Justia Civil Rights Opinion Summaries

Three advocacy organizations filed suit against the South Carolina Department of Juvenile Justice and its executive director, seeking institutional reforms to address alleged unconstitutional and unlawful conditions in the state’s juvenile detention facilities. The plaintiffs alleged that the facilities were overcrowded, understaffed, and dangerous, resulting in violence, isolation, and inadequate services for juveniles. They based their standing on their advocacy and direct representation work with affected youth, and described both the harm to juveniles and the impact on their own organizational missions.The United States District Court for the District of South Carolina dismissed the complaint without prejudice. The district court found that Disability Rights South Carolina (DRSC) had standing to sue on behalf of certain juveniles, but those claims were rendered moot when those juveniles left custody. The court also determined that Justice 360 had standing in its own right but concluded that its claims failed on the merits. The South Carolina State Conference of the NAACP was found to lack standing. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Fourth Circuit held that the advocacy organizations lacked Article III standing to pursue the claims because they failed to demonstrate a sufficient personal stake in the outcome. The court found that DRSC did not meet the requirements for associational standing as its constituents lacked indicia of membership. The court also concluded that none of the organizations suffered a cognizable injury directly caused by the defendants’ actions, but rather incurred self-imposed costs through voluntary advocacy. The court further held that the plaintiffs could not bring claims under 42 U.S.C. § 1983 for the violation of rights belonging to others, as they had not alleged violations of their own federal rights. The dismissal was affirmed. View "South Carolina State Conference of the NAACP v. South Carolina Department of Juvenile Justice" on Justia Law

A group of individuals traveling through Kansas were stopped by Kansas Highway Patrol (KHP) troopers while driving on interstate highways, primarily I-70. In each instance, the drivers and passengers were from out of state, often driving to or from Colorado, and were stopped for alleged traffic violations. After the initial traffic stop was concluded, troopers used a tactic known as the “Kansas Two-Step”—they would briefly disengage, then reinitiate conversation in an attempt to gain consent for further questioning or searches. These stops often led to extended detentions and searches, but no contraband was discovered. The troopers testified that they considered the drivers’ out-of-state status, travel to or from Colorado, and other factors in developing reasonable suspicion.The individuals sued under 42 U.S.C. § 1983 in the United States District Court for the District of Kansas, alleging violations of their Fourth Amendment rights against unreasonable searches and seizures and their constitutional right to travel. Some plaintiffs also brought damages claims, resulting in jury verdicts in their favor. For their claims for injunctive relief, the district court conducted a bench trial and found that KHP had a pattern and practice of targeting out-of-state drivers and using the Two-Step in a manner violating the Fourth Amendment. The court granted a permanent injunction, requiring changes in KHP’s training, documentation, consent procedures, and supervision.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the plaintiffs had standing for injunctive relief and whether the district court abused its discretion in issuing the injunction. The Tenth Circuit held that the plaintiffs had standing because there was a substantial risk they would be stopped again and that KHP had a pattern of unconstitutional conduct. However, the Tenth Circuit found that the injunction was overly broad regarding the use of a driver’s state of origin and the Two-Step tactic. The court affirmed the injunction in part, reversed it in part, and remanded for further proceedings. View "Shaw v. Smith" on Justia Law

Two individuals active in a right-wing political organization alleged that government officials and entities in Portland, Oregon, conspired to arrest and prosecute them without probable cause in order to suppress their political speech. The plaintiffs claimed that city and county officials, various prosecutors, and a police detective orchestrated the investigation and charges after a confrontation at a bar, focusing their efforts on the plaintiffs while allegedly ignoring violent acts by left-wing activists. The plaintiffs were indicted and arrested before a planned protest, but ultimately acquitted at trial. They then sued, asserting violations of federal civil rights statutes and state tort law, including claims of conspiracy, malicious prosecution, and selective enforcement.After the plaintiffs’ acquittal, they filed their action in the United States District Court for the District of Oregon. The district court dismissed the complaint, holding that it was a “shotgun pleading” that failed to satisfy Federal Rule of Civil Procedure 8 because it lumped together claims and factual allegations without specifying which defendants were responsible for which acts. The court also ruled, in the alternative, that several defendants were immune from suit: the Multnomah County District Attorney’s Office (“MCDA”) and prosecutors in their official capacities under the Eleventh Amendment; the prosecutors in their individual capacities under absolute immunity; and the police detective for his grand jury testimony.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the complaint was properly dismissed as a shotgun pleading, but that plaintiffs must be allowed to amend. The court affirmed dismissal with prejudice of all claims against MCDA and prosecutors in their official capacities on sovereign immunity grounds, and against the prosecutors in their individual capacities to the extent their actions were prosecutorial. However, the court reversed the dismissal of claims against a deputy prosecutor for allegedly filing false affidavits, holding that such conduct is not protected by absolute immunity and is not shielded by qualified immunity if false statements were knowingly made to obtain a warrant. The court also reversed dismissal of certain state-law claims against Multnomah County and remanded for further proceedings, allowing plaintiffs to replead those claims not based on the acts of the immune parties. It affirmed immunity for the detective regarding his grand jury testimony. The disposition was affirmed in part, reversed in part, and remanded with instructions to permit amendment of the complaint. View "Gibson v. City of Portland" on Justia Law

A Macon County sheriff’s deputy in Alabama, while off duty but using a police vehicle after caring for his police dog, became intoxicated and drove his police truck at an excessive speed without headlights or emergency lights at night. The deputy struck another vehicle, causing it to overturn and resulting in the death of a passenger, Edwin Moss. After the collision, the deputy fled the scene. He was later indicted for felony reckless manslaughter. The administrator of Moss’s estate filed a lawsuit, bringing state law claims for wrongful death and a federal claim under 42 U.S.C. § 1983, alleging the deputy violated Moss’s substantive due process right to life under the Fourteenth Amendment by acting with deliberate indifference.The case was removed to the United States District Court for the Middle District of Alabama, where the defendant sought dismissal of the federal claim on grounds of qualified immunity and argued he was not acting under color of law. The district court denied the motion, finding that the complaint plausibly alleged the deputy acted under color of law and was not entitled to qualified immunity. Following the deputy’s death, his estate was substituted as appellant and appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed only the denial of qualified immunity, holding that it lacked jurisdiction to review the color of law determination on interlocutory appeal. The appellate court assumed for purposes of appeal that the deputy acted under color of law and within his discretionary authority. It concluded, however, that existing circuit precedent did not clearly establish that the deputy’s conduct constituted a constitutional violation for purposes of § 1983. Therefore, the Eleventh Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Hughes v. Locure" on Justia Law

A Nevada state prisoner claimed that, during the COVID-19 pandemic, staff at High Desert State Prison denied him outdoor exercise, even while requiring him and other inmates in his unit to work together in a prison industry warehouse. He alleged that inmates in other units were permitted outdoor yard time, and that the denial of exercise caused him physical and psychological harm. The plaintiff, housed in a protective segregation unit, asserted that these actions violated his rights under the Eighth and Fourteenth Amendments, as well as similar state constitutional provisions.After filing grievances that were denied at each level by prison officials, the inmate brought a lawsuit in the United States District Court for the District of Nevada against the warden and other prison staff under 42 U.S.C. § 1983. The district court screened the complaint and allowed certain claims, including those regarding denial of outdoor exercise and equal protection, to proceed against the warden. On summary judgment, the district court denied qualified immunity to the warden for both the Eighth Amendment and Fourteenth Amendment claims, prompting the warden to appeal.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court held that the district court correctly denied qualified immunity on the Eighth Amendment claim, finding that the right to outdoor exercise was clearly established and that there were triable issues as to whether the warden’s actions constituted deliberate indifference. However, the Ninth Circuit reversed the denial of qualified immunity on the Fourteenth Amendment claim, concluding that the plaintiff did not provide evidence that ruled out all rational justifications for the difference in yard time between his unit and others. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Cardenas-Ornelas v. Johnson" on Justia Law

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin.After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law.The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law

On February 1, 2018, Christopher Matusak was arrested in Scottsville, New York, after fleeing from police. Deputies from the Monroe County Sheriff’s Office, including Matthew Daminski, Stephen Murphy, and Sergeant Brian Unterborn, apprehended him using various forms of force, such as fist and knee strikes, pepper spray, and a taser, before handcuffing him. Matusak sustained injuries requiring hospitalization. He subsequently filed suit under 42 U.S.C. § 1983, alleging that the deputies violated his Fourth and Fourteenth Amendment rights by using excessive force during his arrest.The United States District Court for the Western District of New York presided over a jury trial. The jury determined that Deputy Daminski did not use excessive force, but found that Murphy and Unterborn did, awarding Matusak $200,000 in compensatory damages. However, the jury also found that, although Matusak did not actually pose a threat to officer safety, Murphy and Unterborn reasonably believed he did, and that Matusak was resisting their attempts to handcuff him. Based on the jury’s special verdicts, the district court granted judgment as a matter of law to Murphy and Unterborn, holding that they were entitled to qualified immunity because it was not clearly established that their conduct was unlawful under the circumstances.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Murphy and Unterborn were entitled to qualified immunity, reasoning that no clearly established law prohibited the use of significant force against an arrestee who was resisting and whom the officers reasonably, though mistakenly, believed posed a threat to officer safety. As it was objectively reasonable for the officers to believe their actions were lawful, the Second Circuit affirmed the district court’s judgment. View "Matusak v. Daminski" on Justia Law

The dispute arose after a citizen, Sanderson, served a summons and complaint on Kelley Cole, the Walsh County State’s Attorney, alleging that Cole failed to investigate crimes as required by law and deprived him of constitutional rights. Sanderson later claimed the complaint was mistakenly served and was only a draft, not intended for court filing. Cole, upon being served, filed the summons and complaint with the district court, moved to dismiss for failure to state a claim, and sought attorney’s fees, arguing the action was frivolous and barred by prosecutorial immunity.The District Court of Walsh County, Northeast Judicial District, reviewed the matter. Cole’s motion to dismiss was based on North Dakota’s procedural rules, which allow an action to commence upon service of summons, and permit a defendant to file the complaint. Sanderson responded by agreeing to dismiss but contested the court’s jurisdiction and objected to the lack of a hearing. The district court determined it had jurisdiction, found Sanderson had commenced the action, and concluded the complaint lacked factual allegations and was barred by absolute prosecutorial immunity. The court dismissed the action, denied Sanderson’s subsequent motions, and awarded Cole attorney’s fees, finding the claims frivolous.The Supreme Court of North Dakota affirmed the district court’s judgment. It held that jurisdiction was proper since Sanderson initiated the action by serving process, and procedural irregularities in filing did not affect substantial rights or deprive the court of jurisdiction. The Supreme Court agreed that the complaint failed to state a claim and that absolute prosecutorial immunity applied. It further upheld the finding of frivolousness and the award of attorney’s fees, determining there was no abuse of discretion or violation of procedural rights. View "Sanderson v. Cole" on Justia Law

A female custodian employed by a public university filed a Title IX complaint alleging physical assault and a pattern of sexual harassment by a male co-worker, both of whom were members of the same union. The university, which receives federal funding, initiated a Title IX grievance process compliant with 2020 federal Title IX Regulations. After an investigation and hearing in which both parties participated, university decision-makers found the accused violated university policy and determined there was just cause for his termination. The accused’s appeal within the Title IX process was unsuccessful, and he was terminated.The union representing the accused employee filed a grievance under its 2019 collective negotiation agreement (CNA) with the university, seeking arbitration to determine whether the termination was for just cause. The university denied the grievance, arguing that the federal Title IX Regulations preempted the CNA’s grievance procedure. The union sought arbitration through the New Jersey Public Employment Relations Commission (PERC), which denied the university’s request to restrain arbitration and held, applying state preemption law, that the Title IX Regulations did not preempt arbitration. The Superior Court, Appellate Division, affirmed, finding no conflict precluding the union’s grievance procedure.The Supreme Court of New Jersey reviewed the case and reversed the lower courts. The Court held that the CNA’s grievance procedure is preempted by the 2020 federal Title IX Regulations because those regulations require that any grievance or appeal process must apply equally to both complainant and respondent. The CNA’s arbitration process excluded the alleged victim from participation, granting rights only to the accused. The Court concluded that this inequality creates a direct conflict with federal law, which therefore preempts the CNA’s arbitration provision in this context. The decision is limited to this particular CNA and does not preempt all union grievance procedures. View "In the Matter of Rutgers, the State University of New Jersey v. AFSCME Local 888" on Justia Law

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law