Justia Civil Rights Opinion Summaries

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

In 1991, an individual was convicted of multiple felonies related to a home invasion and rape, receiving a thirty-five-year prison sentence. In 2011, the conviction was vacated based on newly discovered DNA evidence that excluded the individual as the contributor of DNA found at the crime scene. The prosecution subsequently moved to dismiss the case with prejudice, which the court granted. In 2016, the individual filed a civil petition for compensation under Hawai‘i’s wrongful conviction compensation statute, HRS chapter 661B.The Circuit Court of the Second Circuit held that the individual failed to allege an actionable claim because the order vacating the conviction did not explicitly state that he was “actually innocent.” The court granted summary judgment in favor of the State, concluding that the individual did not meet the statutory requirements for compensation.The Supreme Court of the State of Hawai‘i reviewed the case. It held that HRS § 661B-1 does not require the exact words “actually innocent” to be present in the vacatur order. Instead, the order must state facts supporting the petitioner’s actual innocence. The court found that the vacatur order, which was based on exculpatory DNA evidence, met this standard. Therefore, the individual presented an actionable claim for relief under HRS chapter 661B.The Supreme Court vacated the Circuit Court’s grant of summary judgment to the State and remanded the case for a trial to determine whether the individual is actually innocent and entitled to compensation under the statute. The court emphasized that the trial should follow the procedures outlined in HRS § 661B-2 and HRS § 661B-3. View "Jardine v. State" on Justia Law

William Webb, an inmate at James T. Vaughn Correctional Center (JTVCC) in Delaware, sued prison officials for failing to schedule court-ordered visits with his daughter. A Delaware family court had granted Webb visitation rights in October 2020, but since then, only one visit occurred in 2021, lasting fifteen minutes and concluding without incident. Webb filed a grievance through the prison’s internal process, which was returned unprocessed. He then wrote to three prison officials but received inadequate responses. Webb, representing himself, filed a lawsuit alleging that prison officials violated his constitutional right to reunification with his daughter.The United States District Court for the District of Delaware dismissed Webb’s complaint under the screening provisions of 28 U.S.C. §§ 1915A(b) and 1915(e)(2)(B). The court held that Webb failed to exhaust JTVCC’s internal grievance process and did not state a valid constitutional claim. The court also determined that allowing Webb to amend his complaint would be futile.The United States Court of Appeals for the Third Circuit reviewed the case. The court first addressed the timeliness of Webb’s appeal, applying the prison mailbox rule to JTVCC’s electronic filing system. The court held that Webb’s notice of appeal was timely filed when he placed it in the designated mailbox on November 22, 2022. On the merits, the court found that Webb’s complaint did not definitively show a failure to exhaust administrative remedies and plausibly alleged a constitutional claim under the First and Fourteenth Amendments. The court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Webb v. Department of Justice" on Justia Law

In this case, the plaintiff alleged that a Montana Probation Officer used excessive force during an encounter in a parking lot. The incident was captured by surveillance footage, which was later auto-deleted. Despite efforts to preserve the footage, the State failed to do so, leading to the plaintiff's motion for sanctions against the State for the loss of evidence.The United States District Court for the District of Montana found that the State acted recklessly in failing to preserve the footage but did not act with gross negligence or willfulness. Invoking its inherent authority, the district court sanctioned the State by instructing the jury that it was established as a matter of law that the officer used excessive force. The jury awarded the plaintiff $75,000 in damages for the excessive-force claim.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court committed legal error by relying on its inherent authority to impose sanctions. The appellate court determined that Federal Rule of Civil Procedure 37(e) governs the loss of electronically stored information and the sanctions imposed. Rule 37(e)(2) allows for severe sanctions only if the party acted with the intent to deprive another party of the information's use in litigation. The district court's findings confirmed that no such intent was present, making the sanctions unlawful.As a result, the Ninth Circuit reversed the district court's sanctions orders, reversed the verdict and judgment against the probation officer, vacated the award of attorneys' fees to the plaintiff, and remanded the case for a new trial on the excessive-force claim. View "GREGORY V. STATE OF MONTANA" on Justia Law

Officer Blayne Newton of the Kansas City, Missouri Police Department shot and killed Donnie Sanders during a traffic stop. Sanders’s children, Latetia Nunley and Zahleyiah Fielder, filed a lawsuit against Officer Newton under 42 U.S.C. § 1983, alleging a violation of Sanders’s Fourth Amendment right to be free from excessive force. Officer Newton sought summary judgment based on qualified immunity, which the district court denied, citing genuine issues of material fact. Officer Newton appealed the denial of qualified immunity.The United States District Court for the Western District of Missouri denied Officer Newton’s motion for summary judgment, finding that there were disputed facts essential to the analysis of the totality of the circumstances, including the nature of the threats made by Sanders and his level of compliance with commands. The court highlighted discrepancies between Officer Newton’s testimony and the forensic evidence from the autopsy, which suggested that Sanders was shot in a manner inconsistent with Newton’s account of Sanders pointing something at him.The United States Court of Appeals for the Eighth Circuit reviewed the case. Officer Newton argued that the district court erred in denying him qualified immunity and that the excessive-force claim was barred under the Eleventh Amendment. The appellate court dismissed the appeal for lack of jurisdiction, stating that it could not resolve genuine disputes of material fact in favor of the party seeking summary judgment. The court emphasized that the factual record was unsettled and disputed, preventing it from determining whether Newton’s actions were objectively reasonable or whether they violated clearly established law. The court concluded that the district court’s finding of a material factual dispute precluded it from granting qualified immunity at this stage. View "Nunley v. Newton" on Justia Law

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law

Marc and Augustus Degenhardt alleged that Corpus Christi Police Lieutenant Phillip Bintliff unlawfully initiated a traffic stop and that Bintliff and Officer Armando Cisneros unlawfully searched and towed their vehicle, retaliating against them for engaging in protected speech. The incident occurred when Marc, driving a Dodge Challenger with Augustus as a passenger, was stopped by Bintliff, who accused Marc of reckless driving and racing another vehicle. During the stop, Cisneros arrived and observed an open box of White Claw Hard Seltzers in the car. The officers ordered the brothers out of the car, conducted a search, and impounded the vehicle, charging them with minor alcohol possession and issuing a reckless driving warning. The charges were later dropped.The United States District Court for the Southern District of Texas dismissed the suit, finding that the officers had probable cause to search the vehicle and that the officers were entitled to qualified immunity for the remaining claims. The Degenhardts appealed the dismissal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the Degenhardts had sufficiently alleged a Fourth Amendment violation regarding the initial traffic stop, as the complaint suggested that Bintliff lacked reasonable suspicion. However, the court agreed with the district court that the officers had probable cause to search the vehicle due to the visible alcohol. The court also found that the officers were entitled to qualified immunity for the claims related to the vehicle's impoundment and the alleged retaliation for protected speech.The Fifth Circuit affirmed the district court's dismissal in part, reversed in part, and remanded the case for further proceedings regarding the Fourth Amendment claim related to the traffic stop. View "Degenhardt v. Bintliff" on Justia Law

Seven plaintiffs, all members of the Air Force, challenged the Air Force’s COVID-19 vaccine mandate, arguing it violated their religious beliefs. They sought religious exemptions, which were denied, leading to administrative discharge proceedings. One plaintiff, Byron O. Starks, Jr., was separated from service, allegedly for a preexisting medical condition, though he claimed it was due to his refusal to get vaccinated.The United States District Court for the Western District of Louisiana dismissed the case as moot after the Air Force rescinded the vaccine mandate. The court also dismissed Starks’s claims for lack of standing, citing his separation from service and failure to exhaust administrative remedies.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the rescission of the mandate did not address all alleged harms, particularly the claim that the Air Force’s religious exemption process was a sham. The court held that Starks had standing because his separation caused ongoing harm, such as ineligibility for certain veteran benefits. The court also clarified that RFRA claims are not subject to the Mindes exhaustion requirement, allowing Starks to proceed without exhausting intraservice remedies.The Fifth Circuit determined that the claims of the six still-serving plaintiffs were not moot, as they alleged ongoing harm from the Air Force’s religious exemption process. The court reversed the district court’s dismissal and remanded the case for further proceedings, allowing the plaintiffs to continue their challenge against the Air Force’s broader vaccination policies and religious accommodations process. View "Crocker v. Austin" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law