on their facial challenges to Rule 11’s location sharing requirement for the revised rules subclass. The court determined that the Superior Court exercises a core judicial power in imposing PTEM and that the Sheriff’s program does not create separation-of-powers issues. The court also found that the location sharing provision was reasonable under the Fourth Amendment and the California Constitution when ordered by the Superior Court following an individualized determination. The court vacated the preliminary injunction as to the revised rules subclass but affirmed it for the original rules subclass due to the lack of a clear record that location sharing was a condition of PTEM enrollment. The court also granted the Sheriff’s motion to stay the district court’s subsequent order enforcing the preliminary injunction. View "SIMON V. CITY AND COUNTY OF SAN FRANCISCO" on Justia Law

Alison Mayfield, who is deaf and communicates primarily through American Sign Language (ASL), was pulled over by officers from the City of Mesa’s Police Department (MPD) for suspected reckless driving. During the traffic stop and subsequent DUI processing, Mayfield requested an ASL interpreter but was not provided one. Instead, officers used a combination of written notes, lip-reading, and gestures to communicate with her. Mayfield was ultimately charged with DUI but pleaded guilty to reckless driving.The United States District Court for the District of Arizona dismissed Mayfield’s claims under Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA), holding that her claims were barred by Heck v. Humphrey and that she failed to state a claim for which relief could be granted. Mayfield appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that Mayfield’s ADA and RA claims were not barred by Heck v. Humphrey because a ruling in her favor would not necessarily imply the invalidity of her reckless driving conviction. The court found that the district court erred in considering the original DUI charges rather than the ultimate conviction for reckless driving and that the City of Mesa had not met its burden to establish the applicability of the Heck bar.On the merits, the Ninth Circuit held that the relevant question was whether the means of communication used by the officers were sufficient to allow Mayfield to effectively exchange information during the stop and arrest. The court concluded that Mayfield failed to plead sufficient facts to establish that MPD discriminated against her by not providing a reasonable accommodation. The court affirmed the district court’s dismissal of Mayfield’s complaint without leave to amend, as amendment would be futile. View "MAYFIELD V. CITY OF MESA" on Justia Law

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

In 1990, a group of California state prisoners filed a lawsuit alleging that the State of California violated the Eighth Amendment by failing to provide adequate mental health care in its prisons. The plaintiffs, who later achieved class certification, prevailed in a 1995 bench trial, and the State was found to be in violation of its Eighth Amendment obligations. Despite efforts to develop and implement remedial plans, the State remained noncompliant with court orders to reduce mental health care provider staffing vacancies to fixed levels.The United States District Court for the Eastern District of California issued several orders over the years to address the staffing issues, including a 2017 order requiring the State to achieve a maximum ten percent vacancy rate for mental health care providers. By 2023, the State had not complied, leading the district court to establish a schedule of prospective fines for continued noncompliance. After finding persistent noncompliance, the district court issued final contempt findings in 2024, resulting in over $110 million in fines.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision to hold the State in civil contempt. The Ninth Circuit agreed that the State failed to establish a substantial compliance defense or an impossibility defense. The court also held that the contempt fines were civil in nature and did not require criminal due process protections. However, the Ninth Circuit vacated the fines to the extent they exceeded the State’s monthly salary savings and remanded the case for additional findings and analysis regarding the exact amount of fines to be imposed. View "Coleman v. Newsom" on Justia Law

Abelardo Rodriguez-Arvizu was arrested by U.S. Border Patrol agents on November 18, 2019, for a suspected immigration violation. During processing, an outstanding arrest warrant related to his involvement in a marijuana "rip crew" was discovered. He was subsequently arrested by FBI agents, who did not inform him of the specific charges. During the ride to the FBI office, Rodriguez-Arvizu made incriminating statements. At the FBI office, he was read his Miranda rights, and he made further statements after waiving his rights.The United States District Court for the District of Arizona denied Rodriguez-Arvizu's motion to suppress his statements. The court found that although the FBI agents violated Fed. R. Crim. P. 4(c)(3)(A) by not informing him of the charges, suppression was not warranted. The court also found no violation of his Fifth Amendment right to counsel, as he did not unambiguously invoke this right. Additionally, the court determined that he validly waived his Sixth Amendment right to counsel despite not knowing the specific charges. Finally, the court ruled that his confession was within the safe harbor period of 18 U.S.C. § 3501(c) and did not violate the McNabb-Mallory rule.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that suppression was not warranted for the Rule 4(c)(3)(A) violation, as the agents' conduct was not sufficiently deliberate or culpable. The court also agreed that Rodriguez-Arvizu did not unambiguously invoke his Fifth Amendment right to counsel and that he validly waived his Sixth Amendment right. The court further held that the safe harbor period began with his FBI arrest, making his confession admissible. View "USA V. RODRIGUEZ-ARVIZU" on Justia Law

Keith Paul Bird, a prisoner at High Desert State Prison in Nevada, requested a cell transfer due to concerns about his cellmate, fearing a potential fight. Officer Bruce Huinker, the officer in charge, called for assistance, and Officers Paryga and Atherton responded. Bird explained his concerns, and Officer Paryga allegedly threatened him. The officers then instructed Bird to gather his belongings for a move but later changed their minds, leading to a confrontation. Bird's property was confiscated, and he claimed this was in retaliation for his request. Bird filed grievances, which were denied at all levels.Bird then filed a pro se complaint in federal court against the officers and other prison administrators, alleging retaliation and other claims. The district court found that only the retaliation claim survived screening and was properly exhausted. The district court denied the prison officials' motion for summary judgment on the retaliation claim, holding that they were not entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Bird's request for a cell transfer based on concerns with his cellmate did not constitute "protected conduct" under clearly established law. The court noted that neither the Supreme Court nor the Ninth Circuit had ever held that retaliation for complaints against other prisoners violated the First Amendment right to petition for redress of grievances. Consequently, the prison officials were entitled to qualified immunity. The Ninth Circuit reversed the district court's denial of qualified immunity and remanded with instructions to grant summary judgment on Bird's retaliation claim. View "BIRD V. DZURENDA" on Justia Law

Steven D’Braunstein was involved in a serious single-vehicle accident, resulting in his car being totaled. California Highway Patrol Officer Samantha Diaz-Durazo arrived at the scene and found D’Braunstein disoriented and in physical distress. Despite his evident symptoms, she did not call for medical assistance. Instead, she arrested him for driving under the influence of drugs and took him to jail. A nurse at the jail refused to admit D’Braunstein due to his medical condition, prompting Durazo to finally take him to the hospital, where he was diagnosed with a stroke. The delay in receiving medical treatment allegedly led to permanent injuries for D’Braunstein.The United States District Court for the Central District of California granted summary judgment in favor of Officer Durazo, holding that although she violated D’Braunstein’s Fourth Amendment rights by failing to provide reasonable medical care, she was entitled to qualified immunity. The court reasoned that the constitutional violation was not clearly established, as D’Braunstein’s injury was sustained prior to his arrest and not during the arrest process.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that a reasonable jury could find that Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, given the serious nature of the collision and his symptoms. The court further held that Durazo’s failure to provide medical care was a violation of clearly established law, which requires officers to seek medical assistance for an injured detainee or arrestee facing a substantial and obvious risk of serious harm. The case was remanded for further proceedings. View "D’Braunstein v. California Highway Patrol" on Justia Law

Two professors of Indian descent and adherents to the Hindu religion challenged California State University's (CSU) anti-discrimination and harassment policy, which included "caste" as a protected class. They argued that this inclusion stigmatized their religion and caused them to self-censor certain religious practices. They filed a lawsuit alleging violations of the Due Process Clause, Free Exercise Clause, and Establishment Clause of the U.S. Constitution, as well as equivalent claims under the California Constitution.The United States District Court for the Central District of California dismissed the professors' Equal Protection claim and the equivalent state law claim for lack of standing. The court also dismissed the Free Exercise claim for failing to state a claim without deciding on standing. The Due Process and Establishment Clause claims proceeded to a bench trial, where the court ultimately dismissed these claims as well, finding that the professors lacked sufficient injury for a pre-enforcement challenge and that the policy did not express government disapproval of Hinduism.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the professors lacked Article III standing for their Due Process claim because they failed to show that they intended to engage in any religious practice that could reasonably constitute caste discrimination or harassment. The court also found that the professors lacked standing for their Free Exercise claim, as they did not demonstrate any injury to their ability to exercise their religion. Finally, the court held that the professors lacked standing for their Establishment Clause claim, as the district court's factual finding that the policy had no hostility toward religion was not clearly erroneous. The court affirmed the judgment for the defendants and remanded for entry of judgment of dismissal without prejudice. View "Kumar v. Koester" on Justia Law