Justia Civil Rights Opinion Summaries

James Williams, at midnight on New Year’s Day in Canton, Ohio, fired numerous shots into the air from a patio enclosed by a wooden privacy fence as part of a celebratory tradition. Officer Robert Huber, responding to the gunfire, arrived at the scene and witnessed Williams begin a second round of shooting. Without announcing his presence or issuing a warning, Huber shot Williams through the fence, resulting in Williams’s death. Williams’s wife sued Huber and the City of Canton, alleging excessive force under the Fourth Amendment and municipal liability.The United States District Court for the Northern District of Ohio reviewed Huber’s motion for summary judgment based on qualified immunity. The court determined that there was a genuine dispute of material fact regarding whether Williams had turned his rifle toward Huber or continued firing into the air, and whether celebratory gunfire was common in Canton at that time. Based on these unresolved factual questions, the district court denied Huber’s motion for summary judgment, finding that a reasonable jury could conclude Huber lacked probable cause to believe Williams posed a threat sufficient to justify deadly force.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of summary judgment. The Sixth Circuit held that, construing the facts in the light most favorable to Williams’s wife, Huber violated the Fourth Amendment by using deadly force without probable cause to believe Williams posed a threat of serious physical harm. The court further concluded that this violation was clearly established law in an “obvious” case, as no reasonable officer would have believed it permissible to shoot a person committing a misdemeanor—discharging a gun into the air in celebration—without warning or evidence of a threat. View "Williams v. City of Canton" on Justia Law

Police officers in Calumet City, Illinois, responded to a 911 call in May 2015 reporting a man allegedly throwing a knife near a home. Upon arrival, officers spoke with the caller, who identified the suspect entering a residence. The officers knocked on the door, exchanged words with someone inside who told them to leave, and later decided to enter through an unlocked back door without a warrant, citing concerns for the safety of occupants due to a recent domestic violence report involving the address. Inside, officers found a woman who appeared unhurt and ultimately located Elias Villalobos hiding upstairs. The parties dispute whether Villalobos resisted or threatened the officers before he was tased and shot.Villalobos sued four officers in the United States District Court for the Northern District of Illinois, Eastern Division, alleging excessive force and unlawful entry under the Fourth Amendment. At summary judgment, the district court denied qualified immunity for most excessive force claims, finding factual disputes for trial. On the unlawful entry claim, however, the court granted partial summary judgment for Villalobos, concluding as a matter of law that the officers violated the Fourth Amendment by entering without a warrant and rejecting the officers’ exigent circumstances argument.The United States Court of Appeals for the Seventh Circuit reviewed only the denial of qualified immunity on the unlawful entry issue. The Seventh Circuit vacated the district court’s order, finding that the lower court did not address whether clearly established law put the officers on notice that their conduct was unlawful, as required for denying qualified immunity. The appellate court also noted unresolved factual disputes relevant to the exigent circumstances analysis. The case was remanded for further proceedings, instructing the district court to clarify the facts and address both prongs of the qualified immunity test. View "Villalobos v. Picicco" on Justia Law

The plaintiff, a white male, served for decades in the Borough of Bergenfield’s Police Department and was acting as Officer In Charge in 2019. When the Chief position became available, he sought the promotion but was denied in favor of another candidate, an Arab-Muslim male. The plaintiff alleged that the decision was based on racial and religious discrimination, pointing to statements and actions by council members and the Borough Administrator suggesting that race and religion played a role. He brought claims under New Jersey’s Law Against Discrimination (NJLAD), 42 U.S.C. § 1983 (Equal Protection), and 42 U.S.C. § 1981.The case was first reviewed by the U.S. District Court for the District of New Jersey, which granted summary judgment in favor of the defendants on all claims. Regarding the NJLAD claim, the court relied on New Jersey’s “Background Circumstances Rule,” requiring majority-group plaintiffs to show that they were victimized by an employer who discriminates against the majority. The court also found that the plaintiff failed to adequately rebut the defendants’ justifications. It further held that § 1983 did not provide a remedy for employment discrimination claims and that § 1981 did not support a private cause of action.The U.S. Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the Background Circumstances Rule is incompatible with the text of the NJLAD and predicted that the Supreme Court of New Jersey would follow the U.S. Supreme Court’s ruling in Ames v. Ohio Dep’t of Youth Servs., striking down the rule for state law claims. It reversed the District Court’s summary judgment on the NJLAD and § 1983 claims, finding genuine disputes of material fact requiring a trial. The court affirmed the summary judgment on the § 1981 claim and remanded for further proceedings. View "Massey v. Borough of Bergenfield" on Justia Law

The case involves a defendant who, while guarding a cache of drugs and money, opened fire on law enforcement officers, wounding one but not fatally due to protective gear. He was indicted by a federal grand jury on several charges, including attempted murder of federal officers and using a firearm during a crime of violence under 18 U.S.C. § 924(c). Under a plea agreement, he pleaded guilty to two counts of attempted murder, one § 924(c) count (with attempted murder as the predicate crime of violence), and a firearm possession charge, waiving most rights to appeal or collaterally attack his conviction. In exchange, the government dropped other charges and agreed not to prosecute his son.After his conviction, the defendant pursued multiple post-conviction relief motions under 28 U.S.C. § 2255, all unsuccessful. Following the Supreme Court’s decision in United States v. Davis, which invalidated the “residual clause” of § 924(c)’s definition of “crime of violence” as unconstitutionally vague, he sought authorization to file a successive § 2255 motion. The United States Court of Appeals for the Tenth Circuit granted authorization, and the District of Utah considered the merits. The district court denied relief, concluding the plea waiver barred relief and, alternatively, that the defendant failed to show the sentencing court relied on the residual clause.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the § 2255 motion. The court held that the defendant did not prove by a preponderance of the evidence that the sentencing court relied on the now-invalid residual clause when applying § 924(c). The court further affirmed that attempted murder qualifies as a “crime of violence” under the still-valid “elements clause” of § 924(c). The Tenth Circuit affirmed the district court’s denial of post-conviction relief. View "United States v. Sandoval-Flores" on Justia Law

In the fall of 2025, federal immigration authorities increased enforcement activities in Chicago through “Operation Midway Blitz,” prompting protests near an Immigration and Customs Enforcement (ICE) detention center in Broadview, Illinois. Protesters and journalists alleged that federal officers from ICE, Customs and Border Protection (CBP), and the Department of Homeland Security (DHS) violated their First and Fourth Amendment rights by deploying tear gas and other chemical agents without justification. The plaintiffs described instances of excessive force and sought injunctive relief to stop such practices.The United States District Court for the Northern District of Illinois issued a temporary restraining order and later a broad preliminary injunction that applied districtwide, enjoining all federal law enforcement officers and agencies from using certain crowd control tactics. The court also certified a plaintiff class and required ongoing compliance reporting from DHS officials. The government appealed the preliminary injunction, arguing it was overbroad and infringed on separation of powers principles. The United States Court of Appeals for the Seventh Circuit stayed the injunction, citing its expansive scope and concerns over standing.Subsequently, as the enforcement operation ended and no further constitutional violations were reported, the plaintiffs moved to dismiss the case. The district court dismissed the case without prejudice and decertified the class, contrary to the plaintiffs’ request for dismissal with prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit found that extraordinary circumstances warranted vacating the district court’s preliminary injunction. The Seventh Circuit held that vacatur was appropriate because the case had become moot and to prevent the now-unreviewable injunction from producing adverse legal consequences in future litigation. The court vacated the injunction and dismissed the appeal. View "Chicago Headline Club v. Noem" on Justia Law

After protests in Des Moines, Iowa, escalated into rioting and looting at a mall in late May 2020, law enforcement was deployed to restore order and clear the area. A special police team, including Deputy Jason Tart, was authorized to use less-lethal munitions such as impact rounds. Monica Perkins, who had attended a vigil elsewhere, arrived near the mall area with her daughter. After an argument between Perkins and another driver on a nearby road, Deputy Tart fired an impact round that struck Perkins in her hand, injuring her. Perkins sued the City, various police officials, and Deputy Tart, alleging constitutional violations including excessive force and failure to intervene.The United States District Court for the Southern District of Iowa granted summary judgment to all defendants on every claim. The district court found that Perkins was not “seized” within the meaning of the Fourth Amendment, and even if she had been, Deputy Tart was entitled to qualified immunity. The court also held that Deputy Tart’s conduct did not amount to a substantive due process violation and that, because there was no underlying constitutional violation, the failure-to-intervene claim against other officers could not stand.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit agreed with the district court, holding that Deputy Tart’s actions did not objectively manifest an intent to restrain Perkins and thus did not constitute a seizure under the Fourth Amendment. The court further found no evidence that Deputy Tart’s conduct was conscience-shocking under the Fourteenth Amendment and concluded he was entitled to qualified immunity. As a result, the failure-to-intervene claim against the other officers also failed. The Eighth Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Perkins v. City of Des Moines" on Justia Law

A man was convicted by a Michigan state jury for delivering oxycodone to a friend, resulting in her death from a drug overdose. The evidence showed that the man and the deceased had a longstanding relationship, and after her release from jail, he purchased 40 Percocet pills—containing oxycodone and acetaminophen—and spent time with her at a hotel where she died. Medical experts found oxycodone in her blood and acetaminophen in her urine, both components of Percocet, and testified that oxycodone was a substantial factor in causing her death.After his conviction, the defendant sought a new trial in the Michigan courts, arguing that his trial counsel was ineffective for two reasons: failing to investigate an “acetaminophen-based” defense (that the absence of acetaminophen in the blood meant the deceased had not consumed Percocet), and failing to call an expert witness to challenge the prosecution’s case on causation. The trial court held a hearing and ultimately rejected these claims. The Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied further review.The United States District Court for the Eastern District of Michigan then denied the defendant’s petition for habeas corpus, and the case was appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit held that, under the highly deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA), the state courts did not unreasonably apply clearly established Supreme Court law or make unreasonable determinations of fact in rejecting the ineffective assistance claims. The court further held that counsel’s strategic decisions were not objectively unreasonable and that the alleged failures did not prejudice the outcome of the trial. The Sixth Circuit affirmed the denial of habeas relief. View "DeBruyn v. Douglas" on Justia Law

A company sought to erect a digital billboard in a small Ohio municipality but was prevented from doing so by the local billboard ordinance, which included restrictions on size, location, and type of billboards permitted. The ordinance specifically banned “variable message” (digital) signs and implemented a “cap and replace” rule, allowing new billboards only if older ones were removed. The ordinance also contained several exemptions, including one for “public service” signs, which were allowed to display information like time or weather if not used for advertising.Previously, the United States District Court for the Southern District of Ohio granted summary judgment to the municipality, upholding the ordinance against the company’s First Amendment challenges. On appeal, the United States Court of Appeals for the Sixth Circuit determined that the exemption for public service signs was an unconstitutional, content-based restriction under the First Amendment, but remanded the case for the district court to determine whether the invalid exemption was severable from the rest of the ordinance.On remand, the district court found that the unconstitutional provision could be severed and that the remainder of the ordinance survived intermediate scrutiny, granting judgment again in favor of the municipality. The company appealed.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the public-service exemption was severable under Ohio law, applying the three-part test from Geiger v. Geiger. The court further held that the remaining provisions of the ordinance were content-neutral and survived intermediate scrutiny because they were narrowly tailored to significant governmental interests such as traffic safety and aesthetics. The court also held that the company was not entitled to damages or attorney fees, as it was not a prevailing party under 42 U.S.C. § 1988(b). View "Norton Outdoor Advertising, Inc. v. Village of St. Bernard" on Justia Law

A black-owned construction company was not invited to bid as general contractor on a major Boston public housing redevelopment project after participating in pre-construction work. Years earlier, the developer had called the company’s president to discuss possible involvement, but the parties disputed what promises, if any, were made during that conversation. The construction company performed pre-construction work and was later selected as general contractor for the first phase (Camden), but after performance and communication issues arose during that project, the developer chose a different, white-owned company for the second phase (Lenox). The construction company did not protest at the time but later sued, alleging breach of contract, quasi-contract, violation of Massachusetts consumer protection law, and racial discrimination under 42 U.S.C. § 1981.The matter was first brought in Massachusetts state court, then removed to the United States District Court for the District of Massachusetts based on federal question jurisdiction. After discovery, the developer moved for summary judgment. The District Court granted summary judgment for the developer, finding no enforceable contract or promise had been made regarding the Lenox phase, that the quasi-contract and Chapter 93A claims failed as derivative, and that there was insufficient evidence of racial discrimination.The United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The First Circuit held that the summary judgment record did not contain evidence from which a reasonable jury could find an enforceable implied-in-fact contract or a promise sufficient for promissory estoppel. It further held that the plaintiff failed to create a triable issue of fact regarding pretext or discriminatory intent under § 1981, given the legitimate business reasons cited for the company’s exclusion. Thus, summary judgment on all claims was proper. View "John B. Cruz Construction Co. v. Beacon Communities Corp." on Justia Law

While incarcerated in a Colorado state prison, the plaintiff, a practicing member of the Sac & Fox faith, brought suit seeking monetary and injunctive relief. He alleged that certain prison regulations and practices violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act. His claims focused on being denied possession of sacred items, spiritual cleansing of his cell, use of donated firewood for religious ceremonies, and access to faith grounds during and after the COVID-19 pandemic. The plaintiff named numerous officials and employees, including the Governor of Colorado, in both their official and individual capacities.The United States District Court for the District of Colorado denied the Governor’s motion to dismiss the official-capacity claims for injunctive relief, rejecting his assertion of Eleventh Amendment immunity. The Governor argued he lacked the required connection to the challenged regulations to qualify for the Ex Parte Young exception. During the appeal, the plaintiff was transferred to another facility within the Colorado Department of Corrections. The Governor raised the issue of mootness due to this transfer.The United States Court of Appeals for the Tenth Circuit considered whether the claims for injunctive relief against the Governor were moot because of the transfer and whether Eleventh Amendment immunity applied. The court held that the claims were neither constitutionally nor prudentially moot, as the plaintiff’s affidavit showed ongoing exposure to substantially similar conditions at the new facility. The court further held that, under Colorado law and the facts alleged, the Governor had sufficient authority and demonstrated involvement in the challenged practices to satisfy the Ex Parte Young exception. The court therefore affirmed the district court’s denial of Eleventh Amendment immunity and remanded for further proceedings. View "Eaves v. Polis" on Justia Law