Justia Civil Rights Opinion Summaries

In this case, inmate Kyle Richards alleged that Thomas Perttu, a prison employee, sexually harassed him and other inmates. Richards also claimed that Perttu destroyed his grievance documents and retaliated against him for attempting to file them. Richards sued Perttu under 42 U.S.C. §1983 for violating his constitutional rights, including his First Amendment right to file grievances. Perttu moved for summary judgment, arguing that Richards had failed to exhaust available grievance procedures as required by the Prison Litigation Reform Act (PLRA).The Magistrate Judge found a genuine issue of fact regarding whether Richards was excused from exhausting his claims due to Perttu's interference and held an evidentiary hearing. The Magistrate Judge concluded that Richards's witnesses lacked credibility and recommended dismissal without prejudice for failure to exhaust. The District Court adopted this recommendation. The Sixth Circuit reversed, holding that the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case.The Supreme Court of the United States held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The Court reasoned that the usual practice under the Federal Rules of Civil Procedure is that factual disputes regarding legal claims go to the jury. The PLRA is silent on whether judges or juries should resolve exhaustion disputes, and this silence indicates that the usual practice should be followed. The Court affirmed the judgment of the Sixth Circuit. View "Perttu v. Richards" on Justia Law

Plaintiff SeanPaul Reyes, who frequently posts videos of his interactions with police on YouTube, challenged a New York City Police Department (NYPD) policy that prohibits video recording inside police facilities. Reyes, who had been arrested twice for recording inside police stationhouses, argued that the policy violated his rights under the First Amendment and the New York State and New York City Right to Record Acts (RTRAs). He sought a preliminary injunction to prevent the City from enforcing the policy and to remove signs stating the policy.The United States District Court for the Southern District of New York granted Reyes a preliminary injunction based on his state and local law claims, despite finding that he was unlikely to succeed on his First Amendment claim. The court concluded that Reyes demonstrated a likelihood of success on the merits of his RTRAs claims, irreparable harm, and that the public interest favored an injunction.The City of New York appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court erred in exercising supplemental jurisdiction over the state and local claims and in finding that Reyes met the requirements for a preliminary injunction. The Second Circuit found no abuse of discretion in the district court's exercise of supplemental jurisdiction or its determination of irreparable harm. However, the court noted that the resolution of whether Reyes is likely to succeed on the merits and whether the public interest favors an injunction depends on the interpretation of the RTRAs.Given the lack of clear guidance from New York courts on whether the RTRAs afford a right to record inside police stationhouses, the Second Circuit certified the following question to the New York Court of Appeals: Does either N.Y. Civ. Rights Law § 79-p or N.Y.C. Admin. Code § 14-189 afford individuals the right to video record law enforcement activities inside public facilities, specifically inside the publicly accessible lobbies of police stationhouses, notwithstanding the NYPD policy forbidding such recording? The decision on the appeal is reserved pending the response from the New York Court of Appeals. View "Reyes v. City of New York" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law

The case involves Plaintiff Craig Gabaldon, who was stopped by New Mexico State Police Officer Kevin Smith for multiple traffic violations, including improper merging, speeding, and failing to use a turn signal. During the stop, Officer Smith detected signs of intoxication and arrested Gabaldon after a struggle, during which a loaded gun was found on Gabaldon. Officer Kurtis Ward assisted in the arrest. Gabaldon filed a civil action alleging constitutional violations and state-law claims, asserting that the stop was motivated by his affiliation with the Bandidos Motorcycle Club.The United States District Court for the District of New Mexico granted Defendants' motion for sanctions for spoliation of evidence, as Gabaldon had returned his Bandidos gear to the club, which likely destroyed it. The court also granted summary judgment in favor of Defendants on Gabaldon's Fourth, Fifth, and Fourteenth Amendment claims, citing qualified immunity and finding reasonable suspicion for the traffic stop and probable cause for the arrest. Gabaldon's affidavit, which contradicted his deposition testimony, was struck down as a sham affidavit.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the district court did not abuse its discretion in granting the spoliation motion or in striking Gabaldon's affidavit. The appellate court agreed that the affidavit was an attempt to create a sham fact issue, as it contradicted Gabaldon's earlier deposition testimony without new evidence. The court also upheld the summary judgment, finding that Officer Smith had reasonable suspicion to stop Gabaldon based on observed traffic violations. The appellate court concluded that the district court's rulings were correct and affirmed the judgment. View "Gabaldon v. New Mexico State Police" on Justia Law

In 2008, a class action was filed against officials from the City of Tenaha and Shelby County under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. Plaintiffs claimed that the officials had an illegal practice of targeting and seizing property from racial or ethnic minorities. A settlement agreement, including a consent decree, was reached, requiring the defendants to follow specific procedures to prevent future illegal stops. The decree also included a court-appointed monitor to ensure compliance. The consent decree was initially entered in 2013, amended in 2019, and expired in July 2020. Plaintiffs' motion to extend the decree was denied, and the County Defendants settled, leaving only the City Defendants in the case.The United States District Court for the Eastern District of Texas handled the case, where class counsel filed four motions for attorney fees. The first three motions were granted, totaling $324,773.90. The fourth motion requested $88,553.33 for fees from April to December 2020. Initially denied as untimely, the decision was vacated and remanded by the appellate court. On reconsideration, the district court awarded $16,020, reducing the hourly rates and the hours deemed reasonable.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court failed to provide class-wide notice of the attorney-fee motion as required by Federal Rule of Civil Procedure 23(h). This failure deprived class members of the opportunity to object to the fee motion. The appellate court held that the district court abused its discretion by not enforcing the notice requirement and vacated the fee award, remanding the case for further proceedings to ensure compliance with Rule 23(h). View "Morrow v. Jones" on Justia Law

Mark Petersen sued Deputy Stefanie Pedersen under 42 U.S.C. § 1983, alleging false arrest for drunk driving and an unlawful blood draw. On December 27, 2018, Deputy Pedersen responded to a car crash in rural Wisconsin. She found Petersen, who was intoxicated, attempting to change a tire on a car registered to him. Witnesses confirmed he was the only person near the car. Petersen had a history of uncooperative behavior with law enforcement and prior OWI charges. Based on the scene, his behavior, and his intoxication, Pedersen arrested him for OWI and obtained a search warrant for a blood draw, which confirmed his high BAC.In the Circuit Court of Winnebago County, Petersen was charged with OWI – 4th Offense. He moved to suppress the BAC evidence, arguing lack of probable cause for his arrest. The state court granted his motion, leading to the dismissal of the charges. Petersen then filed a § 1983 lawsuit in the United States District Court for the Eastern District of Wisconsin, which was reduced to claims against Deputy Pedersen for false arrest and unreasonable search. The district court granted summary judgment for Pedersen, finding probable cause for the arrest and a valid search warrant for the blood draw, and also granted her qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that probable cause supported Petersen’s arrest based on the totality of the circumstances, including his intoxication, the scene of the crash, and witness statements. The court also found the blood draw was lawful as it was conducted pursuant to a valid search warrant. Additionally, the court held that Deputy Pedersen was entitled to qualified immunity for both the arrest and the blood draw. View "Petersen v Pedersen" on Justia Law

Lazerek Austin, a state prisoner, filed a lawsuit under 42 U.S.C. § 1983 against three medical providers, alleging deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Austin, representing himself, requested the court to recruit counsel due to his severe mental illness and lack of access to legal resources. The district court initially granted his motion for recruited counsel but was unable to find a volunteer attorney despite extensive efforts. Consequently, Austin continued to litigate his case pro se, participating in discovery and responding to motions.The United States District Court for the Central District of Illinois eventually granted summary judgment in favor of the defendants, concluding that a reasonable jury could not find that they violated Austin’s constitutional rights. Austin appealed, arguing that the district court erred by not continuing to search for counsel after initially granting his motion.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court noted that federal courts cannot compel attorneys to provide free services to civil litigants and that the district court made reasonable efforts to recruit counsel. The court emphasized that the district court was not required to search indefinitely for a volunteer attorney and that it reasonably concluded Austin was capable of litigating his case pro se. The appellate court affirmed the district court's decision, finding no abuse of discretion in its handling of Austin's motion for recruited counsel and its determination that Austin could proceed without counsel. View "Austin v. Hansen" on Justia Law

Edward B. Spencer, an indigent and incarcerated individual, filed multiple lawsuits against various California prison officials. He initially proceeded in forma pauperis (IFP) in each case. Spencer had previously filed numerous lawsuits while incarcerated, and he conceded that two of those actions resulted in strikes under the Prison Litigation Reform Act (PLRA). However, he disputed whether two other actions, which he voluntarily dismissed, should count as strikes.The United States District Court for the Eastern District of California revoked Spencer's IFP status in four cases, finding that he had four strikes, including the two voluntary dismissals. The district court adopted the magistrate judge's findings and recommendations, which concluded that the voluntary dismissals counted as strikes under the PLRA.The United States Court of Appeals for the Ninth Circuit reviewed the district court's revocation of Spencer's IFP status. The Ninth Circuit held that voluntary dismissals under Federal Rule of Civil Procedure 41(a)(1) do not constitute strikes under the PLRA. The court reasoned that the "on the grounds that" clause in 28 U.S.C. § 1915(g) requires grounds to be decided by a court, and voluntary dismissals do not have grounds decided by a court. Therefore, Rule 41(a)(1) voluntary dismissals cannot count as strikes because they are never "on the grounds that" the case was frivolous, malicious, or failed to state a claim.The Ninth Circuit reversed the district court's revocation of Spencer's IFP status in each of the four cases on appeal and remanded for further proceedings. The court did not address any other issues urged by the parties. View "Spencer v. Milan" on Justia Law

In June 2018, Leslie Davies and volunteers from the Animal Protection and Rescue League, Inc. protested against a pet store in a Temecula shopping mall, alleging the store sourced dogs from puppy mills. They were asked by mall officials to move their protest due to a table reservation conflict. When Davies refused, Riverside Sheriff’s Deputy Rudy Leso threatened her with arrest if she did not comply. Davies requested a citation instead, but Leso insisted on arrest. Consequently, Davies and the volunteers left the area.The plaintiffs, Davies and the League, filed a lawsuit against the County of Riverside and Deputy Leso in August 2019. The Superior Court of Riverside County sustained demurrers without leave to amend for several causes of action, including negligence, Bane Act, and Ralph Act claims. The court also granted summary judgment in favor of the defendants on the remaining cause of action for declaratory relief.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court affirmed the lower court’s decisions, finding no error. It held that Davies’s negligence claim failed because she did not allege physical injury or a breach of duty. The Ralph Act claim was dismissed as the threat of arrest did not constitute violence. The Bane Act claim was also dismissed because the threat of arrest alone did not amount to coercion or intimidation. Lastly, the court upheld the summary judgment on the declaratory relief claim, noting there was no actual controversy since the County agreed that mall rules are not laws and cannot provide probable cause for arrest. The appellate court affirmed the judgment in favor of the County and Deputy Leso. View "Animal Protection and Rescue v. County of Riverside" on Justia Law