Justia Civil Rights Opinion Summaries

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

Jonathan Eugene Brunson, an inmate in North Carolina, filed a § 1983 action against the North Carolina Attorney General and other state officials, seeking various forms of relief. Brunson acknowledged that he had previously filed four § 1983 suits that were dismissed under Heck v. Humphrey, which bars federal courts from entertaining § 1983 suits for damages that would undermine the legality of a conviction unless the conviction has been invalidated. Despite these dismissals, Brunson moved to proceed in forma pauperis.The United States District Court for the Eastern District of North Carolina initially granted Brunson’s request to proceed in forma pauperis but later vacated that order, citing the Prison Litigation Reform Act’s (PLRA) three-strikes rule. The district court determined that Brunson’s prior dismissals under Heck counted as strikes for failure to state a claim. Consequently, Brunson prepaid the filing fee, but his § 1983 complaint was eventually dismissed for reasons not relevant to the current appeal. Brunson then appealed and applied to proceed on appeal without prepaying fees, arguing that Heck dismissals should not count as PLRA strikes.The United States Court of Appeals for the Fourth Circuit reviewed the case to determine whether a dismissal under Heck constitutes a strike under the PLRA. The court held that a Heck dismissal is necessarily for failure to state a claim because it denies the existence of a cause of action unless the plaintiff can prove that the conviction or sentence has been invalidated. Therefore, such dismissals count as strikes under the PLRA. As Brunson had at least three prior Heck dismissals, the court denied his motion to proceed in forma pauperis on appeal. View "Brunson v. Stein" on Justia Law

In 2020, the Springfield R-12 School District mandated "equity training" for its employees. Two employees, Brooke Henderson and Jennifer Lumley, attended the training and later sued the school district and several officials under 42 U.S.C. § 1983. They claimed that the training compelled them to speak on matters of public concern and engaged in viewpoint discrimination, violating their First and Fourteenth Amendment rights. The training included interactive sessions and online modules that required participants to discuss prompts and select "correct" answers to questions about equity and diversity.The United States District Court for the Western District of Missouri granted summary judgment in favor of the school district, ruling that the plaintiffs lacked standing because they did not suffer an injury in fact. The court also deemed the lawsuit frivolous and awarded attorney’s fees to the school district. The plaintiffs appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal, agreeing that the plaintiffs did not establish an injury in fact. The court found that the plaintiffs' fear of punishment for their speech during the training was speculative and not objectively reasonable. The court also concluded that the plaintiffs' completion of online modules did not constitute a First Amendment injury. However, the Eighth Circuit reversed the award of attorney’s fees, determining that the plaintiffs' claims were not frivolous given the nuanced and unsettled nature of the constitutional issues involved. View "Henderson v. Springfield R-12 School District" on Justia Law

In the early morning, Javier Ambler II was driving without dimming his high beams, prompting a Texas sheriff’s deputy to signal him to stop. Ambler refused, leading to a high-speed chase involving multiple officers. The pursuit ended when Ambler crashed into trees in Austin, Texas. As officers attempted to arrest him, Ambler, who had congestive heart failure, repeatedly stated he could not breathe. Despite his pleas, Austin City Policeman Michael Nissen and other officers continued to restrain him. Ambler was eventually handcuffed but appeared limp and was later pronounced dead at a hospital. His family sued, alleging excessive force and bystander liability.The United States District Court for the Western District of Texas denied Nissen’s motion for summary judgment on qualified immunity grounds, citing genuine disputes of material fact. The court found that the facts, viewed in the light most favorable to the plaintiffs, could support a finding that Nissen used excessive force and failed to intervene to prevent other officers from using excessive force.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that it lacked jurisdiction to review the district court’s denial of summary judgment because the appeal did not turn on a pure issue of law but rather on disputed facts. The court emphasized that factual disputes, such as whether Ambler was resisting arrest or posed a threat, were material to the plaintiffs’ claims and should be resolved by a jury. Consequently, the Fifth Circuit dismissed the appeal and remanded the case for further proceedings. View "Ambler v. Nissen" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law

A federal inmate, Mitchell Garraway, filed a Bivens action against three prison officials, alleging they were deliberately indifferent to his safety, violating his Eighth Amendment rights. Garraway claimed that despite informing the officials of his cellmate's violent behavior and requesting a cell change, they refused, resulting in an assault by his cellmate. The officials moved for judgment on the pleadings, arguing no Bivens remedy exists for failure to protect an inmate from prisoner violence. The district court denied this motion, and after the Supreme Court's decision in Egbert v. Boule, the officials sought reconsideration, which was also denied. They then filed an interlocutory appeal.The United States District Court for the Eastern District of California initially denied the officials' motion for judgment on the pleadings, agreeing with Garraway that his case did not differ meaningfully from Farmer v. Brennan. After the Supreme Court's decision in Egbert, the officials filed a motion to reconsider, which was denied by the district court, reaffirming that Farmer remained intact post-Egbert. The officials then filed an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and dismissed the interlocutory appeal for lack of jurisdiction. The court held that district court orders extending Bivens, absent a denial of qualified immunity, are not immediately appealable under the collateral order doctrine. The court emphasized that delaying review of such orders does not threaten significant public interests and that any improper judicial intrusion into the legislative function can be effectively rectified upon review of a final judgment. The court concluded that the next logical step in the litigation would be for the federal-officer defendant to claim qualified immunity, the denial of which would be immediately appealable. View "GARRAWAY V. CIUFO" on Justia Law

In the early morning of December 21, 2019, Corey Spiller went to assist his girlfriend, Dashanelle Moore, after her minor car accident on a Houston expressway. While conversing with officers at the scene, Sergeant Jared Lindsay arrived and directed Moore to a nearby truck stop for further procedures, instructing Spiller to follow in his car. When Spiller questioned the officers about Moore, Lindsay became enraged, seized Spiller by the neck, and slammed him onto a parked car, leading to a scuffle where Spiller was tased and arrested. The charges against Spiller were later dropped.Spiller filed a lawsuit under 42 U.S.C. § 1983 against Lindsay, Harris County, Harris County Constable Precinct 7, and Chief Constable May Walker, alleging excessive force, false arrest, bystander liability, retaliation, and ADA violations. The United States District Court for the Southern District of Texas dismissed claims against Harris County, Precinct 7, and Walker for failure to state a claim and granted summary judgment for Lindsay on the basis of qualified immunity. Spiller appealed, challenging the summary judgment on his Fourth Amendment excessive force, false arrest, First Amendment retaliation, and bystander liability claims against Lindsay, and the dismissal of his Monell claim against Harris County.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court’s summary judgment for Lindsay on the excessive force claim, finding genuine disputes of material fact regarding whether Lindsay's use of force was excessive and whether Spiller's actions justified such force. The court affirmed the district court’s rulings on the false arrest and First Amendment retaliation claims, concluding that Lindsay had probable cause for Spiller’s arrest. The court also upheld the dismissal of Spiller’s Monell claim against Harris County for failing to allege specific facts linking his injury to a county policy or custom. The case was remanded for further proceedings consistent with the opinion. View "Spiller v. Harris County" on Justia Law