Justia Civil Rights Opinion Summaries

Bobby Stevenson, a prisoner at the Louisiana State Penitentiary, claims he was forced to labor in the prison’s agricultural fields despite severe ankle pain caused by two broken surgical screws. He alleges that two prison physicians, Dr. Randy Lavespere and Dr. Paul M. Tocé, refused to fix the screws or relieve him from field labor. Stevenson asserts that the broken screws caused him tremendous pain and secondary injuries, and that the physicians ignored his complaints and medical recommendations for surgery.The United States District Court for the Middle District of Louisiana reviewed the case. The magistrate judge allowed Stevenson to file an amended complaint and recommended denying the defendants' motion to dismiss, which argued for qualified immunity. The district court accepted this recommendation and denied the motion, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Stevenson sufficiently alleged that the defendants violated his Eighth Amendment rights by ignoring his severe medical needs and forcing him to work despite his condition. The court also determined that the defendants had fair warning from existing case law that their actions were unconstitutional. Consequently, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss, rejecting the defendants' claim of qualified immunity. View "Stevenson v. Toce" on Justia Law

In February 2016, two Seattle police officers, Scott Miller and Michael Spaulding, fatally shot Che Andre Taylor during an attempted arrest. Kshama Sawant, a Seattle City Council member, publicly referred to the incident as a "blatant murder" and later reiterated that Taylor was "murdered by the police." Following an inquest, prosecutors declined to file charges against the officers due to insufficient evidence of malice. Miller and Spaulding subsequently filed a lawsuit alleging defamation and outrage under state law, as well as a federal defamation claim against Sawant.The United States District Court for the Western District of Washington dismissed the federal defamation claim but retained jurisdiction over the state law claims. The court later granted Sawant's motion for summary judgment on the state law claims and awarded her expert witness deposition expenses, including fees for preparation time. Miller and Spaulding appealed the decision, challenging the award of expert witness fees and the admissibility of the expert's opinions.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that Federal Rule of Civil Procedure 26 allows for the recovery of reasonable expenses for time an expert witness spends preparing for a deposition. The court joined other circuits in concluding that such preparation fees are recoverable under Rule 26. The court found that the expert witness deposition preparation fees awarded to Sawant were reasonable and did not result in manifest injustice. The Ninth Circuit also noted that objections to the admissibility of the expert's opinions did not negate the obligation to pay a reasonable fee under Rule 26. The court affirmed the district court's grant of summary judgment and the award of expert witness deposition expenses. View "Miller v. Sawant" on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law

In 2018, Officer Patrick Kaine of the City of Wauwatosa Police Department stopped a vehicle based on a citizen's tip about a potential robbery. The vehicle contained Akil Carter, Paulette Barr, and Sandra Adams. Officer Kaine handcuffed Carter and placed him in the back of his squad car while he investigated. He soon realized the tip was mistaken, uncuffed Carter, and allowed the group to leave. Carter, Barr, and Adams subsequently sued Officer Kaine, other officers, and the City of Wauwatosa, alleging violations of their Fourth Amendment rights.The case was initially heard in the United States District Court for the Eastern District of Wisconsin, where the jury found in favor of the defendants. The plaintiffs appealed, challenging several pretrial and trial decisions, including the bifurcation of the trial, jury instructions, exclusion of their police-practices expert, and the judge's failure to recuse himself. They also contested the district judge's denial of their Batson challenge to a peremptory strike.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found no error in the district judge's decisions regarding bifurcation, jury instructions, exclusion of the expert, or recusal. However, the court determined that the district judge did not properly conduct the third step of the Batson inquiry, which requires assessing whether the race-neutral reasons for the peremptory strike were pretextual. The court remanded the case for further findings on the Batson challenge to Juror 10, instructing the district judge to complete the three-step Batson process and make the necessary credibility determinations on the record. The court affirmed the district court's decisions in all other respects. View "Carter v. City of Wauwatosa" on Justia Law

Trevor Davis filed a lawsuit against Deputy Christopher Allen under 42 U.S.C. § 1983, claiming that Allen violated his Fourth Amendment rights by using excessive force during his arrest. Davis had several outstanding warrants for violent felonies, and when officers arrived to arrest him, he fled into a trailer. Deputy Allen used his police dog, Koda, to locate Davis inside the trailer. Despite Davis lying face-down with his hands over his head, Koda bit him, causing severe injury. Davis alleged that Allen failed to recall Koda after Davis had surrendered.The United States District Court for the Western District of Wisconsin denied Deputy Allen’s motion for summary judgment. The court found that there were material disputes of fact regarding the circumstances and timing of the use of the police dog, which precluded a finding of qualified immunity at this stage. Specifically, the court noted that a jury could find that a reasonable officer would have known that Davis had surrendered and that continuing to allow Koda to bite him constituted excessive force.The United States Court of Appeals for the Seventh Circuit reviewed the case and dismissed the appeal for lack of appellate jurisdiction. The court noted that the district court’s denial of qualified immunity was based on disputed facts, which are not subject to interlocutory appeal. The Seventh Circuit emphasized that the reasonableness of Deputy Allen’s actions depended on resolving these factual disputes, such as whether Davis was visibly unarmed and compliant. The court concluded that it could not address the merits of the qualified immunity claim without first resolving these factual issues, which must be done by a jury. View "Davis v. Allen" on Justia Law

A Columbia County resident, Roderick McDaniel, was shot and killed by Deputy Charles McClinton outside an apartment complex in Magnolia, Arkansas. McDaniel was a suspect in a first-degree murder case, and an arrest warrant had been issued for him. Deputy McClinton encountered McDaniel in a white SUV, which matched the description of the vehicle used in the crime. When McDaniel attempted to flee by reversing into McClinton's patrol car and then accelerating forward, McClinton fired a single shot, killing McDaniel. A loaded handgun, later confirmed to be the murder weapon, was found near McDaniel.The United States District Court for the Western District of Arkansas denied Deputy McClinton's motion for summary judgment based on qualified immunity. The court found that there were material factual disputes, particularly regarding whether McDaniel was driving the SUV forward toward McClinton when he was shot. The court concluded that McClinton was not entitled to qualified immunity because it was clearly established that using deadly force against a suspect merely for fleeing, even in a vehicle, was unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that Deputy McClinton was entitled to qualified immunity. The court reasoned that McClinton had probable cause to believe McDaniel was a dangerous felon who had committed first-degree murder and was still armed. Therefore, using deadly force to prevent McDaniel's escape was constitutionally permissible. The court also noted that McClinton's conduct did not violate McDaniel's clearly established rights, as existing precedent did not clearly prohibit the use of deadly force in such circumstances. The case was remanded with instructions to enter summary judgment in favor of Deputy McClinton and dismiss the case. View "Arnold v. McClinton" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

Joel Cielak and Barron Hodges were sexually abused by David Johnson, a teacher at Nicolet High School (NHS), in the late 1970s and early 1980s. Hodges reported the abuse in 1983, leading the school board to confront Johnson but keep him employed under supervision. Johnson ceased abusing Hodges but continued to abuse Cielak, who had graduated in 1982. Both plaintiffs sued NHS, the school district, and board members under 42 U.S.C. §§ 1983 and 1985, alleging violations of their Fourteenth Amendment rights and a conspiracy to violate their equal protection rights. The district court dismissed the claims with prejudice and denied leave to amend the complaint.The United States District Court for the Eastern District of Wisconsin granted the defendants' motion to dismiss, concluding that the plaintiffs failed to state claims based on Johnson's abuse predating Hodges's 1983 allegation. The court also found that Hodges's claims were time-barred and that Cielak's allegations of post-allegation harms did not amount to violations of his substantive due process or equal protection rights. The court denied the plaintiffs leave to amend their complaint, deeming it futile.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Hodges's claims were time-barred as he knew of his injuries and their cause in the fall of 1983. In contrast, the court found that it was unclear when Cielak knew or had reason to know that his post-allegation injuries were connected to actions by the defendants, making it improper to dismiss his claims on statute of limitations grounds at this stage. However, the court concluded that Cielak failed to plausibly plead a violation of his substantive due process or equal protection rights because Johnson's post-allegation abuse was not under color of state law. The court also upheld the denial of leave to amend, noting that the plaintiffs failed to explain how they would cure the complaint's defects. View "Cielak v. Nicolet Union High School District" on Justia Law