Justia Civil Rights Opinion Summaries

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The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for being an accomplice to the crime of aggravated murder, holding that it was reasonably probable that the jury would not have convicted Defendant of aggravated murder absent jury instruction errors. After Defendant was convicted she appealed, arguing that her trial counsel was ineffective for failing to object to three errors in the jury instruction regarding accomplice liability. The court of appeals concluded that there were three errors in the jury instruction and that the performance of Defendant's trial counsel was deficient because he did not object to the errors. However, the court of appeals determined that the errors were not prejudicial because there was not a reasonable probability of a more favorable outcome absent the errors. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instruction discussing the elements for accomplice liability on aggravated murder contained three errors; and (2) there was a reasonable probability that at least one juror would not have voted to convict Defendant in the absence of the errors. View "State v. Grunwald" on Justia Law

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Illinois permits voters to place initiatives and referenda on both local and statewide ballots but requires proponents to collect a specific number of signatures during a period of 18 months. That period ended for the state on May 3, 2020, and will end for the city on August 3. Plaintiffs filed suit, 42 U.S.C. 1983, contending that the state’s requirements are unconstitutional, given the social-distancing requirements adopted by Illinois' Governor during the COVID-19 pandemic. A district judge denied relief. The Seventh Circuit affirmed, first holding that at least one plaintiff (Morgan) had standing because began his petition campaign before filing suit. During most of the time available to seek signatures, Morgan did nothing. The other plaintiffs did not do anything of substance until the suit was filed. They had plenty of time to gather signatures before the pandemic began and are not entitled to emergency relief. The Governor’s orders did not limit their speech. The orders concern conduct, not what anyone may write or say. Although the orders make it hard to obtain signatures, so would the reluctance of people to approach strangers during a pandemic. The federal Constitution does not require any state or local government to put referenda or initiatives on the ballot; if the Governor’s orders, coupled with the signature requirements, amount to a decision to skip all referenda for the 2020 election cycle, there is no federal problem. View "Morgan v. White" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress evidence seized from his vehicle during a traffic stop, holding that a driver violates Minn. Stat. 169.30(b) by driving past the stop sign or stop line before coming to a complete stop. Defendant's vehicle was stopped after he failed to stop at a stop sign and stop line. The district court suppressed the evidence seized from Defendant's vehicle, concluding that the traffic stop was unlawful because Minn. Stat. 169.30(b) requires a driver "to stop at the intersection, not at the stop sign or stop line." The court of appeals reversed. The Supreme Court affirmed, holding (1) section 169.30(b) is violated when the driver a vehicle drives past the stop sign or stop line before coming to a complete stop; and (2) because Defendant failed to bring his vehicle to a complete stop before he drove his vehicle past the stop line and the stop sign, the traffic stop was lawful. View "State v. Gibson" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of eighteen counts of financial fraud crimes and sentencing him to a total of seven years to serve in prison, with the balance of the eighteen concurrent sentences suspended with probation, holding that the trial justice did not err or abuse her discretion. Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in admitting evidence related to Defendant's character; (2) the trial justice did not err by permitted a Rhode Island State Police detective to provide expert opinion testimony as a lay witness; (3) the trial justice was not clearly wrong in allowing a waiver of the attorney-client privilege; (4) the trial justice did not err when she denied Defendant’s motion to suppress evidence he claimed was illegally obtained by state action; (5) the trial justice did not err by denying Defendant's motion for a new trial; and (6) Defendant waived his remaining allegations of error. View "State v. Doyle" on Justia Law

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The Patient Protection and Affordable Care Act of 2010 (ACA) requires covered employers to provide women with “preventive care and screenings” without cost-sharing requirements and relies on Preventive Care Guidelines “supported by the Health Resources and Services Administration” (HRSA) to define “preventive care and screenings,” 42 U.S.C. 300gg–13(a)(4). Those Guidelines mandate that health plans cover all FDA-approved contraceptive methods. When the Federal Departments incorporated the Guidelines, they gave HRSA the discretion to exempt religious employers from providing contraceptive coverage. Later, the Departments promulgated a rule accommodating qualifying religious organizations, allowing them to opt out of coverage by self-certifying that they met certain criteria to their health insurance issuer, which would then exclude contraceptive coverage from the employer’s plan and provide participants with separate payments for contraceptive services without any cost-sharing requirements. In its 2014 “Hobby Lobby” decision, the Supreme Court held that the contraceptive mandate substantially burdened the free exercise of closely-held corporations with sincerely held religious objections. In a later decision, the Court remanded challenges to the self-certification accommodation so that the parties could develop an approach that would accommodate employers’ concerns while providing women full and equal coverage. The Departments then promulgated interim final rules. One significantly expanded the church exemption to include an employer that objects, based on its sincerely held religious beliefs, to coverage or payments for contraceptive services. Another created an exemption for employers with sincerely held moral objections to providing contraceptive coverage. The Third Circuit affirmed a preliminary nationwide injunction against the implementation of the rules. The Supreme Court reversed. The Departments had the authority under the ACA to promulgate the exemptions. Section 300gg–13(a)(4) states that group health plans must provide preventive care and screenings “as provided for” in comprehensive guidelines, granting HRSA sweeping authority to define that preventive care and to create exemptions from its Guidelines. Concerns that the exemptions thwart Congress’ intent by making it significantly harder for women to obtain seamless access to contraception without cost-sharing cannot justify supplanting that plain meaning. “It is clear ... that the contraceptive mandate is capable of violating the Religious Freedom Restoration Act.” The rules promulgating the exemptions are free from procedural defects. View "Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania" on Justia Law

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Two teachers at Roman Catholic elementary schools were employed under agreements that set out the schools’ mission to develop and promote a Catholic School faith community; imposed commitments regarding religious instruction, worship, and personal modeling of the faith; and explained that teachers’ performance would be reviewed on those bases. Each taught religion and worshipped with her students, prayed with her students. Each teacher sued after her employment was terminated. One claimed violation of the Age Discrimination in Employment Act; the other claimed she was discharged because she requested a leave of absence to obtain breast cancer treatment. The Ninth Circuit declined to apply the Supreme Court's 2012 Hosanna-Tabor “ministerial exception” to laws governing the employment relationship between a religious institution and certain key employees. The Supreme Court reversed. The First Amendment’s Religion Clauses foreclose the adjudication of employment disputes involving those holding certain important positions with churches and other religious institutions. Several factors may be important in determining whether a particular position falls within the ministerial exception. What matters is what an employee does. Educating young people in their faith, inculcating its teachings, and training them to live their faith lie are the core of a private religious school’s mission. The plaintiff-teachers qualify for the exception; both performed vital religious duties, educating their students in the Catholic faith, and guiding their students to live their lives in accordance with that faith. Their titles did not include the term “minister” but their schools expressly saw them as playing a vital role in carrying out the church’s mission. A religious institution’s explanation of the role of its employees in the life of the religion is important. The Ninth Circuit mistakenly treated the Hosanna-Tabor decision as a checklist; that court invested undue significance in the facts that these teachers did not have clerical titles and that they had less formal religious schooling than the Hosanna-Tabor teacher. The Court rejected a suggestion that an employee can never come within the Hosanna-Tabor exception unless the employee is a “practicing” member of the religion with which the employer is associated. View "Our Lady of Guadalupe School v. Morrissey-Berru" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction on the ground that Defendant was denied effective assistance of counsel because, by conceding in the written closing argument elements of the crimes charged, Defendant's attorney conceded guilt without Defendant's consent or acquiescence, holding that no new trial was required. In reversing the conviction, the court of appeals reasoned that defense counsel's concession of one or more elements of a crime is a concession of guilt and that an unconsented-to concession requires a new trial. The Supreme Court reversed, holding (1) defense counsel's concessions of fewer than all of the elements was not a concession of guilt, and therefore, no new trial was required; and (2) counsel's concessions did not amount to trial error under Strickland v. Washington, 466 U.S. 668 (1984). View "State v. Huisman" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant. Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law

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Koger, an inmate of the Ohio Department of Rehabilitation and Correction (ODRC), is a practicing Rastafarian. Between 2006 and 2018, Koger made several religious-practice accommodation requests, including requests to grow his dreadlocks, keep a religious diet, observe fasts, and commune with other Rastafarians. Alleging that ODRC’s responses were inadequate, Koger brought these claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and 42 U.S.C. 1983 against several ODRC officials. The district court granted the defendants summary judgment. The Sixth Circuit affirmed in part. Koger has not shown that the prison’s grooming policy, which provides for an individualized determination of whether an inmate’s hair is “searchable,” prevents him from growing his locks naturally and, therefore, cannot “demonstrate that [the] prison policy substantially burdens [his] religious practice.” It is not clear that ODRC denied Koger the ability to commune with fellow Rastafarians. The court reversed in part. The defendants did not present any government interest to justify the denial of Koger’s religious diet requests. Koger sufficiently alleged equal protection violations. View "Koger v. Mohr" on Justia Law

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Santos, a native of the Dominican Republic, became a lawful permanent U.S. resident in 2006. In 2017, he pleaded guilty to possessing marijuana with intent to deliver. If that crime is the “aggravated felony,” “illicit trafficking in a controlled substance” he is removable, 8 U.S.C. 1227(a)(2)(A)(iii). Santos was taken to the Pike County Correctional Facility, 8 U.S.C. 1226(c). In 2018, an IJ ordered Santos removed. While awaiting the BIA’s decision on remand from the Third Circuit, Santos filed this federal habeas petition, arguing that the Due Process Clause guarantees a bond hearing to an alien detained under section 1226(c) once his detention becomes “unreasonable.” The district court denied relief, finding no evidence that the government had “improperly or unreasonably delayed the regular course of proceedings, or that [it] ha[d] detained him for any purpose other than the resolution of his removal proceedings.” The BIA then held that Santos’s conviction was not an aggravated felony and remanded for a hearing on his application for cancellation of removal. The IJ denied that application, leaving Santos in prison (then more than 30 months). The Third Circuit reversed; his detention has become unreasonable and Santos has a due process right to a bond hearing, at which the government must justify his continued detention by clear and convincing evidence. View "Santos v. Warden Pike County Correctional Facility" on Justia Law