Justia Civil Rights Opinion Summaries

Derrick Patterson pleaded guilty to one count of Hobbs Act robbery and one count of identity theft. Patterson met his victim through Grindr, a dating application, and during their encounter, he took the victim’s phone and used it to withdraw money from the victim’s bank accounts.The United States District Court for the Central District of California sentenced Patterson to 111 months in prison, including a three-level enhancement for hate crime motivation under U.S.S.G. § 3A1.1. The district court rejected Patterson’s argument that the enhancement required a finding that he was motivated by hate. Patterson appealed the sentence.The United States Court of Appeals for the Ninth Circuit reviewed the case and agreed with Patterson that the language of the enhancement was ambiguous. The court held that the enhancement requires a finding beyond a reasonable doubt that the defendant was motivated by hate or animus. The court concluded that the district court erred by imposing the enhancement without such a finding. Consequently, the Ninth Circuit vacated Patterson’s sentence and remanded the case for resentencing. View "USA V. PATTERSON" on Justia Law

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

In 1991, an individual was convicted of multiple felonies related to a home invasion and rape, receiving a thirty-five-year prison sentence. In 2011, the conviction was vacated based on newly discovered DNA evidence that excluded the individual as the contributor of DNA found at the crime scene. The prosecution subsequently moved to dismiss the case with prejudice, which the court granted. In 2016, the individual filed a civil petition for compensation under Hawai‘i’s wrongful conviction compensation statute, HRS chapter 661B.The Circuit Court of the Second Circuit held that the individual failed to allege an actionable claim because the order vacating the conviction did not explicitly state that he was “actually innocent.” The court granted summary judgment in favor of the State, concluding that the individual did not meet the statutory requirements for compensation.The Supreme Court of the State of Hawai‘i reviewed the case. It held that HRS § 661B-1 does not require the exact words “actually innocent” to be present in the vacatur order. Instead, the order must state facts supporting the petitioner’s actual innocence. The court found that the vacatur order, which was based on exculpatory DNA evidence, met this standard. Therefore, the individual presented an actionable claim for relief under HRS chapter 661B.The Supreme Court vacated the Circuit Court’s grant of summary judgment to the State and remanded the case for a trial to determine whether the individual is actually innocent and entitled to compensation under the statute. The court emphasized that the trial should follow the procedures outlined in HRS § 661B-2 and HRS § 661B-3. View "Jardine v. State" 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

William Webb, an inmate at James T. Vaughn Correctional Center (JTVCC) in Delaware, sued prison officials for failing to schedule court-ordered visits with his daughter. A Delaware family court had granted Webb visitation rights in October 2020, but since then, only one visit occurred in 2021, lasting fifteen minutes and concluding without incident. Webb filed a grievance through the prison’s internal process, which was returned unprocessed. He then wrote to three prison officials but received inadequate responses. Webb, representing himself, filed a lawsuit alleging that prison officials violated his constitutional right to reunification with his daughter.The United States District Court for the District of Delaware dismissed Webb’s complaint under the screening provisions of 28 U.S.C. §§ 1915A(b) and 1915(e)(2)(B). The court held that Webb failed to exhaust JTVCC’s internal grievance process and did not state a valid constitutional claim. The court also determined that allowing Webb to amend his complaint would be futile.The United States Court of Appeals for the Third Circuit reviewed the case. The court first addressed the timeliness of Webb’s appeal, applying the prison mailbox rule to JTVCC’s electronic filing system. The court held that Webb’s notice of appeal was timely filed when he placed it in the designated mailbox on November 22, 2022. On the merits, the court found that Webb’s complaint did not definitively show a failure to exhaust administrative remedies and plausibly alleged a constitutional claim under the First and Fourteenth Amendments. The court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Webb v. Department of Justice" on Justia Law

In this case, the plaintiff alleged that a Montana Probation Officer used excessive force during an encounter in a parking lot. The incident was captured by surveillance footage, which was later auto-deleted. Despite efforts to preserve the footage, the State failed to do so, leading to the plaintiff's motion for sanctions against the State for the loss of evidence.The United States District Court for the District of Montana found that the State acted recklessly in failing to preserve the footage but did not act with gross negligence or willfulness. Invoking its inherent authority, the district court sanctioned the State by instructing the jury that it was established as a matter of law that the officer used excessive force. The jury awarded the plaintiff $75,000 in damages for the excessive-force claim.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court committed legal error by relying on its inherent authority to impose sanctions. The appellate court determined that Federal Rule of Civil Procedure 37(e) governs the loss of electronically stored information and the sanctions imposed. Rule 37(e)(2) allows for severe sanctions only if the party acted with the intent to deprive another party of the information's use in litigation. The district court's findings confirmed that no such intent was present, making the sanctions unlawful.As a result, the Ninth Circuit reversed the district court's sanctions orders, reversed the verdict and judgment against the probation officer, vacated the award of attorneys' fees to the plaintiff, and remanded the case for a new trial on the excessive-force claim. View "GREGORY V. STATE OF MONTANA" on Justia Law

In 2015, Brennan R. Trass was charged with first-degree felony murder and criminal possession of a firearm after killing Jose Morales during a drug deal. Trass admitted to the shooting, claiming self-defense. Before trial, the district court appointed multiple attorneys for Trass due to conflicts, causing significant delays. Two weeks before the trial in 2019, the court allowed Trass' attorneys to withdraw due to a conflict and ordered Trass to represent himself with standby counsel. During the trial, Trass was removed from the courtroom for refusing to participate, and his standby counsel took over. The jury convicted Trass.The Reno District Court initially handled the case, where Trass faced multiple attorney changes and delays. Trass filed a direct appeal, and the Kansas Supreme Court remanded the case to the district court to determine the feasibility of a retrospective competency hearing. The district court found Trass competent before and during his 2019 trial. Trass raised several issues on appeal, including violations of his right to counsel, speedy trial rights, and sufficiency of evidence.The Kansas Supreme Court reviewed the case and found that the district court violated Trass' Sixth Amendment right to counsel by forcing him to represent himself without proper advisories or warnings about the dangers of self-representation. The court concluded that Trass did not waive his right to counsel knowingly and intelligently, nor did he forfeit it through egregious misconduct. The violation of Trass' right to counsel constituted structural error, requiring automatic reversal of his convictions. The court also found no violation of Trass' statutory right to a speedy trial and sufficient evidence to support his felony-murder conviction. The case was reversed and remanded for a new trial before a different judge. View "State v. Trass" on Justia Law

The Tuscaloosa City Council passed an ordinance limiting the maximum occupancy of certain restaurants, affecting a sports bar owned by CMB Holdings Group. The ordinance required establishments with restaurant liquor licenses to maintain occupancy limits based on their configuration as restaurants, not as bars or entertainment venues. This change reduced the sports bar's maximum occupancy from 519 to 287, negatively impacting its revenue. CMB Holdings Group sued the City of Tuscaloosa, the mayor, city council members, and the fire marshal, alleging racial discrimination and other claims.The Tuscaloosa Circuit Court dismissed most of CMB's claims, including those for money damages against the City and personal-capacity claims against the mayor and councilors due to legislative immunity. The court also dismissed claims for procedural and substantive due process, equal protection, and others, leaving only claims for declaratory and injunctive relief under the Alabama Constitution's Contracts Clause. CMB requested the court to alter or amend its judgment or certify it as final for appeal purposes. The court denied the request to alter or amend but granted the Rule 54(b) certification, allowing CMB to appeal the dismissed claims.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court found that the adjudicated and unadjudicated claims were closely intertwined, particularly regarding whether the ordinance affected vested rights or mere privileges and whether it served a legitimate public interest. The court concluded that separate adjudication could lead to inconsistent results and dismissed the appeal for lack of a final judgment. View "CMB Holdings Groupv. City of Tuscaloosa" on Justia Law

Lucas Montel Howard, while detained in the Madison County jail, directed his friend Alissia Washington to purchase crack cocaine from a dealer. Law enforcement monitored their phone calls, and when Washington returned with the drugs, she was pulled over and instructed by Howard to hide the cocaine in her vagina. The drugs were later discovered during a search at the police department, leading to Howard and Washington’s indictment on felony drug charges. Washington entered a best-interest plea, while Howard went to trial and was found guilty of possession of cocaine with intent to sell and conspiracy to possess cocaine with intent to sell.The Madison County Circuit Court sentenced Howard as a nonviolent habitual offender and subsequent drug offender to sixty years for possession with intent to sell and twenty years for conspiracy, to run concurrently. Howard appealed, arguing insufficient evidence of intent to sell, a Confrontation Clause violation, double jeopardy, improper admission of Washington’s guilty plea, prosecutorial misconduct, ineffective assistance of counsel, and a sleeping juror issue.The Supreme Court of Mississippi reviewed the case and found that the evidence, including Howard’s phone calls and prior convictions, sufficiently supported the jury’s findings of intent to sell and conspiracy. The court held that the trial court did not abuse its discretion in limiting cross-examination or in handling the sleeping juror issue. The court also found no merit in Howard’s claims of double jeopardy, prosecutorial misconduct, or ineffective assistance of counsel. The cumulative error doctrine was deemed inapplicable as no errors were identified. Consequently, the Supreme Court of Mississippi affirmed Howard’s convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

In 1998, Khyle Armando Briscoe, then 21, participated in a robbery with Shaun P. During the robbery, Briscoe and Shaun P. both had guns. A struggle ensued, resulting in Ben P., the robbery victim, fatally shooting Shaun P. Briscoe was charged with first-degree murder, robbery, and burglary, with firearm-use enhancements and a special circumstance of murder during a robbery and burglary. A jury convicted Briscoe on all counts, and he was sentenced to life without parole.Briscoe filed a motion in 2022 for a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. He argued that this exclusion violated equal protection under the California and U.S. Constitutions. The trial court denied his motion, adhering to the majority view that section 3051 did not violate equal protection. Briscoe appealed.The California Court of Appeal, First Appellate District, reviewed the case. The court noted that section 3051’s exclusion of youth offenders sentenced to life without parole for special circumstance murder was previously upheld in People v. Hardin. However, Briscoe raised a narrower challenge, arguing that excluding youth offenders sentenced under section 190.2, subdivision (d) for special circumstance murder, while including those convicted of first-degree felony murder under section 189, subdivision (e)(3), violated equal protection. The court agreed, finding no rational basis for treating these equally culpable offenders differently.The court reversed the trial court’s order and remanded the case for a Franklin proceeding and a section 3051 parole hearing, holding that section 3051’s exclusion of youth offenders sentenced under section 190.2, subdivision (d) for murder during a robbery or burglary violated equal protection. View "People v. Briscoe" on Justia Law