Justia Civil Rights Opinion Summaries

The case involves three plaintiffs, Xingjian Sun, Xing Zhao, and Ao Wang, who sued their professor, Gary Gang Xu, for various allegations. Sun and Zhao, former students at the University of Illinois at Urbana-Champaign, accused Xu of sexual and emotional abuse. Wang, a professor at Wesleyan University, posted online that Xu had a history of sexually assaulting students. In response, Xu allegedly posted negative comments about Wang and sent a letter to his employer. Xu counterclaimed, asserting a defamation claim against Sun and claims for intentional infliction of emotional distress against all three plaintiffs.The case was tried in the United States District Court for the Central District of Illinois, where a jury found in favor of Xu on all issues and awarded him damages against Sun and Wang. The plaintiffs appealed, arguing that the district court erred in denying their motion for judgment as a matter of law regarding Xu’s intentional infliction of emotional distress counterclaims. They also contended that the district court erred in denying their motion for a new trial, based on the court’s decision to admit evidence that Sun had a relationship with another professor.The United States Court of Appeals for the Seventh Circuit reversed the judgment in favor of Xu on his counterclaim against Wang, finding that no reasonable jury could find Wang's conduct extreme and outrageous under Illinois law. However, the court affirmed the judgment in favor of Xu on his counterclaim against Sun, concluding that a reasonable jury could find that Sun's conduct met the requirements for intentional infliction of emotional distress. The court also affirmed the district court's denial of the plaintiffs' motion for a new trial. View "Sun v. Xu" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The case involves Maria Acosta, who sued six Miami-Dade officers involved in the arrest of her son, Maykel Barrera, who died after the encounter. Acosta alleged federal excessive-force claims and state wrongful-death claims. The district court granted summary judgment to the officers, and Acosta appealed. The United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting summary judgment to five of the six officers on Acosta’s excessive-force claims and to all of the officers on Acosta’s wrongful-death claims.The Court of Appeals found that, viewing the facts in the light most favorable to Acosta, the officers used excessive force when they tased and kicked Barrera while he was subdued, on the ground, and no longer resisting arrest, violating clearly established Fourth Amendment rights.Furthermore, the court vacated the summary judgment on Acosta’s wrongful-death claim, concluding that there was enough evidence for the case to go to trial. The court ruled that the district court erred in emphasizing Acosta’s lack of expert evidence directed to the cause of Barrera’s death since she did not have to present expert testimony to show causation. View "Acosta v. Miami-Dade County" on Justia Law

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

This case revolves around the fatal shooting of Daniel Hernandez by Officer Toni McBride of the Los Angeles Police Department (LAPD). Hernandez's estate and family members filed a lawsuit against McBride, the LAPD, and the City of Los Angeles, alleging violations of Hernandez's Fourth Amendment rights, the family members' Fourteenth Amendment rights, and several state law claims.The United States Court of Appeals for the Ninth Circuit concluded that a reasonable jury could find that the force McBride used in her final two shots was excessive, but she was entitled to qualified immunity because she did not violate clearly established law. The court explained that while the Fourth Amendment excessive force claim could proceed to trial, McBride was protected by qualified immunity because no prior case law established that her conduct was unlawful.The court also dismissed the Fourteenth Amendment claim, stating that plaintiffs failed to show that McBride acted with a purpose to harm without regard to legitimate law enforcement objectives. The court further ruled that the Monell claim against the City of Los Angeles and the LAPD failed because even if there was an underlying constitutional violation, plaintiffs failed to provide any basis for holding the City and LAPD liable for McBride’s actions.However, the court reversed the dismissal of plaintiffs' state law claims for assault, wrongful death, and violation of the Bane Act, determining that the reasonableness of McBride's final shots presented a question for a trier of fact. The court thus sent these claims back to the district court for further proceedings. View "In re Estate of Hernandez v. City of Los Angeles" on Justia Law

In June 2020, a local newspaper in Polk County published an article criticizing a local assistant district attorney, Tommy Coleman. The article claimed that Coleman had "assisted with the prosecution of Michael Morton" while he was a prosecutor in Williamson County. Michael Morton was wrongfully convicted in 1987 due to prosecutorial misconduct, a conviction that occurred before Coleman began practicing law. Morton was exonerated in 2011 after spending nearly 25 years in prison. The article specifically highlighted an instance during a post-conviction hearing where Coleman mocked requests for DNA testing of evidence that would eventually exonerate Morton. Coleman sued the newspaper and its author for defamation, arguing that the claim that he assisted in Morton's prosecution was false and defamatory.The Supreme Court of Texas held that the article's statement that Coleman "assisted with the prosecution of Michael Morton" was substantially true given Coleman’s public involvement in his office’s efforts to resist DNA testing of the evidence that exonerated Morton. The Court ruled that even if the article was not precise in its characterization of Coleman's role, the "gist" of the article - that Coleman supported the efforts to keep Morton behind bars by resisting DNA testing - was substantially true and therefore not actionably defamatory. As such, Coleman's claims were dismissed. View "POLK COUNTY PUBLISHING COMPANY v. COLEMAN" on Justia Law

A plaintiff, Robert Trebelhorn, suffered a serious knee injury at his apartment complex when a section of an elevated walkway collapsed due to deterioration. The defendants, Prime Wimbledon SPE, LLC, and Prime Administration, LLC, who owned and managed the apartment complex, were aware of the deteriorated condition of the walkway but chose not to repair it. Trebelhorn sued the defendants for negligence and violation of Oregon's Residential Landlord-Tenant Act and won. The jury awarded him just under $300,000 in damages and also imposed punitive damages of $10 million against each defendant. On post-verdict review, the trial court concluded that although the evidence supported some amount of punitive damages, the amount of $10 million would violate the defendants' due process rights. The trial court reduced the punitive damages to just under $2.7 million against each defendant. On cross-appeals, the Court of Appeals agreed with the trial court and affirmed. The Supreme Court of the State of Oregon also agreed with the trial court that $10 million in punitive damages would violate the defendants' due process rights and affirmed the judgment of the trial court and the decision of the Court of Appeals. View "Trebelhorn v. Prime Wimbledon SPE, LLC" on Justia Law

This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law

Edward Zaragoza, an inmate suffering from hypothyroidism, filed a lawsuit against three prison physicians and their employer. Zaragoza claimed that the doctors' treatment decisions, specifically their refusal to provide alternative medication despite the severe side effects he experienced from the prescribed medication, amounted to medical malpractice and deliberate indifference to his serious medical needs. The Indiana Supreme Court found that Zaragoza's expert's affidavit, which challenged the doctors' treatment decisions, was both admissible and substantively sufficient to create an issue of fact in the malpractice case. The court also found that there were disputes over whether the doctors knowingly failed to offer Zaragoza a potentially safer alternative medication. Thus, the court ruled that summary judgment was not warranted and reversed the trial court's decision, allowing Zaragoza's claims to proceed to trial. The court emphasized that summary judgment is not a summary trial and that genuine issues of material fact remained to be determined by a factfinder after a trial. View "Zaragoza v. Wexford of Indiana, LLC" on Justia Law

In the early morning hours of August 1, 2018, Gwendolyn Adams and Glenn Tyler Bolden were pursued in a high-speed chase by Michael William Becker, a peace officer employed by the California Department of Corrections and Rehabilitation (CDCR). Becker suspected Adams and Bolden of wrongdoing, although his suspicions were unfounded. The pursuit resulted in a catastrophic accident that caused severe injuries and, ultimately, the death of Adams's son, D'son Woods.Adams and Bolden filed a lawsuit against the CDCR, alleging negligence causing wrongful death, assault and battery, and violation of the Tom Bane Civil Rights Act. The CDCR sought summary judgment, arguing that Becker was not acting within the scope of his employment during the pursuit. The trial court agreed and entered judgment in favor of CDCR.On appeal, the Court of Appeal of the State of California Fourth Appellate District Division Three reversed and remanded the case. The appellate court found that whether Becker was acting within the scope of his employment when he pursued Adams and Bolden was a question of fact that should be decided by a jury. The court noted that Becker’s actions may have been influenced by his role as a peace officer, and it was not clear whether he was acting as a private citizen or a law enforcement officer during the pursuit. Therefore, the trial court erred in granting summary judgment to the CDCR. View "Adams v. Dept of Corrections and Rehabilitation" on Justia Law