Justia Civil Rights Opinion Summaries

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law

Matthew Metzler, an undergraduate student at Loyola University Chicago, was expelled in January 2017 after a university hearing board found him responsible for sexual misconduct involving another student, referred to as Jane Roe. The university’s Title IX process began after Roe reported feeling pressured into sexual acts without her consent. Initially, Roe declined to file a formal complaint, but later decided to do so after continuing distress. The university investigated, interviewed both parties, and considered evidence, including text messages and witness names provided by Metzler. The hearing board credited Roe’s account over Metzler’s based on the perceived consistency and credibility of her statements and found him responsible, resulting in expulsion. Metzler’s appeal was unsuccessful.Metzler filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, asserting claims under Title IX for unlawful sex discrimination and breach of contract due to alleged procedural irregularities in the disciplinary process. The district court granted summary judgment for Loyola, finding insufficient evidence that Metzler had been discriminated against based on sex or that contractual standards had been violated in a manner lacking rational basis. The case was briefly remanded for jurisdictional review and to determine anonymity, after which the district court reaffirmed its decision for Loyola.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that Metzler failed to present sufficient evidence for a reasonable factfinder to conclude that Loyola discriminated against him on the basis of sex under Title IX, even when considering generalized public pressure and procedural errors. The court further found that Metzler’s breach of contract claim failed because Loyola had a rational basis for its disciplinary decision. The judgment of the district court was affirmed. View "Metzler v Loyola University Chicago" on Justia Law

Margaret Woods, proceeding without an attorney, sued her former employer STS Services, L.L.C., after being terminated from her job. In her Third Amended Complaint, Woods alleged that she was fired because she is a black woman and replaced by white men. Earlier versions of her complaint included claims for breach of contract and race discrimination under 42 U.S.C. § 1981, which she abandoned, leaving only claims of race and sex discrimination under Title VII. Woods did not provide factual details about her qualifications for the position from which she was terminated.The United States District Court for the Northern District of Texas reviewed Woods’s successive complaints. Each time, the district court dismissed her complaints for failure to state a claim but allowed her opportunities to amend and refile. Woods submitted her Second Amended Complaint late, which was also dismissed. Her Third Amended Complaint was timely, but again found deficient for failing to plead facts regarding her qualifications. The court gave her another chance to amend, but Woods did not file a Fourth Amended Complaint within the deadline, or at all. The district court ultimately dismissed the case with prejudice and entered judgment in favor of STS Services, assessing costs against Woods.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The appellate court held that Woods failed to state a Title VII claim because her complaint did not include sufficient factual allegations to establish that she was qualified for her position, a necessary element of a prima facie case under Title VII. The Fifth Circuit also found that the district court did not abuse its discretion in dismissing Woods’s complaint with prejudice after repeated deficiencies and failures to amend. The judgment of the district court was affirmed. View "Woods v. STS Services" on Justia Law

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

Early in the morning, a security guard at a hotel in Oklahoma City called 911 to report an unauthorized individual, Dawawn McCoy, refusing to leave a guest’s room and appearing unable to walk. Sergeant Cassidy of the Oklahoma City Police Department responded, found McCoy noncompliant and apparently under the influence, and requested medical evaluation. After medical personnel determined McCoy did not need immediate attention and he refused care, police were instructed to arrest him for trespassing. Cassidy called for additional officers, and together the officers attempted to handcuff McCoy, who resisted physically by pulling his hands in and kicking. The officers used pepper spray and a taser to subdue him. Once handcuffed, McCoy was rolled onto his stomach and restrained further. For approximately ninety seconds, according to the district court’s findings, McCoy had stopped resisting but officers continued to apply force by holding a knee on his back and pressing his legs upward. McCoy stopped responding verbally and showed signs of medical distress. Officers later attempted resuscitation and administered Narcan, but McCoy died six days later in the hospital.In the United States District Court for the Western District of Oklahoma, LaQuita Bruner, as administrator of McCoy’s estate, brought suit against the officers under 42 U.S.C. § 1983 for excessive force and deliberate indifference to medical needs. The district court granted summary judgment for the officers on the deliberate indifference claim but denied it as to the excessive force claim, finding that a reasonable jury could conclude excessive force was used after McCoy was subdued.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity on the excessive force claim. The court held that, based on the facts found by the district court, the officers’ continued use of force after McCoy was subdued was objectively unreasonable and violated clearly established Fourth Amendment law. The case was remanded for further proceedings. View "Bruner v. Cassidy" on Justia Law

The case involves the death of Ramon Timothy Lopez following an encounter with Phoenix Police Department officers. After receiving reports of erratic behavior, officers pursued Lopez in a foot chase, subdued him, and restrained him with handcuffs and a RIPP hobble device. This restraint bent Lopez’s body into a hogtied position while he was face down. Despite Lopez's distress and visible signs of medical need, officers transported him in the back of a patrol vehicle in this position. He became unresponsive during transport and was later pronounced dead at the hospital. The medical examiner attributed his death to cardiac arrest in the context of methamphetamine intoxication, heart disease, and physical restraint.Plaintiff Laura Gonzalez, Lopez’s mother, filed suit in the United States District Court for the District of Arizona against the City of Phoenix and several officers, asserting claims under federal and state law, including excessive force under the Fourth Amendment. The district court granted summary judgment in part, dismissing claims of false arrest, Monell liability, and others, but denied summary judgment on the excessive force claim related to the officers’ actions after the RIPP restraint was applied, including the transportation of Lopez in the prone, hogtied position.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of qualified immunity. The Ninth Circuit affirmed the denial, holding that a reasonable jury could find the officers’ use of the RIPP restraint and the manner of transport unreasonable and excessive, given Lopez’s lack of resistance and medical distress. The court found that precedent in the Ninth Circuit clearly established that continued use of force or refusal to alleviate its harmful effects against a helpless detainee constitutes excessive force. The case was remanded for further proceedings. View "GONZALEZ V. CITY OF PHOENIX" on Justia Law

On December 25, 2019, a patrol sergeant noticed a van idling in a driveway, twice encountered it, and approached the vehicle. The driver, Raymond Kelley, identified himself and his residence. The sergeant observed signs of alcohol and learned Kelley had a prior DUI and an active warrant. Kelley exited, was patted down, and sat on a wall; after asking to call his wife and being denied, Kelley ran up the driveway. The sergeant pursued and tackled Kelley, gaining control of his wrist. A deputy arrived after Kelley was tackled and assisted with handcuffing. Kelley complained of an arm injury, received medical attention, and was cited for public intoxication and resisting law enforcement before being released. Disputed facts center on the degree of Kelley’s resistance and the force used during handcuffing.Kelley sued under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force against the officers in both their official and individual capacities. The United States District Court for the Eastern District of Arkansas granted summary judgment to the officers on the false arrest claim and on all claims against them in their official capacities. However, the court denied qualified immunity to both officers on the excessive force claim in their individual capacities, finding that disputed facts about Kelley’s conduct and the techniques used precluded summary judgment and should be resolved by a jury.Reviewing this interlocutory appeal, the United States Court of Appeals for the Eighth Circuit determined that the district court erred by failing to construe disputed facts in the light most favorable to Kelley and by not completing the required two-prong qualified immunity analysis. The Eighth Circuit vacated the district court’s order denying qualified immunity and remanded the case for a more detailed assessment, instructing the district court to consider both prongs of the qualified immunity analysis after properly construing the facts. View "Kelley v. Pruett" on Justia Law

Police officers in Rosenberg, Texas conducted a high-risk stop of a white Dodge Charger matching the description of a vehicle involved in a report of armed suspects. The only occupants were Michael Lewis and Regina Armstead, an elderly couple. Lewis had a dialysis-related stent in his left forearm, which could be damaged by placing handcuffs on that arm. During the stop, Lewis was handcuffed for about six minutes, reportedly experiencing pain. He later discovered his stent had been damaged and required surgery. Armstead informed an officer that Lewis was a dialysis patient, and Lewis claimed he told officers about his condition both before and after being handcuffed, though his statements were inconsistent.Lewis and Armstead filed suit in the United States District Court for the Southern District of Texas against the City, the police department, and the officers, including an excessive force claim. After a magistrate judge’s recommendation, the district court granted qualified immunity on most claims but denied it on Lewis’s excessive force claim against the five officers, finding a genuine dispute of material fact as to when the officers were informed about Lewis’s medical condition. The officers appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of qualified immunity de novo. The Fifth Circuit held that the officers did not violate any clearly established law by briefly handcuffing Lewis during a high-risk stop, regardless of whether they had advance notice of his medical condition. The court found that relevant precedent did not place the constitutional question beyond debate under the circumstances, and thus, the officers were entitled to qualified immunity. The Fifth Circuit reversed the district court’s denial of qualified immunity. View "Lewis v. Delgado" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law