Justia Civil Rights Opinion Summaries

Cedric Allen Ricks was convicted of capital murder in Texas state court for killing his girlfriend and her eight-year-old son and was sentenced to death. After his direct appeal and state habeas petition were denied, Ricks filed a federal habeas petition, which the district court also denied, including a certificate of appealability (COA).Ricks sought a COA from the United States Court of Appeals for the Fifth Circuit on several claims. The district court had denied his Batson claim, which alleged racial discrimination in jury selection, finding no prima facie case of discrimination and accepting the prosecution's race-neutral justifications. The district court also found no pattern of racially disparate questioning. The Fifth Circuit agreed, noting that reasonable jurists would not find the district court's assessment debatable or wrong, and thus denied the COA on this claim.Ricks also claimed ineffective assistance of appellate counsel for not raising the Batson claim on appeal. The state court had denied this claim on the merits. The Fifth Circuit found that since the Batson claim was meritless, the appellate counsel's failure to raise it was neither unreasonable nor prejudicial, and denied the COA on this claim as well.Ricks argued that his due process rights were violated when the jury saw him in shackles. The district court rejected this claim, noting that Ricks exposed his shackles himself and failed to show any substantial influence on the jury's verdict. The Fifth Circuit found this claim procedurally defaulted because it was not raised on direct appeal and was barred by the Texas Court of Criminal Appeals. Consequently, no COA was issued for this claim.Lastly, Ricks claimed ineffective assistance of trial counsel for not objecting to the shackling and for not challenging the State's peremptory strikes against female venire members. The Fifth Circuit found the trial counsel's decisions reasonable and strategic, and thus denied the COA on these claims.The Fifth Circuit denied the motion for a COA on all claims. View "Ricks v. Lumpkin" on Justia Law

Benjamin Benfer and his wife were pulled over by Officer Barry Calvert for allegedly running a red light and because their vehicle matched the description of a stolen car. A confrontation ensued, during which Calvert used his K-9 to subdue Benfer. Both Benfer and his wife were arrested and charged with resisting arrest and interference with public duties, but the charges were later dismissed.Benfer filed a lawsuit against Calvert and the City of Baytown under 42 U.S.C. § 1983 and state law, claiming violations of his constitutional rights and state tort claims. The United States District Court for the Southern District of Texas dismissed the case, ruling that Calvert did not violate Benfer’s constitutional rights, that Benfer’s state tort claims were not valid under Texas law, and that Benfer did not provide sufficient facts to support his claims against the City under Monell v. Department of Social Services.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that Calvert had reasonable suspicion to stop Benfer, probable cause to arrest him for resisting arrest, and did not use excessive force in deploying his K-9. The court also found that Benfer’s state law assault claim against Calvert was barred by the Texas Tort Claims Act, which requires such claims to be brought against the municipality, not the individual officer. Additionally, the court ruled that Benfer failed to provide sufficient evidence to support his claims against the City of Baytown for inadequate policies, failure to train, and ratification of Calvert’s conduct. View "Benfer v. City of Baytown" on Justia Law

In 2016, the United States Department of Justice (DOJ) sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act (CRIPA), alleging unconstitutional conditions in the County’s detention facilities, particularly the Raymond Detention Center (RDC). The DOJ and the County entered into a consent decree to improve conditions, but disputes over compliance led to the DOJ alleging the County's non-compliance and seeking contempt sanctions. The district court found the County in contempt twice and, after a hearing, issued a new, shorter injunction focused on RDC and appointed a receiver to oversee compliance.The United States District Court for the Southern District of Mississippi found ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, misuse of force, poor incident reporting, and over-detention. The court declined to terminate the consent decree, instead issuing a new injunction and appointing a receiver to manage RDC. The County appealed the new injunction and the receivership.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision to retain most of the injunction’s provisions, finding that the conditions at RDC constituted ongoing constitutional violations. However, the court found that the district court’s need-narrowness-intrusiveness analysis for the receivership was insufficient and that the receiver’s authority over the budget and financial matters was overly broad. The Fifth Circuit reversed the provisions related to the Prison Rape Elimination Act (PREA) and remanded the case for further proceedings to adjust the scope of the receivership and remove the PREA-related provisions. The court affirmed the district court’s decision in all other respects. View "United States v. Hinds County Board of Supervisors" on Justia Law

Marcus McVae was stopped by Texas State Trooper Jesse Perez for a traffic violation. McVae provided a false identity and fled on foot when the officer attempted to detain him. Despite being tased, McVae continued to flee, leading to a physical altercation with Trooper Perez. During the struggle, McVae threw a rock at Perez, who then fatally shot McVae. McVae’s parents sued Perez under 42 U.S.C. § 1983, claiming excessive force in violation of the Fourth Amendment.The United States District Court for the Western District of Texas granted summary judgment in favor of Trooper Perez, finding that he was entitled to qualified immunity. The court relied on body camera footage to support its decision, concluding that no genuine dispute of material fact existed regarding whether McVae posed an immediate threat to Perez.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Trooper Perez’s use of deadly force was reasonable under the circumstances. The court found that McVae’s actions, including throwing a rock at Perez, constituted a severe threat, justifying the use of deadly force. The court concluded that Perez did not violate McVae’s Fourth Amendment rights and was entitled to qualified immunity. View "McVae v. Perez" on Justia Law

A police officer, David Stanley, was suspended and transferred by the Lafayette Police Department (LPD) following an investigation into his Facebook posts. Stanley took sick leave for about a year and appealed his suspension to the Municipal Fire and Police Civil Service Board. He also filed two petitions in state court seeking to enjoin the suspension and transfer. The state district court granted a temporary restraining order (TRO), but the state appellate court dismissed LPD’s appeal of the TRO. Stanley re-filed his petition, but the state district court found he needed to finalize his appeal with the Civil Service Board first. The Civil Service Board later reduced his suspension but upheld his transfer.Stanley then filed a lawsuit in federal district court under 42 U.S.C. § 1983, alleging First Amendment violations and retaliation. The district court dismissed his claims as time-barred, determining that the one-year prescriptive period began when Stanley was notified of his suspension on June 11, 2021. The court also concluded that Stanley’s state court petitions did not interrupt the prescription period because they did not assert federal claims or seek monetary damages.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Stanley’s § 1983 claims accrued when he received notice of the adverse actions, not when the administrative appeal concluded. The court also found that Stanley’s state court petitions did not interrupt the prescription period because they did not provide adequate notice of his federal claims or demand monetary damages. Consequently, the Fifth Circuit affirmed the district court’s dismissal of Stanley’s claims as prescribed. View "Stanley v. Morgan" on Justia Law

The case involves a challenge to a Mississippi statute that allows absentee ballots to be received up to five days after the federal Election Day. The plaintiffs, including the Republican National Committee and the Mississippi Republican Party, argued that this state law conflicts with federal statutes that establish a uniform Election Day for federal elections. The plaintiffs sought to enjoin state officials from enforcing the post-election ballot deadline.The United States District Court for the Southern District of Mississippi consolidated two lawsuits and granted summary judgment in favor of the defendants, which included various state election officials. The district court held that Mississippi's statute did not conflict with federal law and thus was not preempted. The plaintiffs appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's judgment. The Fifth Circuit held that the federal Election Day statutes preempt Mississippi's law because federal law mandates that all ballots must be received by Election Day. The court emphasized that the term "election" includes both the casting and receipt of ballots, and that the election is not consummated until all ballots are received. The court also noted that historical practices and other federal statutes support this interpretation. The case was remanded for further proceedings to determine appropriate relief, considering the proximity to upcoming elections. The court also vacated the district court's summary judgment on the plaintiffs' § 1983 claims and remanded for reconsideration. View "Republican National Committee v. Wetzel" on Justia Law

In the early morning hours, Officer James Marshall observed Rodney Rucker sitting in a running car outside a hotel known for criminal activity. Marshall approached Rucker, who refused to identify himself or exit the vehicle. After additional officers arrived, they broke Rucker’s window, forcibly removed him, and arrested him. Rucker subsequently sued the officers under 42 U.S.C. § 1983, alleging unlawful seizure and arrest, First Amendment retaliation, excessive force, and bystander liability.The United States District Court for the Northern District of Mississippi denied the officers' motion for summary judgment on all claims, finding genuine disputes of material fact regarding the officers' reasonable suspicion, the alleged manufacturing of evidence, potential retaliation, and the reasonableness of the force used. The officers appealed, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and reversed the district court’s decision. The appellate court found that the bodycam footage clearly showed that Officer Marshall had reasonable suspicion to stop and question Rucker based on the time, location, and Rucker’s behavior. The court also determined that Marshall had probable cause to arrest Rucker for failing to comply with lawful commands and for operating a vehicle without displaying a driver’s license. Additionally, the court held that the officers did not use excessive force, as Rucker’s repeated refusals to comply justified their actions. Consequently, the officers were entitled to qualified immunity on all claims, including the bystander liability claim against Officer Carter. The case was remanded for entry of summary judgment in favor of the officers. View "Rucker v. Marshall" on Justia Law

In the early morning hours of July 10, 2018, Trooper Kasha Domingue stopped a vehicle. After the driver and another passenger fled, Clifton Scott Dilley exited the vehicle from the driver-side rear seat. The events that followed are disputed, but it is undisputed that Domingue shot Dilley, paralyzing him from the waist down. The incident was partially captured by a nearby security camera, which lacked audio. The footage shows Domingue pulling over the SUV, the driver exiting and interacting with Domingue, and then fleeing. Dilley then exited the vehicle, and Domingue shot him in the back.The Louisiana Department of Public Safety terminated Domingue for her actions, citing her failure to use her body camera and her false statements about the incident. Domingue initially claimed she used a taser and later fabricated a story about her defensive posture during the shooting. The Louisiana State Use of Force Board found that Domingue violated multiple policies and committed criminal negligence. She was charged with aggravated second-degree battery and illegal use of weapons, to which she pleaded guilty in 2022.Dilley sued Domingue under 42 U.S.C. § 1983 for using excessive force in violation of the Fourth Amendment. The United States District Court for the Middle District of Louisiana denied Domingue's motion for summary judgment, finding several disputes of material fact and denying her qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that officers cannot use deadly force against a fleeing suspect who poses no immediate threat. Given the numerous factual disputes, including Domingue's inconsistent statements and the video evidence, the court found that a jury could reasonably conclude that Domingue violated clearly established law by shooting an unarmed and nonthreatening Dilley in the back without warning. The denial of qualified immunity was affirmed. View "Dilley v. Domingue" on Justia Law

Steve Winder became suicidal after discovering Facebook messages between his wife and her ex-husband. His wife, Latrisha, who was out of state, called her mother, Lou Anne, and the Young County Sheriff’s Department for a welfare check after Steve sent pictures of himself holding a gun to his head. Deputy Joshua Gallardo arrived at the scene, and after hearing Steve shout from within, opened the front door. Lou Anne indicated that Steve was armed. Deputy Gallardo then fatally shot Steve after ordering him to put the gun down.The United States District Court for the Northern District of Texas dismissed the case at the 12(b)(6) stage. The court found that Steve’s suicidality and possession of a gun created exigent circumstances excusing the need for a warrant. It also ruled that an objectively reasonable officer in Deputy Gallardo’s position would not need to wait for Steve to point the gun at him before using deadly force, thus defeating the excessive force claim. Additionally, the court found no underlying constitutional violation to support claims for supervisory or Monell liability and ruled that Title II of the ADA does not support claims where police officers face exigent circumstances.The United States Court of Appeals for the Fifth Circuit affirmed the District Court’s dismissal. The appellate court held that the exigent circumstances justified the warrantless entry and that Deputy Gallardo’s use of deadly force was reasonable under the circumstances. The court also found no basis for supervisory or Monell liability due to the absence of an underlying constitutional violation. Lastly, the court ruled that the ADA claims were foreclosed by the exigent circumstances and that there was no evidence that Steve was discriminated against by reason of his disability. View "Winder v. Gallardo" on Justia Law

Marc and Augustus Degenhardt alleged that Corpus Christi Police Lieutenant Phillip Bintliff unlawfully initiated a traffic stop and that Bintliff and Officer Armando Cisneros unlawfully searched and towed their vehicle, retaliating against them for engaging in protected speech. The incident occurred when Marc, driving a Dodge Challenger with Augustus as a passenger, was stopped by Bintliff, who accused Marc of reckless driving and racing another vehicle. During the stop, Cisneros arrived and observed an open box of White Claw Hard Seltzers in the car. The officers ordered the brothers out of the car, conducted a search, and impounded the vehicle, charging them with minor alcohol possession and issuing a reckless driving warning. The charges were later dropped.The United States District Court for the Southern District of Texas dismissed the suit, finding that the officers had probable cause to search the vehicle and that the officers were entitled to qualified immunity for the remaining claims. The Degenhardts appealed the dismissal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the Degenhardts had sufficiently alleged a Fourth Amendment violation regarding the initial traffic stop, as the complaint suggested that Bintliff lacked reasonable suspicion. However, the court agreed with the district court that the officers had probable cause to search the vehicle due to the visible alcohol. The court also found that the officers were entitled to qualified immunity for the claims related to the vehicle's impoundment and the alleged retaliation for protected speech.The Fifth Circuit affirmed the district court's dismissal in part, reversed in part, and remanded the case for further proceedings regarding the Fourth Amendment claim related to the traffic stop. View "Degenhardt v. Bintliff" on Justia Law