Justia Civil Rights Opinion Summaries

In this case, the Supreme Court of the State of Nevada considered whether the Nevada State Engineer had the authority to combine multiple existing hydrographic basins into one "superbasin" for the purposes of water administration and management based on a shared source of water. The State Engineer had combined seven basins into one superbasin, the Lower White River Flow System (LWRFS), after determining that the waters of these basins were interconnected such that withdrawals from one basin affected the amount of water in the other basins. The State Engineer also found that the previously granted appropriations of water exceeded the rate of recharge in the LWRFS. Various entities who owned water rights throughout the new superbasin challenged the State Engineer's decision, claiming that he lacked the authority to manage surface waters and groundwater jointly and that his decision violated their due process rights.The Supreme Court of the State of Nevada held that the State Engineer indeed had the authority to manage surface waters and groundwater conjunctively and to jointly administer multiple basins. The court also found that the State Engineer did not violate the rights holders' due process rights because they received notice and had an opportunity to be heard. The court reversed the lower court's decision that had granted the rights holders' petitions for judicial review and remanded the matter back to the lower court for further proceedings to determine whether substantial evidence supported the State Engineer's factual determinations. View "Sullivan v. Lincoln County Water District" on Justia Law

In this case decided by the United States Court of Appeals for the Ninth Circuit, the court considered whether the claims filed by Adriana Holt, her children, and her mother Beatriz Lukens against Orange County and several deputy sheriffs were barred by the applicable statutes of limitations. The plaintiffs alleged unlawful search and arrest and brought claims under 42 U.S.C. § 1983 and California state law. The case involved multiple filings and dismissals in different courts, raising the question of whether the tolling provision of the supplemental jurisdiction statute, 28 U.S.C. § 1367, applied to their claims.The court held that the plaintiffs' claims were not tolled and were therefore properly dismissed as untimely. The court reasoned that § 1367 tolls the applicable statute of limitations for a federal-law claim that is contained in the same federal court complaint as a supplemental state-law claim and that is “voluntarily dismissed at the same time as or after the dismissal of the [supplemental] claim.” However, this tolling provision does not apply when the supplemental claim is voluntarily dismissed, as occurred in Holt's first suit, or when a supplemental claim is dismissed for improper joinder, as occurred in the separate class action.Finally, the court also held that the plaintiffs' state-law claims were not tolled by a Covid-19 pandemic emergency tolling order and rule because the limitations periods for those claims had already lapsed before either the order or rule went into effect. Therefore, the court affirmed the lower court's dismissal of the plaintiffs' claims as time-barred. View "HOLT V. COUNTY OF ORANGE" on Justia Law

The Supreme Court of Louisiana was asked by the United States Court of Appeals for the Fifth Circuit on whether the commencement of a suit in a court of competent jurisdiction and venue interrupts prescription as to causes of action, understood as legal claims rather than the facts giving rise to them, not asserted in that suit. This query arose from the case of Randall Kling who initially filed suit in state court alleging his dismissal from the Louisiana Office of Alcohol and Tobacco Control was in retaliation for submitting written complaints about workplace and ethics violations. He later filed a complaint in federal district court citing substantially similar facts and seeking relief for violations of his federal First and Fourteenth Amendment rights.The Supreme Court of Louisiana answered the certified question by stating that prescription or the period within which a lawsuit may be filed is interrupted when notice is sufficient to fully inform the defendant of the nature of the claim of the plaintiff, and what is demanded of the defendant. The Court explained that the essence of interruption of prescription by suit is notice to the defendant of the legal proceedings based on the claim involved. The court emphasized that notice is sufficient when it fully informs the defendant of the nature of the plaintiff's claim, and what is demanded of the defendant. Thus, the court took a balanced approach between a broad interpretation of interruption and a narrow one, placing emphasis on notice to the defendant, addressed on a case-by-case basis. View "KLING VS. HEBERT" on Justia Law

Larry Trent Roberts spent 13 years in prison for a murder that he did not commit. After being exonerated, he sued several state actors involved in obtaining his wrongful conviction, including Assistant District Attorney John C. Baer. The United States Court of Appeals for the Third Circuit held that Baer is not entitled to absolute immunity from liability under 42 U.S.C. § 1983 because his actions of seeking a new witness to establish a motive for the murder served an investigatory function, not a prosecutorial one. The court noted that prosecutors are not entitled to absolute immunity when they perform investigative functions normally performed by a detective or police officer. Baer argued that he was immune from liability as his conduct occurred post-charge and was designed to produce inculpatory evidence for trial. However, the court clarified that the timing of a prosecutor's actions as pre- or post-indictment and the presence or absence of a connection to a judicial proceeding are only "relevant considerations" in determining whether a prosecutor’s action served a prosecutorial function. They are not enough to establish that a prosecutor's post-charge effort to fabricate evidence for trial served a quasi-judicial function. The court affirmed the District Court's decision denying Baer's motion to dismiss. View "Roberts v. Lau" on Justia Law

The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

In this case, Alyssa Reid, a former faculty member at James Madison University (JMU) in Virginia, was accused of violating JMU’s Title IX policy against non-consensual relationships based on her past relationship with a graduate student. JMU and its officials investigated the accusation and held a hearing, leading to a decision that Reid violated the policy. Reid appealed the decision to JMU’s provost, who denied her appeal. Subsequently, Reid sued JMU and several officials, raising three due process claims under both 42 U.S.C. § 1983 and the Virginia Constitution, as well as a sex discrimination claim under Title IX.The United States District Court for the Western District of Virginia held that Reid’s claims accrued when the dean made his decision, and thus they were barred by the applicable two-year statute of limitations. Reid appealed this decision, arguing that her claims accrued not when the dean issued his decision, but when the provost denied her appeal.The United States Court of Appeals for the Fourth Circuit agreed with Reid. The court found that Reid did not have a complete and present cause of action until JMU reached a final decision in her Title IX proceedings. The court determined that JMU did not make clear that the dean’s decision was its official position. Rather, JMU’s official position was made clear to Reid when the provost denied her appeal with a “final,” non-appealable decision. Therefore, Reid’s due process and Title IX claims were not barred by the applicable two-year statute of limitations, and the court reversed the district court's dismissal of Reid’s claims and remanded for further proceedings. View "Reid v. James Madison University" on Justia Law

This case revolves around Kenneth Bailey's lawsuit against Deputy Shawn Swindell, claiming that Swindell violated his civil rights when he tackled Bailey through the door of Bailey's parents' home and arrested him without a warrant or exigent circumstances. Bailey's suit was filed under Section 1983. The United States District Court for the Northern District of Florida initially granted summary judgment in favor of Swindell based on qualified immunity. However, the United States Court of Appeals for the Eleventh Circuit reversed this decision, concluding that Swindell violated clearly established law when he entered Bailey's parents' home to arrest him without a warrant or exigent circumstances, and was therefore not entitled to qualified immunity.On remand, the case went to trial and the jury returned a verdict for Bailey, awarding him $625,000 for his injuries. However, the district court later granted Swindell's motion for judgment as a matter of law, setting aside the jury's verdict. Bailey appealed this decision.The Eleventh Circuit reversed the district court's grant of judgment as a matter of law. The appellate court found that the jury's factual findings, including that the arrest was initiated outside the home but no exigent circumstances existed allowing for a warrantless entry into the home, should have been used by the district court in making its legal conclusions about qualified immunity. The court emphasized that it was clearly established that an officer violates the Constitution by initiating an arrest outside of a home and then entering the home without a warrant to complete the arrest in the absence of exigent circumstances. Therefore, Swindell was not entitled to qualified immunity, and the jury's verdict in favor of Bailey should be reinstated. View "Bailey v. Swindell" on Justia Law

The case revolves around the death of Rhonda Newsome, a pretrial detainee, who died in Anderson County Jail due to complications from Addison’s disease. Her family filed a lawsuit under 42 U.S.C. § 1983 against Anderson County, Sheriff Greg Taylor, Dr. Adam Corley, Nurse Timothy Green, and several jailers, alleging that the defendants violated Newsome’s Fourteenth Amendment rights as a pretrial detainee by failing to treat her chronic illness, resulting in her preventable death. The district court granted summary judgment for all Defendants and dismissed Plaintiffs’ lawsuit with prejudice. Upon review, the United States Court of Appeals for the Fifth Circuit found that Plaintiffs have established genuine disputes of material fact regarding whether several defendants violated Newsome’s clearly established constitutional rights. Thus, the court reversed the district court’s grant of summary judgment for several defendants, but affirmed the district court’s grant of summary judgment for others. The district court’s denial of Plaintiffs’ motion for leave to file a third amended complaint was also vacated, and instructions were given to grant Plaintiffs leave to amend their pleadings to include additional supervisory and municipal liability claims. Finally, the district court’s denial of Plaintiffs’ motion for sanctions was affirmed. View "Ford v. Anderson County" on Justia Law

The Supreme Court of the State of Kansas has upheld the decision of the lower courts in a case involving a plaintiff, Jason Unruh, who alleged that the City of Wichita police officers used excessive force during his arrest. The plaintiff was apprehended after leading police on a car chase and was subsequently subdued while attempting to collect drugs that had spilled onto the ground. Nearly 23 months later, the plaintiff sued for personal injuries, alleging that the officers negligently used excessive force during his arrest. The case focused on whether the plaintiff's claim was for civil battery, which has a one-year statute of limitations, or negligence, which has a longer time limit. The court found that the plaintiff's claim was essentially a battery claim since the officers intentionally used force to make a lawful arrest. The court further clarified that negligence and battery are distinct legal concepts with different elements. The court noted that a negligence claim requires proof of a legally recognized duty that the defendant breached, causing the plaintiff's injuries. The plaintiff failed to establish that the officers owed him a special duty independent of the force used. As such, the plaintiff's claim was time-barred under the one-year statute of limitations for battery. The court affirmed the judgments of the lower courts. View "Unruh v. City of Wichita" on Justia Law

In this case from the United States Court of Appeals for the Fourth Circuit, the plaintiff, Frank Morgan, appealed from a decision of the United States District Court for the Southern District of West Virginia. Morgan alleged that a police officer, J.D. Tincher, used excessive force during his arrest and subsequent detention, causing him serious injuries. The case proceeded to a jury trial, and the jury found in favor of Officer Tincher.However, after presenting his case, Morgan discovered another lawsuit against Officer Tincher, involving similar allegations of excessive force, which Tincher had failed to disclose during discovery. Morgan requested sanctions and moved for a new trial under Federal Rule of Civil Procedure 60(b)(3), alleging misconduct by the opposing party. The district court denied the motion, leading to this appeal.In its decision, the Fourth Circuit held that Officer Tincher's failure to disclose the other excessive-force lawsuit constituted misconduct under Rule 60(b)(3). It also found that Morgan had presented a meritorious claim and that the misconduct prevented him from fully presenting his case. The court further concluded that the district court had erred in its analysis of whether the undisclosed evidence would have changed the trial outcome. Lastly, the court ruled that the interest of justice in this case outweighed the interest in the finality of judgments.Therefore, the Fourth Circuit reversed the district court's decision, vacated the final judgment in favor of Officer Tincher, and remanded the case to the district court with instructions to allow for a reasonable period of additional discovery before conducting a new trial. View "Morgan v. Tincher" on Justia Law