Justia Civil Rights Opinion Summaries

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

Evy Orellana suffered serious injuries when a tactical canine bit her leg as a U.S. Marshals fugitive task force executed an arrest warrant for her boyfriend, Eric Trinidad. Orellana, Trinidad, and their baby lived in the basement of Trinidad’s mother’s home. The officers breached a sealed door to access the basement, and the dog bit Orellana during the search. Orellana sued the officers under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, claiming a violation of her Fourth Amendment rights due to unreasonable search and seizure.The United States District Court for the District of Maryland denied the officers' motion to dismiss, reasoning that the case was similar enough to Bivens to apply its cause of action. The court also denied the officers' motion for summary judgment on the grounds of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that this case presented a new context for Bivens because the officers were part of a specialized federal-state task force operating under a warrant. The court emphasized that the Supreme Court has cautioned against extending Bivens to new contexts, particularly when Congress is better suited to create a cause of action. The court concluded that special factors, including federalism concerns and the existence of alternative remedial procedures, counseled against extending Bivens in this situation. Therefore, the appellate court reversed the district court's decision, denying Orellana a Bivens remedy. View "Orellana v. Deputy United States Marshal Godec" on Justia Law

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

In this case, the applicant was convicted of capital murder for the 2004 killing of an elderly man, James Tomlin, during a robbery. The applicant and his girlfriend, Leketha Allen, were implicated in the crime, with the applicant providing statements to the police detailing their involvement. The medical examiner, Dr. Nizam Peerwani, testified that Tomlin's death was caused by smothering with positional asphyxia, which was critical in proving the applicant's intent to kill.The Texas Court of Criminal Appeals previously affirmed the applicant's conviction and death sentence. The applicant's first post-conviction application for a writ of habeas corpus was denied. In his subsequent application, the applicant raised claims that his due process rights were violated by the presentation of false or misleading testimony by Dr. Peerwani and that new scientific evidence contradicted the evidence presented at trial.The Court of Criminal Appeals remanded the case to the lower court to review the merits of these claims. The habeas court held evidentiary hearings and considered testimony from various experts, including Dr. Peerwani, who reaffirmed his trial testimony. The habeas court recommended granting relief based on the new evidence and alleged false testimony.Upon review, the Texas Court of Criminal Appeals found that the habeas court considered evidence beyond the scope of the claims raised in the application. The court determined that the applicant failed to demonstrate that Dr. Peerwani's testimony was false or misleading and that the new scientific evidence did not meet the requirements for relief under Article 11.073. Consequently, the court denied the applicant post-conviction habeas relief. View "EX PARTE CARTER" on Justia Law

In 2024, Carlos Huerta filed a petition for a writ of habeas corpus in the superior court, seeking relief under the Racial Justice Act (RJA). The superior court denied the petition without appointing counsel, concluding that Huerta had failed to establish a prima facie claim for relief. Huerta then filed a petition in the Court of Appeal of the State of California, Fifth Appellate District, alleging racial discrimination in his charges and sentence, supported by statistical data.Previously, in 2010, Huerta was convicted of three counts of premeditated attempted murder and other felonies, with gang enhancements, and sentenced to 53 years to life plus 14 years. In 2022, he was resentenced to a determinate term of 26 years following changes in the law concerning attempted murder, retaining multiple gang enhancements. The RJA was not addressed during the resentencing.The Court of Appeal issued an order to show cause (OSC) in October 2024, appointing counsel for Huerta and directing the parties to address the legal showing required for the appointment of counsel in an RJA petition. The respondent initially argued that a prima facie showing was necessary for counsel appointment but later conceded that the McIntosh decision correctly interpreted section 1473, subdivision (e), which requires the appointment of counsel if the petition alleges facts that would establish an RJA violation.The Court of Appeal held that the superior court misapplied the statutory sequence by requiring a prima facie showing before assessing the lower pleading threshold for appointing counsel. However, the Court of Appeal concluded that Huerta's petition was facially defective as it failed to allege facts showing a qualifying offense under the RJA. The petition relied solely on gang enhancements, which do not fall within the scope of the relevant statutory provisions. Consequently, the Court of Appeal denied the petition for writ of habeas corpus. View "In re Huerta" on Justia Law

Donna Christensen, a twenty-year-old inmate at Vilas County Jail, died by suicide after twenty-five days in confinement. She had a history of substance abuse and mental illness and had previously reported suicidal thoughts and hallucinations. During her incarceration, she exhibited withdrawal symptoms and had an altercation with jail staff, leading to her placement on suicide watch. Despite her initial suicidal ideations, she was removed from suicide watch after a brief assessment by a social worker. She was later placed in solitary confinement, where she remained until her death.The Christensens, Donna's parents, sued Vilas County, the jail's medical service provider, and various employees, alleging that Donna's death resulted from inadequate medical treatment, excessive force, and due process violations. The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants, ruling against the Christensens. The court also denied the Christensens' requests to amend their complaint and extend deadlines for additional discovery.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Christensens failed to present sufficient evidence to establish that the defendants were deliberately indifferent to Donna's serious medical condition under the Eighth Amendment. The court found no genuine dispute of material fact regarding the defendants' conduct and concluded that no reasonable jury could find in favor of the Christensens. The court also upheld the district court's denial of the Christensens' motions for additional discovery and to amend their complaint, finding no abuse of discretion in the lower court's case management decisions. View "Christensen v Weiss" on Justia Law

Justin Johnson, a pretrial detainee at Jefferson County Jail, was attacked by two other inmates while in protective custody. Johnson sued correctional officers Jacob Schurman and Christopher Taylor under 42 U.S.C. § 1983 for failure to protect him and for negligence under Missouri law. The district court granted summary judgment in favor of the officers, finding that qualified immunity barred the § 1983 claims and that official immunity and the public duty doctrine barred the negligence claims.The United States District Court for the Eastern District of Missouri determined that Johnson could not show a constitutional violation necessary to overcome qualified immunity. The court found no evidence that the officers were deliberately indifferent to a substantial risk of serious harm, as the attackers were not known to be violent, and Johnson had no prior relationship with them. The court also dismissed the negligence claims, ruling that the officers were protected by official immunity because their actions were discretionary, not ministerial. Additionally, the court found that the public duty doctrine applied, as the officers owed no particular duty to Johnson beyond that owed to the general prison population.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the officers were entitled to qualified immunity, as Johnson failed to show that they were deliberately indifferent to a known risk. The court also upheld the dismissal of the negligence claims, concluding that the officers' actions involved discretionary decisions protected by official immunity. The court did not address the public duty doctrine, as the official immunity finding was sufficient to resolve the negligence claims. View "Johnson v. Schurman" on Justia Law

Amber Lavigne filed a lawsuit against the Great Salt Bay Community School Board and various school staff members, alleging that they infringed on her constitutional right to parent by providing her child, A.B., with a chest binder and referring to A.B. by a different name and pronouns without informing her. Lavigne claimed that these actions were part of a school-wide policy of withholding such information from parents.The United States District Court for the District of Maine dismissed the claims against the individual defendants and later granted the Board's motion to dismiss, concluding that Lavigne had not plausibly alleged that the Board had a custom or policy of withholding information. The court found that Lavigne's allegations were based on conclusions unsupported by factual allegations and that the Board's statements did not constitute active approval of the individual defendants' actions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Lavigne had not plausibly alleged the existence of an unwritten policy or custom of withholding information from parents. The court noted that the Board's written policies encouraged parental involvement and that the statements made by the Board and school officials did not support the inference of an unwritten policy of withholding. The court also found that the Board's decision to renew the contract of the social worker involved did not amount to ratification of the alleged conduct. Thus, the appellate court concluded that Lavigne had failed to show that the Board was responsible for any constitutional violation. View "Lavigne v. Great Salt Bay Community School Board" on Justia Law

Edward Snukis was stopped by Officers Matthew Taylor and Trevor Koontz after a report of an impaired man refusing to leave a parking lot. The encounter escalated when Snukis resisted commands and struck Officer Koontz. Officer Taylor tased Snukis twice, and both officers pinned him to the ground, with Taylor striking Snukis in the head six times. After securing Snukis in handcuffs, the officers noticed he had lost consciousness and provided emergency assistance, but Snukis died later that evening. Snukis’s children, as co-administrators of his estate, sued the officers and the City of Evansville under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendants. The estate appealed the decision, focusing on claims against the officers for excessive force, failure to intervene, and failure to render medical aid.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the officers' use of force was reasonable given Snukis’s resistance and the threat he posed. The court found that Officer Taylor’s use of the taser and subsequent strikes were justified due to Snukis’s active resistance. The court also determined that the officers provided prompt and appropriate medical care once Snukis lost consciousness. Consequently, the court affirmed the district court’s grant of summary judgment in favor of the officers. View "Snukis v. Taylor" on Justia Law