Justia Civil Rights Opinion Summaries

Jason Waterhouse, high on methamphetamine, barricaded himself in his sister's basement and started a fire when Lakewood Police Department officers arrived. After an hour of failed negotiations, seven officers entered the basement to extract him and locate the fire. Sergeant Marc Direzza, providing lethal cover, was among the last two officers in the basement when Waterhouse burst out of a bedroom and rushed towards them. Another officer fired a beanbag shotgun, and Direzza fired his pistol, killing Waterhouse with a shot to the back.The Estate of Jason Waterhouse filed a Fourth Amendment excessive-force claim under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado. The district court granted summary judgment in favor of Sergeant Direzza, concluding he was entitled to qualified immunity. The court found that Direzza's use of lethal force was reasonable under the circumstances and did not violate clearly established law. The district court also dismissed a state-law wrongful-death claim without prejudice.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's summary judgment, holding that Sergeant Direzza was entitled to qualified immunity. The court determined that Direzza's use of lethal force was objectively reasonable given the dangerous circumstances, including the fire and smoke, and the perceived threat posed by Waterhouse. The court also affirmed the dismissal of the wrongful-death claim, as it was contingent on the outcome of the excessive-force claim. View "Estate of Jason Waterhouse v. Direzza" on Justia Law

Jeremy Young was convicted by a jury of possessing an unregistered firearm and being a felon in possession of a firearm. He was also convicted by a separate jury of assaulting a federal officer. Young received a total sentence of 84 months’ imprisonment and 3 years of supervised release. He appealed, challenging the Government’s use of peremptory strikes against Native American venirepersons, the district court’s decision to admit certain evidence as res gestae, and the sufficiency of the evidence at both trials.The United States District Court for the District of South Dakota denied Young’s Batson challenges, finding the Government’s reasons for striking the Native American jurors to be legitimate and race-neutral. The court also admitted excerpts of Young’s recorded interview with Agent Kumley, where Young discussed his plans to transport methamphetamine, as relevant res gestae evidence. The jury found Young guilty on all counts.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court found no clear error in the district court’s Batson analysis, noting that the Government provided race-neutral reasons for striking the jurors and that Young failed to demonstrate pretext. The court also upheld the admission of the recorded interview, agreeing that it provided relevant context for Young’s possession of the shotgun. Finally, the court concluded that the evidence was sufficient to support Young’s convictions, as the jury reasonably found that Young had both actual and constructive possession of the firearm and that he intentionally assaulted Sergeant Antoine. View "United States v. Young" on Justia Law

NYP Holdings, Inc. and a New York Post reporter submitted 144 Freedom of Information Law (FOIL) requests to the New York Police Department (NYPD) for disciplinary records related to specific police officers. The NYPD denied the requests for all but one officer, leading the Post to commence an article 78 proceeding to compel disclosure. The Police Benevolent Association (PBA) intervened, arguing that records created before the repeal of Civil Rights Law § 50-a were not subject to disclosure under FOIL.The Supreme Court granted the Post's petition, rejecting the NYPD's claim that compliance would be too burdensome and refusing to consider the PBA's retroactivity argument. The Appellate Division affirmed, holding that the repeal of section 50-a applied retroactively to records created before the repeal. The court emphasized that the repeal was remedial legislation intended to increase public trust and accountability in law enforcement.The Court of Appeals reviewed the case, focusing on whether law enforcement disciplinary records created while section 50-a was in effect could be disclosed in response to FOIL requests submitted after the repeal. The court concluded that the Legislature intended for the repeal to have retroactive effect, noting that FOIL's presumption of disclosure applies to all records held by an agency, regardless of when they were created. The court also highlighted the legislative intent to enhance public trust and accountability following the repeal of section 50-a.The Court of Appeals affirmed the Appellate Division's order, holding that the repeal of section 50-a applies retroactively, allowing the disclosure of law enforcement disciplinary records created before the repeal. View "Matter of NYP Holdings, Inc. v New York City Police Dept." on Justia Law

In 2020, the New York legislature repealed Civil Rights Law § 50-a, which had exempted law enforcement disciplinary records from public disclosure under the Freedom of Information Law (FOIL). The New York Civil Liberties Union (NYCLU) subsequently requested records of all civilian complaints against Rochester police officers from the City of Rochester and the Rochester Police Department, regardless of whether the complaints were substantiated. When the respondents did not promptly produce the documents, NYCLU initiated a CPLR article 78 proceeding to compel disclosure.The Supreme Court ordered the production of many records but allowed the respondents to withhold records related to unsubstantiated complaints under the personal privacy exemption in Public Officers Law § 87 (2) (b). The Appellate Division modified this decision, ruling that the personal privacy exemption did not permit categorical withholding of all such records. Instead, the respondents were directed to review each record individually to determine if there was a specific justification for redaction or withholding based on personal privacy grounds.The Court of Appeals affirmed the Appellate Division's decision. The court held that FOIL's personal privacy exemption does not allow for a blanket exemption of all records related to unsubstantiated complaints against law enforcement officers. Each record must be evaluated individually to determine if disclosing it would constitute an unwarranted invasion of personal privacy. If redactions can prevent such an invasion, the agency must disclose the record with the necessary redactions. The court emphasized that the 2020 amendments to FOIL aimed to increase transparency in the law enforcement disciplinary process, and categorical exemptions would undermine this objective. View "Matter of New York Civ. Liberties Union v City of Rochester" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

Sharmarke Warsame was convicted of two felony counts of identity theft, two misdemeanor counts of theft, and one misdemeanor count of criminal use of a financial card for using stolen credit cards to purchase Target gift cards. The convictions were vacated on direct appeal, and the State dismissed the felony charges after remand. Warsame served 564 days in prison for the vacated and dismissed felony convictions. He then filed a statutory action for wrongful conviction and imprisonment seeking damages, attorney fees, costs, a certificate of innocence, and expungement of all associated convictions.The Johnson District Court denied the State's motion for summary judgment, reasoning that it needed to hear testimony and make findings concerning the alleged facts under which Warsame was convicted. A bench trial followed, and the district court ultimately ruled against Warsame, holding that he had failed to prove his actual innocence by a preponderance of the evidence.Warsame appealed directly to the Kansas Supreme Court, arguing that the district court incorrectly concluded that he committed felony identity theft against the alleged victims as charged and instructed to the jury. The State cross-appealed the denial of summary judgment, arguing that the actual innocence required under the wrongful conviction statute concerns the statutory elements of the charged crime, not the specific facts alleged in the filings or trial.The Kansas Supreme Court agreed with the State, holding that the crime of conviction is defined by statute and is not limited to the specific facts of the charging document. To receive compensation, Warsame was required to prove actual innocence by a preponderance of the evidence under the statutory elements of the charged crime. Warsame failed to meet this burden, as he admitted facts sufficient to prove he intended to defraud some party to receive a benefit. The court affirmed the denial of Warsame's claim. View "In re Wrongful Conviction of Warsame " on Justia Law

A transgender woman, Darlene Griffith, filed a civil rights lawsuit regarding her pretrial confinement at the El Paso County Jail in Colorado. She alleged that the jail's policies, which assigned housing based on genitalia and denied her access to female clothing and products, violated her constitutional rights and the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court dismissed her complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), leading to this appeal.The United States District Court for the District of Colorado dismissed Ms. Griffith’s complaint, concluding that she failed to state a plausible claim for relief. The court applied rational-basis review to her Equal Protection claim, finding that transgender individuals are not a protected class under existing precedent. The court also dismissed her ADA and Rehabilitation Act claims for lack of subject matter jurisdiction, as she did not properly name the county as a defendant according to state law requirements.The United States Court of Appeals for the Tenth Circuit reviewed the case and concluded that remand was required for some of Ms. Griffith’s claims. The court reversed and remanded for further proceedings on her Fourteenth Amendment Equal Protection claim against Sheriff Elder in his official capacity, her Fourth and Fourteenth Amendment cross-gender search claims against Sheriff Elder in his official capacity, and her Fourth Amendment abusive search claim against Deputy Mustapick. The court vacated the district court’s order dismissing Ms. Griffith’s ADA and Rehabilitation Act claims under Rule 12(b)(6) because those claims were dismissed without prejudice for lack of subject matter jurisdiction under Rule 12(b)(1), and that ruling was unchallenged on appeal. The court otherwise affirmed the district court’s dismissal of the remaining claims. View "Griffith v. El Paso County, Colorado" on Justia Law

Eight Black homeowners in New York City sued a lending institution and affiliated entities, alleging that the lender violated federal, state, and city antidiscrimination laws. They claimed the lender made mortgage refinancing loans with high default interest rates to Black and Latino individuals in poor neighborhoods who had no income, no assets, and low credit scores but high equity in their homes, and then foreclosed on the loans when the individuals defaulted. The United States District Court for the Eastern District of New York entered a final judgment awarding four homeowners $722,044 in compensatory damages and four others nominal damages.The lender appealed, arguing that the district court erred in three ways: by finding the homeowners' claims timely under the doctrine of equitable tolling and the discovery rule of accrual, in its instructions to the jury on disparate impact and disparate treatment theories of discrimination, and in holding that a release-of-claims provision in a loan modification agreement signed by two homeowners was unenforceable as a matter of law.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the district court did not abuse its discretion in holding that the homeowners' claims were timely under the doctrine of equitable tolling. The court also found no error in the district court's instructions to the jury on disparate impact and disparate treatment theories of discrimination. Finally, the court agreed that the release-of-claims provision in the loan modification agreement was unenforceable as a matter of law. Accordingly, the Second Circuit affirmed the judgment of the district court. View "Saint-Jean v. Emigrant Mortg. Co., Inc." on Justia Law

Jonathan Peoples pleaded guilty to felony possession of a controlled substance and was sentenced to one year of incarceration plus one year of mandatory supervised release. He received credit for time served, effectively completing his incarceration term. However, due to Illinois Department of Corrections (IDOC) policies, he was detained at Cook County Jail for four additional days until he could be transferred to IDOC for processing and release.Peoples filed a Section 1983 claim against Cook County and Sheriff Thomas J. Dart, alleging that his detention beyond his sentence violated his constitutional rights. The U.S. District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that neither the Fourth nor the Fourteenth Amendments applied to Peoples's claim and that he failed to present a triable Eighth Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the Fourth Amendment did not apply to Peoples's post-conviction detention. Instead, the Eighth Amendment, which prohibits incarceration beyond the end of a sentence without penological justification, was applicable. The court found that the Cook County Sheriff's Office had a penological justification for detaining Peoples until IDOC could process him, as required by Illinois law and the court's commitment order.The Seventh Circuit affirmed the district court's decision, holding that Peoples failed to establish that the Sheriff acted with deliberate indifference, a necessary element for an Eighth Amendment violation. Consequently, without a constitutional injury, Peoples's Section 1983 claim could not succeed. View "Peoples v Cook County" on Justia Law

Savanaha Works, a former inmate at Pushmataha County jail in Oklahoma, filed a 42 U.S.C. § 1983 action against detention officer Timothy Byers, alleging that he violated her Eighth Amendment rights by sexually assaulting her. The incident occurred on November 13, 2017, when Byers ordered Works to the laundry room, where he coerced her into pulling down her pants and then sexually assaulted her. Works expressed her lack of consent during the encounter and later told her cellmate that the incident "wasn't cool." The incident was captured on a security camera.The United States District Court for the Eastern District of Oklahoma denied Byers' motion for summary judgment based on qualified immunity. Byers appealed the decision, arguing that the district court incorrectly placed the burden of proof on him to establish consent and that the video evidence showed Works consented to the sexual act.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo and determined that the district court erred by shifting the burden of proof to Byers. The appellate court held that the burden remains on the plaintiff to establish non-consent in sexual abuse cases. The court found that Works presented sufficient evidence, including her verbal rejections and the inherently coercive nature of the prison environment, to show that a reasonable jury could find the sexual act was nonconsensual. Additionally, Byers' invocation of the Fifth Amendment right against self-incrimination further supported Works' claim of non-consent.The Tenth Circuit concluded that Byers' conduct violated Works' clearly established Eighth Amendment rights, as precedent clearly establishes that nonconsensual sexual assault by a prison guard constitutes cruel and unusual punishment. The court affirmed the district court's denial of qualified immunity for Byers. View "Harden v. Byers" on Justia Law