Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the district court summarily denying Appellant's petition for postconviction relief without an evidentiary hearing, holding that Appellant was conclusively entitled to no relief on his claims even if the facts alleged were proven by a preponderance of the evidence.Appellant, who was imprisoned for first-degree premeditated murder, filed a petition seeking postconviction relief and an evidentiary hearing, arguing that he was deprived of his Sixth Amendment right to effective assistance of appellate counsel in his direct appeal. The district court summarily denied relief. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the postconviction petition without an evidentiary hearing. View "Woodard v. State" on Justia Law

The Supreme Court held that, under Minnesota statutes in a condemnation proceeding, Blue Earth County did not owe just compensation to Landowners for the loss of a right to access to a newly constructed controlled-access highway built across their property.The district court ruled that Landowners had not been deprived of any right of access for which they should be justly compensated, noting that the County continued to provide farm access to Landowners' property. The court of appeals affirmed. The Supreme Court affirmed, holding that a person who owns property abutting a newly constructed controlled-access highway has no right of access to the controlled-access highway. View "Wood v. County of Blue Earth" on Justia Law

Based on a tip from foreign law enforcement, Kentucky Detective Gatson and federal agents went to Lewis’s home. Lewis invited them inside and signed a form, consenting to “a complete search of the premises, property or vehicle” and electronic devices. A forensic examiner arrived and generated a preview of Lewis’s laptop, which revealed file names indicative of child pornography; on Lewis’s cell phone, he found thumbnail images of Lewis’s cousin’s children bathing naked. Lewis reportedly stated that he did not know that it was illegal to look at child pornography, then invoked his Miranda rights but did not say that he was revoking his consent to search. Gatson obtained a warrant. A forensic search of the seized devices revealed evidence of child pornography on Lewis’s laptop, cell phone, and USB thumb drive.The district court found that the search warrant failed to establish probable cause but that suppression was inappropriate because officers had relied on the warrant in good faith. Lewis conditionally pleaded guilty to producing child pornography, 18 U.S.C. 2251(a). The Sixth Circuit vacated. Lewis consented to the initial search of his laptop and cell phone and the officers’ account of that search and the preview generated were validly obtained and are admissible. All other evidence taken from Lewis’s electronic devices was obtained through searches and seizures that were not supported by a valid warrant. The warrant affidavit stated only Gatson’s conclusory belief that a suspect committed a crime and could not establish probable cause, which precludes the application of the good-faith exception to the exclusionary rule. View "United States v. Lewis" on Justia Law

A nine-year-old girl took her own life after a classmate repeatedly delivered racist insults to her. The girl's mother and grandmother sought to hold the school system and several school officials accountable for her death. The family filed a lawsuit asserting claims arising under federal and state law against the school system and the school officials. The district court granted summary judgment to the school system and its officials, concluding that the family failed to satisfy various elements of their federal statutory claims and that qualified immunity barred at least one of the claims. The court concluded that the state law claims failed on immunity grounds. The family appealed.The Eleventh Circuit affirmed. Although the response of the school system and its officials was "truly discouraging," the standard for relief in cases of student-on-student harassment was not met. The court explained that a reasonable jury could not find that DCS acted with deliberate indifference, that it intentionally discriminated against the girl, or that Defendants' actions were arbitrary or conscience-shocking. Thus, the district court did not err in granting summary judgment to the defendants on the family's Title IX, Title VI, equal protection, and substantive due process claims. View "Jasmine Adams, et al v. Demopolis City Schools, et al" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's second-degree murder conviction, holding that the evidence was sufficient to support a jury finding that Defendant was the aggressor when she shot and killed the victim, and therefore, the trial court did not err in giving an instruction on the aggressor doctrine.At issue was the proper application of North Carolina's castle doctrine statute. See N.C. Gen. Stat. 14-51.2(b). Defendant and the victim in this case had a tumultuous relationship, and on the day of the murder Defendant had warned the victim not to come to her residence. The victim came anyway and was shot and killed. Defendant was convicted of second-degree murder. The court of appeals remanded the case for a new trial, holding that the trial court improperly instructed the jury on the aggressor doctrine. The Supreme Court reversed, holding that the trial court properly instructed the jury that if it found that Defendant was the aggressor, the presumption in section 14-51.2 was no longer available for her. View "State v. Hicks" on Justia Law

The Supreme Court affirmed the jury verdict that Defendant was guilty of the first-degree murder of a young child as well as of first-degree kidnapping, sexual offense with a child and felony child abuse inflicting serious injury, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to disqualify the trial judge; (2) the trial court erroneously admitted at trial a full-body photograph of the victim during certain testimony, but the error was not prejudicial; (3) the trial court may have improperly allowed certain witnesses to testify about their emotional reactions to seeing the victim's injuries, but the evidence was not prejudicial; (4) the trial court erred in denying Defendant's second motion to suppress a statement he made to law enforcement officers at a hospital, but there was no prejudice; (5) there was no cumulative prejudice; (6) there was no error in the trial court's rulings related to Defendant's attempt to establish a prima facie case of racial or gender-based discrimination; (7) North Carolina's death sentence system is constitutional; and (8) Defendant received a fair trial and capital sentencing proceeding. View "State v. Richardson" on Justia Law

The Supreme Court affirmed the order of the district court that overruled Defendant's motion for postconviction relief without an evidentiary hearing, holding that Defendant's challenges to his convictions and the five death sentences he received for murders he committed during a bank robbery were unavailing.After a jury trial, Defendant was found guilty of five counts of first degree murder, among other offenses, and sentenced to death for each of the five murders. Defendant later filed a motion for postconviction relief, alleging prosecutorial misconduct claims, ineffective assistance of counsel claims, and additional claims. The district court denied relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that the district court did not err by (1) denying an evidentiary hearing on Defendant's prosecutorial misconduct and ineffective assistance of counsel claims; and (2) denying relief for other alleged violations of Defendant's constitutional rights. View "State v. Galindo" on Justia Law

Due to a settlement in a civil matter, Plaintiff, an inmate incarcerated in Gatesville, Texas had an inmate trust fund worth nearly $100,000.00. In December of 2019, Plaintiff made a suspicious withdrawal, and Appellee, a former senior warden, notified her that she was under investigation for trafficking. Shortly after, Plaintiff was found guilty of the lowest level of rule violation. Plaintiff now asserts that she has submitted approximately three or four separate withdrawal requests to TDCJ, which were all denied without notice or an opportunity to be heard in violation of her procedural due process rights. The district court granted summary judgment to all Appellees and entered a final judgment. Plaintiff filed a motion for reconsideration pursuant to Rule 59(e) and a Rule 15(a) motion for leave to file a second amended complaint, which the district court denied.   The Fifth Circuit vacated the district court’s judgment and reversed the district court’s ruling denying Plaintiff’s Rule 59(e) motion. The court explained that the Ex Parte Young exception applies to this case. The court explained that any of Plaintiff’s claims seeking declaratory relief based on purported constitutional violations occurring in the past, as well as any requests for monetary damages, are barred by the Eleventh Amendment. However, her claims to enjoin a future action that might violate her constitutional rights may proceed. Further, the court held that Plaintiff provided evidence that her procedural due process rights were violated, which precludes summary judgment. Finally, the court found that the court erred in not vacating the judgment and granting Plaintiff leave to amend her pleadings. View "Calhoun v. Collier" on Justia Law

Patrick was working near the home of an on-and-off girlfriend when gang affiliates of the girlfriend’s current boyfriend–Freeman—shot at him. Patrick escaped and drove to his mother’s house. Patrick left the house to secure his equipment. Freeman and another Gangster Disciple opened fire on Patrick. Patrick ran inside, grabbed a gun loaded with pellet bullets, and fired from the doorway. The bullets struck Freeman in the buttocks and behind the ear. The gang members ran away. Chicago police officers arrived and handcuffed Patrick, demanding that Patrick tell them where the gun was or they were going to tear Patrick’s mother’s home apart. They did not have a warrant. Feeling that he had no choice, Patrick stated that there was a gun in a safe. The officers seized ammunition and several guns. Arrested, Patrick was eventually charged with additional crimes, including attempted murder. He was detained for over five years before pleading guilty to aggravated discharge of a weapon. He received a sentence of time served.Patrick’s suit under 42 U.S.C. 1983. alleged that the city and 23 officers violated his Fourth and Fourteenth Amendment rights by conspiring to conduct an unlawful arrest, execute a warrantless search, and detain him unlawfully. The Seventh Circuit reversed in part. Patrick is not collaterally estopped from pursuing his search and seizure claim based his previous false arrest litigation concerning the attempted murder charge. Because his detention was allotted to a lawful sentence, Patrick has no injury that a favorable decision may redress. View "Patrick v. City of Chicago" on Justia Law

San Francisco Officer Gunn testified that he observed a Buick parked in a “known high-crime area” and ran a license plate check, which came back as belonging to an Acura. Finley, who is Black, stepped out of the vehicle with his wife. Finley stated that they had recently purchased the vehicle and provided title and registration information, establishing the car was not stolen. After obtaining Finley’s driver’s license, Gunn learned that Finley was on federal probation with a search clause. Gunn searched the vehicle and retrieved a backpack, containing a loaded handgun without a serial number.Finley alleged a violation of the Racial Justice Act (Penal Code 745(a)(1)). The prosecution noted that the Supreme Court has stated that an area’s reputation for criminal activity is an appropriate consideration in determining the reasonableness of investigative detention and that it is “common practice” for an officer to run a query of a person’s name. The trial court concluded that Finley did not establish a prima facie violation of the Racial Justice Act under the totality of the circumstances, noting that the officer was courteous.The court of appeal ordered a rehearing. The trial court’s review of Finley’s motion went beyond the confines of determining whether it stated a prima facie case. The focus at this stage of the proceedings should be on Finley’s allegations and supporting evidence, not evidence supporting the prosecution’s argument. View "Finley v. Superior Court" on Justia Law