Justia Civil Rights Opinion Summaries

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

The Paterson, New Jersey, chief of police and Officer Heffernan’s supervisor were appointed by Paterson’s incumbent mayor, who was running for re-election against Heffernan's friend, Spagnola. Heffernan was not involved in Spagnola’s campaign. As a favor to his bed-ridden mother, Heffernan delivered her Spagnola campaign yard sign. Other officers reported seeing Heffernan at a Spagnola distribution point while holding that sign. The next day, Heffernan’s supervisors demoted him from detective to patrol officer as punishment for “overt involvement” in Spagnola’s campaign. Heffernan filed suit under 42 U.S.C. 1983. Affirming the district court, the Third Circuit concluded that Heffernan’s claim was actionable under Section 1983 only if his employer’s action was prompted by Heffernan’s actual, rather than his perceived, exercise of free-speech rights. The Supreme Court reversed. When an employer demotes an employee out of a desire to prevent the employee from engaging in protected political activity, the employee is entitled to challenge that unlawful action under the First Amendment and Section 1983 even if the employer’s actions are based on a factual mistake. An employer’s motive, and the facts as the employer reasonably understood them, matter in determining violation of the First Amendment. The harm— discouraging employees from engaging in protected speech or association—is the same, regardless of factual mistake. The lower courts should decide whether the employer may have acted under a neutral policy prohibiting police officers from overt involvement in any political campaign and whether such a policy would comply with constitutional standards. View "Heffernan v. City of Paterson" on Justia Law

Michigan law enforcement received an anonymous tip that two white males were traveling on I–96 in a white Audi, possibly carrying cocaine. Officers spotted a vehicle matching that description and pulled it over for speeding. Etherton was driving; Pollie was a passenger. A search uncovered 125.2 grams of cocaine in the driver side door. Pollie testified, with a plea agreement, that he had accompanied Etherton, not knowing that Etherton intended to obtain cocaine; that, in Detroit, Etherton left him alone at a restaurant for 45 minutes; and that, while returning to Grand Rapids, Etherton revealed he had obtained the drugs. Officers described the content of the tip; on the third recounting, Etherton’s counsel objected on hearsay grounds. The prosecutor agreed to move on, but, at closing, again described the tip. The court instructed the jury that “the tip was not evidence,” but was admitted “only to show why the police did what they did.” Etherton’s conviction was affirmed. State courts denied post-conviction relief, rejecting arguments that admission of the tip violated the Confrontation Clause; that counsel was ineffective for failing to object; and that appellate counsel was ineffective for failing to raise the Confrontation Clause and ineffective assistance claims. The Sixth Circuit reversed denial of federal habeas relief. The Supreme Court reversed, citing the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254(d)(1) standard of review. A “fairminded jurist” could conclude that repetition of the tip did not establish that the uncontested facts it conveyed were submitted for their truth and that Etherton was not prejudiced when the tip and Pollie’s testimony corresponded on uncontested facts. It would not be objectively unreasonable for a fair-minded judge to conclude that failure to raise a challenge was because the facts in the tip were uncontested and consistent with Etherton’s defense. View "Woods v. Etherton" on Justia Law

Walber was murdered in 1998. Two years later, Scott, then incarcerated, contacted authorities and initially reported that Wearry and others had confessed to shooting and driving over Walber, leaving his body on Blahut Road. Walber had not been shot; his body was found on Crisp Road. Scott changed his story in material ways four times. Another witness, Brown, recanted a prior inconsistent statement and agreed to testify. The prosecution stated that Brown “is doing 15 years on a drug charge… hasn’t asked for a thing” and “has no deal on the table.” Although the state presented no physical evidence, it offered additional circumstantial, but somewhat inconsistent, evidence linking Wearry to Walber. Three women testified that Wearry had been at a wedding reception 40 miles away. The bride testified that the reception had ended around 9:00, potentially leaving time for Wearry to have committed the crime. Jail employees testified that they had overheard Wearry say that he was present at the crime. The jury convicted Wearry of capital murder and sentenced him to death. After unsuccessful direct appeal, it emerged that the prosecution had withheld police records showed that two inmates had made statements that cast doubt on Scott’s credibility and that, contrary to the prosecution’s assertions, Brown wanted a deal for testifying. Police had told Brown that they would “‘talk to the D. A..’” Wearry’s trial attorney admitted at the state collateral-review hearing that he had conducted no investigation. Collateral-review counsel found many witnesses lacking any personal relationship with Wearry to corroborate his alibi until 11 pm. The lower courts and the Louisiana Supreme Court denied relief. The U.S. Supreme Court reversed on the Brady claim, finding that the state withheld material evidence, and did not reach the ineffective assistance claim. View "Wearry v. Cain" on Justia Law

Under federal law, a court has discretion to “allow the prevailing party, other than the United States, a reasonable attorney’s fee” in a civil rights lawsuit filed under 42 U.S.C. 1983 or 42 U.S.C. 1988. The Supreme Court has interpreted section 1988 to permit a prevailing defendant to recover fees only if “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The Idaho Supreme Court concluded that it was not bound by that interpretation and awarded attorney’s fees under section 1988 to a prevailing defendant without first determining that “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The fee award rested solely on that court's interpretation of federal law; the court explicitly refused to award fees under state law. The Supreme Court reversed. Section 1988 is a federal statute; once the Supreme Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law. If state courts were permitted to disregard the Court’s rulings on federal law, “the laws, the treaties, and the constitution of the United States would be different in different states, and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two states." View "James v. Boise" on Justia Law

The 1995 Prison Litigation Reform Act provides that prisoners qualified to proceed in forma pauperis must pay an initial partial filing fee of “20 percent of the greater of ” the average monthly deposits in the prisoner’s account or the average monthly balance of the account over the preceding six months, 28 U.S.C. 1915(b)(1). They must pay the remainder in monthly installments of “20 percent of the preceding month’s income credited to the prisoner’s account.” The initial fee is assessed on a per-case basis and may not be exacted if the prisoner has no means to pay it; no monthly installments are required unless the prisoner has more than $10 in his account. Bruce, a federal inmate and a frequent litigant, argued that monthly payments do not become due until obligations previously incurred in other cases were satisfied. The D.C. Circuit disagreed, holding that Bruce’s monthly payments were due simultaneously with monthly payments for earlier cases. A unanimous Supreme Court affirmed. Section 1915(b)(2) calls for simultaneous, not sequential, recoupment of multiple monthly installment payments. The Court rejected Bruce’s reliance on the contrast between the singular “clerk” and the plural “fees” as those nouns appear in the statute, which requires payments to be forwarded “to the clerk of the court . . . until the filing fees are paid.” Section 1915’s text and context support the per-case approach. View "Bruce v. Samuels" on Justia Law

In 1997, Louisville police found the bodies of Malone and Warfield in their apartment. Malone had been stabbed. Warfield, then pregnant, had been strangled and scissors stuck out from her neck. Crime scene DNA matched Wheeler’s. During voir dire, Juror 638 gave equivocal answers about the death penalty, saying “I’m not sure that I have formed an opinion ... I believe there are arguments on both sides.” Asked about his ability to consider all available penalties, he noted he had “never been confronted with that situation in a, in a real-life sense of having to make that kind of determination.” “So it’s difficult … to judge how I would I guess act.” He agreed that he was “not absolutely certain whether [he] could realistically consider” the death penalty and described himself as “a bit more contemplative on the issue of taking a life and, uh, whether or not we have the right to take that life.” Later, however, he stated that he could consider all the penalty options. The court granted a prosecution motion to strike Juror 638 for cause based on his inconsistent replies. Wheeler was convicted and sentenced to death. The Kentucky Supreme Court affirmed, holding that the judge “appropriately struck for cause those jurors that could not impose the death penalty.” After exhausting state postconviction procedures, Wheeler unsuccessfully sought habeas corpus (28 U.S.C. 2254). The Sixth Circuit reversed, granting relief as to Wheeler’s sentence. The Supreme Court reversed. The Kentucky Supreme Court was not unreasonable in its application of clearly established federal law in concluding that Juror 638's exclusion did not violate the Sixth Amendment. View "White v. Wheeler" on Justia Law