Justia Civil Rights Opinion Summaries

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

A detainee, Kongchi Justin Thao, died by suicide while being temporarily held at a county jail facility in Oklahoma during a transfer to a federal facility in California. Upon arrival, Mr. Thao was placed in a holding pod for short-term inmates. After attempting to leave the pod, he was restrained, handcuffed, and, while being transported, was tased by an officer before being isolated in a shower cell (Cell 126) with no camera. Over the next hour and a half, Mr. Thao repeatedly cried out for help, expressed suicidal ideation, and asked to be killed. Officers told him to be quiet but did not intervene further. Mr. Thao was later found hanging in the cell and died as a result.The decedent’s estate, through his brother as special administrator, filed a lawsuit under 42 U.S.C. § 1983 against the Grady County Criminal Justice Authority (GCCJA), alleging violations of the Eighth Amendment for excessive force and deliberate indifference to serious medical needs. The United States District Court for the Western District of Oklahoma granted summary judgment to GCCJA on both claims. The district court found that the facility had not been deliberately indifferent, reasoning there was evidence of training for officers on suicide risks and inmate supervision, and that the GCCJA’s written use-of-force policy was not plainly unconstitutional.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the summary judgment for GCCJA regarding the excessive force claim, holding that the written taser policy was facially constitutional and that liability could not attach to the county for an officer’s violation of that policy. However, the appellate court reversed the grant of summary judgment on the deliberate indifference claim, finding genuine disputes of material fact about whether officers had adequate training to detect suicide risks in inmates like Mr. Thao. The case was remanded for further proceedings on the inadequate medical care claim. View "Thao v. Grady County Criminal Justice Authority" on Justia Law

The defendant was originally convicted in 2011 of felony possession of child pornography, which required him to register as a sex offender. In 2015, he was convicted of failing to register a change of address, an offense classified as a felony because his registration requirement was based on his prior felony conviction. Years later, after his child pornography conviction was reduced to a misdemeanor and dismissed, he sought to have his 2015 failure to register conviction likewise reduced to a misdemeanor and dismissed, citing his rehabilitation, lack of subsequent offenses, and support from family and associates.The Santa Cruz County Superior Court had previously granted the defendant’s motion to reduce his 2011 conviction to a misdemeanor and dismissed that case. However, when the defendant petitioned to reduce and dismiss his 2015 felony registration offense, the court denied the motion, finding that the offense was a straight felony, not a wobbler, and that it was not appropriate to dismiss the case. The defendant appealed, arguing that the later reduction of his underlying offense should retroactively affect the status of his 2015 conviction, or that the court should have exercised discretion to reduce or dismiss it in the interest of justice.The California Court of Appeal, Sixth Appellate District, affirmed the trial court’s order. The court held that the 2015 failure to register conviction was a straight felony under Penal Code section 290.018(b), and not subject to reduction under Penal Code section 17(b), which only applies to wobblers. The reduction of the underlying 2011 offense did not retroactively convert the 2015 conviction to a misdemeanor. The court also found no substantive due process violation, as the legislative scheme had a rational basis. Finally, the court found no abuse of discretion in denying dismissal under Penal Code section 1203.4. View "People v. Woodward" on Justia Law

In this case, the defendant was charged following two shootings in Buffalo, New York, that occurred about an hour apart on August 4, 2016, resulting in one death and three injuries. Key evidence included witness accounts and surveillance footage showing a shooter in distinctive clothing matching what the defendant wore earlier that day. Forensic testimony linked the fatal weapon to an individual depicted in the videos. After trial, the jury convicted the defendant of murder in the second degree, assault in the first degree, and criminal possession of a weapon in the second degree, while acquitting him of two counts of attempted murder.During jury deliberations, a juror raised concerns that another juror had made a racially biased remark. The trial judge questioned both the reporting juror and the accused juror individually, with input from counsel, but did not question other jurors. Defense counsel moved for a mistrial based on alleged racial bias affecting up to six jurors but declined to request further inquiry or substitution of jurors, relying solely on the mistrial request. The trial judge denied the motion, finding no convincing evidence of grossly unqualified jurors or racial animus affecting deliberations, and subsequently denied a post-verdict motion to set aside the verdict.The Appellate Division, Fourth Department, reviewed the trial court’s response and concluded that the judge had conducted an appropriate inquiry into the allegations and did not abuse discretion by denying the mistrial request. Upon further appeal, the New York State Court of Appeals held that the trial court’s inquiry was sufficient, that the record did not convincingly demonstrate a lack of impartiality among the jurors, and that the denial of the motion for a mistrial was not an abuse of discretion. The Court of Appeals therefore affirmed the order of the Appellate Division. View "People v Wiggins" on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law

A corrections officer employed by the Michigan Department of Corrections suffered a significant hip injury while performing his duties, which led to extended medical leave and ultimately permanent work restrictions. After exhausting his leave, he was placed in a transitional employment position within the department, but this assignment was temporary and not designed to be indefinite. The employee requested a permanent accommodation due to his ongoing disability, but the department denied the request, citing a lack of suitable vacancies. He then entered a leave status that preserved certain employment benefits but ended his active employment. During this period, he became the subject of workplace misconduct investigations, though the most serious allegations were not substantiated. After recovering from surgery, he sought reinstatement but was denied due to an unresolved disciplinary matter, and later declined offers to return to work.He brought suit in the United States District Court for the Eastern District of Michigan, alleging claims under § 504 of the Rehabilitation Act for failure to accommodate his disability and for retaliation in response to his accommodation request and related legal actions. The district court granted summary judgment to the defendants on the failure-to-accommodate claim, finding he was not qualified for his original position with or without reasonable accommodation. The retaliation claim was tried before a jury, which found for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit was asked to determine, among other issues, whether § 504 of the Rehabilitation Act provides a private cause of action for retaliation. The court held that it does not, concluding that neither the text of § 504 nor its cross-reference to the Americans with Disabilities Act unambiguously creates such a cause of action, as required for Spending Clause legislation. The court also affirmed the district court’s summary judgment on the failure-to-accommodate claim, finding no genuine dispute of material fact. The judgment for the defendants was affirmed. View "Smith v. Michigan Department of Corrections" on Justia Law

The plaintiffs in this case are entities that own and operate a four-story building in Kemah, Texas. The building houses a bar, residential rental units, and a food truck. The dispute began when, in July 2021, the city issued a zero-occupancy notice for the building after an inspection found multiple safety hazards, prohibiting anyone except the owner and repair contractors from entering. Plaintiffs allege this deprived them of almost all economic use of the property. Separately, the city took enforcement action against the food truck, culminating in its removal from the property in October 2021. Plaintiffs challenged the food truck towing in state court, but ultimately dropped their appeal. They then sued the city in federal court, raising federal and state takings, due process, and equal protection claims regarding both the zero-occupancy notice and the food truck towing, and sought declaratory relief.The United States District Court for the Southern District of Texas granted the city’s motion to dismiss. The court found the claims related to the zero-occupancy notice were not ripe because plaintiffs had not pursued available administrative appeals to the city council, as allegedly required by city ordinances. The court dismissed the food truck claims on the merits, and dismissed the request for declaratory relief because no substantive claims remained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred in dismissing the zero-occupancy notice claims as unripe. The appellate court determined that the city’s issuance of the zero-occupancy notice constituted a sufficiently final decision for purposes of ripeness and that exhaustion of administrative remedies is not required for claims under 42 U.S.C. § 1983. The court reversed the dismissal of the zero-occupancy notice claims and remanded those claims, including the related request for declaratory relief, for further proceedings. However, the court found that the plaintiffs had waived their food truck claims by failing to adequately brief them on appeal and affirmed their dismissal. View "T&W Holding v. City of Kemah, Texas" on Justia Law

A woman in Indiana was placed on probation in 2011 and assigned to probation officer Miroslav Radiceski in late 2012. Prior to this assignment, Radiceski’s supervisors, Chief Probation Officer Jan Parsons and Judge Clarence Murray, were aware of a previous complaint from a female probationer (A.R.) who reported that Radiceski had behaved inappropriately by asking personal questions and touching her to view her tattoos. After investigating, Parsons and Murray found no concrete proof and considered the incident an unsubstantiated allegation. They temporarily restricted Radiceski from supervising female probationers, but this was later lifted due to staffing shortages, and he was reassigned to supervise women, including the plaintiff. In 2013, Radiceski sexually assaulted and raped the plaintiff during her probation meetings. The plaintiff did not report the misconduct at the time, fearing retaliation and possible incarceration, but Radiceski was later suspended, fired, indicted, and convicted of official misconduct.The plaintiff filed a lawsuit in the United States District Court for the Northern District of Indiana under 42 U.S.C. § 1983 against various officials, including Parsons and Murray, alleging they were deliberately indifferent to her safety in violation of her Fourteenth Amendment rights. The district court granted summary judgment in favor of Parsons and Murray, finding they were entitled to qualified immunity because there was no clearly established law indicating their actions were unconstitutional. The plaintiff’s claim against Radiceski proceeded to trial, resulting in a verdict in her favor.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s entry of summary judgment. The Seventh Circuit held that Parsons and Murray were not deliberately indifferent because, although they were aware of troubling conduct, their response did not amount to a conscious disregard of a known risk of rape. The court concluded that qualified immunity protected the supervisors from liability. View "Bostic v. Vasquez" on Justia Law

A wealthy bond trader from New York, through a network of assistants, recruited women from across the United States to travel to his New York penthouse for what was represented as consensual sadomasochistic sexual encounters in exchange for money. The women were enticed with promises of cash, luxury experiences, and travel. However, once there, while some anticipated rough consensual sex, they were subjected to violent, nonconsensual acts, including severe physical abuse, sexual assault, and use of force far beyond what had been described or agreed to. The trader required the women to sign non-disclosure and purported consent agreements, often after they had used alcohol or drugs, and none received copies. The plaintiffs, six women, alleged lasting physical and psychological harm.The United States District Court for the Eastern District of New York conducted a jury trial on claims under the Trafficking Victims Protection Act (TVPA) and state tort law. After deliberation, the jury found the defendant liable under the TVPA and awarded each plaintiff $500,000 in compensatory damages. Five plaintiffs received $120,000 in punitive damages each, and one plaintiff received $250,000. The jury did not find the defendant’s assistants liable, except for one minor battery claim. The defendant’s post-trial motions for judgment as a matter of law or a new trial were denied.On appeal, the United States Court of Appeals for the Second Circuit reviewed challenges to the sufficiency of the evidence, the district court’s jury instructions, and the availability of punitive damages under the TVPA. The court held that sufficient evidence supported the jury’s verdict, the instructions properly conveyed the applicable law, and punitive damages are available under the TVPA. The Second Circuit affirmed the district court’s judgment in all respects. View "Moore v. Rubin" on Justia Law