Justia Civil Rights Opinion Summaries

Plaintiff, who is serving a sentence for murder, filed a pro se § 1983 complaint in federal court, seeking damages for alleged constitutional violations committed by the State of South Carolina, various state entities and officials, and his defense attorney. Plaintiff, who was filing his first civil rights suit as a prisoner, moved for leave to proceed in forma pauperis under 28 U.S.C. Section 1915, and the district court granted his motion.A magistrate judge screened Plaintiff's case, finding it was barred by Heck v. Humphrey, 512 U.S. 477 (1994), under which a § 1983 plaintiff seeking damages for an unconstitutional conviction must first show that his conviction was reversed or otherwise set aside. The court also found prosecutorial immunity and sovereign immunity precluded relief. The magistrate judge then recommended that Plaintiff's case be “designated a ‘strike’ pursuant to 28 U.S.C. Section 1915(g).”The Fourth Circuit reversed, finding that the district court may not "contemporaneously rule that its dismissal of a complaint constitutes a strike." In so holding, the Fourth Circuit joined all other circuits that have considered the issue. View "Kevin Pitts v. State of South Carolina" on Justia Law

Plaintiff, a former pretrial detainee in the custody of the Ozark County Sheriff’s Department, filed an action pursuant to 42 U.S.C. Section 1983 claiming that Defendants acted with deliberate indifference to Plaintiff’s serious medical needs by denying him prescription medication. Defendants moved for summary judgment on the basis of qualified immunity. The district court denied the motion.   The Eighth Circuit affirmed. The court explained that Plaintiff has sufficiently demonstrated that Defendants were subjectively aware of but disregarded a serious medical need. The facts construed in the light most favorable to Plaintiff show that the “defendants, who are not medical personnel, substituted their controlled substance ‘policy’ and their schedule for administering or failing to administer medication for that of a treating physician.” Further, Defendants failed to administer or misadministered the medication to Plaintiff despite knowing a doctor prescribed them and despite Plaintiff’s repeated requests for his medication. Construing the facts in the light most favorable to Plaintiff, his “right to adequate treatment was clearly established, and the district court properly denied Defendants qualified immunity. View "Tracy Presson v. Darrin Reed" on Justia Law

Parents and guardians of students with disabilities brought an enforcement action under the Individuals with Disabilities Education Act, alleging that the New York City Department of Education must immediately fund their children’s educational placements during the pendency of ongoing state administrative proceedings. Plaintiffs moved for a preliminary injunction, which the district court denied. Plaintiffs appealed from that denial.   The Second Circuit affirmed. As a threshold jurisdictional matter, the court held that although the Plaintiffs are not yet entitled to tuition payments for the portion of the school year that has yet to occur, their claims are nevertheless ripe because they also seek payments for past transportation costs. On the merits, the court held that the IDEA’s stay-put provision does not entitle parties to automatic injunctive relief when the injunctive relief concerns only educational funding, not placement. Applying the traditional preliminary injunction standard, the court concluded that Plaintiffs are not entitled to the relief they seek because they have not shown a likelihood of irreparable injury. View "Mendez v. Banks" on Justia Law

Plaintiff appealed from the district court’s judgment dismissing all claims against Defendants-Newburgh Enlarged City School District, Superintendent, and Assistant Superintendent. Plaintiff, an African American woman of West Indian descent who served as principal of South Middle School, asserts claims of discrimination under Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause of the Fourteenth Amendment.   The Second Circuit affirmed the district court’s dismissal of the Title VII claim to the extent the claim is based on alleged adverse employment actions in May 2019 and vacated the district court’s judgment to the extent it dismissed the Section 1983 claim and the remainder of the Title VII claim. The court remanded the case to the district court for further proceedings, including a determination as to whether Plaintiff should be provided with an extension of time to effectuate proper service as to the Superintendent and Assistant Superintendent. The court explained that taking the allegations in the FAC as true and drawing all reasonable inferences in Plaintiff’s favor, the FAC meets that pleading standard with respect to the denial of the position for RISE administrator, the denial of her application to administer the summer-school program, and the termination of her position as SMS principal. Accordingly, the court explained that Plaintiff has stated plausible discrimination claims under Title VII and Section 1983, and the district court erred in dismissing them. Therefore, Plaintiff may proceed with her Section 1983 claim as to all three alleged adverse employment actions and with her Title VII claim against the School District. View "Buon v. Spindler, et al." on Justia Law

Plaintiffs filed suit under: 42 U.S.C. § 1983; the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. §§ 1961-68; and Oklahoma state law, challenging an allegedly unconstitutional scheme to collect “court debts” from impoverished Oklahoma citizens. The Second Amended Class Action Complaint (“SACAC”) named numerous “Defendants,” which fell into three broad categories: (1) individual Oklahoma sheriffs, the Oklahoma Sheriff’s Association (“OSA”), and officials of Tulsa and Rodgers Counties (collectively, “Sheriffs”); (2) state court judges (collectively, “Judges”); and (3) Aberdeen Enterprises, II, Inc. and its principal officers (collectively, “Aberdeen”). Plaintiffs alleged Aberdeen, a debt-collection company, acting in concert with other Defendants, used actual or threatened incarceration to coerce indigent Oklahomans into paying court debts, without any inquiry into ability to pay. The district court dismissed the complaint for lack of subject matter jurisdiction, broadly holding that three independent doctrines prevented Plaintiffs from proceeding on any claim against any Defendant. Plaintiffs appealed to the Tenth Circuit Court of Appeals, asserting that none of the doctrines identified by the district court deprived federal courts of the ability to reach the merits of the claims listed in the complaint. To this, the Tenth Circuit agrees the district court erred in dismissing the SACAC. Accordingly, the judgment of dismissal was reversed and the matter remanded for further proceedings. View "Graff, et al. v. Aberdeen Enterprizes, II, et al." on Justia Law

Plaintiff appealed the dismissal of his complaint under Federal Rule of Civil Procedure 12(b)(6). Plaintiff alleged that Defendant, in his individual capacity and official capacity as sheriff, violated Plaintiff’s First Amendment rights and falsely arrested him. The district court dismissed Plaintiff’s Second Amended Complaint with prejudice, finding the Complaint still fails to state a claim under the Twobly and Iqbal standard and does not cure the deficiencies that made the first amended complaint a shotgun pleading. Plaintiff appealed this order.The Eleventh Circuit affirmed. The court explained that Plaintiff carries the burden of pointing to what intentionally or recklessly false information went into the warrant affidavit. Otherwise, the presumption that the warrant was validly issued, and thus that probable cause existed, must stand. Here, the court explained that Plaintiff’s Complaint does not plausibly allege an absence of probable cause for his arrest, and Plaintiff failed to satisfy either of the two exceptions to carry that burden or a plausible connection between his election announcement and teleserve reassignment. View "Bryan Turner v. Mike Williams, et al." on Justia Law

Several defendants were charged by indictment in separate cases with various offenses arising from their alleged participation in the Capitol riot on January 6, 2021. Among other charges, the government also charged each Defendant with one count of Obstruction of an Official Proceeding under 18 U.S.C. Section 1512(c)(2). The district court granted each Defendant’s motion to dismiss. The government filed a motion to reconsider, which the district court denied. At issue on consolidated appeal is whether individuals who allegedly assaulted law enforcement officers while participating in the Capitol riot can be charged with corruptly obstructing, influencing, or impeding an official proceeding, in violation of 18 U.S.C. Section 1512(c)(2). The DC Circuit reversed. The court held that the district court erred in dismissing the counts under 18 U.S.C. Section 1512(c)(2). The court wrote that Defendants’ alleged conduct falls comfortably within the plain meaning of “corruptly . . . obstruct[ing], influenc[ing], or imped[ing] [an] official proceeding, or attempt[ing] to do so.” The alternative interpretations of Section 1512(c)(2) proffered by the district court and Defendants failed to convince the court to depart from the natural reading of the statute’s unambiguous text. View "USA v. Joseph Fischer" on Justia Law

Plaintiff filed suit against the Board of Regents of the University of Minnesota (University) following the elimination of the University’s men’s gymnastics team. He then sought a preliminary injunction to reinstate the team pending the outcome of the litigation. The district court denied the motion for the preliminary injunction, finding that Plaintiff’s delay in filing for the injunction undermined his claim of irreparable harm and that the other preliminary injunction factors favored the University. Plaintiff appealed the order denying the motion for the preliminary injunction. At issue on appeal is whether Plaintiff has suffered irreparable harm, and second, whether he unreasonably delayed in bringing the claim.   The Eighth Circuit affirmed. The court explained that it has found that “delay is only significant if the harm has occurred and the parties cannot be returned to the status quo.” Here, the men’s collegiate gymnastics season begins in December at the earliest and January at the latest. The goal of a preliminary injunction is “to preserve the status quo until the merits are determined.” Given that the injunction motion was not filed until November 2021 and that the majority of the coaching staff and other gymnasts had left the University by this time, it would have been improbable, at best, for the team to have competed in the 2021–2022 season. Because Plaintiff sought an injunction after it would have been possible “to preserve the status quo,” the court held that the delay was unreasonable and that it consequently defeated Plaintiff’s goal of preventing irreparable harm. View "Evan Ng v. Board of Regents of the U of M" on Justia Law

On behalf of her son’s estate, Plaintiff brought claims under 42 U.S.C. Section 1983 and North Carolina law against an officer and the City of Charlotte (“City”) in federal district court. The district court granted summary judgment for both Defendants after concluding that the officer was entitled to qualified immunity and the City was not responsible for the officer’s conduct under federal or state law. Plaintiff appealed both aspects of the district court’s decision.   The Fourth Circuit affirmed the district court’s decisions granting summary judgment for the City on Franklin’s § 1983 and negligent training claims. The court vacated the decisions granting summary judgment for the officer on the Section 1983 and assault and battery claims and granting both defendants summary judgment on the wrongful death claim. The court explained that a reasonable jury could conclude that Plaintiff’s son did not pose an imminent threat to the officers or anyone else. Under those circumstances, the court concluded that the officer violated the Fourth Amendment. Therefore, the officer is not entitled to qualified immunity on Plaintiff’s 1983 claim against her.   Moreover, Plaintiff’s son’s death is not traceable to a subordinate’s decision that may be approved as final by a city policymaker. Instead, as the district court concluded, “the City Manager’s post-facto approval of an internal shooting investigation cannot possibly have caused the constitutional violation.” Reversing the City Manager’s decision cannot undo what is done. Therefore, the court affirmed the district court’s holding that the City is not liable under Section 1983 for the officer’s shooting. View "Deborah Franklin v. City of Charlotte" on Justia Law

Plaintiff a devout Jehovah’s Witness, objected to California’s loyalty oath because she believed it would violate her religious beliefs by requiring her to pledge primary allegiance to the federal and state governments and to affirm her willingness to take up arms to defend them. he Controller’s Office rejected this proposal and rescinded the job offer. Plaintiff sued the Controller’s Office and the California State Controller in her official capacity, alleging violations of Title VII under both failure-to-accommodate and disparate-impact theories. She also asserted a failure-to-accommodate claim against the Controller’s Office under the California Fair Employment and Housing Act (“FEHA”), and she alleged that the refusal by both defendants to accommodate her religious beliefs violated the Free Exercise Clauses of the federal and state constitutions.   THe Ninth Circuit reversed the district court’s dismissal. The panel held that, as currently pleaded, Plaintiff’s alleged injury was redressable only through a claim for damages. The panel held that she lacked the actual and imminent threat of future injury required to have standing to seek prospective relief on any of her claims, but she could attempt to cure this defect by amendment. The panel held that Plaintiff could seek damages from the Controller’s Office on her claims under Title VII. As currently pleaded, she could not obtain damages for her free exercise claim under 42 U.S.C. Section 1983. The panel held, however, that the district court abused its discretion in denying Plaintiff leave to amend to seek damages from the State Controller in her individual capacity. View "BRIANNA BOLDEN-HARDGE V. CALIFORNIA STATE CONTROLLER, ET AL" on Justia Law