Justia Civil Rights Opinion Summaries

In the early hours of August 22, 1972, military officers at the Almirante Zar Naval Base in Trelew, Argentina, removed nineteen unarmed political prisoners from their cells and shot them, resulting in what became known as the Trelew Massacre. The plaintiffs in this case are the surviving family members of four of those prisoners. They filed a lawsuit against Roberto Guillermo Bravo, one of the officers involved in the massacre, seeking compensatory and punitive damages under the Torture Victim Protection Act (TVPA) for the extrajudicial killing and torture of their relatives.The United States District Court for the Southern District of Florida heard the case. A jury found Mr. Bravo liable for the deaths and awarded the plaintiffs over $24 million. Mr. Bravo appealed, arguing that the district court erred by equitably tolling the TVPA statute of limitations on the plaintiffs’ claims until October 15, 2012. The district court had concluded that extraordinary circumstances, including the plaintiffs’ fear of reprisal, inability to locate Mr. Bravo, and inability to discover crucial evidence, justified tolling the statute of limitations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court vacated the district court’s judgment, finding that the district court failed to make sufficient findings of fact to support its ruling on equitable tolling. The appellate court remanded the case for additional findings on whether the plaintiffs were entitled to equitable tolling beyond March 2008. The court also instructed the district court to reconsider whether the plaintiffs acted with due diligence in filing their claims, particularly in the case of Eduardo Cappello, who was found not to have acted diligently by the district court. The appellate court upheld the district court’s exclusion of evidence regarding the victims' alleged ties to communism and Cuba, finding no abuse of discretion. View "Camps v. Bravo" on Justia Law

Jesus Zambrano was convicted of first-degree murder in Illinois state court in 2013. The Illinois Appellate Court later found that the trial court erred by not giving a jury instruction on accomplice liability, leading to a retrial where Zambrano was acquitted. Zambrano then filed a federal lawsuit against Detective Patrick Schumacher and sought indemnification from the City of Joliet, alleging that Schumacher fabricated evidence, violating his Fourteenth Amendment due process rights.The case involved the murder of Robert Gooch, who was shot at his girlfriend's apartment in May 2009. Key evidence included testimonies and surveillance videos placing Zambrano at the scene. Detective Schumacher's police report stated that Zambrano identified his friends and the location of his girlfriend's apartment, which Zambrano claimed was false.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, finding that Zambrano failed to provide sufficient evidence that Schumacher deliberately falsified evidence in bad faith or that the alleged fabrication was material to his conviction.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Zambrano did not present enough evidence to show that Schumacher knowingly falsified the police report or acted in bad faith. Additionally, the court found that the alleged fabricated evidence was not material to the outcome of the trial, as it did not affect the jury's judgment. Therefore, the summary judgment in favor of the defendants was upheld. View "Zambrano v City of Joliet" on Justia Law

Luis Martinez Jr. died in February 2021, and his body was taken by the Wayne County Medical Examiner’s Office (WCMEO). Despite identifying his next of kin, the WCMEO did not contact them. The family hired a social worker who located Luis Jr.'s body in April 2021, by which time it was severely decomposed and had to be cremated. The family sued Wayne County and various officials under § 1983 for a Fourteenth Amendment procedural due process violation, a Monell liability claim, and state-law claims.The United States District Court for the Eastern District of Michigan granted the defendants' motion to dismiss. The court found that the alleged conduct did not constitute a clearly established constitutional violation and that the Monell claim failed due to a lack of supporting facts. The court declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that the defendants' conduct did not violate a clearly established constitutional right, as existing precedent did not address delayed notification leading to natural decomposition. The court also found that the Monell claim failed because the complaint did not allege sufficient facts to show a policy or custom of unconstitutional conduct or a failure to train. The court concluded that without a clearly established constitutional violation, the Monell claim could not succeed. View "Martinez v. Wayne Cnty., Mich." on Justia Law

In July 2020, Jamie Cunningham burglarized a car dealership in Cobb County, Georgia, and fled the scene. Cobb County police officers pursued him, and during the arrest, they used physical force to handcuff him. Cunningham later filed a lawsuit under 42 U.S.C. § 1983 against certain police officers and Cobb County, alleging excessive force in violation of the Fourth Amendment and Georgia law. He also claimed that Cobb County was liable under the Monell doctrine for the officers' actions.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the defendants. The court held that the officers were entitled to qualified immunity on the Fourth Amendment claim because their use of force was objectively reasonable and did not violate clearly established law. The court also found that the officers were entitled to official immunity on the state-law claim because Cunningham failed to show that the officers acted with actual malice. Additionally, the court granted summary judgment for Cobb County on the Monell claim, concluding that there was no underlying constitutional violation by the officers and no evidence of a defective custom or policy by Cobb County.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable under the circumstances, as Cunningham had resisted arrest and the officers had a reasonable belief that he might be armed. The court also agreed that the officers did not act with actual malice, and thus were entitled to official immunity. Finally, the court affirmed the summary judgment for Cobb County, as there was no underlying constitutional violation to support the Monell claim. View "Cunningham v. Cobb County, Georgia" on Justia Law

Law enforcement used a specialized software tool, Torrential Downpour, to download files containing child pornography from a specific IP address associated with the defendant. Torrential Downpour is designed to force a single-source download from a user on the BitTorrent peer-to-peer network, allowing officers to link specific files to a particular IP address. After obtaining these files, police secured a warrant and seized the defendant’s computer and other devices, which contained additional child pornography. The defendant argued that he did not knowingly share files and that he had a reasonable expectation of privacy in the files downloaded by law enforcement.The United States District Court for the Northern District of Florida held an evidentiary hearing on the defendant’s motion to suppress the evidence, considering expert testimony about BitTorrent’s functionality. The court found the government’s expert more credible and determined that the defendant had made the files available to the public. The court concluded that the use of Torrential Downpour did not access any information not already publicly shared and denied the motion to suppress. The court also denied a motion in limine to prevent the government from showing child pornography images to the jury, finding that the probative value was not substantially outweighed by the danger of unfair prejudice, especially since the defendant did not object to specific images.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the use of Torrential Downpour to download files from a peer-to-peer network did not constitute a search under the Fourth Amendment because the defendant had no reasonable expectation of privacy in files he made publicly available. The court also held that the district court did not abuse its discretion in allowing the government to show a representative sample of images to the jury without first reviewing specific images, given the lack of specific objections. View "USA v. Ewing" on Justia Law

Cedric Lofton, a seventeen-year-old juvenile, died while in the custody of the Juvenile Intake Assessment Center (JIAC) in Sedgwick County, Kansas. Lofton, experiencing a mental health crisis, was placed in a prone restraint by JIAC officers for over forty minutes, leading to his death from cardiac arrest. Marquan Teetz, representing Lofton's estate, filed a § 1983 action against the officers, alleging excessive force.The United States District Court for the District of Kansas denied the officers' motion for summary judgment on the excessive force claims, finding disputes of material fact. Specifically, the court noted that surveillance footage, although lacking audio, could support Teetz's version of events that Lofton had stopped resisting, making the continued use of force potentially excessive.The officers appealed to the United States Court of Appeals for the Tenth Circuit, arguing that the district court's finding of a factual dispute was "blatantly contradicted" by the record and that the court failed to properly analyze whether the law clearly established that their use of force was unconstitutional.The Tenth Circuit affirmed the district court's decision, holding that the use of a prolonged prone restraint on a subdued suspect constitutes excessive force. The court emphasized that the facts, viewed in the light most favorable to Teetz, showed that Lofton was no longer resisting at some point during the restraint. The court also held that it was clearly established law that applying pressure to a suspect's back while in a prone position after being subdued is unconstitutional due to the significant risk of asphyxiation and death. Thus, the officers were not entitled to qualified immunity. View "Teetz v. Stepien" on Justia Law

Eric Holmes, an Indiana state prisoner, filed a lawsuit against the Marion County Sheriff’s Office under 42 U.S.C. § 1983, alleging unlawful imprisonment in violation of the Fourteenth Amendment. Holmes sought to proceed in forma pauperis, but the Prison Litigation Reform Act (PLRA) restricts this ability for prisoners who have had three prior civil actions or appeals dismissed as frivolous, malicious, or for failing to state a claim.The United States District Court for the Southern District of Indiana found that Holmes had incurred three strikes under the PLRA. The court determined that a previous case dismissed for failure to state a claim because it was barred by Heck v. Humphrey counted as Holmes’s third strike. Holmes did not contest the validity of his first two strikes. He filed a notice of appeal and moved to proceed in forma pauperis on appeal, but a motions panel of the Seventh Circuit denied his motion, identifying a different case dismissed due to judicial immunity as his third strike.The United States Court of Appeals for the Seventh Circuit reviewed whether dismissals based on affirmative defenses, such as those barred by Heck or due to judicial immunity, count as strikes under the PLRA. The court held that a case dismissed for failure to state a claim because it was barred by Heck counts as a strike if the Heck bar is clear from the face of the complaint. Similarly, a case dismissed on judicial immunity grounds incurs a strike if the immunity defense is clear from the face of the complaint. The court affirmed the district court’s dismissal of Holmes’s current suit, concluding that both the Heck dismissal and the judicial immunity dismissal counted as strikes. View "Holmes v Marion County Sheriff's Office" on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance.Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision.The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Stanford" on Justia Law

Carl and Roberta Culp filed a lawsuit alleging federal and state law claims against various defendants, including Fort Wayne and Allen County police officers. The claims included excessive force under 42 U.S.C. § 1983, intentional and negligent infliction of emotional distress, assault and battery, criminal mischief, and violations of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The incident in question occurred on August 20, 2018, when Carl Culp, a double amputee, expressed suicidal intentions during a psychiatric appointment, leading to police intervention.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants on most claims, leaving only Carl Culp’s § 1983 excessive force claim and state law claims against Officers Woods and Schulien for trial. A jury found in favor of the defendants on all claims except for Roberta Culp’s state law battery claim against Officer Woods, awarding her nominal damages of $1. The Culps appealed the summary judgment decision, and Woods and Schulien cross-appealed the denial of costs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment to the defendants, as the defendants’ brief complied with the local rules. The court also found that the Culps failed to present evidence of discrimination or failure to accommodate under the ADA and Rehabilitation Act. The court assumed, without deciding, that these laws applied to law enforcement actions but concluded that the evidence did not support the Culps' claims.Regarding the cross-appeal, the Seventh Circuit upheld the district court’s decision to deny costs to both parties, recognizing the mixed outcome of the case. The court affirmed the district court’s judgment in its entirety. View "Culp v. Caudill" on Justia Law