Justia Civil Rights Opinion Summaries

Blake Stewardson was arrested for driving under the influence on January 1, 2018, and taken to Cass County Jail. While intoxicated, he directed profanities at police and resisted during intake, leading Officer Titus to slam his head against a wall twice, causing a cut. Titus then performed a leg sweep, causing Stewardson to fall and hit his head. Later, Titus opened a cell door into Stewardson and performed a hip toss. Stewardson sued Titus and Biggs, alleging excessive force and failure to intervene.The United States District Court for the Northern District of Indiana granted summary judgment to the defendants on many claims but allowed two to proceed to trial: one against Titus for excessive force and one against Biggs for failing to intervene. The jury found Titus liable and awarded $400,000 in compensatory damages and $850,000 in punitive damages. Biggs was found not liable for failing to intervene. Titus appealed the punitive damages award, and Stewardson cross-appealed the summary judgment decisions.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the jury's punitive damages award against Titus, finding it not unconstitutionally excessive given the reprehensibility of his conduct, the ratio of punitive to compensatory damages, and comparable cases. The court also affirmed the district court's summary judgment in favor of Biggs, concluding that he did not violate clearly established law regarding excessive force or failure to intervene. Additionally, the court upheld the summary judgment on Stewardson's Monell claim against Cass County, finding insufficient evidence of an unconstitutional custom. View "Stewardson v. Titus" on Justia Law

Glorianna Moore was stopped by Officer Brian Wilson for speeding in Pontiac, Michigan. When Moore refused to show her license and moved her hands towards the center console, Wilson reached into her car, grabbed her arm, and ordered her to shut off the car. Moore resisted by screaming and twisting her body. Wilson restrained her by holding her arm and head until backup arrived. Moore was subsequently handcuffed and placed in Wilson's patrol car. Although an initial test indicated the presence of cocaine in Moore's car, further testing revealed it was not cocaine, leading to the dismissal of all charges against her.Moore filed a § 1983 action against Wilson and other officers, alleging excessive force in violation of her Fourth Amendment rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Wilson, who appealed the denial of his motion for summary judgment based on qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Officer Wilson did not violate clearly established Fourth Amendment principles. The court reasoned that Wilson's actions were reasonable given Moore's refusal to show her license, her movement towards the center console, and her active resistance. The court concluded that no clearly established law indicated that Wilson's use of force was excessive under the circumstances, thus entitling him to qualified immunity. View "Moore v. Oakland County" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

In September 2018, police officers in Fayetteville, North Carolina, observed a car performing a U-turn and stopping in front of Allen Wendell McNeil's house. After a brief interaction with the car's occupants, the police conducted a traffic stop and found a small bag of marijuana on the passenger. Without a warrant, the officers then went to McNeil's house for a "knock and talk." When McNeil's children answered the door and said he was not home, the officers proceeded to the backyard, where they found McNeil in a shed and detected the smell of marijuana. This led to McNeil's detention and the subsequent search and seizure of marijuana, money, and guns from his property.McNeil was charged with marijuana distribution and firearm possession. He pleaded guilty without a plea agreement, and the district court sentenced him to 114 months in prison. McNeil's direct appeal was affirmed by the United States Court of Appeals for the Fourth Circuit.McNeil filed a pro se petition under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless search and for not pursuing a plea agreement despite his requests. The district court dismissed the petition without an evidentiary hearing, ruling that McNeil's Fourth Amendment claim was frivolous and that his statements during the Rule 11 hearing precluded his ineffective assistance claim regarding the plea agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that McNeil's ineffective assistance claims could not be resolved on the existing record. The court held that the district court erred in dismissing McNeil's claims without an evidentiary hearing, as the facts surrounding the police officers' entry into the backyard and the plea negotiations required further factual development. The Fourth Circuit vacated the district court's judgment and remanded the case for an evidentiary hearing. View "United States v. McNeil" on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Michael and Rebecca McIntosh owned a mobile home park in Madisonville, Kentucky. In 2020, a tenant complained about mold and mildew in one of the mobile homes. The City of Madisonville inspected the home and found it unsafe, condemning it and giving the McIntoshes 30 days to submit repair plans. The McIntoshes disputed the condemnation, claiming they made necessary repairs and attempted to contact city officials multiple times without success. The City demolished the mobile home a month later.The McIntoshes pursued a § 1983 action, alleging due process violations. The district court granted summary judgment in favor of the City, leading the McIntoshes to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that while the City provided adequate notice of the condemnation, it failed to provide the McIntoshes with a pre-demolition hearing, as required by due process. The court noted that the City’s Code promised a hearing before a Local Appeals Board, which did not exist. The court also found that informal opportunities for a hearing were not adequately communicated to the McIntoshes. However, the court upheld the district court’s decision on the substantive due process claim, stating that the City’s actions did not rise to the level of conscience-shocking behavior. The court reversed the district court’s summary judgment on the procedural due process claim and affirmed the decision on the substantive due process claim, remanding the case for further proceedings on the procedural due process claim. View "McIntosh v. City of Madisonville" on Justia Law

Antonio Fuster went to the Chatham Township Police Department to report that his special needs child had accused an adult male relative of sexual misconduct. His interview with police was recorded on a body worn camera. Fuster and his wife, Brianna Devine, sought access to that video under the Open Public Records Act (OPRA) and the common law right of access. They alleged inaccuracies in the initial police report and wanted the video to potentially file an internal affairs complaint.The trial court ruled in favor of the defendants, holding that the body worn camera footage was a government record under OPRA but exempt from disclosure under N.J.S.A. 47:1A-9(b), which protects the confidentiality of information regarding individuals not arrested or charged. The Appellate Division affirmed, concluding that the video was exempt from disclosure under judicial case law protecting uncharged individuals' law enforcement records.The Supreme Court of New Jersey reviewed the case. The Court held that N.J.S.A. 40A:14-118.5(k) did not permit plaintiffs to review the video because Fuster had already requested the video be retained for three years, and Devine was not entitled to review it under the specified provisions. The Court also held that subsection (l) of the Body Worn Camera Law did not abrogate OPRA’s exemptions, but there was no OPRA exemption supporting the refusal to release the video. The Court found that OPRA does not contain an explicit exemption for information received by law enforcement regarding an individual who was not arrested or charged, and New Jersey case law had not established such an automatic grant of confidentiality.The Supreme Court reversed the Appellate Division’s judgment and ordered the release of the body worn camera footage to the plaintiffs, without reaching the common law claims. View "Fuster v. Township of Chatham" on Justia Law

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law