Justia Civil Rights Opinion Summaries

A federal prisoner, LaQuan Johnson, filed a complaint under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, seeking money damages from federal prison officials, doctors, a nurse, and a kitchen supervisor. Johnson alleged violations of his constitutional rights through excessive force, failure to protect him from other inmates, and deliberate indifference to his serious medical needs. The incidents occurred while Johnson was housed at the United States Penitentiary in Atlanta, Georgia, from September 2015 to April 2019. He claimed that prison officials failed to separate pretrial detainees from convicted inmates, leading to multiple attacks on him, and that medical staff provided inadequate treatment for his injuries.The United States District Court for the Northern District of Georgia initially denied the defendants' motion to dismiss for failure to exhaust administrative remedies, finding that Johnson was denied access to the Bureau of Prisons' (BOP) administrative remedy program. However, after further discovery, the district court granted the defendants' motions for summary judgment, concluding that Johnson's claims did not entitle him to a Bivens remedy because they would require recognizing new Bivens causes of action, which the court is generally forbidden to create.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The Eleventh Circuit held that Johnson's failure to protect and deliberate indifference claims presented new Bivens contexts, as they were meaningfully different from the three contexts previously recognized by the Supreme Court in Bivens, Davis v. Passman, and Carlson v. Green. The court also found that special factors, including the existence of the BOP's administrative remedy program, counseled against extending Bivens to these new contexts. The court emphasized that the existence of an alternative remedial structure alone is sufficient to preclude the creation of a new Bivens remedy. View "Johnson v. Terry" on Justia Law

The case involves a non-fatal shooting of Joseph Williams by officers of the Sparks Police Department following a 42-minute car chase. Williams had stolen alcohol and vandalized a vehicle, leading to a police pursuit. During the chase, Williams ran red lights, drove through a fence, and briefly drove on the wrong side of the freeway. The chase ended when officers pinned Williams's truck, but he continued to attempt to flee, leading officers to fire multiple rounds, injuring him.The United States District Court for the District of Nevada denied summary judgment on Williams's claims of excessive force, municipal liability, and battery, except for the negligence claim. The court found genuine factual disputes about the threat Williams posed and whether he was attempting to flee when officers fired. The court also denied summary judgment on the Monell claims and the battery claim, citing unresolved factual issues.The United States Court of Appeals for the Ninth Circuit reversed the district court's denial of summary judgment. The appellate court found that video evidence clearly showed Williams attempting to accelerate, contradicting his claim. The court held that the officers' use of deadly force was objectively reasonable, given the threat Williams posed to public safety. The court also exercised pendent jurisdiction over the Monell and battery claims, finding no constitutional violation in the officers' use of force and ruling that the battery claim failed because the force used was not unreasonable. The court reversed and remanded the case for further proceedings consistent with its opinion. View "Williams v. City of Sparks" on Justia Law

Jose Vasquez was detained twice by the Metropolitan Police Department (MPD) because he shares the same name and birthdate as a wanted criminal. He sued the District of Columbia and an officer for constitutional violations under Section 1983, and the District alone for negligence, malicious prosecution, and false imprisonment. The District Court granted summary judgment on the Section 1983 and negligence claims. The jury found the District liable for false imprisonment but not for malicious prosecution, awarding Vasquez $100,000. However, the District Court later granted the District's motion for judgment as a matter of law, nullifying the jury's award, and alternatively granted a motion for remittitur.The United States District Court for the District of Columbia initially reviewed the case. It granted summary judgment in favor of the District and Officer Agosto on the Section 1983 claims, finding no constitutional violations. The court also dismissed the negligence claim. The jury trial on the common law claims resulted in a mixed verdict, with the jury awarding damages for false imprisonment but not for malicious prosecution. The District Court subsequently overturned the jury's verdict on false imprisonment and reduced the damages awarded.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It affirmed the District Court's summary judgment on the Section 1983 claims, agreeing that there was no clearly established constitutional violation and that qualified immunity applied to Officer Agosto. However, the appellate court vacated the District Court's judgment as a matter of law and the alternative remittitur on the false imprisonment claim. The appellate court reinstated the jury's verdict and remanded for further proceedings, emphasizing that the jury could reasonably find that the differing social security numbers indicated Vasquez was not the wanted criminal, and that the jury's damages award was justified based on the emotional harm suffered. View "Vasquez v. District of Columbia" on Justia Law

An Arkansas inmate, Steven Pinder, filed a lawsuit under 42 U.S.C. § 1983, alleging that various defendants, including Wellpath, LLC, and its employees, were deliberately indifferent to his serious medical needs, violating his Eighth Amendment rights. Pinder sought declaratory and injunctive relief and substantial damages for several medical issues, including severe glaucoma, peptic ulcers, acid reflux, diabetes, and an orthopedic condition in his right shoulder. The district court granted summary judgment to two defendants on the shoulder claim and dismissed other claims for failure to establish in forma pauperis (IFP) status.The United States District Court for the Eastern District of Arkansas initially denied Pinder's IFP status due to his "three strikes" under the Prison Litigation Reform Act (PLRA), which bars prisoners with three prior dismissals for frivolous or malicious claims from proceeding IFP unless they are in imminent danger of serious physical injury. Pinder filed a declaration asserting imminent danger, which the magistrate judge partially accepted, allowing some claims to proceed. The district court adopted these recommendations but later revoked IFP status for most claims based on new evidence, ultimately granting summary judgment on the remaining shoulder claim.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court remanded the motion to revoke Pinder's IFP status to the district court for further consideration, particularly in light of new medical evidence. The appellate court also remanded the issue of whether the interlocutory dismissals were proper, given a recent Eighth Circuit opinion. The court did not rule on the summary judgment at this time, vacating the district court's judgment and remanding for further proceedings consistent with its opinion. View "Pinder v. WellPath" on Justia Law

In 1984, Richard Wershe, Jr., at fourteen, was recruited by the FBI as a drug informant. Over the next few years, he was involved in dangerous drug operations under the direction of federal and state officers. In 1987, Wershe was arrested and convicted of possessing a large quantity of cocaine, receiving a life sentence without parole, which was later amended to allow parole eligibility. While incarcerated, he cooperated with law enforcement in various investigations, including "Operation Backbone" and a grand jury against the "Best Friends" gang, based on promises of assistance with his parole. Despite his cooperation, Wershe was denied parole in 2003 and was only released in 2017, subsequently serving time in Florida for an unrelated charge until his release in 2020.Wershe filed two lawsuits: one in July 2021 against the City of Detroit and various federal and state officials under 42 U.S.C. § 1983 and Bivens, and another in October 2022 against the United States under the Federal Tort Claims Act (FTCA). He alleged constitutional violations and tort claims related to his time as a juvenile informant and subsequent parole denial. The United States District Court for the Eastern District of Michigan dismissed both lawsuits with prejudice, ruling that Wershe’s claims were time-barred and not subject to equitable tolling.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Wershe’s claims were indeed time-barred under the applicable statutes of limitations and that he was not entitled to equitable tolling. The court found that Wershe had constructive knowledge of the filing deadlines, did not diligently pursue his claims, and that the defendants would be prejudiced by the delay. Additionally, the court ruled that the district court did not err in dismissing the complaints with prejudice or in its handling of materials outside the pleadings. View "Wershe v. City of Detroit" on Justia Law

La Dell Grizzell, acting on behalf of her minor children, sued San Elijo Elementary School and the San Marcos Unified School District, alleging that the school violated her children's federal and state civil rights. The complaint included claims of racial discrimination and other civil rights violations, such as racial epithets, physical assaults, and discriminatory disciplinary measures. Grizzell sought to proceed without legal representation.The United States District Court for the Southern District of California dismissed the case without prejudice, citing the "counsel mandate," which precludes nonlawyer parents from representing their children pro se. The court emphasized that regardless of the merits of the case, Grizzell could not represent her children without an attorney. The district court instructed that the minor plaintiffs could only proceed through a licensed attorney.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that it was bound by its precedent in Johns v. County of San Diego, which prohibits nonattorney parents from representing their children in court. Despite Grizzell's arguments that this rule impedes access to justice for children from low-income families, the panel concluded that it could not deviate from established precedent. The court acknowledged the serious implications of the counsel mandate but affirmed the dismissal without prejudice, indicating that only en banc review could potentially alter the rule. View "GRIZZELL V. SAN ELIJO ELEMENTARY SCHOOL" on Justia Law

Devon Arseneau and her ex-husband were involved in a child custody dispute in the St. Louis County Circuit Court. The court appointed Elaine Pudlowski and Brian Dunlop as guardians ad litem to represent the child's best interests and James Reid to conduct psychological evaluations. Following their testimonies, the court awarded sole legal custody to Arseneau’s ex-husband and joint physical custody to both parents. Arseneau subsequently filed a lawsuit under 42 U.S.C. § 1983 against Pudlowski, Dunlop, and Reid, alleging that their actions during the custody proceedings violated her constitutional rights.The United States District Court for the Eastern District of Missouri dismissed Arseneau’s complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court concluded that the defendants were entitled to absolute immunity and had not acted under color of state law. The district court did not address the defendants' arguments regarding Younger abstention or the Rooker-Feldman doctrine.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court determined that Younger abstention did not apply because there were no ongoing state proceedings. It also bypassed the Rooker-Feldman issue, finding that the merits of the case warranted dismissal. The court held that the defendants, as guardians ad litem and a court-appointed psychologist, were entitled to absolute immunity for actions within the scope of their judicial duties, even if those actions were alleged to be wrongful or illegal. Consequently, the court affirmed the dismissal of Arseneau’s § 1983 claims. View "Arseneau v. Pudlowski" on Justia Law

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

Sherita Hicks was mistakenly identified and arrested for an assault she did not commit. Detective Gregory Pamer, leading the investigation, showed the victim, Devante Allen, a photo lineup that included Hicks, whom Allen incorrectly identified as the female assailant. Pamer also discovered that a van used in the assault was registered to Hicks and that the attack was retribution for a prior break-in at her home. Despite later receiving exculpatory information implicating another woman, Pamer proceeded with Hicks' arrest. Hicks was jailed for one night before posting bond, and the charges against her were eventually dismissed.Hicks filed a civil rights lawsuit under 42 U.S.C. § 1983 against multiple parties, including Pamer and Anne Arundel County, alleging unlawful arrest, detention, and malicious prosecution. The case proceeded to trial against Pamer and the County on claims of malicious prosecution and gross negligence. During the trial, a juror was dismissed for violating court instructions by speaking to Hicks, despite objections from Hicks' counsel. The jury ultimately found in favor of Pamer on all counts, leading Hicks to file a motion for a new trial, which was denied.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the district court did not abuse its discretion in dismissing the juror for good cause under Federal Rule of Civil Procedure 47(c). The court also found no reversible error in the jury instructions, which adequately stated the controlling law. The jury's verdict in favor of Pamer on all counts was upheld, and the court did not need to address issues related to punitive damages or the inclusion of the County on the verdict sheet, as there was no underlying liability. View "Hicks v. Anne Arundel County" on Justia Law

Eva Mae Givens applied for Medicaid assistance in Washington, D.C., but the District miscalculated her copay, requiring her to pay an extra $2,000 per month. Givens requested an administrative hearing to contest the miscalculation, but D.C. did not provide a timely hearing as required by federal law. Givens then filed a lawsuit under 42 U.S.C. § 1983, seeking injunctive and declaratory relief for a fair hearing and monetary damages for the overpayments. While the case was pending, D.C. held a hearing, corrected the miscalculation, and sent back-payments to the nursing homes, but not to Givens. Givens passed away shortly after the hearing.The United States District Court for the District of Columbia dismissed the case with prejudice, ruling that the claims were moot because D.C. had provided the hearing and corrected the miscalculation. The court also held that Givens failed to state a claim for relief. Givens' children, who sought to be substituted as plaintiffs, appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the dismissal of the fair-hearing claims as moot but noted that the dismissal should have been without prejudice. The court found that the calculation claim was not moot because Givens had not received compensation for the overpayments she made. However, the court held that the calculation claim failed to plausibly allege a violation of federal rights under § 1983, as Givens did not identify a specific municipal policy or custom that caused the miscalculation.The appellate court vacated the district court's order dismissing the case with prejudice and remanded the case. The district court was instructed to dismiss the moot fair-hearing claims without prejudice and to either dismiss the calculation claim without prejudice or provide a detailed explanation for a dismissal with prejudice. View "Givens v. Bowser" on Justia Law