Justia Civil Rights Opinion Summaries

Two individuals attended a demonstration in San Juan, Puerto Rico, on May 1, 2018, where they allege that officers of the Puerto Rico Police Bureau used excessive force against them, including the use of tear gas and rubber bullets. In April 2019, they filed lawsuits in the United States District Court for the District of Puerto Rico, asserting violations of their constitutional rights and seeking both injunctive and monetary relief. The suits named the then-Governor and other officials and employees of the Commonwealth, including police officers, as defendants, with claims brought against some defendants in their personal capacities.During this time, the Commonwealth of Puerto Rico was undergoing bankruptcy-like restructuring under Title III of PROMESA, and, in 2022, the Title III court confirmed a Plan of Adjustment, which discharged certain claims against the Commonwealth and enjoined pursuit of those claims. The district court stayed the plaintiffs’ lawsuit pending a determination of whether the Plan discharged their claims. On September 30, 2025, the Title III court held that the Plan did not discharge personal-capacity claims against Commonwealth officials or employees, thus allowing the plaintiffs to proceed. The Financial Oversight and Management Board appealed this decision.The United States Court of Appeals for the First Circuit reviewed the Title III court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the discharge and related injunction in the confirmed Plan of Adjustment do not apply to claims against Commonwealth officers or employees sued in their personal capacities. The court reasoned that discharging such claims would amount to a non-consensual third-party release, which the Plan expressly does not provide. Accordingly, the First Circuit affirmed the Title III court’s decision in full. View "Hernandez Zorilla v. FOMB" on Justia Law

A candidate for the Republican nomination for Governor of Georgia, who was not the incumbent, challenged a unique provision of Georgia’s campaign finance law. This law allows only the incumbent Governor and Lieutenant Governor to establish and control so-called “leadership committees” with the ability to receive unlimited contributions and coordinate spending directly with their campaigns, advantages not available to challengers or other candidates. The challenger entered the 2026 gubernatorial primary and quickly discovered that his opponent, the sitting Lieutenant Governor, had amassed substantial campaign resources through such a leadership committee, while the challenger remained subject to standard contribution limits.After filing suit in the United States District Court for the Northern District of Georgia, the challenger sought a preliminary injunction to stop the Lieutenant Governor’s leadership committee from raising or spending further funds in support of his campaign. The district court initially issued a temporary restraining order, then, after further proceedings, granted a preliminary injunction, holding that the challenger was likely to succeed on his claim that the law violated the First Amendment’s guarantee of free speech and that the leadership committee’s actions could be fairly attributed to state action. The district court determined that the law’s favoritism toward select officials could not be justified and that the harm to the challenger was irreparable. However, the injunction was stayed pending appeal.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of a preliminary injunction. The court held that the selective fundraising advantage granted to certain incumbents by the leadership committee statute was unconstitutional under the First Amendment, as it imposed different contribution limits on candidates for the same office without sufficient justification. The court also found that the leadership committee’s conduct constituted state action, making it subject to suit under 42 U.S.C. § 1983. The preliminary injunction was affirmed. View "Jackson v. Jones" on Justia Law

A man was observed by Detroit police officers in a convenience store with a partially concealed handgun. Upon being questioned, he admitted he did not have a concealed pistol license. An officer ordered him to keep his hands raised, but he failed to comply and instead pulled out the weapon, pushing the officer and attempting to flee. Two other officers responded; one fired twice but missed, while another fired several shots as the man moved toward the exit, hitting him multiple times. The man survived and subsequently sued the officers for excessive force under both federal and Michigan state law.The United States District Court for the Eastern District of Michigan granted summary judgment for the officers, finding they were protected by qualified immunity. The plaintiff appealed, but only pursued claims against the two officers who fired their weapons, abandoning his claims against the third officer. The district court’s decision was based on its determination that the officers had not violated the plaintiff’s constitutional rights and were entitled to immunity.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo, considering the facts most favorably to the plaintiff and using video evidence to resolve disputed facts. The court held that the officer who fired and hit the plaintiff seized him, but that the officer who fired and missed did not seize him under the Fourth Amendment. The court further concluded that the force used by the officer who struck the plaintiff was reasonable, given the circumstances and the officer’s perception of an immediate threat. The Sixth Circuit also found that both officers were entitled to state-law immunity for assault and battery claims under Michigan law. The district court’s judgment was affirmed. View "Ward v. Brotzke" on Justia Law

A company that owned several billboards in Texas faced administrative action by the Texas Department of Transportation (TxDOT), which sought to cancel four of its billboard permits due to alleged noncompliance with state regulations. The company requested an administrative hearing, after which TxDOT dismissed its claims for cancellation of three permits but proceeded against one. An administrative law judge recommended canceling the remaining permit and imposing significant administrative penalties for violations related to the other permits. The Texas Transportation Commission (TTC) adopted this decision.The company then filed for judicial review in a Texas state district court, but its petition was dismissed because it was filed past the statutory thirty-day deadline. This dismissal for lack of jurisdiction was affirmed by the state appellate court, and the Supreme Court of Texas declined review. While the state proceedings were ongoing, the company separately filed a federal lawsuit in the United States District Court for the Southern District of Texas against TxDOT, TTC, and TxDOT’s Executive Director, asserting five claims under 42 U.S.C. § 1983 and state law. The district court dismissed most claims on sovereign immunity grounds, and held that the remaining claims were barred by res judicata, entering final judgment for the defendants.Upon appeal, the United States Court of Appeals for the Fifth Circuit determined that it lacked jurisdiction over all of the company’s claims. The court found that the company had failed to adequately allege the necessary connection between the individually named official and the enforcement of the challenged law, a requirement under the Ex parte Young doctrine for suits against state officials. As a result, the Fifth Circuit modified the district court’s judgment to dismiss all claims without prejudice and affirmed the judgment as modified. View "Gannon v. Texas Dept of Trans" on Justia Law

At a school board meeting in Xenia, Ohio, a member of the public sought to use her allotted time during the public comment period to criticize the school district’s handling of alleged critical race theory instruction, as well as the conduct of the superintendent and board. Although her remarks were calmly delivered, board president Mary Grech interrupted her, threatened to cut her microphone, and eventually did so, recessing the meeting amid disruptions from the audience. The speaker was not permitted to complete her five-minute comment, nor was she allowed additional time after the meeting resumed.The individual who was silenced brought a lawsuit against the school board and its president under 42 U.S.C. § 1983, arguing that her First Amendment rights were violated. She sought a preliminary injunction to prevent enforcement of the board’s public comment policy against her in the future. The United States District Court for the Southern District of Ohio conducted a hearing and denied the request for a preliminary injunction. The court concluded that the plaintiff had not demonstrated a strong likelihood of success on the merits or irreparable harm, and found the facts and motives for the board president’s actions to be equivocal.The United States Court of Appeals for the Sixth Circuit reviewed the matter and reversed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiff’s speech—critical of school officials—was protected by the First Amendment and did not fall into any unprotected category. The court found that the board president engaged in impermissible viewpoint discrimination by curtailing speech because of its critical content, and also ratified a heckler’s veto by silencing the speaker rather than the disruptive audience. The Sixth Circuit concluded that the plaintiff demonstrated a strong likelihood of success on the merits and that irreparable harm to constitutional rights was presumed. The case was remanded with instructions to grant the preliminary injunction. View "Boddy v. Grech" on Justia Law

A Black resident of the Middle District of Florida, descended from enslaved individuals, brought suit against the Mayor of Jacksonville and the Governor of Florida in their official capacities. He alleged that the continued presence and maintenance of nearly fifty Confederate memorials, monuments, and naming tributes on public land, funded by city or state tax dollars, caused him to feel “deeply repulsed, disheartened, and intimidated.” He asserted that these symbols were governmental celebrations of White supremacy, and sought a declaratory judgment that their presence violated his rights under Title II of the Civil Rights Act, the Thirteenth Amendment, the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and 42 U.S.C. § 1981.The United States District Court for the Middle District of Florida dismissed the complaint. The magistrate judge had recommended dismissal, finding that the plaintiff failed to allege facts showing a particularized injury, and thus lacked Article III standing. The magistrate also found that the plaintiff did not have taxpayer standing, as he failed to allege a direct injury or that taxpayer funds were specifically used to maintain the memorials. The district court adopted the recommendation, concluding that the plaintiff’s objections were not sufficiently specific, but nonetheless conducted a de novo review and agreed that standing was lacking.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that the plaintiff’s alleged psychological harm—feelings of repulsion and intimidation—did not constitute a concrete or particularized injury for Article III standing. It further found he did not demonstrate municipal taxpayer standing, as he failed to allege facts indicating that taxpayer funds were used for the memorials. The Eleventh Circuit concluded that the plaintiff lacked standing and affirmed the dismissal. View "Johnson v. Mayor, City of Jacksonville" on Justia Law

The plaintiff, a pretrial detainee at a small Wyoming jail, experienced severe dental pain and underwent three emergency room visits during his two-month incarceration. Medical professionals prescribed pain medication and instructed him to seek dental care within specific timeframes, and also recommended daily oral rinses. The jail, lacking on-site medical staff, required officers to schedule appointments or transport inmates for care. After each emergency visit, discharge instructions were handed to incoming staff, and eventually, a dental appointment was scheduled for August, though the plaintiff was released before it occurred. The plaintiff repeatedly requested timely dental care and rinses, but officers only partially provided the prescribed treatments.In the United States District Court for the District of Wyoming, the plaintiff sued jail officials under 42 U.S.C. § 1983, alleging deliberate indifference to his serious medical needs in violation of the Fourteenth Amendment. The district court granted summary judgment for the defendants on qualified immunity grounds. It found insufficient evidence that the named officers had a duty to schedule dental appointments under jail policy or that they intentionally delayed care. The court also concluded that failure to provide oral rinses did not constitute deliberate indifference, and even if a constitutional violation occurred, the officers did not violate clearly established law.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. It held that the officers were not responsible for scheduling the dental appointments under jail policy, reasonably believed others were handling scheduling, and responded to the plaintiff’s pain with medication and emergency room visits. The court also found that failure to provide oral rinses did not rise to deliberate indifference, as there was no evidence the officer recognized a substantial risk from their absence. Furthermore, it concluded that no clearly established law required different conduct under these circumstances. Accordingly, the Tenth Circuit affirmed the district court’s judgment. View "Jarvis v. Liggett" on Justia Law

Deputies from the Pueblo County Sheriff’s Office responded to a 911 call at a local middle school, where they encountered Richard Ward in a car with his mother, Kristy Ward Stamp. During questioning, Mr. Ward placed anti-anxiety medication in his mouth, which led Deputy McWhorter to attempt to remove him from the vehicle. A brief struggle ensued, after which Deputy McWhorter shot Mr. Ward three times, resulting in his death. Following the shooting, Ms. Ward Stamp was ordered to remain in the car, her phone and vehicle were seized, she was detained, patted down, handcuffed, moved between police vehicles, transported to a sheriff’s facility, and held in an interview room for several hours.Mr. Ward’s estate and Ms. Ward Stamp filed suit in the United States District Court for the District of Colorado against the deputies, alleging violations of their rights under the Fourth Amendment, specifically excessive force against Mr. Ward and unlawful arrest and seizure of Ms. Ward Stamp and her property. The officers moved for summary judgment, invoking qualified immunity. The district court denied qualified immunity, finding that a reasonable jury could determine that Mr. Ward did not resist or pose a threat when force was used, and that there was no probable cause to detain Ms. Ward Stamp or seize her property.The United States Court of Appeals for the Tenth Circuit reviewed the officers’ interlocutory appeal. It affirmed the district court’s denial of qualified immunity to the extent the appeal raised abstract legal questions but dismissed the remainder of the appeal for lack of jurisdiction, because the officers’ arguments relied on disputed facts rather than accepting the district court’s factual findings. The Tenth Circuit held it lacked jurisdiction to review factual disputes at this stage and that the district court properly applied the qualified immunity framework. View "Estate of Ward v. Lucero" on Justia Law

While incarcerated at a Missouri correctional center, Corey Coffelt exhibited significant mental health challenges, including diagnoses of substance-induced mood disorder with psychosis and a history of suicide attempts. Despite being prescribed psychiatric medications, Coffelt’s medication administration was inconsistent in the weeks preceding his death. On February 4, 2022, Coffelt was placed in administrative segregation, partly for safety concerns. Although his mental health conditions were noted, a nurse practitioner determined suicide watch was not necessary. Two days later, Coffelt died by suicide in his segregation cell. The corrections officers on duty were responsible for conducting visual checks per facility policy, but Coffelt was found deceased approximately an hour after he was last seen alive.In the United States District Court for the Eastern District of Missouri, Coffelt’s parents brought state wrongful death and federal civil rights claims against several corrections officers. The officers moved to dismiss, asserting official immunity on the state claim and qualified immunity on the federal deliberate indifference claim. The district court denied the motions, finding that the complaint plausibly alleged a ministerial duty under facility policy for the wrongful death claim and sufficient facts for the § 1983 deliberate indifference claim, allowing both to proceed.The United States Court of Appeals for the Eighth Circuit reviewed the denial of immunity de novo. It held that the cell check policy required some officer discretion and was not a purely ministerial duty; therefore, official immunity barred the state wrongful death claim. Regarding the § 1983 claim, the court concluded that the complaint did not sufficiently allege the officers had actual knowledge of a substantial suicide risk or acted with deliberate indifference. The Eighth Circuit reversed the district court’s denial of both official and qualified immunity and remanded the case for further proceedings. View "Headley v. Ognenovski" on Justia Law

In the early morning hours of March 11, 2019, a police officer in Siloam Springs, Arkansas, stopped Christopher Lockhart, a licensed bail bondsman and private investigator, after observing Lockhart’s vehicle touch the centerline while driving below the speed limit. During the stop, the officer noted Lockhart’s slow and slurred speech, bloodshot and glassy eyes, droopy eyelids, and apparent confusion. Lockhart performed poorly on field sobriety tests and admitted to recent use of prescription pain medication. Although a subsequent blood test showed no alcohol, and a Drug Recognition Expert concluded Lockhart was not impaired but rather had medical issues, the officer arrested him for driving while intoxicated (“DWI”) and related offenses. The charges were later dismissed, and Lockhart was found not guilty on the DWI charge after no evidence was presented at trial.Lockhart filed suit in the United States District Court for the Western District of Arkansas against the City of Siloam Springs and several employees, asserting constitutional and state law claims, including false arrest and malicious prosecution. The district court granted summary judgment on most claims but allowed the false arrest claim against the officer and the malicious prosecution claim against the city to proceed. On a previous appeal, the United States Court of Appeals for the Eighth Circuit upheld the denial of summary judgment for the malicious prosecution claim but reversed as to the Fourth Amendment claim, remanding for further consideration of whether probable cause supported the arrest.In the current appeal, the United States Court of Appeals for the Eighth Circuit held that Officer Ware was entitled to qualified immunity on the false arrest claim because, under the undisputed facts, he had probable cause to arrest Lockhart for DWI. The court reversed the denial of summary judgment for the officer, remanded for entry of judgment in his favor, and dismissed the city’s appeal on the malicious prosecution claim, declining to revisit its prior decision. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law