Justia Civil Rights Opinion Summaries

Andrew Fields, while incarcerated at U.S. Penitentiary Lee, alleged that he was subjected to excessive force by several prison officials, violating his Eighth Amendment rights. Fields claimed that after failing to carry his inmate movement pass, he was berated, placed in administrative segregation, and had his legal documents and prescription eyeglasses seized. He further alleged that during his transfer to the Special Housing Unit (SHU), he was physically abused, including being hit and having his head rammed into a wall, despite posing no threat. Fields also claimed that prison staff denied him access to the Bureau of Prisons' administrative grievance procedure, preventing him from pursuing alternative remedies.The United States District Court for the Western District of Virginia dismissed Fields's complaint under the Prison Litigation Reform Act’s prescreening procedure, concluding that his allegations either did not state a constitutional violation or were not cognizable under Bivens v. Six Unknown Named Agents of Federal Narcotics Bureau. Fields appealed the dismissal, focusing solely on his Eighth Amendment excessive force claim.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and concluded that Fields's allegations, if true, could overcome the limitations on Bivens claims. The court found that Fields's claim did not implicate systemic prison policies but rather concerned individual officers' conduct in violation of prison policy. The court also noted that Fields was denied access to alternative remedies due to the officers' actions. Consequently, the Fourth Circuit affirmed the dismissal of claims against the Bureau of Prisons and supervisory officials but reversed and remanded the excessive force claim against the individual officers who allegedly subjected Fields to abuse. View "Fields v. Federal Bureau of Prisons" on Justia Law

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Adelina Gabriela Suarez, a nondenominational Christian, was employed by Yakima Valley School, a nursing facility operated by the State of Washington. Suarez requested Saturdays off to observe her Sabbath and additional religious holidays, but her requests were denied due to staffing needs and her probationary status. After refusing to work mandatory overtime shifts and taking an unscheduled leave for a religious event, Suarez was terminated for unreliability.In Yakima County Superior Court, Suarez claimed Yakima Valley failed to accommodate her religious practices and wrongfully terminated her in violation of public policy under the Washington Law Against Discrimination (WLAD). The court granted summary judgment in favor of the State, finding that the accommodations sought by Suarez would cause undue hardship and that her termination was not due to religious discrimination. Suarez's motion for reconsideration was denied.The Washington Court of Appeals reversed the superior court's decision, holding that there were genuine issues of material fact regarding whether Yakima Valley provided reasonable accommodations and whether Suarez was terminated due to her religion. The appellate court applied a "significant difficulty or expense" test from WAC 82-56-020, rather than the "undue hardship" analysis from Hardison.The Supreme Court of the State of Washington reviewed the case and clarified that the correct analysis for an "undue hardship" defense under the WLAD is the substantial burdens test from Hardison, as clarified by Groff v. DeJoy. The court held that accommodating Suarez's requests would violate seniority rights under the collective bargaining agreement, constituting an undue hardship. The court reversed the Court of Appeals' decision and affirmed the superior court's summary judgment, dismissing Suarez's claims. View "Suarez v. State" on Justia Law

In January 2021, Julius Lamart Hodges, an inmate at the Prince William-Manassas Adult Detention Center, volunteered to work in the kitchen during a COVID-19 outbreak while most inmates quarantined. Hodges did not contract COVID-19 but claimed that his exposure to the virus constituted cruel and unusual punishment under the Eighth Amendment. He also alleged that his working conditions were harsh and that he was retaliated against for filing grievances about these conditions.The United States District Court for the Eastern District of Virginia dismissed Hodges’s complaint. The court found that Hodges failed to state a claim under the Eighth Amendment because he voluntarily chose to work and could have opted to quarantine. The court also dismissed his First Amendment retaliation claim, concluding that Hodges did not plausibly allege a causal connection between his grievances and any adverse action taken by the prison officials.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s dismissal. The Fourth Circuit held that Hodges’s Eighth Amendment claim failed because he voluntarily exposed himself to the conditions he complained about, and thus, the prison officials did not inflict those conditions upon him. The court also found that Hodges’s First Amendment retaliation claim was insufficient because he did not adequately allege a causal relationship between his grievances and the denial of his Work Release application. The court noted that the temporal gap between his grievance and the adverse action was too long to support an inference of causation.The Fourth Circuit modified the district court’s dismissal to be without prejudice, allowing Hodges the opportunity to amend his complaint if he could address the deficiencies identified by the court. View "Hodges v. Meletis" on Justia Law

Gary Hicks, a corrections sergeant, was suspended for 10 days by the Illinois Department of Corrections after an internal investigation into his Facebook posts, which were described as "Islamophobic" and "offensive" by a news article. The investigation concluded that Hicks violated Department policies prohibiting conduct unbecoming of a State employee or that may reflect unfavorably on the Department. Hicks admitted to making the posts, which included derogatory comments about various groups and a prayer for a civil war or government overthrow. He sued the Department and officials under 42 U.S.C. § 1983, alleging First Amendment retaliation and a Fourteenth Amendment challenge to the Department’s policies.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants on both claims. The court held that Hicks’s suspension did not violate the First Amendment because his posts were not on matters of public concern, and the Department’s interest in maintaining discipline outweighed his interest in speaking. The court also found that the Department’s policies were not impermissibly vague as applied to Hicks’s conduct and granted qualified immunity to the defendants.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court concluded that the Department’s interest in managing its affairs outweighed Hicks’s interest in posting the content, thus he could not sustain a First Amendment retaliation claim. Additionally, the court found that the Department’s code of conduct was not impermissibly vague as applied to Hicks, as a reasonable officer would understand that his posts were unbecoming and could reflect unfavorably on the Department. Therefore, the court affirmed the summary judgment in favor of the defendants on both the First and Fourteenth Amendment claims. View "Hicks v. Illinois Department of Corrections" on Justia Law

Kenneth Hunt arrived at the Lee County Courthouse to testify in a criminal case. Directed outside due to courtroom scheduling, Hunt re-entered and sat on a staircase. Officer Dale Acosta confronted Hunt, leading to a heated exchange. Despite Hunt's explanation of his courthouse business, Acosta arrested him for obstruction, claiming Hunt disrupted the county tax office.The United States District Court for the Eastern District of Arkansas dismissed most of Hunt's claims but allowed his Fourth Amendment claim against Acosta, a failure to train or supervise claim against Mayor Jimmy Williams and Chief of Police Martin Wilson, and a Monell claim against the City of Marianna. The court denied qualified and quasi-judicial immunity for Acosta and qualified immunity for Williams and Wilson. Acosta, Williams, and Wilson appealed the denial of immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of quasi-judicial immunity for Acosta's initial stop of Hunt, as Acosta acted under a judge's directive. However, the court affirmed the denial of quasi-judicial and qualified immunity for Acosta's arrest of Hunt, finding no probable cause for obstruction. The court also reversed the denial of qualified immunity for Williams and Wilson, ruling that Hunt failed to show a pattern of unconstitutional acts by Acosta that would have put them on notice. The case was remanded for further proceedings consistent with these findings. View "Hunt v. Acosta" on Justia Law

Joseph Smith was convicted of child sexual abuse and related offenses after sexually abusing his stepdaughter, A.S., starting when she was twelve years old. Smith forced A.S. to engage in sexual acts, sent her explicit messages, and coerced her into sending him nude photos. The abuse was reported to the police in April 2017, leading to a search of Smith’s residence, where incriminating evidence was found on a personal computer and two cell phones.The United States District Court for the District of Columbia denied Smith’s pretrial motions, including a motion to dismiss the indictment based on an alleged underrepresentation of Black residents in the jury pool, a motion to suppress evidence found on the seized devices, and motions related to the government’s case agent’s presence and testimony. Smith was convicted on multiple counts, including child sexual abuse, production and possession of child pornography, and enticement of a minor, and was sentenced to two concurrent life terms.The United States Court of Appeals for the District of Columbia Circuit reviewed Smith’s appeal and rejected all four of his challenges. The court held that Smith failed to demonstrate systematic exclusion of Black residents in the jury-selection process, as required by the Sixth Amendment. The court also found that the search warrant for Smith’s residence was sufficiently particular and that the good-faith exception precluded suppression of the evidence. Additionally, the court ruled that the district court did not plainly err in allowing the case agent to remain in the courtroom and testify based on her knowledge of Cellebrite, as any error did not affect the trial’s outcome given the overwhelming evidence against Smith. Consequently, the appellate court affirmed Smith’s convictions. View "U.S. v. Smith" on Justia Law

An inmate at the Marion Correctional Institution, Willard McCarley, submitted a statement alleging sexual assault by a prison doctor. The institutional investigator found the allegation to be false and issued a conduct report accusing McCarley of violating Rule 27, which prohibits giving false information to departmental employees. The Rules Infraction Board (RIB) found McCarley guilty and placed him in disciplinary control for 14 days. McCarley appealed the decision to the warden and the Ohio Department of Rehabilitation and Correction’s (DRC) chief legal counsel, both of whom affirmed the RIB’s decision.McCarley then filed a mandamus action in the Tenth District Court of Appeals, seeking to compel the DRC to vacate the RIB’s decision. He argued that there was no evidence to support the finding that he lied. The court referred the matter to a magistrate, who recommended granting the DRC’s motion for judgment on the pleadings, stating that McCarley failed to show a clear legal right to the relief sought or a clear legal duty on the part of the DRC. The court of appeals initially remanded the case to the magistrate to address the sufficiency of evidence but ultimately adopted the magistrate’s recommendation and denied the writ.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District’s judgment. The court held that McCarley did not demonstrate that the RIB’s guilty finding imposed an atypical and significant hardship or affected the duration of his confinement, which are necessary to establish a constitutionally protected liberty interest. Additionally, the court found that the RIB’s decision was supported by “some evidence,” specifically the “unfounded” finding of the PREA investigation. Therefore, McCarley was not entitled to mandamus relief, and the DRC was entitled to judgment as a matter of law. View "State ex rel. McCarley v. Dept. of Rehab. & Corr." on Justia Law

A mother, K.G., gave birth to twins in September 2020. Due to concerns about her mental health and ability to care for the children, Muskingum County Adult and Child Protective Services (the agency) took emergency temporary custody of the children. The children were placed with their maternal aunt. The juvenile court adjudicated the children as dependent and continued the agency's temporary custody. K.G. was required to undergo a psychological evaluation, which revealed several mental health conditions that could impair her parenting abilities.The juvenile court later transferred temporary legal custody to the maternal aunt, with the agency maintaining protective supervision. The agency then moved for the maternal aunt to be granted legal custody and for the agency's supervision to be terminated. At the hearing, the agency presented a psychological report by Dr. Wolfgang, which K.G. objected to, arguing she should be able to cross-examine the psychologist. The juvenile court admitted the report and granted legal custody to the maternal aunt.The Fifth District Court of Appeals reversed the juvenile court's decision, holding that K.G.'s due process rights were violated because she was not able to cross-examine Dr. Wolfgang. The agency appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the appellate court's decision, holding that the juvenile court was permitted to consider the psychologist’s report under the statutory scheme governing legal-custody proceedings. The court found that K.G. was not denied an opportunity to cross-examine Dr. Wolfgang and that her due process rights were not violated. The case was remanded to the appellate court for consideration of K.G.'s remaining assignment of error. View "In re R.G.M." on Justia Law