Justia Civil Rights Opinion Summaries

Dezmon Moore, a police officer with the Louisville Metro Police Department (LMPD), was terminated after the Chief of Police found he had committed three violations of the department's Standard Operating Procedures (SOPs). These violations stemmed from incidents involving domestic altercations with his wife, Bethel Moore, which led to multiple arrests and charges, including assault and violation of a no-contact order. Moore's criminal charges related to these incidents were eventually dismissed or expunged.Moore appealed his termination to the Louisville Metro Police Merit Board, which upheld the termination after finding he had committed two of the three SOP violations. The Jefferson Circuit Court affirmed the Merit Board's decision, and the Court of Appeals also affirmed, though it noted errors in the Merit Board's consideration of expunged materials and transcribed witness statements without cross-examination. However, the Court of Appeals deemed these errors harmless.The Supreme Court of Kentucky reviewed the case. The Court held that the Merit Board did not violate Moore's statutory or constitutional due process rights by considering transcribed witness statements without live testimony and cross-examination. The Court found that the statutes governing the Merit Board provided sufficient procedural safeguards, including the opportunity for Moore to subpoena witnesses. The Court also determined that the expungement statutes did not apply to the internal employment records of the LMPD's Professional Standards Unit (PSU), and thus, the Merit Board did not err in considering those materials.Finally, the Court held that Moore's termination was not arbitrary, even though it was based on arrests and charges rather than convictions. The Chief's decision was supported by proper evidence, and the Merit Board's affirmation of the termination was justified. The Supreme Court of Kentucky affirmed the decision of the Court of Appeals. View "LOUISVILLE/JEFFERSON COUNTY METROPOLITAN GOVERNMENT V. MOORE" on Justia Law

Sara Caruso, a flight attendant for Delta Air Lines, failed a breathalyzer test on August 4, 2018, after a layover in Dallas, Texas. Caruso claimed she was drugged and sexually assaulted by Delta First Officer James Lucas the night before. The Dallas Police Department found insufficient evidence to support her claim, and Delta also took no action against Lucas after its investigation. Caruso completed an alcohol rehabilitation program and sought accommodations from Delta for PTSD related to the alleged assault. Although Delta and Caruso initially agreed on accommodations, Caruso resigned after a month back at work.Caruso sued Delta in Massachusetts state court, alleging violations of Massachusetts General Laws chapter 151B, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA). The case was removed to the U.S. District Court for the District of Massachusetts, which granted summary judgment for Delta on all counts. The court found no causal connection between Delta's actions and the alleged harassment and determined that Delta responded reasonably to the allegations. Additionally, Caruso's disability discrimination claims failed because she did not engage in an interactive process in good faith with Delta to develop reasonable accommodations.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Caruso failed to show a causal connection between Delta's actions and the alleged harassment, and that Delta's investigation and response were reasonable. The court also found that Caruso did not cooperate in the interactive process for her disability accommodations, and her retaliation claims were either waived or undeveloped. Thus, the summary judgment for Delta was affirmed on all counts. View "Caruso v. Delta Air Lines, Inc." on Justia Law

Eddie Sorto was sentenced to over 100 years in prison for crimes committed at age 15, including first-degree murder, second-degree murder, assault, and shooting at an occupied vehicle. The jury found multiple special-circumstance allegations and enhancements true. After serving 15 years, Sorto petitioned for recall and resentencing under Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and thus entitled him to relief under equal protection principles.The Superior Court of Los Angeles County denied Sorto’s petition, stating that he was not eligible for relief under section 1170(d) because he had not been sentenced to an explicit LWOP term. The court did not address Sorto’s equal protection argument directly but noted that he was eligible for parole after 25 years under section 3051, which it found sufficient to deny the petition.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. The court held that juvenile offenders sentenced to functionally equivalent LWOP terms are entitled to relief under section 1170(d) based on equal protection guarantees. The court rejected the Attorney General’s argument that the case People v. Heard was wrongly decided and contrary to California Supreme Court precedent. The court also held that parole eligibility under section 3051 does not render offenders ineligible for relief under section 1170(d).The Court of Appeal reversed the trial court’s denial of Sorto’s petition and remanded the case for the lower court to consider whether Sorto meets the other requirements for relief under section 1170(d). View "People v. Sorto" on Justia Law

In 2016, John O. Kalu, an inmate at FCI Allenwood, alleged that he was sexually assaulted on three separate occasions by Lieutenant K. Middernatch. Kalu reported the first two incidents to Warden Spaulding, who responded that he would investigate but took no further action. Following his report, Kalu was placed in the Special Housing Unit (SHU) and later returned to the general population, where he was assaulted a third time. Kalu also claimed that he was subjected to inhumane conditions of confinement, including being forced to sleep on a cold metal bunk in freezing temperatures without adequate clothing.Kalu filed a pro se complaint in the Middle District of Pennsylvania against Warden Spaulding and Lt. Middernatch, seeking damages under Bivens for violations of his Eighth Amendment rights. The District Court dismissed Kalu’s claims against Warden Spaulding for lack of personal involvement but allowed the sexual assault claim against Lt. Middernatch to proceed. Kalu later amended his complaint, but the District Court ultimately dismissed all claims, determining that they presented new Bivens contexts and that special factors counseled against extending Bivens remedies.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s dismissal. The court held that Kalu’s Eighth Amendment sexual assault and conditions-of-confinement claims presented new Bivens contexts. It found that special factors, including the availability of alternative remedies through the Bureau of Prisons’ Administrative Remedy Program, Congress’s omission of a standalone damages remedy in the Prison Litigation Reform Act (PLRA) and the Prison Rape Elimination Act (PREA), and separation of powers principles, counseled against extending Bivens liability. The court also agreed that Kalu’s complaint failed to allege sufficient facts to establish a plausible claim against Warden Spaulding for deliberate indifference or failure to protect. View "Kalu v. Spaulding" on Justia Law

Rebecca Adeyanju, a White woman, was employed by Foot and Ankle Associates of Maine, P.A. as a medical assistant and radiology technician since 2012. In 2018, she married a Black man from Nigeria. In August 2019, Adeyanju missed three consecutive workdays to assist her husband, who was being sought by ICE agents. She informed her employer of her absences via text messages. Upon returning to work, she was terminated for "job abandonment" due to her three-day absence.The Superior Court (Cumberland County) granted summary judgment in favor of Foot and Ankle Associates, concluding that Adeyanju failed to show sufficient evidence that her termination was motivated by discriminatory animus or that the stated reason for her termination was pretextual. Adeyanju appealed the decision.The Maine Supreme Judicial Court reviewed the case de novo. The court found that the summary judgment record, viewed in the light most favorable to Adeyanju, revealed genuine issues of material fact. These included inconsistencies in the employer's enforcement of its attendance policy, differential treatment of employees with similar absences, and potential racial animus linked to the involvement of ICE. The court concluded that these issues warranted a trial to determine whether the termination was indeed motivated by discriminatory animus or if the employer's stated reason was pretextual.The Maine Supreme Judicial Court vacated the summary judgment and remanded the case for trial, allowing Adeyanju to present her claims of employment discrimination under Title VII and 42 U.S.C. § 1981. View "Adeyanju v. Foot and Ankle Associates of Maine, P.A." on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

In 2000, Karl Roberts was convicted and sentenced to death in Arkansas state court for the rape and murder of his twelve-year-old niece. Roberts waived his right to challenge his conviction on direct appeal, in state postconviction proceedings, and in federal habeas corpus proceedings. Both the Arkansas state trial court and the Arkansas Supreme Court found the waiver to be knowing and voluntary. On the day of his scheduled execution in 2004, Roberts moved for a stay of execution, which was granted, and subsequently filed a petition for writ of habeas corpus, initiating two decades of litigation.The United States District Court for the Eastern District of Arkansas denied Roberts’s nineteen habeas corpus claims but granted a certificate of appealability (CoA) on three claims: whether Roberts was intellectually disabled, competent to be tried, and competent to waive his direct appeal. The Eighth Circuit expanded the CoA to include two ineffective assistance of counsel claims: failure to investigate and challenge Roberts’s competency to be tried and failure to investigate and present evidence of Roberts’s mental health as mitigating evidence at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s denial of Roberts’s habeas petition. The court held that the Arkansas courts’ findings that Roberts was not intellectually disabled, was competent to stand trial, and was competent to waive his direct appeal were reasonable and supported by the record. The court also found that Roberts’s trial counsel was not ineffective, as the counsel’s performance did not fall below an objective standard of reasonableness, and there was no prejudice to Roberts. The court concluded that Roberts failed to show that the outcome of his trial would have been different but for the alleged errors by his counsel. View "Roberts v. Payne" on Justia Law

Sha Kendrick Smith was convicted under 18 U.S.C. § 2422(b) for enticing a minor to engage in prostitution. The minor victim (MV) was a thirteen-year-old runaway who was a ward of the state. Smith provided MV with a cell phone and took her to various locations where she engaged in commercial sex with multiple men, with Smith keeping the money. MV initially told Smith she was eighteen, but he later learned she was underage. MV described Smith as always carrying a gun and being feared by those who knew him. Smith was eventually arrested after MV reported her situation to the police.The United States District Court for the Southern District of Texas sentenced Smith to 235 months of imprisonment and ten years of supervised release. The court applied two sentencing enhancements: one under U.S.S.G. § 2G1.3(b)(2)(B) for undue influence over the minor and another under U.S.S.G. § 3A1.1(b)(1) for MV’s status as a vulnerable victim. Smith objected to these enhancements, but the district court overruled his objections, adopting the presentence investigation report (PSR) and the government’s arguments.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s application of both sentencing enhancements. It found that the district court’s determination that Smith unduly influenced MV was plausible given the evidence of Smith’s control over MV, including his age, size, possession of a gun, and the fear he instilled in others. The court also upheld the vulnerable-victim enhancement, noting that MV’s age, status as a ward of the state, and economic desperation made her unusually vulnerable, and Smith knew or should have known of her vulnerabilities. The Fifth Circuit concluded that the district court did not commit clear error in its findings and affirmed Smith’s sentence. View "United States v. Smith" on Justia Law

Detective Frias of the Richmond Police Department observed an Instagram video showing known gang member J.S. and others brandishing firearms at the Belt Atlantic apartment complex. The video, posted shortly before the incident, depicted two men later identified as Anthony Cornelius Brown, Jr., and Dequane Aquil McCullers. Detectives accessed live surveillance footage showing individuals matching the video’s description at the same location. Upon arrival, the officers approached the men, who attempted to walk away. Brown and McCullers were detained and frisked, leading to the discovery of firearms.The United States District Court for the Eastern District of Virginia denied Brown and McCullers' motions to suppress the evidence of the firearms. The court found that the officers had reasonable suspicion to stop and frisk the defendants based on the video and their behavior. Brown and McCullers entered conditional guilty pleas, reserving the right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officers had reasonable suspicion to stop Brown and McCullers based on the Instagram video and their actions upon the officers' arrival. The court also found that the frisk of McCullers was justified as the officers reasonably believed he was armed. Additionally, the court ruled that the length of Brown’s detention was reasonable given the circumstances and the need to ensure officer safety. The Fourth Circuit affirmed the district court’s denial of the motions to suppress. View "US v. Brown" on Justia Law

Wade Jones was incarcerated at the Kent County Correctional Facility for five days in April 2018. During his incarceration, he experienced severe alcohol withdrawal symptoms. Despite being placed on an alcohol-withdrawal protocol, Jones did not receive timely or adequate medical care. On April 27, 2018, Jones went into cardiac arrest and was later transferred to a hospital, where he died a week later. His estate sued Kent County and several nurses, alleging deliberate indifference to his medical needs.The United States District Court for the Western District of Michigan held a trial where a jury found that nurses Melissa Furnace, Chad Goetterman, and James Mollo were deliberately indifferent to Jones’s medical condition, which was a proximate cause of his death. The jury awarded Jones’s estate $6.4 million in compensatory damages. The defendants moved for judgment as a matter of law or a new trial, arguing that the jury’s verdict was inconsistent, that no reasonable jury could find proximate cause, that the estate’s counsel engaged in misconduct, and that a juror’s failure to disclose his criminal history warranted a new trial. The district court denied these motions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the defendants had forfeited their inconsistent-verdict argument by not objecting before the jury was discharged. It also found sufficient evidence to support the jury’s finding of proximate cause, noting that the jury could reasonably conclude that the nurses’ failure to provide timely medical care significantly decreased Jones’s likelihood of survival. The court further held that the estate’s counsel’s emotional display during trial did not constitute contumacious conduct warranting a new trial. Lastly, the court found no basis for a new trial due to juror misconduct, as the juror was never directly asked about his own criminal history during voir dire. View "Jones v. Kent County" on Justia Law