Justia Civil Rights Opinion Summaries

The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief. View "Corrigan v. Boston University" on Justia Law

Two campus police officers at Shepherd University, Jay Longerbeam and Donald Buracker, were terminated due to alleged "misconduct" and "unprofessionalism" during two incidents in 2018 and 2019. The officers claimed that their termination was a result of age and disability discrimination, retaliation under the West Virginia Human Rights Act (HRA), violation of the West Virginia Whistle-blower Law, and common law wrongful discharge. The Circuit Court of Jefferson County granted summary judgment against both officers on all claims.The officers appealed the decision, arguing that the lower court erred in finding no genuine issues of material fact and in its handling of the burden-shifting paradigm. They contended that their conduct during the incidents was legally proper and that the court failed to consider intervening acts of reprisal which were more temporally proximate to their protected activity than their discharge.The Supreme Court of Appeals of West Virginia found that the lower court erred in its handling of the "temporal proximity" issue and the burden-shifting paradigm. The court also found that the officers offered more than sufficient evidence upon which a rational trier of fact could find retaliatory motivation. Therefore, the court reversed the lower court's grant of summary judgment as to the officers’ whistle-blower and Harless claims and remanded for further proceedings. However, the court affirmed the lower court's grant of summary judgment as to Buracker’s HRA disability discrimination claim, finding his evidence insufficient to create an inference of disability discrimination. View "Jay Longerbeam v. Shepherd University" on Justia Law

Two members of the Lipan-Apache Native American Church, Gary Perez and Matilde Torres, sued the City of San Antonio over its development plan for Brackenridge Park. They claimed that the plan, which involved tree removal and bird deterrence measures, would prevent them from performing religious ceremonies in the park, violating their rights under the First Amendment, the Texas Religious Freedom Restoration Act, and the Texas Constitution. They sought an injunction requiring the city to grant them access to the park for worship, minimize tree removal, and allow cormorants to nest.The district court granted them access to the park for religious ceremonies but declined to enjoin the city's planned tree removal and bird deterrence measures. Both parties appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the city's development plan did not substantially burden the appellants' religious exercise. The court also found that the city's plan served two compelling interests: public health and safety, and compliance with federal law. The court concluded that the city's tree removal and bird deterrence plans were the least restrictive means to advance these interests. Therefore, the appellants failed to show a likelihood of success on the merits of their claims. The court also denied the appellants' emergency motion for an injunction pending appeal. View "Perez v. City of San Antonio" on Justia Law

Eric Demond Lozano, a Texas state prisoner and Sunni Muslim, filed a lawsuit against three officials of the Texas Department of Criminal Justice (TDCJ) alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Establishment Clause. Lozano claimed that his ability to practice his religion was substantially burdened due to the conditions in the prison. His claims included the inability to shower privately before Jumah, a weekly prayer service, due to non-Muslim inmates being allowed to shower at the same time; insufficient space to pray in his cell due to hostile cellmates; and lack of access to religious programming and instruction, specifically Taleem and Quranic studies, due to the absence of Muslim volunteers.The United States District Court for the Southern District of Texas granted summary judgment in favor of the TDCJ officials. The court found that Lozano failed to demonstrate a genuine issue of material fact on whether the absence of a Muslim-designated unit or dorm violated the Establishment Clause. The court also concluded that Lozano provided no evidence to support his allegation that the faith-based dorms required inmates to study Christian materials.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court's order granting summary judgment on Lozano's RLUIPA claims regarding Jumah showers and adequate prayer space. The appellate court found that there was a genuine dispute of material fact on whether Lozano's ability to practice his religion was substantially burdened. The court also vacated the district court's grant of summary judgment on Lozano's RLUIPA claim regarding additional religious programming and his Establishment Clause claim, and remanded the case for further proceedings. View "Lozano v. Collier" on Justia Law

Michael Rivera, a Pennsylvania state prisoner, was in an open-air telephone cage when he overheard prison officials preparing to forcibly extract another inmate, Ryan Miller, from a nearby cell. Anticipating the use of pepper spray, Rivera informed the officials that exposure to the spray would trigger his asthma. Despite his pleas to be moved back to his cell, the officials refused, citing the lack of available personnel due to the ongoing preparations for Miller's extraction. After the pepper spray was deployed, Rivera suffered an asthma attack. He sued the prison officials for damages, alleging they had acted with deliberate indifference to the substantial risk of serious harm to him, in violation of the Eighth Amendment.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the prison officials. The court concluded that the law was not clearly established to the extent that the officials would have known that their actions violated the Eighth Amendment.On appeal, the United States Court of Appeals for the Third Circuit affirmed the lower court's decision. The appellate court found that the prison officials were entitled to qualified immunity because their actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. The court noted that the officials were confronted with competing institutional concerns and that the cited case law did not clearly establish that the officials' decision to prioritize one prisoner's health and safety over another's violated the Eighth Amendment. View "Rivera v. Redfern" on Justia Law

Jessie Hill, a prisoner serving life imprisonment without parole for capital murder and an additional 720 months for first-degree murder, filed multiple pro se petitions for writ of habeas corpus. He claimed double jeopardy, violations of his right to due process, insufficient evidence supporting his convictions, and other obscure claims. The Jefferson County Circuit Court dismissed his petitions, noting that Hill's pleadings were often illegible and contained profane language. The court concluded that Hill failed to establish that he was being illegally detained.Hill had previously filed multiple petitions for postconviction relief, including four habeas corpus petitions, all of which were denied by the circuit court and affirmed on appeal. In his current appeal, Hill argued that his convictions violated the prohibition against double jeopardy, that the charging informations were defective and violated his right to due process, and that there was insufficient evidence to support his convictions.The Supreme Court of Arkansas affirmed the circuit court's decision, stating that Hill's claims did not challenge the legality of his sentences or the subject-matter jurisdiction of the trial courts that entered the judgments of conviction. The court noted that a habeas proceeding does not afford a petitioner an opportunity to retry his case and is not a substitute for raising an issue either at trial or on direct appeal. The court concluded that Hill's double-jeopardy claim failed to state a basis for habeas relief, and his sufficiency-of-the-evidence claims represented an abuse of the writ as he had raised these claims in his previous habeas petitions. View "Hill v. Payne" on Justia Law

The case revolves around the death of Darius Caraway, who overdosed while serving a murder sentence at Whiteville Correctional Facility in Tennessee, operated by CoreCivic, Inc. Caraway's estate, represented by his mother, sued CoreCivic and three of its officials, alleging that they violated Caraway's Eighth Amendment rights by failing to protect him from overdosing. The estate argued that CoreCivic deliberately understaffed the facility, leading to inadequate screening of prison guard applicants, smuggling of illegal drugs, and lack of supervision, which allowed fentanyl to proliferate at Whiteville. The estate claimed that the defendants knew about this proliferation but did nothing about it, leading to Caraway's death by overdose.The United States District Court for the Western District of Tennessee dismissed the estate’s complaint, stating that the claims were conclusory allegations of unconstitutional conduct devoid of well-pled factual support. The estate appealed this dismissal to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the district court's decision. The court found that the estate failed to adequately allege that Caraway faced an objectively excessive risk of harm from unfettered access to drugs inside Whiteville. The court also found that the estate failed to sufficiently allege that the defendants knew of a drug problem at Whiteville or that they didn't reasonably respond to the alleged risk. The court concluded that the estate failed to meet the requirements of a failure-to-protect claim under the Eighth Amendment. The court also dismissed the estate's procedural claims, stating that the district court properly treated the motion as one to dismiss and that the estate had forfeited its argument about the district court's failure to issue a scheduling order. View "Caraway v. CoreCivic of Tennessee, LLC" on Justia Law

The estate and heirs of Dale O'Neal, a pre-trial detainee who was murdered by his cellmate in Clay County's jail, filed a lawsuit against several officers and the county under Section 1983. They alleged that the defendants failed to protect O'Neal, thereby violating his Fourteenth Amendment rights. The case centered around the actions of the intake officer, Annie Avant, who assigned O'Neal's murderer, Cameron Henderson, to the same cell as O'Neal. The parties disputed what information was conveyed to Avant about Henderson's violent behavior and whether the booking system would have revealed that Henderson was previously determined to be a threat.The district court agreed with the magistrate judge's decision to exclude a late-designated expert and the accompanying report, which the plaintiffs relied on to establish the County's liability. The court then granted summary judgment to all defendants, concluding that the plaintiffs could not create a fact question as to whether the individual defendants acted with deliberate indifference. The court also found that Avant had qualified immunity.On appeal to the United States Court of Appeals for the Fifth Circuit, the plaintiffs argued that it was an abuse of discretion to exclude the expert and error to grant summary judgment to Avant. The appellate court affirmed the lower court's decision. It found no abuse of discretion in excluding the late-designated expert, considering factors such as the explanation for the failure to identify the witness, the importance of the testimony, potential prejudice in allowing the testimony, and the availability of a continuance to cure such prejudice. The court also affirmed the grant of summary judgment to Avant on the basis of qualified immunity, noting that the plaintiffs failed to point to any case supporting the proposition that the alleged constitutional violation was of clearly established law. View "Culberson v. Clay County" on Justia Law

The case involves Adree Edmo, a transgender woman incarcerated in Idaho, who sued the State of Idaho, private prison company Corizon, and individual prison officials for failing to provide her with adequate medical care, including gender-confirmation surgery. Edmo alleged violations of the Eighth Amendment, the Fourteenth Amendment’s Equal Protection Clause, the Affordable Care Act, the Americans with Disabilities Act, and negligence under Idaho law. The district court granted an injunction on Edmo’s Eighth Amendment claim and ordered the defendants to provide her with adequate medical care, including gender-confirmation surgery. The court denied preliminary injunctive relief on Edmo’s Fourteenth Amendment and ACA claims because the record had not been sufficiently developed.The district court's decision was appealed, and the injunction was stayed. The Ninth Circuit Court of Appeals affirmed the district court’s decision except as it applied to five defendants in their individual capacities. After the Supreme Court denied a writ of certiorari, the parties engaged in settlement negotiations that led to Edmo voluntarily dismissing the remainder of her claims. The district court awarded Edmo $2,586,048.80 for attorneys’ fees incurred up until the injunction became permanent and all appeals were resolved.The Ninth Circuit Court of Appeals reversed in part, affirmed in part, and vacated in part the district court’s award of attorneys’ fees to Edmo. The court held that Edmo was entitled to fees incurred litigating her successful Eighth Amendment claim. However, the court found that the district court erred in calculating the lodestar amount to include fees incurred litigating unsuccessful claims advanced in the complaint, even if those claims were premised on the same facts that supported Edmo’s Eighth Amendment claim. The court also held that the district court did not err by applying an enhancement to the lodestar amount given that Edmo’s counsel operated under extraordinary time pressure and that the customary fee for counsel’s services is well above the PLRA cap. The case was remanded for recalculation of the lodestar amount to include only fees incurred litigating Edmo’s successful claim against the defendants who remained in the case. View "Edmo v. Corizon, Inc." on Justia Law