Justia Civil Rights Opinion Summaries

Anthony Frank Romane, Jr. was arrested for driving under the influence after being found unconscious in his car. He exhibited signs of intoxication and failed field sobriety tests. At the police station, he refused to submit to a chemical test after being read the Chemical Test Admonition. The Department of Motor Vehicles (DMV) initiated proceedings to suspend his license for one year due to his refusal to submit to testing. Romane requested an Administrative Per Se (APS) hearing to challenge the suspension.The APS hearing was conducted by a single hearing officer, Trena Leota, who introduced three documents into evidence: the arresting officer’s sworn DS 367 form, the unsworn arrest report, and Romane’s driving record. Romane’s counsel objected, arguing that the hearing officer was acting as an advocate, violating due process as explained in California DUI Lawyers Association v. Department of Motor Vehicles. The hearing officer overruled the objections and admitted the documents. Romane’s bodyworn camera footage was also admitted into evidence. The hearing officer ultimately sustained the suspension of Romane’s license.Romane filed a petition for writ of administrative mandate in the Superior Court of San Diego County, arguing that his due process rights were violated because the hearing officer acted as both advocate and adjudicator. The superior court agreed and ordered the DMV to set aside the suspension unless a new hearing was conducted with separate individuals acting as advocate and adjudicator.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case and reversed the superior court’s decision. The appellate court held that the hearing officer did not act as an advocate but merely collected and developed evidence, which is constitutionally permissible. The case was remanded to the superior court to consider Romane’s contention that the evidence did not support the hearing officer’s findings. View "Romane v. Dept. of Motor Vehicles" on Justia Law

Three criminal defendants in San Francisco, on behalf of themselves and a putative class, challenged the constitutionality of the San Francisco Sheriff's Office (SFSO) Pre-Trial Electronic Monitoring program (PTEM). They specifically contested Rule 5, which requires enrollees to submit to warrantless searches, and Rule 11, which allows SFSO to share participants’ location data with other law enforcement agencies without a warrant and to retain the data. The plaintiffs were divided into two subclasses: those enrolled in the program before May 2023 ("original rules subclass") and those enrolled after May 2023 ("revised rules subclass").The United States District Court for the Northern District of California granted a preliminary injunction in favor of the plaintiffs, finding that the Program Rules likely violated their rights under the United States and California constitutions. The court enjoined the enforcement of the challenged Program Rules for both subclasses. The Sheriff appealed the injunction, particularly the prohibition on enforcing the location sharing provision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction over the appeals and that abstention was not warranted. The court found that the plaintiffs were unlikely to succeed on their facial challenges to Rule 11’s location sharing requirement for the revised rules subclass. The court determined that the Superior Court exercises a core judicial power in imposing PTEM and that the Sheriff’s program does not create separation-of-powers issues. The court also found that the location sharing provision was reasonable under the Fourth Amendment and the California Constitution when ordered by the Superior Court following an individualized determination. The court vacated the preliminary injunction as to the revised rules subclass but affirmed it for the original rules subclass due to the lack of a clear record that location sharing was a condition of PTEM enrollment. The court also granted the Sheriff’s motion to stay the district court’s subsequent order enforcing the preliminary injunction. View "SIMON V. CITY AND COUNTY OF SAN FRANCISCO" on Justia Law

Patrick Harmon was stopped by Salt Lake City police officer Kris Smith for a traffic violation while riding a bicycle. Harmon provided a false name, but Officer Smith identified him and discovered an active felony warrant. When Officer Smith attempted to arrest Harmon, he fled. Officers Clinton Fox and Scott Robinson joined the chase. The officers reported seeing Harmon reach towards his waist or pocket and heard him mention cutting or stabbing. Officer Fox claimed he saw Harmon holding a knife and shot him three times from five to seven feet away. Officer Smith, who was about fifteen feet away, fired his taser. Harmon died from the gunshots, and a knife was found near his right arm.Harmon's estate and his children sued Officer Fox and Salt Lake City for excessive force. The United States District Court for the District of Utah dismissed the case, but the Tenth Circuit Court of Appeals reversed and remanded. On remand, the district court granted summary judgment to Officer Fox and Salt Lake City, concluding that any factfinder would determine Harmon was holding a knife and that the shooting was reasonable.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court found that a genuine dispute of material fact existed regarding whether Harmon brandished a knife or threatened the officers. The court noted that the video evidence did not clearly show a knife, and Officer Smith testified he did not see a knife. The court concluded that a factfinder could reasonably find that Harmon did not pose an imminent threat, making the use of deadly force unreasonable. The court held that Officer Fox was not entitled to qualified immunity and reversed the summary judgment, remanding the case for further proceedings. View "Harmon v. Salt Lake City" on Justia Law

A police officer, Mathew Grashorn, shot a dog named Herkimer after responding to a business owner's call about a truck in a parking lot after hours. Upon arrival, Officer Grashorn saw the truck and two dogs, Bubba and Herkimer. Bubba initially ran towards the officer but returned to his owner when called. Herkimer then emerged and ran towards the officer, who shot the dog when it was a few feet away. Herkimer was later euthanized due to the injuries.The plaintiffs, Wendy Love and Jay Hamm, sued Officer Grashorn for violating the Fourth Amendment. The United States District Court for the District of Colorado denied the officer's motion for summary judgment based on qualified immunity, concluding that a jury could reasonably find that Herkimer did not pose an immediate danger, and thus the shooting could be a clearly established violation of the Fourth Amendment.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court upheld the district court's denial of summary judgment, agreeing that a jury could find no immediate danger and that the officer had time to consider non-lethal options. The court emphasized that common sense and case law clearly establish that shooting a pet dog without an immediate threat constitutes a Fourth Amendment violation. The court also rejected the officer's argument that a reasonable mistake about the danger would grant him qualified immunity, as the district court's factual conclusions suggested the mistake was unreasonable. The Tenth Circuit affirmed the district court's decision, denying qualified immunity to Officer Grashorn. View "Love v. Grashorn" on Justia Law

In the early hours of July 19, 2018, Peoria Police Officer Ryan Isonhart fatally shot Luis Cruz, who was fleeing from officers and allegedly pointing a gun at Officer Nicholas Mason. Lyrah Hernandez, Cruz’s sister, filed a lawsuit on behalf of Cruz’s estate, alleging federal claims under 42 U.S.C. § 1983 and state law claims against Officers Isonhart and Mason, and the City of Peoria. The district court granted summary judgment for Officer Mason, and the case proceeded to trial against the remaining defendants. The jury found in favor of the defendants. Hernandez appealed, arguing that the district court erred in admitting certain evidence and excluding testimony from two individuals.The United States District Court for the Central District of Illinois admitted evidence including the crimes underlying the 49 messages, the Department of Child and Family Services investigation, Cruz’s incarceration at the time of his daughters’ birth, and his pending drug charge. The court found these pieces of evidence relevant to the officers’ state of mind and Cruz’s damages. The court also barred testimony from forensic scientist Jennifer MacRitchie, ruling it was expert in nature and not properly disclosed, and excluded a recorded statement from Shaquille Alexander, finding it lacked trustworthiness.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The appellate court affirmed the district court’s decisions, finding that the admitted evidence was relevant and not unduly prejudicial, and that the exclusion of MacRitchie’s testimony and Alexander’s statement was appropriate. The court concluded that any potential error in admitting Cruz’s pending drug charge was harmless given the overwhelming evidence supporting the jury’s verdict. The judgment of the district court was affirmed. View "Hernandez v City of Peoria, Illinois" on Justia Law

Julie Nevarez, on behalf of herself and her minor children, filed a lawsuit under 42 U.S.C. § 1983 against Louisiana State Police Troopers Justin Leonard and Anthony Dorris. The case stems from the fatal shooting of her husband, Miguel Nevarez, by officers from the Houma Police Department and the Terrebonne Parish Sheriff’s Office. Following the shooting, the Troopers obtained search warrants for the Nevarez home, the car Mr. Nevarez was in, and Mrs. Nevarez’s cell phone, claiming they were investigating an aggravated assault against a police officer by Mr. Nevarez. Mrs. Nevarez contended that this justification was pretextual and that the affidavits lacked probable cause.The United States District Court for the Eastern District of Louisiana denied the Troopers' third motion to dismiss, ruling that they were not entitled to qualified immunity. The court found that the plaintiffs plausibly alleged a claim under Malley v. Briggs, concluding that a reasonable officer would understand there was no probable cause to support the search warrants, given that Mr. Nevarez was deceased and the affidavits did not suggest others were involved or that the crime was ongoing.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that there was no clearly established law indicating that probable cause could not support a warrant to search for evidence of a crime that could not be prosecuted because the suspect had died. Consequently, the Troopers were entitled to qualified immunity. The case was remanded for further proceedings consistent with this opinion. View "Nevarez v. Dorris" on Justia Law

K.A. and C.P. were married and had three daughters. Their marriage ended in divorce, and the Arapahoe County Department of Human Services (ACDHS) initiated actions against K.A. regarding her relationships with her children, leading to the termination of her parental rights and several contempt judgments. K.A. attempted to appeal the termination, but the Colorado Court of Appeals denied it as untimely, and the Colorado Supreme Court declined review. She also sought to appeal a contempt sentence, but it was again deemed untimely.K.A. filed a complaint under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado against Michelle Barnes, Executive Director of the Colorado Department of Human Services (CDHS), in her official capacity; ACDHS; and Michelle Dossey, Manager of the ACDHS Division of Child and Adult Protective Services, in her official capacity. The Arapahoe County Board of Commissioners was initially named but later dismissed by K.A. The district court dismissed K.A.'s claims and denied her motion to amend her complaint. K.A. filed a timely appeal.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that it lacked jurisdiction to hear K.A.'s claims due to sovereign immunity, the Rooker-Feldman doctrine, and lack of standing. The court found that K.A.'s claims for damages were barred by sovereign immunity, and her requests to reverse the termination of her parental rights and order a new hearing were barred by the Rooker-Feldman doctrine. Additionally, her requests for declaratory relief were either barred by sovereign immunity or lacked standing. The court also upheld the district court's denial of K.A.'s motion to amend her complaint, as she failed to explain how the amendments would cure the jurisdictional defects. View "K.A. v. Barnes" on Justia Law

Samuel Shanks and Taylor Lambert, former employees of the International Union of Bricklayers & Allied Craftworkers, filed pro se lawsuits against the Union alleging discrimination. Shanks, who worked in accounting for over twenty years, claimed discrimination based on disability, race, color, and sexual orientation, as well as a hostile work environment and retaliation. Lambert, his niece, alleged wrongful termination, retaliation, and discrimination based on race, religion, and gender. Both claimed violations of various civil rights laws, including the D.C. Human Rights Act, the Americans with Disabilities Act, and Title VII of the Civil Rights Act of 1964.The Union removed the cases to the United States District Court for the District of Columbia, which dismissed the complaints for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Shanks and Lambert appealed the dismissals. The United States Court of Appeals for the District of Columbia Circuit affirmed the dismissals in part but appointed amicus curiae to present arguments in favor of claims that were not suited for summary dismissal.The D.C. Circuit reviewed the district court’s dismissal de novo and concluded that the allegations of racial discrimination related to the Union’s COVID-19 vaccination policy were plausible. The court found that the Union’s two-stage roll-out of the policy disproportionately affected Black employees, who were given less time and fewer resources to comply with the vaccination mandate. The court held that the disparate impact and discriminatory treatment claims based on race were sufficiently pled to survive a motion to dismiss. The court affirmed the dismissal of other claims, including those based on sexual orientation, gender, and religion, as well as Shanks’ hostile work environment claim. The case was remanded to the district court for further proceedings on the racial discrimination claims. View "Shanks v. International Union of Bricklayers and Allied Craftworkers" on Justia Law

Tayvin Galanakis sued Officers Nathan Winters and Christopher Wing under 42 U.S.C. § 1983 and Iowa law, alleging they arrested him without probable cause. He also brought federal and state claims against the City of Newton, Iowa. The district court denied summary judgment in part, determining that the officers were not entitled to qualified immunity or state statutory immunity, and the City was subject to vicarious liability on a surviving state-law claim.The United States District Court for the Southern District of Iowa denied summary judgment with respect to the § 1983 and false arrest claims against Winters and Wing, as well as the respondeat superior claim against the City predicated on Galanakis’s false arrest claim. The defendants appealed, arguing that qualified immunity and state statutory immunity protected the officers—and, as to the false arrest claim, the City—from suit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on Galanakis’s Fourth Amendment claim, concluding that no objectively reasonable officer could have concluded that there was a substantial chance Galanakis had driven while under the influence of marijuana. The court found that Galanakis evinced almost no indicia of intoxication and that his behavior during the stop did not suggest impairment. The court also dismissed the interlocutory appeal as to the state-law claims, noting that without clarification that resolution of the qualified immunity claim necessarily resolves the pendent claims, it declined to exercise jurisdiction. View "Galanakis v. City of Newton, Iowa" on Justia Law

On Thanksgiving night in 2018, Officer David Alexander, a policeman with the City of Hoover, was on foot patrol at the Galleria Mall in Birmingham, Alabama. During a suspected active shooting situation, Officer Alexander saw Emantic "E.J." Fitzgerald Bradford moving towards two men with a gun in his hand. Without issuing a verbal warning, Officer Alexander shot and killed Mr. Bradford, who was legally authorized to carry his gun and was attempting to provide assistance.April Pipkins, Mr. Bradford's mother and representative of his estate, filed a lawsuit against Officer Alexander, the City of Hoover, and other defendants, asserting Fourth Amendment claims under 42 U.S.C. § 1983 and state law claims for negligence and wantonness. The United States District Court for the Northern District of Alabama dismissed the state law claims and granted summary judgment on the § 1983 claims, ruling that Officer Alexander's use of deadly force was reasonable under the Fourth Amendment and that a verbal warning was not feasible under the circumstances.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decisions. The court held that Officer Alexander acted reasonably under the Fourth Amendment given the circumstances, which included a crowded mall, the sound of gunshots, and Mr. Bradford running with a gun towards two men. The court also found that a verbal warning was not feasible due to the immediate threat perceived by Officer Alexander. Additionally, the court upheld the dismissal of the state law claims, concluding that the Mall defendants did not owe a duty to protect Mr. Bradford from the criminal acts of a third party and that the complaint did not plausibly allege foreseeability or incompetency in hiring, training, and supervising Officer Alexander. View "Pipkins v. City of Hoover, Alabama" on Justia Law