Justia Civil Rights Opinion Summaries

After a jury trial in an Illinois state court, Appellant was found guilty of murdering his girlfriend’s one-year-old daughter. After exhausting his state appeals, Appellant filed a federal habeas petition, claiming, inter alia, that the forty-two-month delay in bringing his case to trial violated his Sixth Amendment right to a speedy trial. The district court denied the habeas petition. On direct appeal, the Illinois Appellate Court concluded that the pretrial delay was presumptively prejudicial but that the delay was attributable to continuances requested by Appellant’s counsel and did not impair the defense. The Seventh Circuit affirmed, holding that the Illinois court’s decision was not an unreasonable application of federal law, and therefore, habeas relief was unwarranted. View "O'Quinn v. Spiller" on Justia Law

Plaintiff, an employee of Costco Wholesale Corporation, made two requests for a medical leave under the FMLA. Costco granted both requests. During that time, Plaintiff was demoted from optical manager to cashier. Plaintiff filed this lawsuit against Costco and Gail Hinds, his supervisor, alleging retaliation and interference, both in violation of the FMLA, and discrimination based upon a disability and failure to accommodate, both in violation of the Americans with Disabilities Act. The district court granted summary judgment for Defendants on all of Plaintiff’s causes of action. The Seventh Circuit affirmed, holding that the district court (1) did not abuse its discretion in finding that Plaintiff failed to comply with the requirements of the Northern District of Illinois Local Rule 56.1; (2) properly granted summary judgment in favor of Defendants on Plaintiff’s FLMA retaliation and interference claims; and (3) properly granted summary judgment in favor of Defendants on Plaintiff’s reasonable accommodation claim. Lastly, Plaintiff waived any arguments with regard to disparate treatment. View "Curtis v. Costco Wholesale Corp." on Justia Law

Sixteen days after Defendant, a dentist, learned Plaintiff, an inmate of Illinois’s Stateville prison, was complaining of a tooth abscess, Defendant diagnosed an abscessed molar, prescribed penicillin to bring the infection under control, and extracted the molar. Plaintiff sued the dentist and a prison guard (together, Defendants), charging them with deliberate indifference to his abscess. The district judge granted summary judgment in favor of Defendants. The Seventh Circuit reversed, holding that the evidence of deliberate indifference by Defendants to Plaintiff’s serious medical need precluded granting summary judgment in their favor. Remanded. View "Dobbey v. Mitchell-Lawshea" on Justia Law

On July 5, 2013, the Governor of Wisconsin signed into a law a statute that the Wisconsin legislature had passed one month earlier prohibiting a doctor from performing an abortion unless he or she has admitting privileges at a hospital no more than thirty miles from the clinic in which the abortion is performed. Planned Parenthood of Wisconsin and Milwaukee Women’s Medical Services (which operate the only four abortion clinics in Wisconsin) joined by two doctors employed by Planned Parenthood, challenged the statute’s constitutionality under 42 U.S.C. 1983, first seeking and obtaining a preliminary injunction and ultimately seeking a permanent injunction against enforcement of the statute. After a trial, the trial judge granted a permanent injunction against enforcement of the statute. The Seventh Circuit affirmed, holding (1) Plaintiffs had standing to sue; and (2) the statute is unconstitutional because it imposes a burden excessive in relation to the aims of the statute and the benefits likely to be conferred by it. View "Planned Parenthood of Wisconsin, Inc. v. Schimel" on Justia Law

Plaintiff, who is black, filed a complaint against the Chicago Transit Authority (CTA) in federal court, alleging that the CTA fired him because of his race in violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The CTA responded that Plaintiff was fired because he violated CTA’s policy against sexual harassment. The district court granted the CTA’s motion for summary judgment, concluding that Plaintiff’s evidence was insufficient to create a triable issue under either the direct or indirect methods of proving unlawful discrimination. The Seventh Circuit affirmed, holding that Plaintiff’s case failed under both the direct and indirect methods of proof. View "Smith v. Chicago Transit Auth." on Justia Law

Vinyard pled guilty to conspiracy to manufacture, distribute, and possess methamphetamine with intent to distribute. At sentencing, he started to backtrack on whether he was admitting some of the relevant conduct. After consulting his attorney, he withdrew his objections. His hesitation prompted the district judge (Gilbert) to vacate his plea and sentence on the court’s own initiative, which led to unusual proceedings culminating in a writ of mandamus ordering the court to reinstate Vinyard’s plea and sentence. Vinyard tried to challenge his plea in district court proceedings conducted to comply with the mandate. Judge Stiehl rejected Vinyard’s challenge and reinstated the plea and sentence. Vinyard then could have filed either direct appeal or a collateral attack under 28 U.S.C. 2255. On his attorney’s advice, he chose collateral attack. He later sought reinstatement of his right to direct appeal, arguing that advice caused him to default some claims and amounted to constitutionally ineffective assistance of counsel under Strickland v. Washington. The district court denied relief, concluding that the decision to forgo a direct appeal was strategic and not objectively unreasonable, and that Vinyard could not show prejudice in any event. The Seventh Circuit affirmed, finding that Vinyard proved neither deficient performance nor prejudice. View "Vinyard v. United States" on Justia Law

Plaintiff has a neurological disorder, tardive dyskinesia. Plaintiff’s involuntary movements include tongue thrusting, pursing of the lips, choking, and side-to-side chewing of the jaw. She becomes mute, screams or makes non-verbal sounds, particularly under stress. She also suffers post-traumatic stress disorder and bipolar disorder, with severe anxiety. Shortly after plaintiff was diagnosed with TD, a personal injury suit that she had filed went to trial. She had no lawyer. Before trial, she sought accommodations of her medical problems, and was permitted to have a friend and a family member take notes, was given a podium, and was allowed to take occasional recesses. She was denied other requested help—a microphone, an interpreter, and a jury instruction explaining her disorder, lest the jurors think she was just acting up. She was hectored by the judge, who told the jury that the plaintiff has a “speech impediment.” She suffered other embarrassments in front of the jury, which returned a verdict for the defendant. Plaintiff unsuccessfully moved for a new trial on the ground that she was disabled within the meaning of the Americans with Disabilities Act yet had been denied reasonable accommodations. The Seventh Circuit reversed and remanded, finding that plaintiff was denied a full and fair opportunity to vindicate her claims. View "Reed v. State of Illinois" on Justia Law

In 2001, Sherman was shot and died from multiple gunshot wounds. When an officer arrived, Sherman lay on the ground with 50-60 people gathered around. Long was tried for first degree murder. No physical evidence tied Long to the crime. The state presented four witnesses. Two witnesses named Long as the shooter during the investigation, but recanted at trial. In closing argument, the prosecutor made improper statements, resulting in reversal of Long’s conviction and a new trial. At Long’s second trial, the state again presented the four eyewitnesses. One maintained her identification of Long. The two witnesses who recanted during the first trial continued to deny having seen Long shoot Sherman, despite their prior videotaped statements. The fourth witness, Irby, gave inconsistent testimony. During closing arguments, the prosecutor made comments that no evidence or theory was presented that another individual committed the crime, referred to the movie “Gone with the Wind,” and referenced the contents of a letter written by Irby that had not been admitted into evidence. The jury found Long guilty. His state court appeals and post-conviction petitions were unsuccessful. The district court dismissed Long’s federal habeas petition, finding the prosecutorial misconduct claims procedurally defaulted and that Long had not shown a reasonable likelihood that Irby’s testimony or the closing argument prejudiced the outcome; that Long’s ineffective assistance claim was without sufficient merit to overturn the state court; and that his post-conviction counsel ineffective assistance claim was procedurally barred. The Seventh Circuit reversed, finding that the state’s failure to correct Irby’s denial of her recantation prejudiced Long. View "Long v. Butler" on Justia Law

In 2000, Huri began working at the Circuit Court of Cook County. Her manner of dress marked her as a follower of Islam. Huri is from Saudi Arabia. From 2002-2010, she worked as a child care attendant—the only one who was an Arab, and the only one who was a Muslim— under McCullum, a devout (and allegedly vocal) Christian. Huri filed internal complaints regarding McCullum’s behavior. McCullum became aware of those complaints and told Huri that the Chief Judge’s Office was uninterested in — and tired of—Huri’s complaints. McCullum apparently complained about Huri. In2010, Huri was transferred to the Court Reporters’ Office, where, Huri alleges, she was also treated badly and subject to retaliation for filing Equal Employment Opportunity complaints. The district court dismissed Huri’s suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e and under 42 U.S.C. 1983, claiming her First and Fourteenth Amendment rights were violated. The Seventh CIrcuit reversed, concluding that Huri had stated a claim of hostile work environment and that Huri’s superiors were not protected by qualified immunity. View "Huri v. Office of the Chief Judge, Cook County" on Justia Law

In 2007, Adkins, a detective at a Chicago Veterans Affairs (VA) Medical Center, installed a hidden surveillance camera in the ceiling of an office used by female officers as a changing area. The camera captured images of female officers dressing and undressing. VA personnel discovered the covert surveillance equipment during a 2009 renovation. Gustafson learned that the camera had captured images of her changing and filed suit against Adkins, alleging an unconstitutional search in violation of the Fourth Amendment. The district court denied Adkins’s motion for summary judgment on qualified immunity grounds. The Seventh Circuit affirmed, rejecting Adkins’s claims that Gustafson’s Bivens claim was precluded by the “comprehensive remedial scheme[s]” laid out in the Civil Service Reform Act and the Federal Employees’ Compensation Act. Supreme Court precedent clearly established the contours of the Fourth Amendment violation Gustafson alleged. View "Gustafson v. Adkins" on Justia Law