Justia Civil Rights Opinion Summaries

The Supreme Court of Arkansas heard an appeal from Michael Jenkins, who was challenging the denial of his pro se petition for a writ of "mandamus/prohibition" by the Jefferson County Circuit Court. Jenkins, who was convicted of first-degree sexual assault in 2018 and sentenced to 180 months' imprisonment, claimed that the Arkansas Department of Correction (ADC) and its record keeper had incorrectly deemed him ineligible for parole. He argued that the application of Arkansas Code Annotated section 16-93-609(b), which disqualifies for parole a sex offender previously convicted of a violent felony, was an ex post facto violation as it was based on his 1981 convictions for armed robbery and home invasion in Illinois - offenses that occurred before the enactment of the cited statute.The Supreme Court of Arkansas held that there was no ex post facto violation in the ADC’s application of the statute to Jenkins's parole eligibility. The court pointed out that the statute was enacted in 2001 and eliminates parole eligibility for persons who committed a felony sex offense after August 13, 2001, and had been previously convicted of a violent felony offense or any felony sex offense. Jenkins was convicted of a sexual assault committed in 2016, and his previous violent offenses committed in Illinois before the act's enactment were valid grounds for the application of section 16-93-609(b)(2). Consequently, the court affirmed the lower court's denial of Jenkins's petition for a writ and also denied his motion for the appointment of counsel. View "JENKINS v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

Sammy Tawakkol sued two Texas state officials, alleging that they violated his right to procedural due process when they notified him that he was required to register as a sex offender under Texas law. The district court ruled in Tawakkol's favor. However, the United States Court of Appeals for the Fifth Circuit found that Tawakkol's suit was barred by sovereign immunity and therefore the district court lacked jurisdiction to rule on the case.The case began when Tawakkol was required to register as a sex offender under the federal Sex Offender Registry and Notification Act (SORNA) because of a crime he committed while he was a cadet at the United States Air Force Academy. After he moved to Houston, Texas, state officials determined that he also needed to register as a sex offender under Texas's system. Tawakkol sued the state officials, alleging that their registration determination violated his procedural due process rights under the Fourteenth Amendment.The district court ruled in favor of Tawakkol, but the Court of Appeals vacated this decision and remanded the case back to the district court with instructions to dismiss for lack of jurisdiction. The Court of Appeals found that the suit was barred by sovereign immunity, a legal doctrine that prevents certain lawsuits against state officials. The court concluded that Tawakkol's case did not meet the criteria for an exception to sovereign immunity established in Ex parte Young, a Supreme Court case that allows lawsuits against state officials to prevent them from enforcing state laws that violate federal law.The court reasoned that unlike in Ex parte Young, the district court's order did not enjoin the state officials from enforcing a state law that violated federal law. Instead, the district court invalidated federal law and prohibited the state officials from enforcing a state law that was consistent with that federal law. The court determined that this type of relief fell outside the narrow parameters of the Ex parte Young exception and did not serve its purpose, which is to vindicate federal rights. View "Tawakkol v. Vasquez" on Justia Law

A plaintiff, Elvin Torres-Estrada, brought claims against several Federal Bureau of Investigation (FBI) agents and the United States under the Federal Tort Claims Act (FTCA) and Bivens, alleging violations of his constitutional and statutory rights. The district court dismissed his complaint, arguing that some of his claims were not filed within the required time frame and that the FTCA's discretionary function exception stripped the court of jurisdiction over his other claims. Torres-Estrada appealed the dismissal, arguing that his claims are timely, the discretionary function exception does not apply, and even if it does, it does not cover the alleged misconduct of the FBI.The United States Court of Appeals for the First Circuit held that the district court erred in its interpretation of the discretionary function exception. The court explained that this exception does not serve as a bar to FTCA tort claims that plausibly allege constitutional violations. In addition, at least two of Torres-Estrada's claims could be subject to the "continuing violation" doctrine, which means the district court erred in dismissing his claims as untimely without considering this doctrine. Given that new facts have emerged throughout the litigation, the court granted Torres-Estrada leave to amend his complaint. Therefore, the court affirmed in part, reversed in part, and remanded the case for further proceedings.The background facts of the case are that Torres-Estrada was detained at the Metropolitan Detention Center (MDC) in Guaynabo, Puerto Rico, pending prosecution for drug and money laundering offenses. During this time, he was investigated by the FBI as a potential suspect in the murder of a correctional officer at the MDC. Torres-Estrada alleges that the FBI violated his rights through various actions, including the use of informants to elicit incriminating statements about the murder, subjecting him to invasive body searches, and maintaining records falsely linking him to the murder. View "Torres-Estrada v. Cases" on Justia Law

Sherelle Thomas, on behalf of the estate of Terelle Thomas, sued the City of Harrisburg, PrimeCare Medical, Inc., and several individual law enforcement officers (the Officers) alleging that they failed to provide medical care and to intervene in the prevention of a violation of Thomas's right to medical care. The Officers moved to dismiss the case on grounds of qualified immunity, but the United States District Court for the Middle District of Pennsylvania denied the motion. The Officers then appealed the decision.The United States Court of Appeals for the Third Circuit, reviewing the case de novo, affirmed the District Court's denial of qualified immunity regarding the failure to render medical care. The court found that the Officers, based on their observations and knowledge, should have recognized that Thomas had ingested a significant amount of cocaine, presenting a serious medical need. The Officers' decision not to take Thomas to the hospital amounted to deliberate indifference to that need, constituting a violation of Thomas' constitutional right to medical care.However, the Court of Appeals reversed the District Court's recognition of a claim of failure to intervene. The court explained that neither the Supreme Court nor the Third Circuit have recognized a right to intervene in the context of rendering medical care. As such, the Officers were entitled to qualified immunity on this claim.The case was remanded to the District Court with instructions to dismiss the claim regarding the Officers' failure to intervene. View "Thomas v. City of Harrisburg" on Justia Law

The United States Court of Appeals for the Third Circuit reviewed a case involving the estate of Terelle Thomas who died after ingesting a large amount of cocaine while in police custody. The plaintiffs, acting on behalf of the estate, brought a suit against the City of Harrisburg, PrimeCare Medical, and several individual law enforcement officers, alleging that they failed to render medical care and intervene to prevent a violation of the right to medical care. The officers moved to dismiss the case on the grounds of qualified immunity, but the District Court denied the motion.On appeal, the Third Circuit affirmed in part and reversed in part. The court held that the officers were not entitled to qualified immunity for the failure to render medical care claim as the plaintiffs successfully alleged a violation of the constitutional right to medical care. The court found that the officers had a clear indication that Thomas had ingested a significant amount of drugs and thus had a serious medical need, and their decision to book Thomas instead of taking him to a hospital demonstrated deliberate indifference to that need.However, the court reversed on the failure to intervene claim. The court noted that neither the Third Circuit nor the Supreme Court had recognized a right to intervene in the context of rendering medical care. Therefore, the officers were entitled to qualified immunity on the failure to intervene claim. The case was remanded to the District Court with instructions to dismiss the failure to intervene claim. View "Thomas v. City of Harrisburg" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Rudolph Betancourt, a disabled individual, filed a lawsuit against Indian Hills Plaza LLC, the owner of a shopping plaza, citing violations of the Americans with Disabilities Act (ADA). The plaintiff experienced difficulties accessing the shopping plaza due to his disability. The parties agreed that the defendant had violated the ADA in 17 aspects, and Indian Hills Plaza LLC undertook remediation measures. The district court awarded Betancourt $12,000 in attorney's fees and costs. However, Betancourt appealed this decision, believing he was entitled to more.The main issue on appeal was the challenge to the district court's award of attorney’s fees and costs. The Court of Appeals affirmed the District Court's decision, finding no abuse of discretion. The court explained that the district court properly calculated the lodestar amount (reasonable hourly rate multiplied by the reasonable number of hours worked), which serves as a baseline for attorney's fees. It reduced the hourly rate considering the quality of the performance of Betancourt’s attorney and reduced the number of hours billed by 20% due to excessive billing. The court further reduced the attorney’s fees award based on deficiencies in the actions by Betancourt’s counsel during the litigation. The district court also deemed the requested expert costs as unreasonable and reduced them.Therefore, the holding of the case is that the district court did not abuse its discretion in awarding $12,000 in attorney’s fees and costs to the plaintiff, and that the court properly calculated the lodestar amount and adjusted it based on relevant considerations. The court also held that the plaintiff's attorney's premature fee motions, not the defendant's opposition to those motions, caused the excessive fees. View "Betancourt v. Indian Hills Plaza LLC" on Justia Law

Bradley Peterson, a former professor at Ohio State University, claimed his procedural-due-process rights were violated when the university stripped him of his emeritus status without adequate process. Following a sexual harassment complaint against him, the university conducted an investigation, concluded that Peterson violated the university's Sexual Misconduct Policy, and subsequently revoked his emeritus status. Peterson argued that he had a property interest in his emeritus status and its related benefits. The United States Court of Appeals for the Sixth Circuit, however, affirmed the district court's decision to dismiss Peterson's complaint. The court held that Peterson failed to establish a constitutionally protected property interest in his emeritus status. The court noted that emeritus status was an honorific title, and Peterson did not show that he lost pay or tangible benefits from Ohio State when his emeritus status was revoked. The court also noted that Peterson's claim of harm to his professional reputation was akin to a liberty interest claim, and he did not request a name-clearing hearing, which was a prerequisite for asserting such a claim. View "Peterson v. Johnson" on Justia Law

The Supreme Court of the State of Alaska ruled that the extended pre-evaluation detentions of two individuals, Abigail B. and Jethro S., violated their substantive due process rights. Both individuals were detained at local hospitals after suffering psychiatric emergencies. Court orders authorized immediate transportation of each individual to an available bed at an evaluation facility for further examination. However, due to a lack of available beds, neither individual was immediately transported, resulting in prolonged detentions. Abigail B. was detained for 13 days before transportation for evaluation, while Jethro S. was detained for 17 days. Both individuals appealed the detention orders, arguing that their prolonged detentions violated their substantive due process rights. The court agreed, citing a recent decision (In re Hospitalization of Mabel B.) that stated pre-evaluation detentions must bear a reasonable relation to the purpose of facilitating immediate transportation for evaluation. The court concluded that the nature and duration of Abigail's and Jethro's detentions were not reasonably related to their purpose, thereby violating their substantive due process rights. View "In the Matter of the Necessity for the Hospitalization of: Abigail B." on Justia Law

In this case, a man identified as Sergio F. was taken into emergency custody after his religious delusions led him to walk naked along a road during the winter. Following this incident, the Superior Court of the State of Alaska ordered his evaluation at a treatment facility, and subsequently involuntarily committed him for up to 30 days of treatment. A subsequent petition led to the superior court ordering a 90-day involuntary commitment to the treatment facility, as it found that the man was gravely disabled and needed additional treatment.On appeal, the Supreme Court of the State of Alaska vacated the superior court’s 90-day commitment order. It agreed with the man's argument that there was insufficient evidence to show he was gravely disabled and that the court failed to determine whether his commitment to the treatment facility was the least restrictive alternative for his treatment. The Supreme Court emphasized that less restrictive alternatives to hospitalization must be considered before ordering involuntary commitment and that it was the state’s burden to show that those alternatives do not exist or are not feasible. The Supreme Court found that this did not happen in this case, as neither the parties nor the court engaged in the specific inquiry required to address the petition’s allegations that less restrictive alternatives were considered and rejected by the treatment facility. Therefore, the Supreme Court vacated the 90-day commitment order. View "In the Matter of the Necessity for the Hospitalization of: Sergio F." on Justia Law

In the State of Alaska, a man diagnosed with bipolar disorder stopped taking his medication, experienced a manic episode, and was hospitalized as a result. The hospital staff petitioned for him to be involuntarily committed for 30 days, which the superior court granted. The man appealed, arguing against the court's decision that he was likely to cause harm to others, was gravely disabled, and that there was no less restrictive alternative to involuntary commitment. The Supreme Court of the State of Alaska held that the man's rights were violated because there was a feasible, less restrictive alternative to the involuntary commitment. The court also ruled that even if the suggested outpatient treatment proposal was not feasible, the State had failed to meet its burden of proving that no less restrictive alternative existed, as it did not consider any other treatment options beyond the man's proposal. The commitment order was vacated on these grounds. View "In the Matter of the Necessity of the Hospitalization of Declan P." on Justia Law