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Brief • July 20, 2010
Filed under: Government Misconduct
plaintiffs’ home based on what turned out to be incorrect information that a suspect named Kinte Carter lived there. Plaintiffs thereupon sued the individual officers under Bivens v. Six Unknown Named Agents ...
for help, and not wanting to trigger a move to what prisoners refer to as the “naked room,” will state that he is okay, and the questioner will move on. The “naked room” is an isolation cell that contains ...
Brief • October 19, 2015
conduct is inadequate and what harm, if any, the inadequacy has caused or will likely cause.” Salahuddin v. Goord, 467 F.3d 263, 280 (2d Cir. 2006), quoting Helling v. McKinney, 509 U.S. 25 (1993). Because ...
Brief • 2018
to meaningfully discuss with the petitioner what immigration consequences could . . . flow from the pleas. The petitioner alleged that Ignal’s representation was below that displayed by attorneys with ordinary ...
. at 45. It does not specify what these enactments are. GEO’s invitation to follow the intent, rather than the plain language, of § 1589 is unpersuasive. The TVPA criminalizes obtaining labor through threat ...
Brief • February 7, 2018
the PCR court nor the court of appeals appears to have considered the specific impact of counsel's error. Rather, both courts used what they considered "overwhelming evidence of guilt" as a categorical bar ...
objections raised by the defendants. 4 Case 1:18-cv-00013-JPJ-PMS Document 140 Filed 08/24/20 Page 5 of 27 Pageid#: 4237 (4th Cir. 2013). In the Fourth Circuit, “[t]o ascertain what is reasonable in terms ...
Brief • June 19, 2019
Complaint border on conclusory, but they are sufficient “to give [Hutchens and Park] fair notice of what the claim is and the grounds upon which it rests.” Twombly, 550 U.S. at 555 (internal alterations ...
Brief • October 31, 2018
criminal activity. According to Officer Esparza, they were traveling northbound on Fair Oaks Avenue, north of Woodbury Road, when the officers observed what was later determined to be a 2002 Mercedes S430 ...
Brief • August 28, 2015
Filed under: Food, Overcrowding, Sanitation
on June 23, 2015. (ECF No. 25.) 14 This Court’s order of August 14, 2015, requiring Defendants to produce the video- 15 recordings, forced Defendants to admit what they had done. In summary, from early ...
, policies and procedures, as well as expert testimony, will establish what reasonable officers under these circumstances would have done. Plaintiffs have also distilled their municipal liability claim down ...
not know, however, in what percentage of cases 22 defense attorney availability is the cause of delay because DSHS’s data keeping methodology 23 lumps together defense counsel availability with interpreter ...
Brief • February 15, 2001
is entitled to relief." The statement need not contain detailed facts, but it 1221*1221 "must give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Conley, 355 ...
Brief • March 1, 2019
Defendants cite Shedden v. United States, 101 F. App’x 114 (6th Cir. 2004), to support their contention that a failure to allege with specificity what each individual officer did to violate the constitutional ...
much he liked Plaintiff and that he needed to do what he was told in order for it to all go away. Plaintiff replied that he was not gay, that he has a family, but Defendant Allen stated it was the only ...
it . Nurse tine.. asked th e P l a intiff what did h e want her t o do . l' l r1int ifl Lold her he neeclecl h e l p , so L',DL i.L doesn't happen l1?'-ni n . 27 . On J u.Ly 12, 2016 , Pla intj f[ see n Jane ...
and Defendant Jane Doe, Plaintiff became desperate. 78. As a final cry for help, Plaintiff attempted to hang himself in a manner he believed would nol result in death. A correctional officer who saw what ...
Brief • April 16, 2015
Filed under: Excessive Force
training provided by the Custody Training & Standard Bureau on an inservice and refresher basis. 3.5 Unit Commanders should determine what additional training, counseling or mentoring may be required when ...
with the 17 County, administrative claims in substantial compliance with Cal. Gov't Code§ 910. The 18 19 claims sought compensation based on the basic facts of what occurred beginning 20 September 15, 2017 ...
. Williams asked Mitchell what happened in the store and why they were being chased by police. Mitchell responded with words to the effect of, “I just killed two people. Don’t you be the third one.” 7 Case ...
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