Justia Civil Rights Opinion Summaries

Hill filed suit in state court, asking a judge to compel Young, his prison’s warden, to mail two complaints that Hill wanted to file in federal court. The defendants removed Hill’s suit to federal court. The district judge dismissed the complaint, observing that its records showed that the two complaints at issue had been filed.At Hill’s request, the Seventh Circuit vacated language from the judgment: “This dismissal shall count as one of [Hill’s] allotted ‘strikes’ under" 28 U.S.C. 1915(g). This statute provides: In no event shall a prisoner bring a civil action or appeal ... under this section if the prisoner has, on 3 or more prior occasions, while incarcerated or detained ... brought an action or appeal in a court of the United States that was dismissed" as frivolous, malicious, or failing to state a claim unless the prisoner is under imminent danger of serious physical injury.Section 1915(g) requires prepayment of the docket fees only if the plaintiff has thrice “brought an action or appeal in a court of the United States” decided on one of the listed grounds. Hill did not “bring” this suit in a court of the United States. Defendants brought it to federal court under 28 U.S.C. 1441(a). This suit does not count as a “strike.” While the comment is dicta and is not binding in future litigation, it aggrieves Hill by drawing a future judge’s attention to this suit. View "Hill v. Madison County" on Justia Law

In 2014-2016, Onamuti, a Nigerian citizen, led an identity-theft ring responsible for filing almost 1,500 tax returns and netting $5 million in illicit refunds. Charged with 11 counts of presenting false claims, 18 U.S.C. 287, nine counts of identity theft, section 1028(a)(7), two counts of aggravated identity theft, section 1028A, and conspiracy to defraud the government, section 371, Onamuti pleaded guilty to one count each of false claims, identity theft, and aggravated identity theft. Onamuti expressly acknowledged that, while his plea “may have consequences” for his immigration status, he wanted to accept responsibility. He certified that he had read the agreement, discussed it with his attorney, and understood its terms. Onamuti also “expressly waive[d]” the right to appeal “on any ground” except a claim alleging the ineffective assistance of counsel. During his plea colloquy, Onamuti confirmed under oath that, by pleading guilty, he “may very well be deported” and that he was waiving his appellate rights. The district court sentenced him to 204 months’ imprisonment.Onamuti sought to withdraw his plea, arguing that his lawyer failed to advise him that his convictions would subject him to mandatory deportation. The district court denied the motion without an evidentiary hearing. The Seventh Circuit dismissed his appeal without addressing the merits. Onamuti is bound by the waiver of appeal. The court noted that “almost invariably, defendants are better served by pursuing such claims on collateral review under 28 U.S.C. 2254 or 2255.” View "United States v. Onamuti" on Justia Law

Knudtson worked for Trempealeau County for over 45 years. She eventually became a paralegal/office manager in the District Attorney’s Office. When his friend, the Jackson County District Attorney, died, McMahon, the Trempealeau County District Attorney, closed his office for a day and encouraged his staff to attend the funeral. Knudtson refused to attend because she wanted to complete work at the office. McMahon offered Knudtson three choices: work from home, attend the funeral, or take a vacation day. The disagreement became a bitter dispute. The County placed Knudtson on paid leave. Knudtson declined another position at the same pay grade. The County had no other available position and terminated her employment.Knudtson filed suit, citing the Establishment Clause because the funeral took place at a church and involved a religious service. The Seventh Circuit affirmed summary judgment in favor of the defendants. Knudtson acknowledged that when she stated that she did not want to attend the funeral, she did not know that it would be a religious service; her decision not to attend had nothing to do with its religious nature. Organizing a delegation from a public office to attend a funeral normally raises no implication that the government, or any officials, endorse the deceased person's religion. View "Knudtson v. Trempealeau County" on Justia Law

The Cook County Jail houses primarily people who have not yet been convicted. Under the jail’s “paper triage” policy, a detainee who has dental pain and wants treatment must submit a health service request form (HSRF). Staff review the HSRF and categorize it as “routine,” “priority,” or “urgent.” The detainee is referred to a dentist for treatment in three to 30 days, depending on the categorization. Most detainees do not receive a face-to-face assessment from a nurse or higher-level practitioner before they see a dentist. An assessment could identify bona fide complaints of dental pain or reveal serious medical issues and would allow a nurse to dispense over-the-counter pain medication.McFields, a former detainee, filed a putative class action, alleging that detainees suffered gratuitous pain as a result of the paper triage policy. They alleged that the standard of care for processing a health service request requires a face-to-face assessment within 48 hours and that the jail’s policy is objectively unreasonable. The Seventh Circuit affirmed the denial of class certification, noting that each detainee presents a different situation that involved a different type of pain, took place at a different time, and involved different medical professionals and prison staff. McFields failed to satisfy the commonality and typicality requirements of Rule 23. Individual issues predominate over common questions. View "McFields v. Dart" on Justia Law

Williams, a Chicago school social worker, suffers from depression, anxiety, and chronic sinusitis. For the 2013–14 school year, Williams received an evaluation score that placed him in the “developing” category, and was given a Professional Development Plan. Social workers' hours depend on the school they are serving on a particular day. The Board denied Williams's first accommodation request, for consistent work hours. During the 2014–15 school year, Williams was cited for interrupting a teacher, failing to read a student’s individual educational plan before a meeting, speaking inappropriately about his personal life, making personal calls during school hours, and failing to report to work. Williams was twice denied titles that may be awarded to “proficient” social workers. Williams filed a discrimination charge and another accommodation request, seeking a consistent start time, a reduced caseload, and assignment to a single school. The Board denied these requests but assigned him to schools with 7:45 a.m. start times. Williams's third accommodation request sought a private office, dedicated equipment, and exemption from evaluations. The Board supplied Williams with HEPA filters, computer monitors, and access to a private meeting space; it denied his other requests. Williams was not selected for special assessment teams because he did not have the “proficient” rating and was not bilingual. He filed his second charge of discrimination.The Seventh Circuit affirmed the dismissal of his suit under the Americans with Disabilities Act. 42 U.S.C. 12101, and Title VII, 42 U.S.C. 2000e, rejecting claims that the Board discriminated against Williams because of his disability and gender, failed to accommodate his disability, and retaliated against him for filing discrimination claims. View "Williams v. Board of Education of the City of Chicago" on Justia Law

Donald has glaucoma and keratoconus, a thinning of the cornea that causes distorted vision. To treat his keratoconus, Donald had left-eye corneal transplant surgery in 2011. A few years later, Donald was convicted of drug crimes. He began his prison sentence at Illinois River Correctional Facility in 2014. His eye problems started flaring up, causing redness and poor vision. He was subsequently seen by Illinois River’s optometrists and at Illinois Eye Center several times. Ultimately, he was diagnosed with a rupture of the globe, an irreversible loss of vision in his left eye. After surgery, pathological tests revealed that the infection that led to the ruptured globe was caused by bacteria that can act very quickly and cause perforation in as few as 72 hours. Donald filed suit under 42 U.S.C. 1983 for deliberate indifference to a serious medical need.The district court granted the defendants summary judgment. The Seventh Circuit affirmed. The undisputed evidence shows that the defendants did not act with deliberate indifference toward an objectively serious medical condition and the district court appropriately exercised supplemental jurisdiction to dispose of the malpractice claim. View "Donald v. Wexford Health Sources, Inc." on Justia Law

In 2016 agents found Barrett with nearly 15,000 images and 2,450 videos of child pornography. A search of his computer also uncovered a “Pedophile’s Handbook.” Barrett pled guilty to possessing child pornography under a plea agreement with a provision waiving any appellate challenge “on any ground” to “all components” of his sentence. Barrett confirmed that he understood the waiver during his plea colloquy. The district court sentenced Barrett to 97 months’ imprisonment followed by 10 years of supervised release. Barrett brought a First Amendment challenge to “Condition 31” of supervised release that will prevent him from viewing any material depicting “sexually explicit conduct,” defined in 18 U.S.C. 2256(2) to include adult pornography.The Seventh Circuit affirmed Barrett’s sentence, citing its previously-announced “clear and precise rule” that such conduct constitutes waiver, rendering the challenge unreviewable on appeal. Barrett confirmed at sentencing that he received advance notice of all 34 proposed conditions of supervised release and discussed them with his counsel. The district court invited objections; Barrett responded with several. The objections resulted in a colloquy with the judge and ended with rulings on each challenge. Barrett expressed no reservation with and asked no questions about, Condition 31. That Barrett asserts the First Amendment is irrelevant. View "United States v. Barrett" on Justia Law

In 1995, Sanders, age 15, forcibly entered his victims’ homes while they slept, suffocated and raped them, and then robbed them. His youngest victim lived in a foster home. Another had given birth only a few weeks earlier. Sanders admitted that he committed his crimes near the first of the month, believing the victims would have just received public assistance checks. Fingerprints recovered from three homes led the police to Sanders. Charged as an adult with five counts of sexual assault and one count of armed robbery, Sanders entered an Alford plea. Wisconsin courts rejected Sanders’s argument that his Alford plea was not knowing, intelligent, and voluntary, then denied post‐conviction relief, rejecting ineffective assistance claims.In 2011, Sanders, who will be eligible for parole in 2030, sought federal habeas relief, 28 U.S.C. 2254, reviving his challenge to his Alford plea, and arguing that his sentence did not conform with the Supreme Court’s 2010 "Graham" holding, which requires that states give juvenile nonhomicide offenders “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation,” and that the sentencing court violated the Eighth Amendment by not considering his youth in sentencing him. The Seventh Circuit affirmed the denial of relief. Sanders, who will be eligible for parole in his early 50s, has not been denied a meaningful opportunity for release under the rule announced by the Supreme Court. View "Sanders v. Eckstein" on Justia Law

Dunn slapped Schuckman in a bar's parking lot, causing him to fall to the ground. Witnesses reported seeing Schuckman upright and apparently unharmed afterward. Hours later, Schuckman was found dead on the bar’s patio. Dunn and Crochet were charged with felony murder, battery, and theft from a corpse. Dunn’s counsel consulted with a forensic pathologist. After viewing the medical examiner’s report, the pathologist believed that Schuckman died immediately from his head injuries—suggesting that Dunn’s slap could not have caused his death. Before trial, defense counsel repeatedly, erroneously, stated that the medical examiner had concluded that Schuckman died immediately from a fatal blow and would testify to that at trial. The medical examiner’s report did not contain such conclusions and counsel never confirmed them. The prosecutor informed Dunn’s counsel that Crochet had retained experts, who were going to produce reports that bolstered Dunn’s no-causation defense. The prosecution considered the reports exculpatory. Dunn’s counsel did not ask for a continuance or attempt to view the reports. At trial, defense counsel did not call his forensic pathologist as a witness. The medical examiner testified that there was no reason to think that Schuckman would have died immediately from the fatal head injury, and it would have been possible for Schuckman to move after sustaining this injury.The Seventh Circuit upheld an order granting federal habeas relief. Dunn’s trial counsel provided ineffective assistance by failing to investigate and offer evidence to support a no-causation defense and Dunn was prejudiced by that deficient performance. View "Dunn v. Jess" on Justia Law

Anderson participated in an Illinois conspiracy to distribute heroin that included a dealer, Mansini. In 2012, Reader, a 21-year-old addict, purchased and used heroin from another dealer. Later that day, Reader purchased an additional half-gram of heroin from Mansini, who had obtained it from Anderson. Reader used that heroin and was found dead that evening. According to the coroner’s report, the cause of death was “opiate intoxication.” The report did not attribute Reader’s death to one particular heroin dose or make findings on the incremental effects of other drugs. Anderson and others were charged with conspiracy to distribute heroin, 21 U.S.C. 841(a)(1), 841(b)(1)(A), 846. Three defendants, including Anderson, pleaded guilty. Anderson admitted to distributing the heroin that resulted in Reader’s death, which carried a mandatory minimum sentence of 20 years imprisonment and a maximum sentence of life imprisonment. Anderson concurred with the plea agreement’s factual statements but told the court that he might have a factual defense to Reader’s death because Reader had bought heroin from other sources and used prescription drugs. The court sentenced him to 223 months’ imprisonment.Anderson's 28 U.S.C. 2255 petition claimed ineffective assistance of counsel because his counsel did not adequately investigate the cause of Reader’s death and advise Anderson of the “but-for” causation standard articulated by the Supreme Court in 2014. Counsel responded that Anderson authorized her to proceed with plea negotiations without hiring a medical examiner and she was “not trained to interpret toxicology results” and “never discussed” the toxicology evidence with anyone who had relevant training. The Seventh Circuit vacated a denial of relief. Anderson was entitled to an evidentiary hearing on his claim of ineffective assistance of counsel. View "Anderson v. United States" on Justia Law