Justia Civil Rights Opinion Summaries

Benjamin Benfer and his wife were pulled over by Officer Barry Calvert for allegedly running a red light and because their vehicle matched the description of a stolen car. A confrontation ensued, during which Calvert used his K-9 to subdue Benfer. Both Benfer and his wife were arrested and charged with resisting arrest and interference with public duties, but the charges were later dismissed.Benfer filed a lawsuit against Calvert and the City of Baytown under 42 U.S.C. § 1983 and state law, claiming violations of his constitutional rights and state tort claims. The United States District Court for the Southern District of Texas dismissed the case, ruling that Calvert did not violate Benfer’s constitutional rights, that Benfer’s state tort claims were not valid under Texas law, and that Benfer did not provide sufficient facts to support his claims against the City under Monell v. Department of Social Services.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that Calvert had reasonable suspicion to stop Benfer, probable cause to arrest him for resisting arrest, and did not use excessive force in deploying his K-9. The court also found that Benfer’s state law assault claim against Calvert was barred by the Texas Tort Claims Act, which requires such claims to be brought against the municipality, not the individual officer. Additionally, the court ruled that Benfer failed to provide sufficient evidence to support his claims against the City of Baytown for inadequate policies, failure to train, and ratification of Calvert’s conduct. View "Benfer v. City of Baytown" on Justia Law

In 2016, the United States Department of Justice (DOJ) sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act (CRIPA), alleging unconstitutional conditions in the County’s detention facilities, particularly the Raymond Detention Center (RDC). The DOJ and the County entered into a consent decree to improve conditions, but disputes over compliance led to the DOJ alleging the County's non-compliance and seeking contempt sanctions. The district court found the County in contempt twice and, after a hearing, issued a new, shorter injunction focused on RDC and appointed a receiver to oversee compliance.The United States District Court for the Southern District of Mississippi found ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, misuse of force, poor incident reporting, and over-detention. The court declined to terminate the consent decree, instead issuing a new injunction and appointing a receiver to manage RDC. The County appealed the new injunction and the receivership.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision to retain most of the injunction’s provisions, finding that the conditions at RDC constituted ongoing constitutional violations. However, the court found that the district court’s need-narrowness-intrusiveness analysis for the receivership was insufficient and that the receiver’s authority over the budget and financial matters was overly broad. The Fifth Circuit reversed the provisions related to the Prison Rape Elimination Act (PREA) and remanded the case for further proceedings to adjust the scope of the receivership and remove the PREA-related provisions. The court affirmed the district court’s decision in all other respects. View "United States v. Hinds County Board of Supervisors" on Justia Law

In 2002, Natale Cosenza was convicted by a Massachusetts state court jury of assault and battery with a dangerous weapon and armed burglary. The prosecution's case heavily relied on the victim, Melissa Horgan, identifying Cosenza from a photo array administered by Worcester police. In 2016, state courts granted Cosenza a new trial, and in 2017, they suppressed the photo array evidence, leading the Commonwealth to drop the charges.Cosenza then filed a federal civil rights lawsuit in 2018 against the City of Worcester, alleging that the City had a policy of not properly training its officers on photo arrays and other investigative techniques, which he claimed violated his constitutional rights. The U.S. District Court for the District of Massachusetts granted summary judgment in favor of the City, finding no evidence of deliberate indifference to Cosenza's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case. The court found that there was no evidence Worcester had a policy of not training its officers on photo arrays. The court noted that officers received training at a police academy and on-the-job training, and that the law at the time did not clearly establish the procedures Cosenza argued were required. The court also found no evidence that the City had a policy of fabricating or suppressing evidence. Consequently, the First Circuit affirmed the district court's summary judgment in favor of the City of Worcester. View "Cosenza v. City of Worcester, MA" on Justia Law

A police officer, David Stanley, was suspended and transferred by the Lafayette Police Department (LPD) following an investigation into his Facebook posts. Stanley took sick leave for about a year and appealed his suspension to the Municipal Fire and Police Civil Service Board. He also filed two petitions in state court seeking to enjoin the suspension and transfer. The state district court granted a temporary restraining order (TRO), but the state appellate court dismissed LPD’s appeal of the TRO. Stanley re-filed his petition, but the state district court found he needed to finalize his appeal with the Civil Service Board first. The Civil Service Board later reduced his suspension but upheld his transfer.Stanley then filed a lawsuit in federal district court under 42 U.S.C. § 1983, alleging First Amendment violations and retaliation. The district court dismissed his claims as time-barred, determining that the one-year prescriptive period began when Stanley was notified of his suspension on June 11, 2021. The court also concluded that Stanley’s state court petitions did not interrupt the prescription period because they did not assert federal claims or seek monetary damages.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Stanley’s § 1983 claims accrued when he received notice of the adverse actions, not when the administrative appeal concluded. The court also found that Stanley’s state court petitions did not interrupt the prescription period because they did not provide adequate notice of his federal claims or demand monetary damages. Consequently, the Fifth Circuit affirmed the district court’s dismissal of Stanley’s claims as prescribed. View "Stanley v. Morgan" on Justia Law

A man was unable to purchase a firearm because a background check revealed he was subject to a long-term domestic violence protective order (DVPO). He sued the State, claiming he was no longer subject to a protective order as defined by federal statute and sought a permanent injunction and declaratory judgment to have the Department of Public Safety (DPS) notify a national database that he was no longer subject to a protective order under 18 U.S.C. § 922(g)(8). He filed a motion for summary judgment, which the State opposed, filing a cross-motion for summary judgment. The superior court granted the State’s cross-motion, and the man appealed.The superior court found that the DVPO had not expired and remained a qualifying order under Section 922(g)(8). It also concluded that the man’s constitutional claims were not ripe because he had not initiated modification or dissolution of the order. The court entered a final judgment in favor of the State.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the DVPO remained in effect and was a qualifying order under 18 U.S.C. § 922(g)(8). The court found that the legislative history supported the interpretation that DVPOs issued under AS 18.66.100(c)(1) are effective until further order of the court. The court also concluded that the man’s remaining claims were not ripe for adjudication because he had not attempted to dissolve or modify the DVPO. View "Eng v. State" on Justia Law

The appellant, a federal prisoner serving a twenty-two-year sentence, has a history of filing numerous lawsuits regarding his prison conditions. In this case, he sought to proceed in forma pauperis (IFP) under the Prison Litigation Reform Act (PLRA) despite having three prior cases dismissed as frivolous, malicious, or for failure to state a claim. He claimed imminent danger of serious physical injury due to worsening glaucoma and alleged that prison officials denied him necessary medical treatment and incited other inmates to assault him.The United States District Court for the District of Columbia denied his motion to proceed IFP, finding that he did not demonstrate imminent danger of serious physical injury. The court dismissed his case without prejudice. The appellant then appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court disagreed with the District Court's assessment regarding the appellant's glaucoma, finding that the appellant's allegations of being denied necessary medical treatment for his worsening glaucoma did place him under imminent danger of serious physical injury. Consequently, the court granted the appellant's motion to proceed IFP and reversed the District Court's denial of his motion, allowing his complaint to be docketed.However, the court also found that some of the appellant's claims were frivolous, particularly those against high-ranking officials such as the United States Attorney General and members of the United States Senate Judiciary Committee. These claims were dismissed under the PLRA's mandate to dismiss frivolous claims. The court's decision allowed the appellant to proceed with his claims related to his medical treatment and alleged assaults but dismissed the frivolous claims against the aforementioned officials. View "Owlfeather-Gorbey v. Avery" on Justia Law

L.C. Slaughter and Isiac Jackson were removed from their positions as commissioners of the Canton Municipal Utilities Commission by the City of Canton Board of Aldermen. They appealed their removal to the Madison County Circuit Court, arguing that their removal was illegal and violated their due process rights. The circuit court agreed, finding the removal void as a matter of law, and reinstated them to their positions. The Board appealed this decision.The Mississippi Supreme Court affirmed the circuit court's decision, holding that the Board's removal of Slaughter and Jackson without notice and an opportunity to be heard was improper. The Court issued its mandate on April 6, 2023, affirming their reinstatement. Subsequently, on April 27, 2023, Slaughter and Jackson filed a petition for back pay in the same circuit court case, seeking compensation for the period they were removed.The circuit court denied the petition for back pay, citing lack of jurisdiction, as the issue of back pay was not raised before the mandate was issued. Slaughter and Jackson appealed this denial. The Mississippi Supreme Court reviewed the case de novo and held that the circuit court lost jurisdiction once the appeal was filed and did not regain it after the Supreme Court's mandate, which did not remand any issues for further consideration. Consequently, the circuit court's denial of the petition for back pay was affirmed. View "Slaughter v. City of Canton, Mississippi" on Justia Law

Thomas Eugene Creech, who has been on death row for over four decades for the 1981 murder of fellow inmate David Dale Jensen, filed a petition for a writ of mandamus. Creech alleged that the Ada County Prosecutor’s Office introduced fabricated or misleading evidence at his clemency hearing. He sought to recuse U.S. District Judge Amanda K. Brailsford from presiding over his underlying § 1983 suit, arguing that Judge Brailsford and Ada County Prosecutor Jan Bennetts are close friends, which could affect the judge's impartiality.The U.S. District Court for the District of Idaho denied Creech’s motion to preliminarily enjoin his execution, and the Ninth Circuit affirmed. Creech continued to litigate his § 1983 claim, alleging prosecutorial misconduct. He then moved to disqualify Judge Brailsford, citing her friendship with Bennetts. Judge Brailsford denied the recusal motion, stating that although she and Bennetts were close during their clerkship, they had since lost touch and a reasonable person would not question her impartiality.The United States Court of Appeals for the Ninth Circuit reviewed Creech’s petition for a writ of mandamus. The court found that the longstanding friendship between Judge Brailsford and Bennetts, combined with the allegations of prosecutorial misconduct involving Bennetts, could lead a reasonable person to question the judge’s impartiality. The court emphasized that public confidence in the judiciary requires that any appearance of bias be addressed promptly. Consequently, the Ninth Circuit granted the petition for a writ of mandamus and remanded the case for reassignment to a different judge. View "Creech v. United States District Court for the District of Idaho, Boise" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

Lamonte Jackson-Gibson celebrated his birthday with friends, including his girlfriend, Toriel Dixon, in Detroit’s Greektown neighborhood. While listening to street musicians, Sergeant Reginald Beasley and other officers asked the group to move along. Jackson-Gibson questioned the order, leading to a verbal exchange and some physical pushing. Sgt. Beasley tased Jackson-Gibson in the back while he was embracing Dixon, and both were arrested. They were charged with obstructing or resisting a police officer, and Jackson-Gibson was also charged with disturbing the peace. A jury acquitted them of all charges.The United States District Court for the Eastern District of Michigan reviewed the case. Sgt. Beasley moved for summary judgment on the excessive-force claims, arguing for qualified immunity, but did not move for summary judgment on the wrongful-arrest claims. The district court granted summary judgment on Dixon’s excessive-force claim but denied it for Jackson-Gibson’s excessive-force claim. Sgt. Beasley’s motion to reconsider was also denied, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Sgt. Beasley’s challenge to the wrongful-arrest claims for lack of jurisdiction, as he did not seek qualified immunity for those claims in the lower court. The court affirmed the district court’s denial of qualified immunity on Jackson-Gibson’s excessive-force claim. The court held that a reasonable jury could find that Sgt. Beasley’s use of a taser was objectively unreasonable, as Jackson-Gibson’s alleged crimes were not severe, he did not pose an immediate threat, and he was not actively resisting arrest. The court also held that the right to be free from excessive force when not actively resisting was clearly established by 2019. View "Jackson-Gibson v. Beasley" on Justia Law