Justia Civil Rights Opinion Summaries

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The First Circuit affirmed the district court's decision granting summary judgment to Defendants, Norman Sylvester and the Town of Bourne, Massachusetts and dismissing Plaintiff's lawsuit alleging that the discipline he faced as a firefighter violated his constitutional rights, holding that the district court did not err.In his complaint, Plaintiff claimed that he refused to sit for a "promotional" photograph in violation of his religious beliefs and that he was disciplined as a result of his refusal. Plaintiff brought this complaint against Sylvester, in his role as Fire Chief of the Bourne Fire Department, under 42 U.S.C. 1983, for violation of his rights under the Free Exercise Clause, and against the Town and Sylvester under the Massachusetts Wage Act, Mass. Gen. Laws ch,. 149, 148. The district court granted summary judgment to Sylvester on qualified immunity grounds on the section 1983 claim and declined to exercise supplemental jurisdiction over the state law claim. The First Circuit affirmed, holding (1) the district court correctly concluded that Sylvester did not violate Plaintiff's constitutional rights, as required by the first prong of the qualified immunity analysis; and (2) there was no abuse of discretion in the district court's decision declining to exercise supplemental jurisdiction over the remaining state law claim. View "Swartz v. Sylvester" on Justia Law

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Plaintiff, an Alabama prisoner, brought this 42 U.S.C. Sec. 1983 action alleging long delays in his receipt of treatment for hernias and for post-surgery complications. In his pro se third amended complaint, Plaintiff asserted claims of deliberate indifference to his serious medical needs against: (1) Wexford Health Sources, Inc. (“Wexford”), a private contractor that provides health care services for Alabama inmates; (2) Kay Ivey, the Governor of Alabama; and (3) Jefferson Dunn, the Commissioner of the Alabama Department of Corrections.The district court (1) granted summary judgment in favor of Wexford and (2) dismissed Roy’s complaint against Governor Ivey and Commissioner Dunn for failure to state a claim.The Eleventh Circuit affirmed, finding that only one of several statements from other inmates that Plaintiff presented satisfied the requirements of 28 U.S.C. Sec. 1746 because the other statements were only presented as "affidavits" and did not mention the statement was “true and correct” and was made “under penalty of perjury." Considering Plaintiff's remaining evidence, the Eleventh Circuit held that the district court did not err in entering judgment in favor of Defendants. View "Larry Roy v. Kay Ivy, et al." on Justia Law

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The First Circuit vacated Defendant's convictions for nine counts of wire fraud and six counts of aggravated identity theft for his participation in an alleged health insurance fraud scheme, holding that the verdict form that was submitted to the jury violated Defendant's federal constitutional right to a jury trial, and the error was not harmless beyond a reasonable doubt.Specifically, the First Circuit held (1) the district court invaded the jury's over fact-finding by overemphasizing certain of the government's evidence in a manner that was contrary to Appellant's interests, in violation of Appellant's Sixth Amendment right; and (2) there was a reasonable possibility that the constitutional violation at issue influenced the jury in reaching its verdicts in this case, and therefore, the verdicts could not stand, and remand was required. View "United States v. Moffett" on Justia Law

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Hewittel was convicted of armed robbery and related offenses based solely on the testimony of the victim. Three witnesses—one of them having little relationship with anyone in the case—were prepared to testify in support of Hewittel’s alibi that he was at home, almost a half-hour from the crime scene when the crime occurred. Hewittel’s attorney failed to call any of those witnesses at trial, not because of any strategic judgment but because Hewittel’s counsel thought the crime occurred between noon and 12:30 p.m. when Hewittel was at home alone. The victim twice testified (in counsel’s presence) that the crime occurred at 1:00 or 1:30 p.m.—by which time all three witnesses were present at Hewittel’s home. Counsel also believed that evidence of Hewittel’s prior convictions would have unavoidably come in at trial. In reality, that evidence almost certainly would have been excluded, if Hewittel’s counsel asked. Throughout the trial, Hewittel’s counsel repeatedly reminded the jury that his client had been convicted of armed robbery five times before.The trial judge twice ordered a new trial. The Michigan Court of Appeals reversed, based in part on the same mistake regarding the time of the offense. The federal district court granted a Hewittel writ of habeas corpus. The Sixth Circuit affirmed, calling the trial “an extreme malfunction in the criminal justice system.” View "Hewitt-El v. Burgess" on Justia Law

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Wellpath contracted with the jail to provide on-site medical staff and services. Wellpath assigned Dr. Cogswell, to work at the jail. While there, he sexually assaulted three inmates during their visits to the medical clinic. None of the women called out for help or otherwise indicated to the jail staff that anything untoward was occurring. One inmate, Bills recounted seeing an unidentified officer “glance through the little crack of the white curtain [and give] kind of like a head nod,” which Bills interpreted as the officer saying to Cogswell “I got your back.” Wellpath had a policy that if there was a sensitive exam going on, there would be a chaperone. During Cogswell’s tenure, Macomb Officer Horan reported to Wellpath’s nursing director and a Wellpath paramedic that Cogswell was potentially violating this policy by seeing patients unchaperoned, using a privacy screen. At Horan’s request, the nursing director “pop[ped] [her] head in” and saw “nothing out of the ordinary[ or] suspicious.”Days after their assaults, inmates reported the incidents to the jail. Wellpath learned of the reports the same day and immediately informed Cogswell not to report to work. Following an investigation, his employment was terminated. Cogswell was later convicted of second-degree criminal sexual conduct. In the inmates’ suit under 42 U.S.C. 1983, the Sixth Circuit affirmed summary judgment in favor of the defendants, citing the lack of evidence that the defendants knew of Cogswell’s assaults before they were reported. View "Buetenmiller v. Macomb County Jail" on Justia Law

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In 2021, Tennessee enacted a statute that vaccination, masking, and quarantine decisions: “A local health entity or official, mayor, governmental entity, or school does not have the authority to quarantine a person or private business for purposes of COVID-19,” and “a school or a governing body of a school shall not require a person to wear a face mask while on school property” unless various conditions are met. Before seeking accommodation under its terms, eight minor students with disabilities filed suit, alleging that the legislation violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101m Section 504 of the Rehabilitation Act, 29 U.S.C. 794, the Equal Protection Clause, and the Supremacy Clause. The district court granted a preliminary injunction with respect to sections of the Act concerning face coverings for schools and provisions that prohibit local health officials and schools from making quarantining decisions as they relate to public schools.While acknowledging that the case is moot, the Sixth Circuit dismissed it for lack of jurisdiction. The plaintiffs’ argument that they are injured because the Act categorically violates the ADA amounts to an overly generalized grievance. They do not seek redress for a completed violation of a legal right; they seek only prospective relief to protect against future violations. Their injuries are not fairly traceable to any defendant, so no remedy applicable to those defendants (be it an injunction or a declaration) would redress the alleged injuries. View "R. K. v. Lee" on Justia Law

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The Supreme Court affirmed the order of the circuit court resentencing Petitioner, for purposes of this appeal, to an aggregate term of incarceration of five to twenty-five years for her convictions for child neglect resulting in death and gross child neglect creating a risk of substantial injury or death, holding that Petitioner was not entitled to relief.On appeal, Petitioner argued that the circuit court violated her right under the Sixth Amendment to conflict-free counsel and that the State violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose certain records. The Supreme Court disagreed and affirmed, holding (1) the trial court did not err in finding that even if counsel's performance was deficient, the deficient performance did not adversely affect the outcome of the trial; and (2) there was no merit in Petitioner's contention that a Brady violation occurred in this case. View "State v. A.B." on Justia Law

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Respondent has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. Respondent pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. Federal prisoners on the cusp of being released may be civilly committed if they are “presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk” to the person or property of others. Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner’s conduct post-release.   The Fourth Circuit held that a court must consider any terms of supervision that would govern the prisoner’s conduct post-release. Thus, because the record offers no assurances the district court appropriately considered the terms of Respondent’s supervised release before ordering him committed, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "US v. Nathaniel Williams" on Justia Law

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In this petition for an extraordinary writ the Supreme Court held that when probable cause has been found after a preliminary hearing but the case is dismissed without prejudice due to a defect in the prosecution, Haw. R. Pen. P. 12(g) permits a court to hold a defendant in custody or continue bail for a specified time that is reasonable under the circumstances.After the court dismissed charges against Scott Deangelo, it ordered under Rule 12(g) that Deangelo remain in custody for ninety days while the State sought a grand jury indictment. Deangelo brought this challenge to Rule 12(g), arguing that it violates the Fourth Amendment to the United States Constitution and Haw. Rev. Stat. 803-9(5), which requires an arrested person to be taken before a qualified magistrate for examination within forty-eight hours of arrest. The Supreme Court held that Rule 12(g) is constitutional and that the time specified must be reasonable in light of all of the circumstances. View "Deangelo v. Souza" on Justia Law

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Plaintiffs, who identify as Moorish Americans, sought to enter the Caddo Parish Courthouse to file documents with the court clerk. Upon arriving at the security-screening station, plaintiffs informed the officers on duty that they wished to enter without passing through the security screening. After Plaintiffs’ repeated refusals to depart, the officers stated they would count to three and, if Plaintiffs refused to leave, they would be arrested. They did not depart and were arrested, charged with violating Louisiana Revised Statutes Section 14:63.3.Plaintiffs brought a litany of claims against various officials serving in Caddo Parish and the Louisiana state government based on their actions taken during the arrest. Plaintiffs also moved for recusal of the magistrate judge, which the district court denied.   The Fifth Circuit affirmed. The court explained that Plaintiffs have pointed to no precedent that abrogates the general “search incident to arrest” rule when religious headwear is involved. Accordingly, the district court correctly granted summary judgment on the ground of qualified immunity. Further, the court held that there was no error in the district court’s denial of Plaintiffs’ motion for recusal of the magistrate judge. The magistrate judge did not work on this case in private practice nor work with Defendants’ counsel in the practice of law while he was working on this case. Nor is there evidence of any bias or knowledge of the case that would have required the district court, in its discretion, to order recusal. View "Foley Bey v. Prator" on Justia Law