Justia Civil Rights Opinion Summaries

A decision from the United States Court of Appeals for the Eleventh Circuit concerned whether the Governor of Florida, Ron DeSantis, violated the First Amendment rights of Andrew Warren, a state attorney for Florida’s Thirteenth Judicial Circuit, when he suspended Warren from office. Warren, a vocal advocate for criminal justice reform, had been elected to his position twice. During his time in office, he implemented several policies and signed onto advocacy statements related to issues such as transgender health care and abortion rights. Governor DeSantis suspended Warren from his position, justifying the decision on the basis of these activities. Warren sued, claiming that the suspension was retaliation for his First Amendment-protected activities. The district court found that six factors motivated DeSantis to suspend Warren, two of which were protected by the First Amendment. However, the court concluded that DeSantis would have suspended Warren regardless of these protected activities, basing this conclusion on the other four factors. On appeal, the Eleventh Circuit found that the district court erred in not considering all of Warren's activities as protected by the First Amendment. The court emphasized that, as an elected official, Warren had a right to express his views on policy matters of public concern and that his suspension based on these expressions violated his First Amendment rights. The court vacated the district court's decision and remanded the case for further proceedings. View "Warren v. DeSantis" on Justia Law

The case concerned Everett Maynard, a police officer in West Virginia, who was convicted of deprivation of rights under color of law. This conviction was based on his use of excessive force against an arrestee, Robert Wilfong, which resulted in Wilfong being hospitalized with a broken nose and lacerations on his upper head. During the trial, witnesses were required to wear face masks due to the COVID-19 pandemic. Maynard appealed his conviction, arguing that the mask requirement violated his Sixth Amendment rights, and that the district court erred in applying sentencing enhancements for obstruction of justice and for causing "serious bodily injury."The United States Court of Appeals for the Fourth Circuit affirmed the conviction and sentence. It held that the mask requirement did not violate Maynard's Sixth Amendment right, as the protection against the spread of COVID-19 is an important public policy interest and the reliability of the witnesses’ testimony was assured. This was because the witnesses were under oath, cross-examined, and the jury could observe their demeanor. The court also found no error in the application of sentencing enhancements. The court agreed with the district court's finding that the injuries inflicted on Wilfong constituted "serious bodily injury," and affirmed the application of the obstruction of justice enhancement, finding that a defendant's perjurious testimony at trial is relevant to sentencing because it reflects on a defendant’s criminal history, willingness to obey the law, and general character. View "US v. Maynard" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the district court's grant of a preliminary injunction in favor of the plaintiffs, a coalition on homelessness and seven current or formerly homeless residents of San Francisco, who sought to prevent the City and County of San Francisco from enforcing any ordinance that punishes sleeping, lodging, or camping on public property. The plaintiffs argued that such enforcement violated the Eighth Amendment. On appeal, the defendants argued, for the first time, that the enforcement actions did not leave unhoused individuals with nowhere else to go, but instead required them to relocate from specific encampment sites and only at certain times. The Ninth Circuit deemed this argument waived as it was not brought up in the lower court and even if it was considered, the argument would not change the outcome as the defendants' enforcement of the laws were no narrower in scope than the laws at issue in prior cases, Martin v. City of Boise and Johnson v. City of Grants Pass. The court held that the defendants have yet to show that the preliminary injunction was improper based on the arguments and evidentiary record before the district court. View "Coalition on Homelessness v. City of San Francisco" on Justia Law

Larry Trent Roberts spent 13 years in prison for a murder that he did not commit. After being exonerated, he sued several state actors involved in obtaining his wrongful conviction, including Assistant District Attorney John C. Baer. The United States Court of Appeals for the Third Circuit held that Baer is not entitled to absolute immunity from liability under 42 U.S.C. § 1983 because his actions of seeking a new witness to establish a motive for the murder served an investigatory function, not a prosecutorial one. The court noted that prosecutors are not entitled to absolute immunity when they perform investigative functions normally performed by a detective or police officer. Baer argued that he was immune from liability as his conduct occurred post-charge and was designed to produce inculpatory evidence for trial. However, the court clarified that the timing of a prosecutor's actions as pre- or post-indictment and the presence or absence of a connection to a judicial proceeding are only "relevant considerations" in determining whether a prosecutor’s action served a prosecutorial function. They are not enough to establish that a prosecutor's post-charge effort to fabricate evidence for trial served a quasi-judicial function. The court affirmed the District Court's decision denying Baer's motion to dismiss. View "Roberts v. Lau" on Justia Law

In this case, Alexander Hebrard, an inmate in Oregon, brought a complaint under 42 U.S.C. § 1983 alleging that he was disciplined in prison without due process of law. Hebrard claimed that he was found guilty of prison rule violations without sufficient evidence and was denied the opportunity to present a defense. As a result of his alleged wrongful conviction, Hebrard was fined, had money confiscated from his prison account, was placed in segregated housing, lost visitation rights, and had earned-time credits revoked. In his lawsuit, Hebrard sought damages for all these sanctions, except for the revocation of his earned-time credits. The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of Hebrard's complaint as barred by Heck v. Humphrey. Under Heck, a claim for damages that would necessarily imply the invalidity of the length of an inmate's sentence must be dismissed unless the inmate first challenges his sentence in a habeas corpus proceeding and obtains relief. The Ninth Circuit determined that even though Hebrard did not seek relief for the revocation of his earned-time credits, his claim nonetheless implicated the validity of his disciplinary conviction, which in turn affected the length of his sentence. The court concluded that Hebrard needed to obtain habeas relief before filing this § 1983 action. Because he did not do so, his claim was barred by Heck. View "Hebrard V. Nofziger" on Justia Law

In this case, the United States Court of Appeals for the Fifth Circuit dismissed an appeal by police officer Rudy Guillen, who was seeking qualified immunity in a lawsuit brought against him by Akeem Bagley. Bagley had sued Guillen under 42 U.S.C. § 1983, alleging excessive force, unlawful arrest, and illegal detention in violation of the Fourth Amendment. The lawsuit stemmed from an incident in which Guillen had pulled Bagley over for a minor traffic violation and subsequently tased him. The district court had granted Guillen qualified immunity as to Bagley’s unlawful arrest and illegal detention claims, but denied it as to Bagley’s excessive force claim.On appeal, the court held that at the time of the conduct in question, it was clearly established that an officer may not use force on a suspect who is complying with his commands. Viewing the evidence in the light most favorable to Bagley, the court found that Bagley had presented sufficient evidence of excessive force to defeat qualified immunity at the summary judgment stage. Accordingly, the appeal was dismissed for lack of jurisdiction. View "Bagley v. Guillen" on Justia Law

In the case before the United States Court of Appeals for the Eleventh Circuit, Young Israel of Tampa, Inc., an Orthodox Jewish synagogue, sued the Hillsborough Area Regional Transit Authority (HART) for rejecting its proposed advertisement for a Chanukah on Ice event. The synagogue argued that HART’s policy, which prohibited advertisements that “primarily promote a religious faith or religious organization,” violated the Free Speech Clause of the First Amendment. The district court granted summary judgment in favor of Young Israel on two grounds: 1) HART’s policy violated the First Amendment because it discriminated on the basis of viewpoint, and 2) even if the policy was viewpoint neutral, it was unreasonable because it lacked objective and workable standards and was inconsistently and haphazardly applied. The court subsequently issued a permanent injunction against HART, prohibiting it from rejecting any advertisement on the ground that it primarily promotes a religious faith or religious organization, including any future policies.On appeal, the Eleventh Circuit affirmed the district court’s decision, but on narrower grounds. The appellate court concluded that HART's policy was unreasonable under the Supreme Court's decision in Minnesota Voters Alliance v. Mansky because it failed to define key terms, lacked any official guidance, and vested too much discretion in those who applied it. The court declined to address the question of whether the policy constituted impermissible viewpoint discrimination. However, the court concluded that the permanent injunction issued by the district court needed to be revised to apply only to HART’s current policy, rather than any future policies, and remanded the case to the district court for that purpose. View "Young Israel of Tampa, Inc. v. Hillsborough Area Regional Transit Authority" on Justia Law

The United States Court of Appeals for the Eleventh Circuit partially affirmed and partially reversed a lower court's ruling in a case involving James McDonough, a citizen activist, who was banned from future meetings and arrested for disorderly conduct and cyberstalking by the City of Homestead, Florida. McDonough claimed these actions violated his First and Fourth Amendment rights.The court determined that the city council meetings were designated public forums, and the ban was not narrowly tailored to serve a significant government interest as required, thus violating McDonough's First Amendment rights.The court also found that the officers did not have probable cause to arrest McDonough for disorderly conduct, which involved swearing at officers and making obscene gestures. The court stated that such actions do not constitute disorderly conduct and are protected under the First Amendment. However, the court ruled that the City had probable cause to arrest McDonough for cyberstalking, as it was not unreasonable for the City to interpret Florida’s cyberstalking statute as barring McDonough from targeting one of its officers with his series of posts.The case was sent back to the lower court for further proceedings consistent with the appellate court’s opinion. View "McDonough v. Garcia" on Justia Law

The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

In the early morning hours of August 1, 2018, Gwendolyn Adams and Glenn Tyler Bolden were pursued in a high-speed chase by Michael William Becker, a peace officer employed by the California Department of Corrections and Rehabilitation (CDCR). Becker suspected Adams and Bolden of wrongdoing, although his suspicions were unfounded. The pursuit resulted in a catastrophic accident that caused severe injuries and, ultimately, the death of Adams's son, D'son Woods.Adams and Bolden filed a lawsuit against the CDCR, alleging negligence causing wrongful death, assault and battery, and violation of the Tom Bane Civil Rights Act. The CDCR sought summary judgment, arguing that Becker was not acting within the scope of his employment during the pursuit. The trial court agreed and entered judgment in favor of CDCR.On appeal, the Court of Appeal of the State of California Fourth Appellate District Division Three reversed and remanded the case. The appellate court found that whether Becker was acting within the scope of his employment when he pursued Adams and Bolden was a question of fact that should be decided by a jury. The court noted that Becker’s actions may have been influenced by his role as a peace officer, and it was not clear whether he was acting as a private citizen or a law enforcement officer during the pursuit. Therefore, the trial court erred in granting summary judgment to the CDCR. View "Adams v. Dept of Corrections and Rehabilitation" on Justia Law