Justia Civil Rights Opinion Summaries

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

Green complained to his employer, the U.S. Postal Service, that he was denied a promotion because he was black. His supervisors then accused him of the crime of intentionally delaying the mail. In a 2009 agreement, USPS agreed not to pursue criminal charges. Green agreed either to retire or to accept another position in a remote location. Green chose to retire. In 2010, 41 days after resigning and 96 days after signing the agreement, Green reported an unlawful constructive discharge to the EEOC under Title VII of the Civil Rights Act., 42 U.S.C. 2000e Green eventually filed suit, which was dismissed as untimely because he had not contacted EEOC within 45 days of the “matter alleged to be discriminatory.” The Tenth Circuit affirmed. The Supreme Court vacated. Because part of the “matter alleged to be discriminatory” in a constructive-discharge claim is an employee’s resignation, the 45-day limitations period begins running after an employee resigns. Resignation is part of the “complete and present cause of action” in a constructive-discharge claim, which requires: discriminatory conduct such that a reasonable employee would have felt compelled to resign and actual resignation. Nothing in Title VII or the regulation suggests an exception to the rule. Starting the clock before a plaintiff can file suit would not further the limitations period’s goals and would negate Title VII’s remedial structure. View "Green v. Brennan" on Justia Law

CRST trucking company requires its drivers to graduate from its training program before becoming certified drivers. In 2005, new driver Starke filed an EEOC charge, alleging that she was sexually harassed by male trainers during her training (42 U.S.C. 2000e–5(b)).The Commission ultimately informed CRST that it had found reasonable cause to believe that CRST subjected Starke and “a class of employees and prospective employees to sexual harassment.” In 2007, having determined that conciliation had failed, the Commission filed suit. During discovery, the Commission identified over 250 allegedly aggrieved women. The district court dismissed, held that CRST was a prevailing party, and awarded the company over $4 million in fees. The Eighth Circuit reversed the dismissal of two claims and vacated the award. On remand, the Commission settled Starke’s claim and withdrew the other. The district court again awarded more than $4 million, finding that CRST had prevailed on more than 150 claims because of the Commission’s failure to satisfy pre-suit requirements. The Eighth Circuit reversed, stating that dismissal was not a ruling on the merits. A unanimous Supreme Court vacated. A favorable ruling on the merits is not a necessary predicate to find that a defendant is a prevailing party. A plaintiff seeks a material alteration in the legal relationship between the parties; a defendant seeks to prevent that alteration, and that objective is fulfilled whenever the plaintiff ’s challenge is rebuffed, irrespective of the precise reason for the decision. Title VII’s fee-shifting statute allows prevailing defendants to recover whenever the plaintiff ’s “claim was frivolous, unreasonable, or groundless.” Congress must have intended that a defendant could recover fees expended in such litigation when the case is resolved in the defendant’s favor, whether on the merits or not. View "CRST Van Expedited, Inc. v. Equal Employment Opportunity Comm'n" on Justia Law

Betterman pleaded guilty to bail jumping after failing to appear on domestic assault charges. He was then jailed for over 14 months awaiting sentence, in large part due to institutional delay. He was eventually sentenced to seven years’ imprisonment, with four of the years suspended. The Montana Supreme Court and U.S. Supreme Court affirmed, ruling that the Sixth Amendment’s Speedy Trial Clause does not apply to post-conviction, presentencing delay. The Speedy Trial Clause right attaches upon a defendant’s arrest or formal accusation, but detaches upon conviction. Before conviction, the accused is shielded by the presumption of innocence, which the Speedy Trial Clause implements by minimizing the likelihood of lengthy incarceration before trial, lessening the anxiety and concern associated with a public accusation, and limiting the effects of long delay on the accused’s ability to mount a defense. The sole remedy for a violation of the speedy trial right— dismissal of the charges—fits the preconviction focus of the Clause; it would be an unjustified windfall to remedy sentencing delay by vacating validly obtained convictions. View "Betterman v. Montana" on Justia Law

Hinojosa was serving a sentence for armed robbery when, in 2009, prison officials “validated” him as a prison-gang associate and placed him in secured housing (Cal. Penal Code 2933.6). In 2010, the state amended the law so that secured housing prison-gang associates placed could no longer earn future good-time credits. Hinojosa filed a state habeas petition, arguing violation of the Constitution’s prohibition of ex post facto laws. The Orange County Superior Court denied the claim on venue grounds. Challenges to conditions of confinement should be filed in the superior court of county of confinement. Rather than file a new petition, Hinojosa turned to the appellate court, which summarily denied his petition. Hinojosa then sought an original writ of habeas corpus in the Supreme Court of California, which summarily denied relief. The federal district court denied Hinojosa’s ex post facto claim under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which requires a state prisoner seeking federal habeas relief to exhaust state remedies, 28 U.S.C. 2254(b)(1)(A). If the state courts adjudicate a federal claim “on the merits,” AEDPA mandates deferential, rather than de novo, review, unless the state-court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law,”, or “was based on an unreasonable determination of the facts.” The Ninth Circuit decided that the Supreme Court of California’s summary denial was not “on the merits.” The Supreme Court reversed. While, generally, “silence implies consent," strong evidence can refute that presumption. Improper venue could not possibly have been a ground for the high court’s summary denial of Hinojosa’s claim. There is only one Supreme Court of California, so its denial “obviously rested upon some different ground” and was on the merits. View "Kernan v. Hinojas" on Justia Law