Justia Civil Rights Opinion Summaries

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

In the case of Veronica-May Clark, an incarcerated transgender woman, against corrections officers who allegedly sexually assaulted her, the United States Court of Appeals for the Second Circuit affirmed the decision of the United States District Court for the District of Connecticut. The District Court had dismissed Clark's case as untimely, denying her claim for equitable tolling of the statute of limitations due to the effects of the abuse. The Court of Appeals found that the District Court did not err in holding an evidentiary hearing to resolve Clark’s equitable tolling claim and did not make any factual findings that infringed the Seventh Amendment. The court also found no abuse of discretion in the District Court's determination that Clark had failed to demonstrate circumstances that would warrant equitable tolling. In effect, the court ruled that Clark had not sufficiently proven that her trauma and fear of retaliation prevented her from filing the lawsuit within the required time frame. View "Clark v. Hanley" on Justia Law

The United States Court of Appeals for the Second Circuit dismissed an interlocutory appeal from the City of New Haven and three of its police officers (collectively, "the City"), who sought to challenge the district court's denial of their motion for summary judgment on the claims of Solomon Maye. Maye alleged that the City violated his constitutional rights by evicting him from his place of business. The district court had denied the City's motion for summary judgment, which was based on the defense of qualified immunity, because the motion was filed more than six months after the court's deadline for dispositive motions. The Court of Appeals held that a district court's denial of a motion for summary judgment as untimely is not a "denial of a claim of qualified immunity" that turns on an issue of law and is thus not subject to immediate appeal under the collateral order doctrine. Consequently, the Court of Appeals found no jurisdiction to hear the City's interlocutory appeal and dismissed it. View "Maye v. City of New Haven" on Justia Law

In a dispute between Christopher Leahy and Jeffrey Peterson, the Court of Appeal, Fourth Appellate District Division One State of California, reversed and remanded a lower court's decision to renew a civil harassment restraining order for a second five-year period without requiring a demonstration of new harassment. Leahy, a police detective, had obtained the original restraining order against Peterson in 2014, followed by a five-year renewal in 2017, based on Peterson's stalking and harassment. In 2022, Leahy requested another five-year renewal, which was granted by the Superior Court of San Diego County.The court of appeal held that the lower court erred in its interpretation of section 527.6, subdivision (j)(1) of the Code of Civil Procedure, which allows for renewal of a civil harassment restraining order “without a showing of any further harassment since the issuance of the original order.” This provision, according to the court of appeal, does not authorize a second five-year renewal without a showing of new harassment. The court also clarified that constitutionally protected activity, such as filing a lawsuit, cannot constitute harassment under section 527.6. The case was remanded to the lower court to reconsider the renewal petition under the proper standard. View "Leahy v. Peterson" on Justia Law

The case before the United States Court of Appeals for the Eighth Circuit involved Allen Thomas Bloodworth, II, a business owner who operated two towing businesses in Kansas City. Bloodworth alleged that the Kansas City Board of Police Commissioners and fourteen officers of the Kansas City Police Department conspired to stop him from running his businesses and shut down his ability to conduct business in Kansas City. He brought 17 state and federal claims, including defamation, tortious interference with contract and business expectancy, intentional infliction of emotional distress, and negligent hiring, training, supervision, or retention. He also alleged Fourth Amendment violations for an unlawful warrant search and seizure of his residence and business, the shooting of his dog during the search, and the seizure of business records.The district court granted summary judgment in favor of the defendants. On appeal, the Eighth Circuit affirmed the ruling. The appellate court concluded that Bloodworth failed to link the specific conduct of individual defendants to the alleged constitutional violations, and his claims were based on general assertions mostly. It also ruled that Bloodworth failed to establish that the defendants' conduct was extreme and outrageous to support his claim for intentional infliction of emotional distress. The court further found that Bloodworth failed to establish a constitutional violation resulting from the official policy, unlawful practice, custom, or failure to properly train, retain, supervise, or discipline the police officers. Therefore, there was no basis for municipal liability against the Kansas City Board of Police Commissioners. View "Bloodworth v. Kansas City Board of Police Commissioners" on Justia Law

This case concerns John HR Doe and other Doe plaintiffs, who alleged that William Babcock, a counselor at an elementary school in the Marysville Joint Unified School District, committed sexual misconduct causing them injury and damages. The Doe plaintiffs filed three separate lawsuits against the School District. The first two, filed in state court, were voluntarily dismissed. The third, filed in federal court, also alleged violations of federal law. The School District moved to dismiss the federal court action, claiming immunity under the Eleventh Amendment for most of the claims. The Doe Plaintiffs then voluntarily dismissed their federal court action and filed a third state court action.The School District demurred to the third state court complaint, arguing res judicata based on the plaintiffs' voluntary dismissal of the second action in federal court. The trial court sustained the demurrer and dismissed the complaint, ruling that the dismissal of the federal court action constituted res judicata. On appeal, the Doe plaintiffs contended that the federal court lacked subject matter jurisdiction to adjudicate the claims on the merits because the School District argued Eleventh Amendment immunity. They also argued that California state law controls, under which a second voluntary dismissal does not constitute res judicata.The Court of Appeal of the State of California, Third Appellate District, affirmed the trial court's decision. The appellate court found that the federal court did have subject matter jurisdiction over the plaintiffs' claims because it had jurisdiction over the federal law claims, with supplemental jurisdiction over the state-law claims. Moreover, the court held that res judicata applied because federal law determines the claim-preclusive effect of a federal court judgment in a federal question case, and under federal law, a second voluntary dismissal operates as an adjudication on the merits. The court rejected the plaintiffs' argument that California law should control, stating that states must accord federal court judgments the effect that federal law prescribes. As such, the Doe plaintiffs' third state court action was barred by res judicata due to their second voluntary dismissal in federal court. View "Doe v. Marysville Joint Unified Sch. Dist." on Justia Law

The case involves Timothy Bell, who, after serving a sentence for sexual assault, remained incarcerated in an Illinois prison for over 16 years under the state’s Sexually Violent Persons Commitment Act. Bell sued two state officials under 42 U.S.C. § 1983, claiming that his civil commitment had exceeded the duration allowed by the Act. The district court dismissed Bell's case, citing the Supreme Court’s 1994 decision in Heck v. Humphrey as barring his claims. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the lower court's judgment.The main holding in the case is that Heck v. Humphrey's favorable-termination requirement, which prevents prisoners from using § 1983 to challenge the fact or duration of their confinement unless their conviction or disciplinary sanction has been invalidated, applies to civil detainees such as those confined under the Illinois Sexually Violent Persons Commitment Act. The court reasoned that like a prisoner wishing to contest a criminal conviction or sentence, a civil detainee cannot sue a state official under § 1983 for violating his constitutional rights when a judgment in the plaintiff’s favor would necessarily imply the invalidity of his confinement, unless the grounds for the confinement have already been set aside in other proceedings. This conclusion remains the same regardless of whether the individual is civilly committed or criminally imprisoned.Furthermore, the court pointed out that Bell's release from confinement to home confinement did not change the court's conclusion. The Heck bar applies until the judgment that caused the detention is invalidated, even after a detainee's release. Therefore, Bell must wait until he receives a favorable termination of his civil commitment before seeking relief under § 1983 for his allegedly excessively long confinement. View "Bell v. Raoul" on Justia Law