Justia Civil Rights Opinion Summaries

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

In 2005, Martinez, Vallejo, and 47 others were indicted for crimes committed while they were members of the Milwaukee chapter of the Latin Kings gang organization. Martinez and Vallejo pled guilty to a RICO offense, 18 U.S.C. 1962, and admitted to engaging in predicate racketeering activities, including a 2003 murder. Vallejo, who was 17 years old at the time, and Martinez, who was 16, each fired several shots at the victim. Martinez also pled guilty to attempted murder of a rival gang member; Vallejo’s plea agreement included two attempted murders. All of the attempted murders occurred while the defendants were under the age of 18. In both cases, the court imposed the “maximum sentence”—life in prison.. Neither Martinez nor Vallejo filed a direct appeal. In 2012, the Supreme Court held, in Miller v. Alabama, that the Eighth Amendment prohibits the imposition of a mandatory life sentence without the possibility of parole for juveniles. The Seventh Circuit affirmed the district court’s denial of their motion to vacate, set aside, or correct their sentences under 28 U.S.C. 2255. Martinez and Vallejo’s life sentences were imposed after an individualized sentencing, and not by statutory mandate,and did not violate Miller. View "Vallejo v. United States" on Justia Law

Woods told a coworker at the Berwyn Fire Department that “he wanted to kill somebody, all of them” and that his children were going to “go over there” and “tune them up,” referring to his coworkers and superiors. Chief O’Halloran looked into the statements and eventually recommended termination. A three-member panel for the Board of Fire and Police Commissioners conducted a hearing. Woods was represented by counsel, who gave opening and closing statements, put on witnesses, cross-examined others, made and won objections, and presented exhibits. After the hearing, the Board voted to terminate Woods based largely on the testimony of the co-worker to whom Woods made the statement. Woods filed suit asserting discrimination and unlawful retaliation and attempted to proceed under a “cat’s paw” theory of liability, which applies in employment discrimination cases when a biased subordinate (O’Halloran) who lacks decision-making power uses the formal decision-maker (the Board) as a dupe in a deliberate scheme to trigger a discriminatory employment action. The Seventh Circuit affirmed summary judgment, rejecting Woods’s claims, noting the full and independent evidentiary hearing and the Board’s almost complete reliance on the co-worker’s testimony. View "Woods v. City of Berwyn" on Justia Law

The Centralia state-operated developmental center, one of seven Illinois SODCs, houses approximately 200 severely disabled individuals, some having the mentality of an infant or toddler. Many also have serious aggressive, or self-destructive behavioral disorders. The seven SODCs have, in total, about 1800 residents, while about 10,000 people with severe developmental disabilities live in community-based facilities: houses or apartments in residential settings that accommodate one to eight residents. The state agency provides services (such as housing and medical care) to approximately 25,000 developmentally disabled persons. Another 23,000 or so are on a waiting list; 6000 are considered to be in emergency situations. Since 2012 Illinois has been trying to shift SODC residents to community-based facilities, in accordance with a national trend: community-based facilities are cheaper than SODCs and there is evidence that even persons who are severely disabled mentally or behaviorally or both do better in community-based facilities. A suit, on behalf of the Centralia SODC residents, alleged violation of the Americans with Disabilities Act, 42 U.S.C. 12132. The Seventh Circuit affirmed denial of a preliminary injunction to prevent assessment and transfer of those residents, reasoning that the urgency required for emergency relief had not been shown. View "Ill. League of Advocates for Developmentally Disabled v. Ill. Dep't of Human Servs." on Justia Law