Justia Civil Rights Opinion Summaries

In September 8, 2018, Michael Holmes attended a public fair in Belle Chasse, Louisiana, to test a new camera lens. While taking photos, Holmes was approached by Deputy Sheriff Corbett Reddoch, who asked for his identification. Holmes questioned the request, leading to a physical altercation where Reddoch arrested Holmes, claiming he was taking pictures of children. Holmes was charged only with resisting arrest.Holmes filed a lawsuit in the United States District Court for the Eastern District of Louisiana, asserting claims under 42 U.S.C. § 1983 and Louisiana state law. The jury found in favor of Holmes on his Fourth Amendment unlawful arrest claim but granted qualified immunity to Reddoch for the investigatory stop. The jury also found for Holmes on state-law claims of battery, false imprisonment, and malicious prosecution. Reddoch's post-verdict motions for judgment as a matter of law and a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of Reddoch's motions, holding that there was sufficient evidence for the jury to conclude that Reddoch did not have probable cause to arrest Holmes. The court also found that Reddoch forfeited his qualified immunity defense for the false arrest claim by not raising it in his Rule 50 motion. Additionally, the court held that the jury's verdicts on the investigatory stop and arrest were not inconsistent, as they involved different legal standards. The court also upheld the jury's award of punitive damages, finding that Reddoch's actions demonstrated reckless or callous indifference to Holmes's constitutional rights. The judgment of the district court was affirmed. View "Holmes v. Reddoch" on Justia Law

In 1999, a Virginia state court jury convicted Askari Lumumba of second-degree murder and other related charges, sentencing him to fifty-eight years in prison. While serving his sentence, Lumumba engaged in communications that led to disciplinary action. He spoke on the phone about organizing inmates and sent emails discussing potential group actions within the prison. As a result, he was charged with attempting to garner support for a group demonstration, violating Disciplinary Offense Code 128, which prohibits participating in or encouraging work stoppages or group demonstrations.Lumumba's disciplinary hearing concluded with a finding of guilt, resulting in 30 days of disciplinary segregation and a loss of 180 days of good-conduct sentence credits. His appeals to the Warden and Regional Director were denied. He then petitioned for a writ of habeas corpus in the Supreme Court of Virginia, which was denied on jurisdictional grounds. Subsequently, Lumumba filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing that Offense Code 128 was void for vagueness and violated the First Amendment. The district court dismissed his petition, finding the regulation clear and reasonably related to legitimate penological interests.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Offense Code 128 is not facially unconstitutional under the First Amendment, as it reasonably relates to maintaining order and security in prisons. The court also found that the regulation is not void for vagueness, as it provides sufficient notice of prohibited conduct and does not invite arbitrary enforcement. Consequently, the Fourth Circuit affirmed the district court's dismissal of Lumumba's petition. View "Lumumba v. Kiser" on Justia Law

Kyle J. Rodney was convicted in Nevada state court of multiple charges, including burglary while in possession of a deadly weapon, conspiracy to commit murder, robbery with use of a deadly weapon, attempted murder with use of a deadly weapon, and battery with use of a deadly weapon resulting in substantial bodily harm. The convictions stemmed from an incident where Rodney and an accomplice attacked and severely injured Ralph Monko after Monko won a significant amount of money at a casino. Monko's injuries were severe, including head trauma and long-term physical and cognitive impairments.Rodney's convictions were affirmed by the Nevada Supreme Court. He then filed a pro se post-conviction petition for a writ of habeas corpus in state court, which was denied without the appointment of counsel or an evidentiary hearing. A second post-conviction petition was also denied on procedural grounds. Rodney subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254, raising several ineffective-assistance-of-counsel (IAC) claims. The federal district court found these claims procedurally defaulted. On appeal, the Ninth Circuit vacated and remanded for the district court to determine if the procedural default could be excused under Martinez v. Ryan, which allows for such an excuse if the IAC claims are substantial.The United States District Court for the District of Nevada, on remand, initially allowed new evidence and discovery but later ruled that it could not consider new evidence due to the Supreme Court's decision in Shinn v. Ramirez. The district court concluded that Rodney's IAC claims were not substantial based on the state-court record alone and denied relief.The Ninth Circuit Court of Appeals affirmed the district court's decision. The court held that Rodney did not fail to develop the state-court record within the meaning of 28 U.S.C. § 2254(e)(2) and that the district court erred in limiting its analysis to the state-court record. However, the Ninth Circuit found that even considering the new evidence, Rodney's IAC claims were not substantial. The court concluded that there was no reasonable probability that the outcome of Rodney's trial or sentencing would have been different but for counsel's alleged errors. Thus, the procedural default of Rodney's claims could not be excused, and the denial of his habeas petition was affirmed. View "RODNEY V. GARRETT" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Russell Hotchkiss, a resident of Linn County, Iowa, began sending emails to the Cedar Rapids Community School District officials in September 2021, criticizing their COVID-19 masking and vaccination policies. His communications included threats of criminal charges against board members, particularly targeting Jennifer Borcherding, a board member. Hotchkiss attended board meetings in November and December 2021, where he voiced his opposition aggressively. Following these incidents, the District issued a no-trespass notice to Hotchkiss on January 10, 2022, barring him from District premises due to his disruptive and threatening behavior.Hotchkiss filed a lawsuit on May 17, 2023, claiming First Amendment retaliation under 42 U.S.C. § 1983 and a violation of the Iowa Open Meetings Act. He sought a preliminary injunction to prevent the enforcement of the no-trespass order. The United States District Court for the Northern District of Iowa denied his motion, concluding that Hotchkiss failed to demonstrate irreparable harm. The court noted that Hotchkiss had not attempted to return to District premises, had moved his child to another school district, and had not communicated with the District since the notice was issued.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision. The appellate court affirmed the denial of the preliminary injunction, agreeing that Hotchkiss did not show a likelihood of irreparable harm. The court emphasized that speculative harm does not justify a preliminary injunction and noted Hotchkiss's delay in seeking relief and lack of recent attempts to exercise his First Amendment rights. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction based on the failure to demonstrate irreparable harm. View "Hotchkiss v. Cedar Rapids Community School District" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law

Three retired New Hampshire State Police troopers challenged their inclusion on the Exculpatory Evidence Schedule (EES), claiming their placement was based on outdated and misinterpreted conduct. Approximately twenty years ago, the troopers inflated traffic stop records in their activity logs to meet mandated quotas. An internal investigation led to their discipline but not termination. Initially placed on the "Laurie List," their names were later removed, only to be reinstated on the EES over a decade later.The Superior Court dismissed the troopers' complaint, finding their conduct potentially exculpatory and their placement on the EES appropriate. The court also ruled that the troopers had received adequate due process. The troopers appealed, arguing that their conduct was not fraudulent and that the age of the conduct diminished its relevance.The Supreme Court of New Hampshire reviewed the case, focusing on whether the troopers' conduct was "potentially exculpatory" under RSA 105:13-d. The court noted that "potentially exculpatory evidence" includes evidence that could be material to guilt or punishment, including impeachment evidence. The court emphasized that factors such as the age and nature of the conduct should be considered in determining its relevance.The court concluded that the limited record did not establish whether the troopers' conduct was potentially exculpatory, as it could have been a result of a mistaken interpretation of reporting requirements rather than dishonesty. Therefore, the court reversed the Superior Court's dismissal and remanded the case for further proceedings to determine the potential exculpatory nature of the conduct, considering its admissibility and relevance in future criminal cases. View "Doe v. N.H. Attorney Gen." on Justia Law