Justia Civil Rights Opinion Summaries

Margaret Woods, proceeding without an attorney, sued her former employer STS Services, L.L.C., after being terminated from her job. In her Third Amended Complaint, Woods alleged that she was fired because she is a black woman and replaced by white men. Earlier versions of her complaint included claims for breach of contract and race discrimination under 42 U.S.C. § 1981, which she abandoned, leaving only claims of race and sex discrimination under Title VII. Woods did not provide factual details about her qualifications for the position from which she was terminated.The United States District Court for the Northern District of Texas reviewed Woods’s successive complaints. Each time, the district court dismissed her complaints for failure to state a claim but allowed her opportunities to amend and refile. Woods submitted her Second Amended Complaint late, which was also dismissed. Her Third Amended Complaint was timely, but again found deficient for failing to plead facts regarding her qualifications. The court gave her another chance to amend, but Woods did not file a Fourth Amended Complaint within the deadline, or at all. The district court ultimately dismissed the case with prejudice and entered judgment in favor of STS Services, assessing costs against Woods.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The appellate court held that Woods failed to state a Title VII claim because her complaint did not include sufficient factual allegations to establish that she was qualified for her position, a necessary element of a prima facie case under Title VII. The Fifth Circuit also found that the district court did not abuse its discretion in dismissing Woods’s complaint with prejudice after repeated deficiencies and failures to amend. The judgment of the district court was affirmed. View "Woods v. STS Services" on Justia Law

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

In September 2020, a college student alleged she was sexually assaulted by a man during a late-night traffic stop in Virginia. She reported the incident to local law enforcement and participated in multiple interviews with detectives, who investigated her claims but found surveillance footage that was low-quality and recorded at a different time than the alleged assault. During a subsequent interview, detectives pressured her about inconsistencies in the evidence and, after the interview, she received threatening text messages. The detectives later told university officials she had confessed to fabricating her report. The sheriff then directed detectives to use her confession as probable cause for an arrest warrant charging her with filing a false police report. After her arrest, officers issued a press release with her personal information and photo, which led to widespread public shaming and emotional distress.Initially, she was convicted in a bench trial in Washington County District Court, but after appealing, her conviction was annulled and she was acquitted in a de novo bench trial in Washington County Circuit Court. She then sued the officers and the sheriff in the United States District Court for the Western District of Virginia, alleging violations of her constitutional rights and state law torts.The district court dismissed the complaint under Rule 12(b)(6), relying on an audio recording of the key interview. The court found the recording contradicted her claims of coercion, ruling that it showed a civil discussion without coercion and that her confession appeared voluntary. It also found her allegation of having no choice but to confess was not credible based on the recording.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by dismissing the complaint based on the audio recording, because the recording did not "blatantly contradict" her factual allegations as required by Fourth Circuit precedent. The appellate court vacated the dismissal and remanded the case for further proceedings. View "Bermeo v. Andis" on Justia Law

On July 29, 2007, Noel Dean’s wife, Shannon, died from a gunshot wound at their home after she became severely intoxicated and after Noel confronted her with evidence of an affair. Noel reported that Shannon shot herself, but law enforcement suspected homicide. The next day, Dr. Darshan Phatak, an assistant medical examiner, performed the autopsy. Initially, he could not determine whether the death was a homicide or suicide and marked the cause as “pending.” After meeting with colleagues and reviewing police interviews and other evidence, Dr. Phatak concluded the gun’s orientation at the time of the shooting was inconsistent with Noel’s account and classified the death as a homicide in the official autopsy report. This report contributed to Noel’s arrest and indictment for murder. During a subsequent trial, photographic overlays created by Dr. Phatak’s supervisor suggested the gun orientation matched Noel’s story, prompting a change in the autopsy report’s classification to “undetermined” and a dismissal of charges.Noel Dean then filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging Dr. Phatak intentionally fabricated the autopsy report. The United States District Court for the Southern District of Texas denied Dr. Phatak’s summary judgment motion based on qualified immunity, relying on allegations rather than evidence. On initial appeal, the United States Court of Appeals for the Fifth Circuit vacated and remanded for proper consideration of the summary judgment record. After further briefing and significant delay, the district court again denied summary judgment, applying a “deliberate indifference” standard.On this second interlocutory appeal, the United States Court of Appeals for the Fifth Circuit held that the district court applied the wrong legal standard by using a “deliberate indifference” test rather than determining whether a rational juror could find Dr. Phatak intentionally misstated his conclusions. The appellate court vacated the denial of summary judgment and remanded for reconsideration under the correct standard. View "Dean v. Phatak" on Justia Law

The underlying dispute arose after an individual was convicted of a crime in Louisiana, served part of his sentence, and later had his conviction reversed or vacated. Claiming factual innocence, he sought compensation under Louisiana’s wrongful conviction statute, which provides monetary awards to qualifying persons. Prior to filing this petition in state court, he had also initiated a separate federal lawsuit under 42 U.S.C. § 1983, alleging violations of his constitutional rights stemming from the same prosecution and conviction.In the Criminal District Court for the Parish of Orleans, the State requested a stay of the wrongful conviction compensation proceedings, citing Louisiana Code of Civil Procedure article 532. This provision allows a court to stay proceedings when there is a related action in another jurisdiction involving the same parties and occurrence. The State argued that the federal suit should proceed first. The district court denied the motion to stay in open court on March 27, 2025. The State then sought supervisory review from the Louisiana Fourth Circuit Court of Appeal, which also denied relief on April 30, 2025.The Supreme Court of Louisiana reviewed the district court’s denial of the stay. The court examined the statutory differences between the state law compensation claim, which requires proof of factual innocence, and the federal civil rights action, which focuses on constitutional violations by individual actors. Concluding that the district court did not abuse its discretion in refusing to stay the state court proceedings—especially in light of the legislative instruction to decide wrongful conviction claims expeditiously—the Supreme Court of Louisiana affirmed the district court’s decision. The main holding is that denial of the State’s motion to stay the wrongful conviction compensation proceedings was proper under the circumstances. View "Williams v. State" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

During the COVID-19 pandemic, a university in Nebraska instituted a policy requiring all students to be vaccinated against COVID-19 by a specified deadline, with the only exemptions allowed for medical reasons or until a vaccine received full FDA approval. Religious exemptions were not permitted. Students who failed to comply were unenrolled and barred from campus, and some had holds placed on their accounts, preventing access to transcripts. One student complied with the mandate but suffered adverse effects and was medically exempted from further doses. Another student withdrew voluntarily before the deadline.After the university enforced the mandate, several students sought injunctive relief in the District Court for Douglas County to prevent their unenrollment, alleging breach of contract and unjust enrichment. The court denied relief, finding that any contract included the Emergency Use Authorization waiver agreements and that the students breached the contract by not being vaccinated after FDA approval. An initial appeal was dismissed by the Nebraska Supreme Court for lack of a final, appealable order. The students then consolidated their actions and filed an operative complaint alleging breach of implied contract, denial of due process, conversion, negligence, and violations of the Nebraska Consumer Protection Act (NCPA). The district court dismissed the complaint with prejudice and denied leave to amend.The Nebraska Supreme Court reviewed the district court’s dismissal de novo and found that the students plausibly alleged claims for breach of an implied contract and conversion, based on the university’s unilateral modification of conditions mid-semester and the withholding of transcripts. The court affirmed the dismissal of the negligence and NCPA claims, finding them preempted by the federal Public Readiness and Emergency Preparedness Act, and held that the due process claim was abandoned on appeal. The case was affirmed in part, reversed in part, and remanded for further proceedings on the breach of contract and conversion claims. View "Ramaekers v. Creighton University" on Justia Law