Justia Civil Rights Opinion Summaries

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After a jury trial, Appellant was convicted of two counts of unlawful possession of a loaded firearm and one count of possession of a firearm without a license. Appellant appealed, arguing that the Commonwealth failed to demonstrate that the police had reasonable suspicion to conduct an investigatory stop of his vehicle, and therefore, the trial court erred in denying his motion to suppress. The Court of Appeals agreed with Appellant and reversed the judgments of conviction, the verdicts, and the motion to suppress, holding that the police did not have reasonable suspicion to conduct the investigatory stop. View "Commonwealth v. Pinto" on Justia Law

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Plaintiff filed suit alleging, inter alia, violation of his First and Fourth Amendment rights after he was silenced and then ejected at a city council meeting. The court dismissed Councilman Roberts's appeal of the district court's denial of summary judgment based on qualified immunity because a factual dispute exists as to whether Roberts's conduct was viewpoint-based; affirmed the district court's grant of summary judgment for Roberts as to punitive damages where there is no question that Roberts's conduct did not rise to the level of reckless indifference or evil intent; affirmed the district court's grant of summary judgment for Black on the First Amendment claim because his actions as sergeant-at-arms were not objectively unreasonable in light of clearly established law; affirmed the district court's grant of summary judgment for Black on the Fourth Amendment claim based on qualified immunity; affirmed the district court's grant of summary judgment on the false arrest claim; and dismissed Black’s cross-appeal on the state tort claims for lack of jurisdiction. View "Heaney v. Roberts" on Justia Law

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Plaintiff filed suit challenging the procedure for contesting parking citations pursuant to the California Vehicle Code. Plaintiff filed a putative class action against various city officials alleging 42 U.S.C. 1983 claims for due process violations, malicious prosecution, conspiracy, and Monell liability, as well as a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq. The district court dismissed plaintiff's claims with prejudice. The court rejected plaintiff's claim for violation of procedural due process based on the Code's deposit requirement given the availability of prompt post-deprivation review and correction. The court explained that plaintiff's modest interest in temporarily retaining the amount of a parking penalty is outweighed by the City’s more substantial interests in discouraging dilatory challenges, promptly collecting penalties, and conserving scarce resources. The court also rejected plaintiff's substantive due process challenge, concluding that plaintiff has failed to allege conduct so egregious as to amount to an abuse of power lacking any reasonable justification in the service of a legitimate governmental objective. Because plaintiff has not alleged a violation of his constitutional rights, he cannot maintain derivative constitutional claims based on that conduct. The court rejected plaintiff's remaining claims and agreed with the district court's denial of leave to amend based on futility. Accordingly, the court affirmed the judgment. View "Yagman v. Garcetti" on Justia Law

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Defendant was indicted for multiple firearms offenses, among other offenses. Defendant moved to suppress evidence seized during the search of a motor vehicle he had been driving. A superior court judge allowed the motion, concluding that, at the time a police officer stopped and seized the vehicle, the officer lacked a reasonable, articulable suspicion that criminal activity was afoot. The Supreme Judicial Court reversed the motion judge’s order allowing the motion to suppress, holding (1) the investigatory stop was predicated on reasonable suspicion of criminal activity; and (2) the officer’s actions were “reasonably related in scope to the circumstances which justified the interference in the first place.” View "Commonwealth v. Edwards" on Justia Law

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A student was dismissed from a Ph.D. program at the University of Alaska Fairbanks after several years of poor performance and negative feedback. She claimed that her advisors discriminated and retaliated against her, that she was dismissed in violation of due process, and that the University breached duties owed to her under an implied contract. After review, the Alaska Supreme Court affirmed the superior court's decision to uphold the University's action because the student was dismissed based on her poor research performance and the dismissal was conducted under adequate procedures and within accepted academic norms. View "Horner-Neufeld v. University of Alaska Fairbanks" on Justia Law

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HansaWorld USA, Inc. (HansaWorld) registered a foreign judgment with a Mississippi circuit court against Kimberlee Davenport from an award ordered by a court in Florida on claims of conversion and extortion. Davenport, a former employee of HansaWorld, also maintained claims against HansaWorld in a separate action before a federal district court in Mississippi alleging several violations of state and federal law, including Title VII of the Civil Rights Act for sexual harassment and discrimination. HansaWorld sought to collect on its foreign judgment by petitioning the circuit court to sell Davenport’s Employment Action, so the circuit court entered a Writ of Execution. With the Employment Action set to be auctioned off by the Forrest County sheriff, Davenport filed an Emergency Motion to Quash Writ of Execution mere days before the scheduled sale. At a hearing on the motion, the circuit court granted Davenport’s motion to quash on the condition that she post a $100,000 bond by that afternoon, the day of the scheduled sheriff’s sale. Davenport failed to post the conditional bond, and as a result, the sheriff sold her Employment Action to the highest bidder, HansaWorld, for $1,000. Following sale of her Employment Action, Davenport appealed to the Supreme Court. Having determined that the circuit court’s order was a final, appealable judgment and that the Supreme Court has jurisdiction to hear the appeal, the Supreme Court concluded that Davenport waived her right to challenge the circuit court’s imposition of the bond on appeal because she failed to challenge the bond before the circuit court. View "Davenport v. Hansaworld, USA, Inc." on Justia Law

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After plaintiffs' convictions for rape and murder were vacated and they had served eighteen years in prison, plaintiff filed suit alleging, inter alia, malicious prosecution and denial of fair trial claims. Defendant, as executrix of the Estate of Joseph Volpe, appealed the district court's judgment for plaintiffs. Volpe was a homicide detective that investigated the rape and murder case. The court concluded that the district court did not abuse its discretion in determining that a new trial was warranted; the court rejected defendant's evidentiary challenges; the court rejected defendant's argument that a conflict of interest deprived Volpe of a fair trial; the district court correctly denied Volpe's request for a setoff; the court denied Volpe's motion for remittitur and concluded that the district court did not abuse its discretion in holding that the jury award did not shock the conscience or materially deviate from what would be reasonable compensation; and the court affirmed the district court's award of attorney fees. Because the court found no basis for reversal, the court affirmed the judgment. View "Restivo v. Hessemann" on Justia Law

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Plaintiffs filed suit challenging Mo. Rev. Stat. 311.070.4(10) and its regulations, which detail the information alcohol manufacturers, wholesalers, distributors, and retailers can include in their advertisements. Plaintiffs alleged a violation of their freedom of speech under the First Amendment because the challenged provisions prohibit truthful, non-misleading commercial speech and restrict the free flow of truthful information to potential customers. Plaintiffs also claim that the provisions are inconsistently enforced. The district court granted defendants' motion to dismiss. The court reversed, concluding that the amended complaint included sufficient allegations that the challenged provisions did not directly advance the substantial interest of promoting responsible drinking and the amended complaint included more than sufficient information to plead the challenged restrictions are more extensive than necessary. The court found it clear that there are reasonable alternatives to the challenged restrictions Missouri could have enacted that are less intrusive to plaintiffs’ First Amendment rights. Finally, plaintiffs have pled that the provisions unconstitutionally compel speech and association. View "Missouri Broadcasters Association v. Lacy" on Justia Law

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Semmie John Guenther, Jr., filed an administrative charge with the EEOC, alleging that his former employer, Griffin Construction, discriminated against him on the basis of his disability, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. When Guenther passed away while his charge was pending, the special administrator of his estate filed suit on his behalf when he received the EEOC right-to-sue letter. The district court dismissed the action based on Ark. Code Ann. 16-62-101(a)(1) and found the claim had abated. The court held that federal common law does not incorporate state law to determine whether an ADA claim for compensatory damages survives or abates upon the death of the aggrieved party. The court joined its sister circuits that have allowed the individual’s estate to bring and maintain a suit for compensatory damages under the ADA in place of the aggrieved party. Therefore, Guenther’s ADA claim for compensatory damages survived his death and Griffin Construction is not entitled to judgment on the pleadings. The court reversed and remanded for further proceedings. View "Guenther v. Griffin Construction Co." on Justia Law

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After plaintiff was released from a twenty-year period of commitment when a jury found him responsible by reason of insanity, he filed suit against various psychologists, psychiatrists, and other employees, alleging medical malpractice under Nebraska state law. Plaintiff also alleged violation of his constitutional rights to be free from unnecessary confinement and free from retaliation for seeking access to courts. The court concluded that the district court did not err by dismissing the medical malpractice claim where plaintiff failed to comply with the requirements set forth by Nebraska's State Tort Claims Act (STCA), Neb. Rev. Stat. 81-8, 209 et seq. Assuming that Nebraska waived its sovereign immunity, plaintiff still failed to bring the suit in the district court of the county in which the act or omission occurred pursuant to the STCA. In regard to the district court's dismissal of the unnecessary confinement claim, the court concluded that plaintiff only alleged defendants' actions were negligent or, at worst, grossly negligent. Therefore, defendants are entitled to qualified immunity where actions that are merely negligent or grossly negligent do no implicate the protections of the Due Process Clause. Finally, the court affirmed the district court's dismissal of plaintiff's retaliation claim where plaintiff failed to address the claim in his opening brief. View "Montin v. Moore" on Justia Law