Justia Civil Rights Opinion Summaries

Marc Susselman received a traffic ticket from a Washtenaw County Sheriff’s deputy for failing to yield to a police cruiser with flashing lights. This ticket was later dismissed, but Susselman received another citation for failing to obey a police officer directing traffic. The Michigan circuit court ultimately dismissed the second ticket as well. Susselman then filed a federal lawsuit asserting constitutional and state law claims against Washtenaw County, the Washtenaw County Sheriff’s Office, the sheriff’s deputy, and Superior Township, Michigan.The United States District Court for the Eastern District of Michigan granted the defendants' motions to dismiss all claims. Susselman appealed the decision. The district court had found that the Washtenaw County Sheriff’s Office could not be sued under 42 U.S.C. § 1983 and that Susselman had waived certain state-law claims. The court also dismissed Susselman’s federal claims, including First Amendment retaliation and Fourteenth Amendment malicious prosecution, as well as state-law claims for malicious prosecution and intentional infliction of emotional distress.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Susselman failed to plausibly allege a constitutional violation or behavior by the deputy that would support his claims. Specifically, the court found that the issuance of the second ticket did not constitute a violation of substantive due process or First Amendment rights. Additionally, the court determined that Susselman did not establish a civil conspiracy or meet the requirements for his state-law claims. The court also concluded that Susselman did not identify any municipal policy or custom that resulted in a constitutional violation, thus dismissing his claims against Washtenaw County and Superior Township. View "Susselman v. Washtenaw County Sheriff's Office" on Justia Law

Nasanto Antonio Crenshaw, a 17-year-old, was shot and killed by Officer Matthew Sletten of the Greensboro, North Carolina police department while driving an allegedly stolen car. Crenshaw's mother, Wakita Doriety, filed a lawsuit against Officer Sletten for excessive force under 42 U.S.C. § 1983 and various state law claims. The City of Greensboro was also named as a defendant for the state law claims. The City moved to dismiss the claims, asserting governmental immunity, and the district court agreed, dismissing all claims against the City. Officer Sletten also moved to dismiss the claims against him, arguing that the video evidence contradicted the plaintiff's allegations.The United States District Court for the Middle District of North Carolina dismissed the claims against the City based on governmental immunity, ruling under Rule 12(b)(2). The court also dismissed the claims against Officer Sletten under Rule 12(b)(6), finding that the video evidence showed Crenshaw driving directly towards the officer, justifying the use of deadly force. The court concluded that the officer's actions were reasonable and dismissed the excessive force claim and the state law claims against him.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the dismissal of the claims against the City but reversed the dismissal of the claims against Officer Sletten. The appellate court held that the district court erred in dismissing the excessive force claim because the video did not blatantly contradict the plaintiff's allegations. The court found that the plaintiff's allegations, when properly construed, were sufficient to state a claim of excessive force under § 1983. The case was remanded for further proceedings on the claims against Officer Sletten. View "Doriety v. Sletten" on Justia Law

Joshua Francisco, an inmate at Farmington Correctional Center (FCC), suffered from mental illness and was placed on suicide watch multiple times during his incarceration. Despite receiving treatment and being evaluated by mental health professionals, Francisco was found hanging in his cell on October 22, 2014, after his cellmate reported he was suicidal. Francisco had denied being suicidal to correctional officers and mental health staff earlier that day.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the correctional officers and the warden, finding no deliberate indifference to Francisco's medical needs. The court determined that the officers' actions did not rise to the level of criminal recklessness required to establish a violation of the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the correctional officers and the warden were entitled to qualified immunity. The court found that the officers had conducted reasonable investigations and searches based on the information available to them and that Francisco's repeated denials of suicidal intent, along with the absence of a noose, did not indicate a strong likelihood of self-harm. The court also concluded that the warden was not personally involved in any unconstitutional custom or practice and that the claim of an unconstitutional policy requiring inmates to explicitly state they were suicidal was not supported by the evidence. View "Francisco v. Villmer" on Justia Law

In January 2021, Julius Lamart Hodges, an inmate at the Prince William-Manassas Adult Detention Center, volunteered to work in the kitchen during a COVID-19 outbreak while most inmates quarantined. Hodges did not contract COVID-19 but claimed that his exposure to the virus constituted cruel and unusual punishment under the Eighth Amendment. He also alleged that his working conditions were harsh and that he was retaliated against for filing grievances about these conditions.The United States District Court for the Eastern District of Virginia dismissed Hodges’s complaint. The court found that Hodges failed to state a claim under the Eighth Amendment because he voluntarily chose to work and could have opted to quarantine. The court also dismissed his First Amendment retaliation claim, concluding that Hodges did not plausibly allege a causal connection between his grievances and any adverse action taken by the prison officials.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s dismissal. The Fourth Circuit held that Hodges’s Eighth Amendment claim failed because he voluntarily exposed himself to the conditions he complained about, and thus, the prison officials did not inflict those conditions upon him. The court also found that Hodges’s First Amendment retaliation claim was insufficient because he did not adequately allege a causal relationship between his grievances and the denial of his Work Release application. The court noted that the temporal gap between his grievance and the adverse action was too long to support an inference of causation.The Fourth Circuit modified the district court’s dismissal to be without prejudice, allowing Hodges the opportunity to amend his complaint if he could address the deficiencies identified by the court. View "Hodges v. Meletis" on Justia Law

Kenneth Ray Jenkins, a pretrial detainee at Wilson County Detention Center (WCDC) in 2018, alleged that he was subjected to unsanitary living conditions, including confinement in cells infested with feces, which led to a bacterial illness. Jenkins, who suffers from mental health disorders, claimed that he was denied his medication, placed in solitary confinement, and later moved to an unsanitary "Rubber Room." He further alleged that he was denied medical attention for severe rectal bleeding for several months, which resulted in a diagnosis of multiple medical conditions.Jenkins filed a pro se complaint under 42 U.S.C. § 1983, asserting violations of his Fourteenth Amendment rights. The United States District Court for the Eastern District of North Carolina dismissed most of his claims but allowed his conditions-of-confinement and deliberate-indifference claims against Sheriff Calvin Woodard to proceed. Jenkins requested additional time for discovery and appointment of counsel, both of which were denied by the district court. The court granted summary judgment in favor of Sheriff Woodard, finding that Jenkins failed to demonstrate a material factual dispute.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court abused its discretion in denying Jenkins’s requests for counsel and additional time for discovery. The appellate court noted that Jenkins’s severe mental illness, lack of legal knowledge, and inability to access legal materials and evidence while incarcerated demonstrated that he lacked the capacity to present his claims. The Fourth Circuit reversed the district court’s denials of Jenkins’s requests for discovery and counsel, vacated the summary judgment decision, and remanded the case for further proceedings, directing the district court to appoint counsel for Jenkins. View "Jenkins v. Woodard" on Justia Law

T.W., a Harvard Law School graduate with disabilities, sued the New York State Board of Law Examiners for denying her requested accommodations on the New York State bar exam in 2013 and 2014. She alleged violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. T.W. claimed that the Board's actions caused her to fail the bar exam twice, resulting in professional and financial harm.The United States District Court for the Eastern District of New York initially denied the Board's motion to dismiss, finding that the Board had waived its sovereign immunity under the Rehabilitation Act. However, the United States Court of Appeals for the Second Circuit reversed this decision, holding that the Board was immune from suit under Section 504. On remand, the district court granted the Board's motion to dismiss T.W.'s Title II claim, ruling that the Board was an "arm of the state" and entitled to sovereign immunity. The court also held that Title II did not abrogate the Board's sovereign immunity for money damages and that T.W. could not seek declaratory and injunctive relief under Ex parte Young.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the Board is an arm of the state and thus entitled to sovereign immunity. It further concluded that Title II of the ADA does not validly abrogate sovereign immunity in the context of professional licensing. Additionally, the court found that the declaratory relief sought by T.W. was retrospective and therefore barred by the Eleventh Amendment. The court also ruled that the injunctive relief sought by T.W. was not sufficiently tied to an ongoing violation of federal law, making it unavailable under Ex parte Young. Consequently, the court affirmed the dismissal of T.W.'s claims for compensatory, declaratory, and injunctive relief. View "T.W. v. New York State Board of Law Examiners" on Justia Law

Vincent Bell, a pretrial detainee with an amputated right leg, alleged that deputies used excessive force during a cell extraction and transfer at the San Francisco Jail. Bell claimed that Sergeant Yvette Williams did not provide him with a wheelchair or other mobility device, forcing him to hop on one leg until he fell. Deputies then carried him by his arms and leg, causing him pain and minor injuries. Bell sued under the Fourteenth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act.The United States District Court for the Northern District of California held a jury trial. The jury found in favor of Bell on his excessive force claim against Williams and his ADA and Rehabilitation Act claims against the City and County of San Francisco. However, the jury did not find that Williams caused Bell physical or emotional harm. The jury awarded Bell $504,000 in compensatory damages against the City but not against Williams. The district court denied the defendants' post-trial motion for judgment as a matter of law or a new trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the jury's verdict on Bell's Fourteenth Amendment excessive force claim and his ADA and Rehabilitation Act claims, finding substantial evidence supported these claims. However, the court reversed the district court's decision on Bell's Monell theory of liability, concluding that Bell did not present substantial evidence showing that the City's training was the product of deliberate indifference to a known risk. The court also vacated the jury's compensatory damages award, deeming it grossly excessive, and remanded for a remittitur or a new trial on damages. View "BELL V. WILLIAMS" on Justia Law

Phillip Robbin was removing a tree from a residential lot in the City of Berwyn when he was confronted by Sarah Lopez, a city inspector. Lopez berated Robbin using racial slurs, which led Robbin to demand disciplinary action against her. The Mayor of Berwyn denied Robbin's request for Lopez's termination, leading Robbin to sue the City, the Mayor, and Lopez for violations of his substantive due process rights under the Fourteenth Amendment and state law.The United States District Court for the Northern District of Illinois dismissed Robbin’s complaint under Federal Rule of Civil Procedure 12(b)(6), finding that he failed to state a federal claim. The court also declined to exercise supplemental jurisdiction over the state law claims, leading to Robbin's appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that Robbin failed to allege a violation of a fundamental right and that the conduct described did not "shock the conscience," which are necessary elements for a substantive due process claim under the Fourteenth Amendment. The court noted that while Lopez's use of racial slurs was deplorable, it did not rise to the level of a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's dismissal of Robbin's complaint. View "Robbin v. City of Berwyn" on Justia Law

Reginald Pittman, a pretrial detainee at the Madison County jail, attempted suicide and suffered a severe brain injury. He claimed that two guards ignored his requests for crisis counseling before his suicide attempt. Pittman sued Madison County and various jail officials under 42 U.S.C. § 1983, alleging a violation of the Fourteenth Amendment for failing to provide adequate medical care. The case has a lengthy procedural history, including three appeals and three trials.The United States District Court for the Southern District of Illinois initially granted summary judgment for the defendants, but this was reversed in part by the Seventh Circuit in Pittman I. After a first trial, the Seventh Circuit in Pittman II reversed and remanded for a new trial due to the erroneous exclusion of evidence. In Pittman III, the Seventh Circuit found a jury instruction error and remanded for a third trial. In the third trial, the district court instructed the jury in line with Pittman III, requiring proof that the officers were subjectively aware or strongly suspected a high likelihood of self-harm. The jury returned a verdict for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the jury instruction was erroneous. The court clarified that Pittman did not need to prove subjective awareness of the risk of harm. Instead, the jury should have been instructed to determine whether the defendants made an intentional decision regarding Pittman’s conditions of confinement and whether they acted objectively unreasonably by failing to mitigate the risk. Despite this error, the court concluded that the erroneous instruction did not prejudice Pittman, as the case was presented as a credibility contest between the testimony of the guards and an inmate. Therefore, the Seventh Circuit affirmed the verdict for the defendants. View "Pittman v. Madison County, Illinois" on Justia Law

Harris Ford, an inmate in the North Carolina Department of Corrections, filed a lawsuit against six prison officials under 42 U.S.C. § 1983, alleging that they violated his Eighth Amendment rights by failing to protect him from an attack by another inmate. Ford claimed that he had informed the officials of the risk through numerous complaints and grievances, but they were deliberately indifferent, leading to the attack where he was severely injured.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the prison officials. The court concluded that Ford's complaints were not specific enough to enable the officials to investigate and respond appropriately. Additionally, the court found that Ford failed to demonstrate the necessary mens rea of deliberate indifference required for an Eighth Amendment violation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment regarding five of the six prison officials. The appellate court agreed that Ford did not provide sufficient evidence to show that these officials were deliberately indifferent to his safety. However, the court vacated the summary judgment concerning Officer Jerry Ingram. The court found that there was a genuine issue of material fact regarding whether Ingram's actions, specifically his public questioning of Ford about the threats, knowingly exacerbated the risk to Ford and contributed to the attack. The case was remanded for further proceedings against Officer Ingram. View "Ford v. Hooks" on Justia Law