Justia Civil Rights Opinion Summaries

Nathan Wilson and Christopher Beasley were alleged to have set fire to a police car during a protest in Santa Monica, California, following the killing of George Floyd. They were federally indicted on one count of arson. The defendants moved to dismiss the indictment, arguing they were selectively prosecuted based on perceived anti-government views. Alternatively, they sought discovery on their selective-prosecution claim.The United States District Court for the Central District of California denied the motion to dismiss but granted discovery on the selective-prosecution claim. The government indicated it would seek appellate review rather than comply with the discovery order, leading the district court to dismiss the indictment without prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction under 18 U.S.C. § 3731, which allows for government appeals in criminal cases without requiring final decisions. The court found that the district court abused its discretion by granting discovery based on an erroneous view of the law. The district court had incorrectly defined the control group for determining discriminatory effect, failing to account for relevant factors beyond committing the same crime in the same location.The Ninth Circuit reversed the district court’s selective-prosecution discovery order and the dismissal of the indictment without prejudice. The case was remanded for further proceedings consistent with the opinion. The court did not address whether the defendants presented evidence of discriminatory intent. View "USA V. WILSON" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

The defendant, Angelo Clark, was charged with multiple counts of attempted first-degree murder and aggravated battery following a gang-related shooting in 2013 that injured two people. Clark moved to quash his arrest, which was based on an investigative alert issued by the Chicago Police Department. The circuit court denied his motion, and Clark did not contest this denial further in the circuit court.In 2017, a jury in the Cook County Circuit Court convicted Clark of two counts of aggravated battery with a firearm under an accountability theory. He was initially sentenced to 46 years in prison, which was later reduced to 32 years upon reconsideration.Clark appealed, and the Appellate Court, First District, affirmed his conviction and sentence. The appellate court rejected Clark's argument that his arrest was unconstitutional because it was based on an investigative alert rather than a warrant. The court also found no plain error in the circuit court's consideration of sentencing factors for juvenile offenders, as Clark was 17 at the time of the offense.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that warrantless arrests based on probable cause do not violate the Illinois Constitution, even if communicated via an investigative alert. The court also found that the circuit court had considered the relevant factors for sentencing juvenile offenders, as required by section 5-4.5-105(a) of the Unified Code of Corrections, and thus, there was no clear or obvious error in the sentencing process. View "People v. Clark" on Justia Law

David Vincent was stopped by Officer David Robertson of the Edmonton Police Department based on a tip from a known informant and an alleged equipment violation. The informant reported that two individuals at a gas station appeared to be intoxicated. Officer Robertson observed a vehicle with red parking lights, which he believed violated a new law that had not yet taken effect. He followed the vehicle, observed no traffic violations, and stopped it. Vincent was found to have a suspended license, and a search of the vehicle revealed drugs and paraphernalia.The Metcalfe Circuit Court denied Vincent's motion to suppress the evidence obtained from the stop, ruling that the officer's belief about the equipment violation was an objectively reasonable mistake of law. The court also found the informant's tip provided a sufficient basis for the stop. Vincent entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The Court of Appeals affirmed the trial court's decision, holding that the stop was supported by reasonable suspicion and the subsequent search was lawful under the automobile exception to the warrant requirement.The Supreme Court of Kentucky reviewed the case and reversed the lower courts' decisions. The court held that the stop was not justified by the equipment violation because the law had not yet taken effect, and the officer's mistake of law was not reasonable. Additionally, the informant's tip did not provide reasonable suspicion for the stop, as it was based on observations that could be explained by innocent behavior and was not corroborated by the officer's own observations. The court remanded the case for the trial court to grant Vincent's motion to suppress the evidence obtained from the unlawful stop. View "VINCENT V. COMMONWEALTH OF KENTUCKY" on Justia Law

Officer Henry Volentine, a deputy of the Hardin County Office of Sheriff (HCOS), initiated a traffic stop of Maurice Green on October 14, 2014, after noticing Green's vehicle had an expired license plate belonging to a different vehicle. Green initially pulled over but then drove off, prompting Volentine to pursue him. During the pursuit, Volentine believed Green had committed assault and wanton endangerment by nearly hitting two pedestrians. The pursuit ended in a head-on collision with Susan Sheehy’s vehicle, leading to the present litigation.The Hardin Circuit Court denied Volentine’s and HCOS’ motion for summary judgment based on qualified and governmental immunity. The court found that Volentine did not have a reasonable basis to believe a violent felony had occurred to justify the pursuit and that his actions were not in good faith. The court also determined that Volentine violated ministerial duties by failing to terminate the pursuit when it posed an extreme safety hazard and by not obtaining approval from a supervisor to continue the pursuit.The Kentucky Court of Appeals reversed the trial court’s decision, holding that Volentine was entitled to qualified official immunity and that HCOS was entitled to governmental immunity. The Court of Appeals reasoned that Volentine’s belief that he witnessed a felony was reasonable and that his actions during the pursuit were discretionary.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals. The Supreme Court held that Volentine was not entitled to qualified official immunity because he failed to abide by ministerial duties and lacked good faith in exercising his discretion to initiate the pursuit. Consequently, HCOS’ governmental immunity was waived by operation of KRS 70.040. The case was remanded to the Hardin Circuit Court for further proceedings consistent with the Supreme Court’s opinion. View "SHEEHY V. VOLENTINE" on Justia Law

Tyler Story was charged with first-offense DUI after being observed driving at high speed with one headlight and failing field sobriety tests. He admitted to drinking and had a breathalyzer result of 0.178. Story requested an independent blood test, which was drawn but not tested immediately. The sample was stored by the police. Story was charged and sought to preserve the sample for independent testing. The District Court suppressed the breathalyzer results due to an error in administration, leaving the Commonwealth without evidence. The Commonwealth obtained a warrant to test the independent blood sample, which Story opposed.The Campbell District Court denied Story's motion to return the blood sample for independent testing, finding he had abandoned it. The Campbell Circuit Court denied Story's petition for a writ of prohibition against the search warrant. The District Court allowed the Commonwealth to test the sample, which showed a blood alcohol level above the legal limit. Story entered a conditional guilty plea and appealed. The Circuit Court and the Court of Appeals affirmed the District Court's decisions, with the Court of Appeals disagreeing on the abandonment but upholding the testing as evidence.The Supreme Court of Kentucky reviewed the case and found that Story's statutory right to an independent blood test was infringed, but the error was harmless since the breathalyzer test was suppressed. However, the Court concluded that the Commonwealth's testing of the blood sample was conducted under an invalid warrant and without Story's consent, violating his Fourth Amendment rights. The Court reversed the District Court's denial of Story's motion to suppress the test results, vacated his conviction, and remanded for further proceedings. View "STORY V. COMMONWEALTH OF KENTUCKY" on Justia Law

Roderick Barnes III was convicted by a jury of three counts of attempted murder, three counts of attempted robbery, and three counts of assault with a firearm. The jury also found that Barnes personally discharged a firearm causing great bodily injury and that he participated in a criminal street gang, committing the crimes for the benefit of the gang. Barnes was sentenced to 70 years to life in prison.Barnes appealed, arguing that the trial court erred in overruling his objection to the prosecutor’s use of a peremptory challenge against a Black prospective juror, failing to instruct the jury with CALCRIM No. 332, and that there was insufficient evidence to support the gang participation conviction and enhancements. The People conceded the latter two points but argued that the gang-related offenses could be retried.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court found that the trial court erred in overruling Barnes’s objection to the peremptory challenge. The court determined that the prosecutor’s reasons for striking the juror were not valid and that the trial court improperly considered reasons not stated by the prosecutor. The court also found that substantial evidence did not support the gang participation conviction and enhancements, as the prosecution failed to provide a sufficient foundation for the expert’s opinion that the murder of P.M. commonly benefited the gang.The Court of Appeal reversed the judgment in its entirety and remanded the case for a new trial on counts 1 through 9. The court held that the prosecution could not retry Barnes for the gang participation offense or the gang enhancements due to insufficient evidence. View "People v. Barnes" on Justia Law

Henry Washington, a state prisoner, alleged that prison guard T.S. Oswald sexually assaulted him twice, once in 2013 and again in 2015. During the first incident, Washington claimed that Oswald and another guard handcuffed him, fondled him, and attempted to insert a nightstick into his rectum, causing him to bleed. In the second incident, Oswald allegedly fondled Washington and attempted to insert his finger into Washington's rectum while escorting him back to his cell.Washington sued Oswald under 42 U.S.C. § 1983 for cruel and unusual punishment. The jury found in favor of Washington, awarding him $20,000 in compensatory damages and $25,000 in punitive damages for the 2013 assault, and $20,000 in compensatory damages and $200,000 in punitive damages for the 2015 assault. Oswald moved for judgment as a matter of law or a new trial, arguing insufficient evidence and excessive punitive damages. The United States District Court for the Western District of Pennsylvania denied these motions.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that there was sufficient evidence for the jury to find Oswald liable for both assaults. The court also upheld the punitive damages, finding them not excessive under the Due Process Clause. The court noted that Oswald's actions were highly reprehensible, the punitive damages were proportionate to the harm caused, and the awards were consistent with those in comparable cases. The court affirmed the District Court's decision, maintaining the jury's awards. View "Washington v. Gilmore" on Justia Law

Petitioner Maryanne McCabe lived with her long-time romantic partner, David Burrows, in a New York City cooperative building. Upon Burrows' death, he bequeathed his unit to McCabe. She sought to acquire his lease and shares under a lease provision allowing automatic transfer to a shareholder's "spouse." The cooperative board did not recognize McCabe as a spouse but offered to consider her under a clause for family members. McCabe argued that the board's refusal violated the New York City Human Rights Law (NYCHRL) prohibition against marital status discrimination.The Supreme Court denied McCabe's petition, stating that the denial was not due to her being unmarried but because she was not married to Burrows, which did not constitute marital status discrimination. The court also found that McCabe had not proven she was a family member or financially responsible. The Appellate Division affirmed the Supreme Court's decision on the same grounds.The New York Court of Appeals reviewed the case and affirmed the lower courts' decisions. The Court held that the term "marital status" under the NYCHRL refers to the legal condition of being single, married, legally separated, divorced, or widowed, and does not extend to individuals in long-term romantic relationships who are not legally married or in a registered domestic partnership. The Court concluded that the cooperative board's actions did not constitute marital status discrimination under the NYCHRL, the New York State Human Rights Law, or federal law. The Court also deferred to the board's decision to reject McCabe's application based on her financial representations. View "Matter of McCabe v. 511 W. 232nd Owners Corp." on Justia Law

Kyle J. Dalen was civilly committed but not taken into custody. Five months later, he was arrested for felony harassment and stalking and placed in county jail. Dalen sued, alleging pretrial punishment, unreasonable restraint, and deliberate indifference to his medical needs. The district court dismissed his complaint, and Dalen appealed.The United States District Court for the District of Minnesota dismissed Dalen's complaint, concluding that he failed to plausibly allege his claims under federal law. Dalen argued that the district court improperly dismissed his claim of deliberate indifference in violation of the Fourteenth Amendment’s Due Process Clause. He also claimed that the defendant’s failure to transfer him from jail to a treatment facility was punitive and that his detention constituted unreasonable restraint.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Dalen's complaint lacked sufficient facts to support an objectively serious medical need, as required to prove deliberate indifference. The court also found that Dalen failed to show that his detention conditions were intentionally punitive or not reasonably related to a legitimate governmental purpose. Additionally, the court determined that Dalen did not provide specific facts about how he was restrained, which is necessary to support a claim of unreasonable restraint.The Eighth Circuit affirmed the district court's dismissal of Dalen's claims, concluding that he did not meet the necessary legal standards to proceed with his lawsuit. View "Dalen v. Harpstead" on Justia Law