Justia Constitutional Law Opinion Summaries

Stoudemire, then age 23, entered the Michigan Department of Corrections system in 2002, suffering from systemic lupus erythematosus, a chronic, painful autoimmune disease; hypercoagulapathy, a related disorder involving tendency to develop blood clots; and depression. Stoudemire bore a significant risk of experiencing kidney and liver damage, heart attacks, amputations, and chronic pain. Stoudemire’s health quickly deteriorated. She experienced a heart attack, liver failure, and life-threatening embolisms. She underwent three amputations, losing both legs below the knee. At her 2007 parole, she suffered from chronic depression, posttraumatic stress disorder, and conditions related to medications. In her suit under 42 U.S.C. 1983, the Americans with Disabilities Act, 42 U.S.C. 12132; and Michigan law, Stoudemire, alleged that she was placed in a segregation unit following her amputation that lacked accommodations for disabled persons, and was subjected to a strip search that served no legitimate purpose. The district court denied motions by the warden and an officer, seeking summary judgment on qualified immunity grounds. The Sixth Circuit vacated with respect to the warden, stating that the court did not adequately analyze deliberate indifference, but affirmed with respect to the officer, stating that the excessively invasive nature of the search outweighed any need to conduct it. View "Stoudemire v. MI Dep't of Corrs." on Justia Law

Luedtke, a pro se federal prisoner, sought a writ of habeas corpus under 28 U.S.C. 2241, alleging that prison officials violated his Thirteenth Amendment rights by refusing to pay him the wages he earned in his prison job, failed to require all inmates to work, discriminated against white inmates in favor of black inmates and “illegal aliens from Mexico,” and improperly placed him on refusal status for the Inmate Financial Responsibility Program. The district court dismissed under its screening authority, 28 U.S.C. 2243. The Seventh Circuit affirmed in part, stating that section 2241 is not the proper vehicle for a prisoner to challenge conditions of confinement. Luedtke’s fourth claim is cognizable under 2241 as a challenge to the execution of a portion of his sentence and the district court erred in dismissing it as unexhausted at the screening stage. Exhaustion is an affirmative defense, generally and in the context of prisoner lawsuits. Even under the Prison Litigation Reform Act, an inmate’s section 1983 claim “may not be dismissed at the screening stage for failure to plead or attach exhibits with proof of exhaustion.” The court denied Luedtke’s motion for appointment of counsel View "Luedtke v. Berkebile" on Justia Law

Susan called 911, seeking help for her 21-year-old son, Andrew, who had “overdosed on some kind of drugs.” EMS personnel waited outside for police per township policy. Sergeant Hunt informed dispatch that he had previously arrested heroin addicts who lived at the address. Hunt was admitted by Andrew’s father and observed Andrew looking very pale. Learning that Hunt was a police officer, Susan demanded that Hunt leave. Hunt explained that rescue personnel have a duty to check the victim, but will not enter a home without a police officer. Susan told Hunt that she was a nurse and that there was no longer any need for EMS. Hunt left and waited in the driveway with medical personnel. Other officers arrived and demanded that the door be opened or that Andrew be sent outside to be checked out. The Strickers continued to resist. A state police dispatcher recommended forced entry to help Andrew, considering Andrew’s history as a heroin user. Assistant Prosecutor Riley agreed that a forced entry was warranted. The officers entered and handcuffed the parents while they administered care to Andrew. The district court granted defendants summary judgment in the Stricklers’ suit under 42 U.S.C. 1983, finding that exigent circumstances justified all of the police’s actions. The Sixth Circuit affirmed. View "Stricker v. Twp. of Cambridge " on Justia Law

McClellan, then age 19, was convicted of first degree murder in connection with a barroom conflict between two groups. McClellan received a mandatory life sentence without parole and a consecutive two-year sentence for a firearm conviction. The district court granted a writ of habeas corpus on the ground that McClellan’s defense lawyer did not provide the effective assistance of counsel required by the Sixth Amendment because the lawyer did not interview numerous eyewitnesses who would have testified that McClellan acted in self-defense. The Sixth Circuit affirmed, rejecting the state’s assertions that the defense lawyer did not violate the ineffective assistance of counsel standard set out in Strickland v. Washington, 466 U.S. 668 (1984); that the district court should not have reached the merits because McClellan defaulted his claim by not raising it in a procedurally correct way; and that the Antiterrorism and Effective Death Penalty Act and recent Supreme Court cases so limit the federal courts’ authority to decide habeas cases on the merits that McClellan’s petition must be dismissed. View "McClellan v. Rapelje" on Justia Law

Columbus motorists reported a person driving erratically. One saw that the driver was a woman and that there was a child in the truck. Both witnessed the truck jump onto the median at least twice. One followed the truck, trying to help the police locate it. The truck crashed into a tree. At the scene, the police found Volpe, intoxicated and trapped behind the steering wheel. Volpe’s daughter, ejected from the truck, died days later from multiple injuries. Volpe was convicted on two counts of aggravated vehicular homicide (operating a vehicle while under the influence (OVI) and recklessly causing her daughter’s death), each with a specification that she had been convicted of three or more OVI or equivalent offenses within the last six years, and of OVI with a specification that she had been convicted of five or more equivalent offenses within the last 20 years. Volpe received a total prison term of 20 years and six months. She argued that convictions of both OVI, Ohio Rev. Code 4511.19(A)(1)(a), and aggravated vehicular homicide as a proximate result of OVI, 2903.06(A)(1)(a), violated the federal Double Jeopardy Clause. The Sixth Circuit affirmed the district court’s rejection of her habeas corpus petition. View "Volpe v. Trim" on Justia Law

Alman and Barnes are gay domestic partners. Alman was arrested in Westland, Michigan in 2007, during an undercover police operation in Hix Park, while taking a break from helping his mother move to a nearby apartment building. When officers arrived at the park, they observed Alman sitting on a picnic bench. A decoy officer sat down and struck up a conversation with Alman. The nature of the conversation and subsequent physical contact between the two is disputed. Alman was arrested; the charges were ultimately dropped. The car he was driving, which belonged to Barnes, was towed and impounded. In Alman’s suit under 42 U.S.C. 1983, the district court granted defendants summary judgment, finding that probable cause existed for the state and municipal offenses charged. The Sixth Circuit reversed in part, holding that there was no probable cause supporting any of the charges brought against Alman; that the officer was not shielded by qualified immunity; and that Alman had not stated a claim for malicious prosecution, for failure to train, or for abuse of process. View "Alman v. Reed" on Justia Law

In 1988, Thompson was murdered in Detroit. Bell was found guilty of felony murder and possessing a firearm while committing a felony. He was sentenced to life imprisonment without parole. On appeal he argued that counsel provided ineffective assistance in failing to interview two alibi witnesses and present them at trial. The conviction was affirmed on the merits by the Michigan Court of Appeals in 1992 and the state supreme court denied review. In 2006 Bell sought habeas corpus. Counsel was appointed and, while investigating, found what was believed to be material, relevant evidence not disclosed by the prosecution, in violation of Brady v. Maryland. The district court granted a stay and Michigan courts denied Bell’s claims on the merits. The district court granted Bell’s petition with regard to Brady and ineffective assistance of counsel. The Sixth Circuit reversed, holding that the district court did not properly defer to the trial court with respect to the alleged Brady violation and that Bell did not prove that it was more likely than not that no reasonable juror would have found him guilty. Equitable tolling was not appropriate; Bell’s ineffective-assistance claim remains precluded by AEDPA’s statute of limitations. View "Bell v. Howe" on Justia Law

The Office of the Racing Commissioner regulates the Michigan horse-racing industry. The ORC hires racing stewards as independent contractors to perform regulatory, judging, and enforcement functions in conjunction with three types of horse races. The plaintiffs were appointed as racing stewards in the 1980s and 1990s. Hall currently works as a state steward for the Michigan Gaming Board. Dye was appointed in 1988 and was promoted to Administrative Liaison Steward in 1998, but was demoted to State Steward in 2006 and was terminated in 2009. Perttunen was appointed in 1994, and remains employed as a racing steward for the Gaming Board. Erskine was appointed in 1999, and was terminated in 2009. The four claim that their Democratic supervisors retaliated against them for voicing support for or being perceived as affiliated with the Republican candidate in the 2006 gubernatorial election. Although certain stewards openly endorsed the candidate in the workplace, others remained silent. The district court granted the defendants summary judgment. The Sixth Circuit reversed the district court with respect to Dye’s protected-speech, holding that retaliation based on perceived political affiliation is actionable under the political-affiliation retaliation doctrine. View "Dye v. Office of the Racing Comm'n" on Justia Law

In 2008, Dixon, an African-American woman and then-interim Associate Vice President for Human Resources at the University of Toledo, wrote an op-ed column in the Toledo Free Press rebuking comparisons drawn between the civil-rights and gay-rights movements. Shortly thereafter, Dixon was fired. Claiming violations of her First and Fourteenth Amendment rights, Dixon filed a 42 U.S.C. 1983. The district court granted summary judgment to the defendants on all claims. The Sixth Circuit affirmed. The speech of a high-level Human Resources official who writes publicly against the very policies that her government employer charges her with creating, promoting, and enforcing is not protected speech. View "Dixon v. Univ. of Toledo" on Justia Law

The affidavit for a warrant for Fields’s arrest for misdemeanor domestic assault noted that arrest would be without bond. Three days later, Fields turned himself in. During booking, Fields requested to post bail. Told that he could not do so until the next day, Fields demanded to speak to a judge. There is no right under Tennessee law to post bail immediately after arrest. The Sheriff incorrectly stated that Fields had to be detained for 12 hours because he was charged with domestic assault. Under Tennessee law, domestic violence defendants must be held for 12 hours only if the official authorized to release the arrestee “finds that the offender is a threat to the alleged victim.” No such finding was made. The county admits that it had a policy of placing a 12-hour hold on all persons arrested for domestic violence regardless of individual circumstances. The next morning, a judge set bail and imposed conditions. Ten months later, prosecutors dropped the charge. Fields sued under 42 U.S.C. 1983, alleging violation of his Eighth Amendment right to be free from excessive bail and his right to procedural due process. The district court granted Henry County for summary judgment. The Sixth Circuit affirmed. View "Fields v. Henry Cnty." on Justia Law