Justia Civil Rights Opinion Summaries

The Supreme Court of Florida was asked to interpret Florida’s law prohibiting riot, section 870.01(2), Florida Statutes (2021). The question was whether the law applies to a person who is present at a violent protest, but neither engages in, nor intends to assist others in engaging in, violent and disorderly conduct. The court ruled that it does not.The case originated from a lawsuit filed by a group of plaintiffs against Governor Ron DeSantis, three Florida sheriffs, and Attorney General Ashley Moody in the U.S. District Court for the Northern District of Florida. The plaintiffs argued that the statute was vague and overbroad in violation of the Fourteenth Amendment. The district court agreed and enjoined the enforcement of the statute. On appeal, the U.S. Court of Appeals for the Eleventh Circuit found that the central constitutional question was the statute’s scope and certified the question to the Supreme Court of Florida.The Supreme Court of Florida concluded that a "violent public disturbance" under section 870.01(2) is characterized by harm to persons or property, and not by peacefulness. To "willfully participate" in a "violent public disturbance," a defendant must have "intentionally, knowingly, and purposely" chosen to be part of it. Therefore, to be guilty of the crime of riot, one must "engage in," or at least "intend to assist others in engaging in, violent and disorderly conduct." The court found that the statute was not ambiguous and returned the case to the U.S. Court of Appeals for the Eleventh Circuit. View "DeSantis v. Dream Defenders" on Justia Law

The case revolves around a defendant who was convicted of continuous sexual abuse of a child and sentenced to sixty years in prison. The defendant was the victim's mother's boyfriend, and they lived together for about five years. The victim testified that the defendant sexually abused her when she was six or seven years old. The abuse was reported to the Polk County Sheriff’s Department by Alyssa Crawford, who learned about it from the victim. Two years later, during the trial, the State moved to present Crawford’s testimony via Zoom due to her fear of retaliation, her responsibility of caring for her husband with a broken back, and a conflicting court appearance in Colorado. The defendant objected, arguing that allowing Crawford to testify remotely would violate his right to confront her face to face.The trial court overruled the defendant's objection and allowed Crawford to testify via Zoom. The court of appeals, however, reversed the conviction, holding that the trial court’s necessity finding in support of its ruling was too general and unjustified by any public-policy interest.The Court of Criminal Appeals of Texas disagreed with the court of appeals. It held that the trial court’s necessity finding was sufficient and justified by the witness’s fear of retaliation. The court noted that retaliation is a crime and protecting witnesses from retaliation is an important public-policy interest. The court also pointed out that Crawford had provided a basis for her fear—death threats and break-ins at her home soon after her report to the sheriff. Therefore, the court reversed the judgment of the court of appeals and remanded the case for further proceedings. View "MCCUMBER v. STATE OF TEXAS" on Justia Law

The case involves Erie Insurance Company and its affiliates (collectively, Erie) and the Maryland Insurance Administration (MIA). In 2021, the MIA initiated two separate administrative investigations into Erie following complaints alleging racial and geographic discrimination. The first investigation broadly examined Erie’s market conduct, while the second focused on the specific allegations in the individual complaints. In 2023, the MIA issued four public determination letters stating that Erie had violated state insurance laws. These letters referenced documents obtained during the market conduct investigation, which had not yet concluded. Erie requested and was granted administrative hearings on all four determination letters.Erie then filed a lawsuit against the MIA and its commissioner in federal district court, alleging due process violations under 42 U.S.C. § 1983 and violations of Maryland state law. Erie sought a declaration that the determination letters were unlawful, an injunction preventing the defendants from disseminating the letters, and a requirement for the defendants to publicly withdraw them. The district court dismissed Erie's complaint, citing the principles of abstention outlined in Younger v. Harris, which generally discourages federal courts from interfering with ongoing state proceedings.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Erie had an adequate opportunity to raise its constitutional claims in the administrative hearings and subsequent state court review, as required for Younger abstention. The court also rejected Erie's argument that this case fell within an exception to Younger abstention due to extraordinary circumstances or unusual situations. The court concluded that Erie had not demonstrated that the MIA's actions were motivated by bias or that the administrative proceedings would not afford Erie constitutionally adequate process. View "Erie Insurance Exchange v. Maryland Insurance Administration" on Justia Law

The case involves three transgender individuals, Rowan Fowler, Allister Hall, and Carter Ray, who sued the Governor of Oklahoma, the Commissioner of Health for the Oklahoma State Department of Health, and the State Registrar of Vital Records. The plaintiffs challenged an executive order issued by the Governor that directed the Oklahoma State Department of Health to stop amending sex designations on birth certificates. The plaintiffs, who had obtained court orders directing that their sex designations on official documents be amended, had their applications for amended birth certificates denied by the Department of Health, citing the Governor's executive order.The plaintiffs filed a lawsuit alleging that the policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment. The district court dismissed the case, ruling that the plaintiffs failed to state a claim. The plaintiffs appealed the decision.The United States Court of Appeals for the Tenth Circuit reversed the district court's dismissal of the equal protection claim, but affirmed the dismissal of the plaintiffs' substantive due process claim. The court found that the policy of denying sex-designation amendments on birth certificates was not rationally related to any legitimate state interest and therefore violated the Equal Protection Clause. However, the court affirmed the dismissal of the plaintiffs' substantive due process claim, concluding that the plaintiffs failed to allege that their involuntary disclosures of their transgender status amounted to state action. View "Fowler v. Stitt" on Justia Law

Anthony Buntyn, an employee of a private company that transported detainees for law enforcement agencies, was charged with willfully violating the detainees' rights under the Fourteenth Amendment's due process clause due to inhumane conditions of confinement. The conditions developed while Buntyn transported the detainees in a van to various detention facilities. The government alleged that Buntyn had violated the Fourteenth Amendment's due process clause through deliberate indifference to intolerable conditions of confinement and that this indifference had resulted in bodily injury to three detainees. The jury found Buntyn guilty of depriving the detainees of humane conditions, acting willfully and with deliberate indifference, and causing bodily injury to one detainee.Buntyn appealed his conviction to the United States Court of Appeals for the Tenth Circuit, arguing that the evidence was insufficient for a finding of guilt, that the district court erred in preventing his attorney from using the term malice in closing argument, and that the court coerced the jury to reach a verdict. The Tenth Circuit rejected Buntyn's arguments and affirmed his conviction. The court found that the evidence was sufficient to support the jury's findings of inhumane conditions, deliberate indifference, and willfulness. The court also found that the district court did not err in prohibiting the use of the term malice in closing argument, and that Buntyn had waived his challenge to the district court's instruction for the jury to continue deliberating. View "United States v. Buntyn" on Justia Law

On March 26, 2017, two men robbed a restaurant in Queens. One of the robbers, a Black man wearing a red hoodie, black jacket, and a bandana over his face, approached the Assistant Manager, Sumintra Ramsahoye, and demanded she open the safe. When she couldn't, she handed over the contents of the cash register drawers. Meanwhile, the other perpetrator stood next to another employee, Jordan Guzman. After the robbers fled, Guzman called the police. Police Officer Bryce Blake and his partner arrived at the restaurant within minutes and observed the defendant, Freddie T. Wright, standing in the parking lot dressed in a black jacket and red hoodie. Wright fled upon seeing the patrol car, but was eventually arrested. Guzman and Ramsahoye were brought to the house where Wright was arrested to identify him.Wright moved to suppress the identification testimony, arguing that the identification procedures were unduly suggestive. The court denied the motion, finding that the identifications were not "overly suggestive and improper" because they were made in a "very short spatial and temporal time between the incident and arrest." During jury selection, Wright raised a Batson challenge to the People's use of peremptory strikes on two prospective jurors—C.C. and K.C. The court found that the reasons proffered by the People for their strike of C.C. and K.C. were not pretextual. Wright was ultimately convicted of second-degree robbery and second-degree criminal trespass.The Appellate Division affirmed the conviction, holding that Wright had "failed to satisfy his burden of demonstrating, under the third prong of the Batson test, that the facially race-neutral explanation given by the prosecutor was a pretext for racial discrimination." The Court of Appeals granted Wright leave to appeal.The Court of Appeals affirmed the lower courts' decisions. The court found that there was record support for the determinations that the People had valid, race-neutral reasons for striking the two prospective jurors. The court also found record support for the conclusions of the courts below that the show-up procedure used by police was not unduly suggestive. The court concluded that the order of the Appellate Division should be affirmed. View "People v Wright" on Justia Law

The case involves Sharon Lewis, an African-American woman who worked as an assistant athletic director for Louisiana State University’s (LSU) football team. Lewis alleges that she experienced and witnessed numerous instances of racist and sexist misconduct from former head football coach Les Miles and that she received complaints of sexual harassment from student workers that she oversaw. In 2013, LSU retained Vicki Crochet and Robert Barton, partners of the law firm Taylor, Porter, Brooks & Phillips LLP, to conduct a Title IX investigation of sexual harassment allegations made against Miles. The report and its contents were kept confidential, and allegations brought by the student complainants were privately settled.The district court dismissed Lewis's Racketeer Influenced and Corrupt Organization Act (RICO) claims against Crochet and Barton because Lewis’s claims were time-barred and she failed to establish proximate causation. On appeal of the dismissal order, a panel of this court affirmed the district court on the grounds that Lewis knew of her injuries from alleged racketeering as early as 2013, and thus the four-year statute of limitations had expired before she filed suit in 2021.The district court ordered Lewis to file a motion to compel addressing the lingering “issues of discoverability and the application of [its Crime-Fraud Exception Order].” The district court denied Crochet and Barton’s motion for a protective order and compelled the depositions of Crochet and Barton and the disclosure of documents drafted during the 2013 investigation. Crochet and Barton timely appealed.The United States Court of Appeals for the Fifth Circuit reversed the district court’s Crime-Fraud Exception Order and remanded for proceedings consistent with this opinion. The court concluded that the district court clearly erred in holding that Lewis established a prima facie case that the Board violated La. R.S. 14:132(B) and that the alleged privileged communications were made in furtherance of the crime and reasonably related to the alleged violation. View "Lewis v. Crochet" on Justia Law

The case involves Jeremy and Kristy Morris, who sued the West Hayden Estates First Addition Homeowners Association (HOA) under the Fair Housing Act. The Morrises alleged that the HOA discriminated against them based on religion by attempting to prevent them from conducting a Christmas program. The jury ruled in favor of the Morrises, awarding them compensatory and punitive damages. However, the district court granted judgment as a matter of law to the HOA, alternatively granted a new trial, and issued a permanent injunction against future productions of the Christmas program that violate the HOA’s covenants, conditions, restrictions, and easements.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s judgment. The appellate court held that the district court properly granted judgment as a matter of law to the HOA as to the Morrises’ disparate treatment claim under 42 U.S.C. § 3604(b) because they did not show that they were adversely affected by the HOA’s actions. However, the court reversed the district court's judgment as a matter of law on the Morrises’ claim that the HOA interfered with their right to purchase and enjoy their home free from discrimination, in violation of 42 U.S.C. § 3617. The court affirmed the district court’s grant of a new trial to the HOA as to the § 3617 claim and vacated the district court’s grant of an injunction to the HOA. The case was remanded for further proceedings. View "MORRIS V. WEST HAYDEN ESTATES FIRST ADDITION HOMEOWNERS ASSOCIATION, INC." on Justia Law

The case revolves around Erin Bulfin, who sued St. Louis County and several employees of St. Louis County Animal Care & Control (ACC) after her pet dog, Daisy, was euthanized at ACC. Bulfin's dog had bitten her daughter, requiring hospitalization. Following the incident, Bulfin's husband, Edward Nea, took Daisy to ACC. The details of the conversation between Nea and ACC employees are disputed, but it is undisputed that Nea signed a form authorizing the euthanasia of Daisy. The next day, Bulfin went to ACC to pick up Daisy for home quarantine and was informed that Daisy had been euthanized.The district court granted summary judgment to the individual defendants, concluding that Bulfin's Fourth Amendment rights were not violated because the defendants reasonably relied on the apparent consent of Bulfin's husband to euthanize Daisy. The court also granted summary judgment in favor of the County on Bulfin's federal municipal liability claims and declined to exercise supplemental jurisdiction over Bulfin's state law claims.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that when ACC accepted custody of Daisy, that was not a seizure because it is undisputed Bulfin approved of Daisy being quarantined in ACC custody after biting her daughter. The court also held that the individual defendants were entitled to qualified immunity unless the evidence established a violation of her Fourth Amendment rights that was clearly established at the time of the violation. The court concluded that no Fourth Amendment violation occurred and that the individual defendants are entitled to qualified immunity because there is no clearly established authority holding that government officials violate the Fourth Amendment by seizing and destroying an effect with the consent of a person who reasonably has actual or apparent authority. View "Bulfin v. Rainwater" on Justia Law

Michael Jones, a pretrial detainee, filed a lawsuit against the City of St. Louis and four city employees, alleging that they held him in custody for eight months after his criminal charges were dismissed and failed to inform him of his right to be released. Jones's lawsuit, filed under 42 U.S.C. § 1983, included claims under both state and federal law. The defendants moved to dismiss all fourteen counts of the lawsuit. The district court dismissed seven counts, leaving no federal due process claims against the individual defendants at issue on appeal. The defendants appealed the denial of their motion to dismiss the remaining counts, arguing that Jones failed to allege plausible constitutional violations and that they were entitled to qualified immunity from damage claims.The United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo, accepting the factual allegations in Jones's First Amended Complaint as true. The court found that Jones failed to allege specific facts of personal involvement in, or direct responsibility for, a deprivation of his constitutional rights by the individual defendants. The court also found that Jones's allegations that the defendants "should have known" that he was incarcerated despite his charges being dismissed failed to state a claim under either the Fourth Amendment or the Due Process Clause.The court reversed the denial of qualified immunity and directed that the remaining counts be dismissed with prejudice. The case was remanded for further proceedings consistent with the court's opinion. The court did not rule on the state law claims of false imprisonment, leaving that for the district court to resolve on remand. View "Jones v. City of St. Louis" on Justia Law