Justia Civil Rights Opinion Summaries

Two women called 911 to report Daniel as a “‘drunk driver’” on a highway near Santa Fe, then followed Daniel with their bright lights on. Daniel, feeling threatened, pulled over at an off-ramp to confront them. After a nonviolent encounter, Daniel drove to a secluded house where he lived with his brother, Samuel. Officer Truesdale interviewed the women at the off-ramp and obtained Daniel’s license plate number. The dispatcher identified the brothers’ address. Truesdale was joined by Officers White and Mariscal. The three agreed there was insufficient probable cause for arrest, but decided to speak with Daniel. White remained behind in case Daniel returned. Truesdale and Mariscal drove separately, less than a half mile, to the address, without flashing lights. They approached the house in a covert manner, found Daniel’s pickup truck, and spotted two men moving inside the residence. They radioed White, who left the off-ramp to join them. At approximately 11 p.m., the brothers became aware of their presence and yelled, “‘Who are you?’” and “‘What do you want?’” Mariscal and Truesdale laughed and responded: “‘Hey, (expletive), we got you surrounded. Come out or we’re coming in.’” Truesdale shouted: “‘Open the door, State Police, open the door.’” Mariscal yelled: “‘Open the door, open the door.’” The brothers heard, “We’re coming in” and did not hear the officers identify themselves. They armed themselves and yelled, “We have guns.” Truesdale positioned himself behind the house and shouted “‘Open the door, come outside.’” White, walking toward the house, heard “We have guns,” drew his gun and took cover behind a stone wall. Mariscal took cover behind a truck. Daniel fired two shotgun blasts from the back door while screaming loudly. Seconds later, Samuel opened a window and pointed a handgun in White’s direction. Mariscal fired at Samuel but missed. “‘Four to five seconds’” later, White shot and killed Samuel. In a suit under 42 U.S.C. 1983, the district court denied the officers summary judgment on the defense of qualified immunity. The Tenth Circuit affirmed. The Supreme Court vacated. Officer White did not violate clearly established law. The Court declined to consider whether a reasonable jury could infer that White witnessed the other officers’ deficient performance and should have realized that corrective action was necessary before using deadly force because neither lower court addressed that argument. The Court expressed no opinion on whether Truesdale and Mariscal are entitled to qualified immunity. View "White v. Pauly" on Justia Law

Texas House Bill 2 (2013) required that a “physician performing or inducing an abortion . . . must, on the date [of service], have active admitting privileges at a hospital . . . not further than 30 miles from the” abortion facility, and that the facility meet the state’s “minimum standards . . . for ambulatory surgical centers.” As a basis for enjoining enforcement, the district court found: as enforcement of the admitting-privileges requirement began, the number of abortion facilities dropped from about 40 to about 20, so that the number reproductive-age women living more than 50 miles from a clinic doubled and the number living more than 200 miles away increased about 2,800%; the number of facilities would drop to seven or eight if the surgical-center provision took effect; before H.B. 2’s passage, abortion was extremely safe with very low rates of complications and virtually no deaths; abortion was safer than many more common procedures not subject to the same level of regulation; and the cost of compliance with the surgical-center requirement would likely exceed $1.5 million-$3 million per clinic. The Fifth Circuit reversed, citing res judicata. The Supreme Court reversed: the constitutional claims are not barred by res judicata. This as-applied, post-enforcement challenge rests upon factual developments that occurred after an earlier facial challenge, once enforcement started and several clinics closed. Both of the challenged requirements place a substantial obstacle in the path of women seeking a previability abortion and constitute an undue burden on abortion access. Courts must consider the burdens a law imposes on abortion access together with the benefits those laws confer. The state’s evidence did not show how the law advanced its legitimate interest in protecting women’s health when compared to prior law, which required providers to have a “working arrangement” with doctors who had admitting privileges and required abortion facilities to meet extensive health and safety requirements that were policed by inspections. View "Whole Woman’s Health v. Hellerstedt" on Justia Law

The University of Texas at Austin’s undergraduate admissions system offers admission to all students who graduate in the top 10% of their Texas high school class, as required by the Texas Top Ten Percent Law. It fills the remainder of its freshman class, about 25%, by combining an applicant’s “Academic Index” (SAT score and high school academic performance) with a “Personal Achievement Index,” a holistic review containing numerous factors, including race. The University adopted the system in 2004, after a year-long-study of its admissions process—undertaken following two Supreme Court decisions—led it to conclude that its prior race-neutral system did not reach its goal of providing the educational benefits of diversity. Fisher was denied admission to the 2008 freshman class. She alleged that the University’s consideration of race disadvantaged her and other Caucasian applicants, in violation of the Equal Protection Clause. On remand for application of the strict scrutiny standard, the Fifth Circuit again affirmed summary judgment in the University’s favor. The Supreme Court affirmed. The race-conscious admissions program is lawful under the Equal Protection Clause. The compelling interest that justifies consideration of race in college admissions is not an interest in enrolling a certain number of minority students, but an interest in obtaining “the educational benefits that flow from student body diversity.” The University articulated concrete and precise goals—e.g., ending stereotypes, promoting “cross-racial understanding,” preparing students for “an increasingly diverse workforce and society,” and cultivating leaders with “legitimacy in the eyes of the citizenry” and gave a “reasoned, principled explanation” for its decision. The University’s conclusion that race-neutral programs had not achieved its diversity goals was supported by significant statistical and anecdotal evidence, while consideration of race has had a meaningful, but limited, effect on freshman class diversity. That race consciousness played a role in a small portion of admissions decisions is a hallmark of narrow tailoring, not evidence of unconstitutionality. The Top Ten Percent Plan had more of an impact on Fisher’s chances of admission. The Court noted the University’s continuing obligation to satisfy the strict scrutiny burden by periodically reassessing the program and by tailoring it to ensure that race plays no greater role than necessary to meet its compelling interests. View "Fisher v. Univ. of Tex. at Austin" on Justia Law

Enacted in response to the high incidence of domestic violence against Native American women, 18 U.S.C. 117(a), applies to any person who “commits a domestic assault within . . . Indian country” and who has at least two prior convictions for domestic violence rendered “in Federal, State, or Indian tribal court proceedings.” The Sixth Amendment guarantees indigent defendants appointed counsel in state or federal proceedings in which a term of imprisonment is imposed, but does not apply in tribal-court proceedings. The Indian Civil Rights Act, (ICRA) which governs tribal-court proceedings, includes a right to appointed counsel only for sentences exceeding one year, 25 U.S.C. 1302(c)(2). Supreme Court precedent holds that convictions obtained in state or federal court in violation of a defendant’s Sixth Amendment right to counsel cannot be used in subsequent proceedings “to support guilt or enhance punishment for another offense” except for uncounseled misdemeanor convictions for which no prison term was imposed. The Ninth Circuit reversed Bryant’s section 117(a) conviction, finding that the Sixth Amendment precluded use of his prior, uncounseled, tribal-court convictions a predicate offenses. The Supreme Court reversed. Because Bryant’s tribal-court convictions complied with ICRA and were valid when entered, use of those convictions as predicate offenses in a section 117(a) prosecution does not violate the Constitution. Bryant’s sentence for violating section 117(a) punishes his most recent acts of domestic assault, not his prior crimes. He suffered no Sixth Amendment violation in tribal court, so he cannot “suffe[r] anew” from a prior deprivation. ICRA sufficiently ensures the reliability of tribal-court convictions, guaranteeing “due process of law,” providing other procedural safeguards, and allowing a prisoner to challenge the fundamental fairness of proceedings in federal habeas proceedings. View "United States v. Bryant" on Justia Law

Williams was convicted of a 1984 murder and sentenced to death. Philadelphia District Attorney Castille approved a request to seek the death penalty. Williams’s conviction and sentence were upheld on direct appeal, state post-conviction review, and federal habeas review. In 2012, Williams filed a successive petition under Pennsylvania’s Post-Conviction Relief Act (PCRA), arguing that the prosecutor had obtained false testimony from his codefendant and suppressed exculpatory evidence. Finding that the prosecutor had committed Brady violations, the court stayed Williams’s execution. The Commonwealth asked the Pennsylvania Supreme Court, whose chief justice was former District Attorney Castille, to vacate the stay. Without explanation, Castille denied Williams’s motion for recusal and request for referral to the full court; Castille joined an opinion vacating PCRA relief and reinstating Williams’s death sentence. Two weeks later, Castille retired. The U.S. Supreme Court vacated, holding that Castille’s participation violated the Due Process Clause. There is an impermissible risk of actual bias when a judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding the defendant’s case. No attorney is more integral to the accusatory process than a prosecutor who participates in a major adversary decision; the decision to pursue the death penalty is a critical choice. Neither the involvement of multiple actors nor the passage of time relieves the former prosecutor of the duty to withdraw. An unconstitutional failure to recuse constitutes structural error, “not amenable” to harmless-error review, regardless of whether the judge’s vote was dispositive. The Court noted that many jurisdictions, including Pennsylvania, have statutes and professional codes that already require recusal under these circumstances. View "Williams v. Pennsylvania" on Justia Law

Guards (Madigan and Ross) undertook to move Blake, a Maryland inmate, to the prison’s segregation unit. Madigan assaulted Blake, punching him in the face. The prison system’s Internal Investigative Unit (IIU), issued a report condemning Madigan’s actions. Blake sued both guards under 42 U.S.C. 1983, alleging excessive force and failure to take protective action. A jury found Madigan liable. Ross raised the Prison Litigation Reform Act (PLRA) requirement that an inmate exhaust “such administrative remedies as are available” before bringing suit. Blake argued that the IIU investigation was a substitute for those procedures. The Fourth Circuit reversed dismissal of the suit, holding that “special circumstances” can excuse a failure to comply with administrative procedural requirements, particularly where the inmate reasonably, although mistakenly, believed he had sufficiently exhausted his remedies. The Supreme Court vacated: “The Fourth Circuit’s unwritten ‘special circumstances’ exception is inconsistent with the text and history of the PLRA.” Mandatory exhaustion statutes like the PLRA foreclose judicial discretion. There are, however, circumstances in which an administrative remedy, although officially on the books, is not available. An administrative procedure is unavailable when it operates as a dead end, with officers unable or consistently unwilling to provide relief. An administrative scheme might be so opaque that it becomes, practically speaking, incapable of use. Finally, a grievance process is rendered unavailable when prison administrators thwart inmates from taking advantage of it through misrepresentation, or intimidation. The record raised questions about whether Blake had an “available” administrative remedy to exhaust. View "Ross v. Blake" on Justia Law

Himmelreich, a federal prisoner, sued the United States, alleging that he was severely beaten by a fellow inmate as the result of negligence by prison officials. The government treated the suit as a claim under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b). The court granted the defendants summary judgment on the ground that the claim fell into the exception for “[a]ny claim based upon . . . the exercise or performance . . . [of] a discretionary function,” namely, deciding where to house inmates. While the motion was pending, Himmelreich filed a second suit: a constitutional tort suit against individual Bureau of Prison employees, again alleging that his beating was the result of officials’ negligence. After the dismissal of Himmelreich’s first suit, the court dismissed the second suit as foreclosed by the FTCA’s judgment bar provision. The Sixth Circuit reversed. The Supreme Court affirmed. The FTCA “Exceptions” section’s plain text dictates that the judgment bar does “not apply” to cases that, like Himmelreich’s first suit, are based on the performance of a discretionary function. Had the court dismissed Himmelreich’s first suit because, e.g., the employees were not negligent, it would make sense that the judgment bar provision would prevent a second suit against the employees. Where an FTCA claim is dismissed because it falls within one of the “Exceptions,” the dismissal signals merely that the United States cannot be held liable for the claim; it has no logical bearing on whether an employee can be liable instead. View "Simmons v. Himmelreich" on Justia Law

Lynch was convicted of first-degree murder, kidnapping, armed robbery, and burglary for a 2001 killing. The state sought the death penalty. Before Lynch’s penalty phase trial began, Arizona successfully moved to prevent his counsel from informing the jury that the only alternative sentence to death was life without the possibility of parole. The jury failed to reach a unanimous verdict. A second jury was convened and sentenced Lynch to death. The Arizona Supreme Court vacated the sentence because the jury instructions improperly described Arizona law, but did not address Lynch’s argument that the trial court violated the 1994 Supreme Court holding, Simmons v. South Carolina, “where a capital defendant’s future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole,” the Due Process Clause “entitles the defendant ‘to inform the jury of [his] parole ineligibility.’” .On remand, a third penalty phase jury sentenced Lynch to death. The Arizona Supreme Court affirmed, rejecting Lynch’s Simmons claim, while acknowledging that the state suggested that Lynch could be dangerous. The Supreme Court, per curiam, reversed. Under state law, the only kind of release for which Lynch would be eligible is executive clemency. Simmons expressly rejected the argument that the possibility of clemency diminishes a capital defendant’s right to inform a jury of his parole ineligibility. The Court rejected Arizona’s argument that “nothing prevents the legislature from creating a parole system in the future" for which Lynch would be eligible. View "Lynch v. Arizona" on Justia Law

Lee and her boyfriend stabbed two women to death and were convicted of first-degree murder. Lee received a sentence of life without the possibility of parole. In 1999, Lee unsuccessfully raised four claims on appeal. After California appellate courts affirmed, Lee filed a federal habeas petition, 28 U.S.C. 2254(a), raising mostly claims not raised on direct appeal. The court stayed federal proceedings to allow Lee to pursue her new claims in a state habeas petition. The California Supreme Court denied Lee’s petition, citing California’s “Dixon bar,” under which a defendant procedurally defaults a claim raised for the first time on state collateral review if he could have raised it earlier on direct appeal. The federal court then dismissed her new claims as procedurally defaulted. For the first time, Lee challenged the Dixon bar, citing the California Supreme Court’s state habeas denials on a single day. Lee claimed that out of the 210 summary denials on December 21, 1999, the court failed to cite Dixon in nine cases where it should have been applied. The court denied those nine petitions without any citation. Without evaluating that evidence, the Ninth Circuit reversed and remanded “to permit the Warden to submit evidence.” On remand, the warden submitted a study analyzing about 4,700 summary habeas denials during a two-year period around the same date: the California Supreme Court cited Dixon in approximately 12% of all denials—more than 500 times. The district court held that the Dixon bar is adequate. The Ninth Circuit again reversed. The Supreme Court, per curiam, reversed, stating that the decision “profoundly misapprehends” what makes a state procedural bar “adequate.” California’s procedural bar is longstanding, oft-cited, and shared by habeas courts across the country. View "Johnson v. Lee" on Justia Law

During jury selection at Foster’s trial, the state (Georgia) used peremptory challenges to strike all four qualified black prospective jurors. Foster was convicted of capital murder and sentenced to death. The trial court rejected an argument that the strikes were racially motivated, in violation of Batson v. Kentucky. While his state habeas petition was pending, Foster obtained copies of the prosecution’s trial file, including the jury venire list with the names of each black prospective juror highlighted; an investigator's statement comparing black prospective jurors and concluding, “If it comes down to having to pick one of the black jurors, [this one] might be okay”; notes with “N” (for “no”) appearing next to the names of all black prospective jurors; a document with notes about a church, annotated "No. Black Church”; and questionnaires, on which each juror’s response indicating race was circled. The state court denied relief. The Georgia Supreme Court denied a certificate of appeal. The U.S. Supreme Court reversed, first holding that it had jurisdiction to review the denial of a Certificate of Probable Cause; there was no indication that denial rested on state law “independent of the merits” of Foster’s Batson claim. The lower court’s application of res judicata depended on a federal constitutional ruling; its decision that Foster failed to show purposeful discrimination was clearly erroneous. Though the trial court accepted the prosecution’s justifications for the strikes, "the record belies much of the prosecution’s reasoning." That a prosecutor’s reasons for striking a black prospective juror apply equally to an otherwise-similar nonblack prospective juror, who is allowed to serve, suggests purposeful discrimination. The Court noted “the prosecution’s shifting explanations, misrepresentations of the record, and persistent focus on race.” Because Batson was decided only months before Foster’s trial, the state argued that the prosecution’s file was an effort to maintain a detailed account should the prosecution need a defense against any suggestion that its reasons were pretextual. That argument, having never before been raised in the 30 years since Foster’s trial, “reeks of afterthought.” View "Foster v. Chatman" on Justia Law