Justia Civil Rights Opinion Summaries

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law

A police union sought an injunction requiring the City of Los Angeles to comply with a state law mandating that anyone filing a complaint of police misconduct must first read and sign an advisory warning that knowingly filing a false complaint is a crime. The law, Penal Code section 148.6(a), singles out complaints against peace officers for this treatment, and its legislative history shows it was enacted to address concerns about reputational and professional harm to officers from false complaints, as well as the administrative burden of investigating such claims.Previously, the Los Angeles County Superior Court granted the injunction, finding itself bound by the California Supreme Court’s earlier decision in People v. Stanistreet, which had upheld the constitutionality of section 148.6(a). The California Court of Appeal affirmed, also relying on Stanistreet, despite several federal court decisions—including Chaker v. Crogan and Hamilton v. City of San Bernardino—holding that the statute violated the First Amendment.The Supreme Court of California reviewed the case and reconsidered its prior holding in light of subsequent U.S. Supreme Court decisions, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that section 148.6(a) is a content-based regulation within a proscribable category of speech (defamation) but, as drafted, it incidentally burdens protected speech by deterring truthful or well-intentioned complaints of police misconduct. Applying intermediate scrutiny, the court found the statute was not narrowly tailored to serve the government’s interests and burdened substantially more speech than necessary. The Supreme Court of California reversed the Court of Appeal’s judgment and remanded the case for further proceedings. View "L.A. Police Protective League v. City of L.A." on Justia Law

Donovan Lewis, a twenty-year-old Black man, was fatally shot by a Columbus police officer while in bed at his apartment during an attempted arrest on outstanding warrants. His estate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Columbus and the police chief, alleging that the city’s police department maintained a policy or custom of racially discriminatory policing and excessive force, which led to Lewis’s death. The complaint sought damages and permanent injunctive relief, including specific reforms to police disciplinary and employment practices that were rooted in the collective bargaining agreement (CBA) negotiated by the Fraternal Order of Police (FOP), Capitol City Lodge #9.After the estate initiated the suit, FOP moved to intervene as of right or, alternatively, permissively, arguing that the proposed reforms would violate the CBA and impact its legal obligations as the exclusive bargaining representative for Columbus police officers. The United States District Court for the Southern District of Ohio denied FOP’s motion without prejudice, finding that FOP had only a limited interest in the remedial phase and that any liability-phase interest was adequately represented by the City. The court invited FOP to renew its motion if the estate prevailed or if settlement discussions occurred.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of intervention. The Sixth Circuit held that FOP satisfied all requirements for intervention as of right under Federal Rule of Civil Procedure 24(a)(2): FOP demonstrated a substantial legal interest in the subject matter, impairment of its interests absent intervention, and that the City may not adequately represent those interests. The court concluded that FOP should be allowed to intervene in all phases of the litigation and reversed the district court’s denial of intervention. View "Estate of Lewis v. City of Columbus, Ohio" on Justia Law

A 12-year-old boy was killed by police officers during an attempt to rescue him from a neighbor who had already killed the boy’s mother and housekeeper, gravely wounded his sister, and was holding the boy hostage in a vehicle. The officers responded to multiple 911 calls, surrounded the vehicle, and attempted to negotiate with the hostage-taker, who was armed and making threats against the child’s life. After the hostage-taker was shot and killed by an officer, other officers fired additional shots, which resulted in the boy’s death.The boy’s father, siblings, and estate filed a lawsuit in the United States District Court for the District of Nevada against the city, police department, and individual officers. They alleged violations of the Fourth Amendment (excessive force), Fourteenth Amendment (substantive due process), a Monell claim for failure to train, and state law claims. The district court dismissed the federal claims with prejudice, finding that the officers had not seized the boy for Fourth Amendment purposes, had not acted with deliberate indifference or intent to harm for Fourteenth Amendment purposes, and that the Monell claim failed in the absence of a constitutional violation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the officers did not violate the boy’s Fourth Amendment rights because their actions during the active hostage situation did not constitute a seizure, and even if a violation had occurred, qualified immunity would apply as the right was not clearly established. The court also found no Fourteenth Amendment violation, as the officers’ actions did not shock the conscience or demonstrate deliberate indifference, and qualified immunity would apply. The Monell claim failed due to the absence of an underlying constitutional violation. View "HAWATMEH V. CITY OF HENDERSON" on Justia Law

Eddie Bolden was arrested in 1994 for double murder and attempted murder, convicted by a jury in 1996, and sentenced to life in prison. After more than 22 years incarcerated, his conviction was vacated by Illinois courts in 2016 due to ineffective assistance of counsel, and the State dismissed all charges, leading to his immediate release. Bolden subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police officers, alleging constitutional and state law violations stemming from his wrongful conviction and imprisonment.The case was heard in the United States District Court for the Northern District of Illinois, Eastern Division. After delays, including judicial reassignment and the COVID-19 pandemic, the trial occurred in October 2021. The jury found in Bolden’s favor, awarding $25 million in compensatory damages for pain, suffering, and loss of normal life, plus punitive damages against two individual defendants. The district court later granted Bolden’s motion to amend the judgment to include $7.6 million in prejudgment interest, calculated from the date his conviction was vacated to the entry of final judgment.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether prejudgment interest could be awarded on noneconomic damages and whether the district court abused its discretion in granting the interest. The Seventh Circuit held that prejudgment interest is available as a matter of law for noneconomic damages in federal civil rights cases, reaffirming its precedent. However, the court found that interest should only be awarded on past damages, not future damages, and remanded for the district court to apportion the jury’s verdict accordingly. In all other respects, the district court’s judgment was affirmed. View "Bolden v. Pesavento" on Justia Law

In 2017, the California Legislature enacted the LGBT Long-Term Care Facility Residents’ Bill of Rights, which included a provision prohibiting staff at long-term care facilities from willfully and repeatedly failing to use a resident’s preferred name or pronouns after being clearly informed of them, when such conduct is based on the resident’s sexual orientation, gender identity, gender expression, or HIV status. The law was designed to address documented discrimination and mistreatment of LGBT seniors in long-term care settings, where residents are particularly vulnerable and often lack alternative support networks.Before the pronouns provision took effect, Taking Offense, an association opposed to laws requiring recognition of transgender identities, filed a petition for writ of mandate in Sacramento County Superior Court, seeking to block enforcement of the provision as facially unconstitutional under the First Amendment. The trial court denied the petition, finding the law to be a permissible, narrowly tailored regulation serving a significant state interest in preventing discrimination. On appeal, the California Court of Appeal, Third Appellate District, reversed in part, holding that the pronouns provision was a content-based restriction on speech that failed strict scrutiny and was therefore facially unconstitutional.The Supreme Court of California reviewed the case. The State argued for the first time that Taking Offense lacked taxpayer standing under Code of Civil Procedure section 526a, as amended in 2018, which now limits such standing to suits against local, not state, entities. The Supreme Court agreed but exercised its discretion to address the merits due to the public importance of the constitutional question. The Court held that the pronouns provision regulates discriminatory conduct that only incidentally affects speech, is not subject to First Amendment scrutiny as an abridgment of free speech, and, even if intermediate scrutiny applied, the provision would satisfy that standard. The Court reversed the Court of Appeal’s judgment. View "Taking Offense v. State of Cal." on Justia Law

The plaintiff, a black woman, worked as a Supervisory Medical Support Assistant at the Kansas City Veterans Administration (KCVA). After her supervisor, Angela Frey, was hired, the plaintiff alleged that Frey harassed her from the outset. The plaintiff was eventually assigned to a different position outside her original office and retired from the KCVA over a year later. She claimed that Frey discriminated against her based on race, retaliated against her for complaining about racial discrimination, created a racially hostile work environment, and constructively discharged her.The United States District Court for the Western District of Missouri granted summary judgment in favor of the KCVA. The district court found that the plaintiff’s allegations regarding denial of training, a negative performance review leading to reassignment, and interference with a job application in Florida were either too vague, unsupported by evidence, or based on inadmissible hearsay. The court also determined that the plaintiff failed to provide evidence of discriminatory intent or a causal link between any protected activity and adverse employment actions. Additionally, the court concluded that the incidents described did not rise to the level of a hostile work environment or constructive discharge.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the grant of summary judgment. The Eighth Circuit held that the plaintiff failed to present sufficient evidence to support her claims of racial discrimination, retaliation, hostile work environment, or constructive discharge under Title VII. The court emphasized that speculation and conclusory statements were insufficient to create a genuine issue for trial and that the conduct alleged did not meet the legal threshold for actionable discrimination or harassment. The judgment of the district court was affirmed. View "Sherman v. Collins" on Justia Law

A police dispatcher who worked for a Michigan city alleged that she and other female dispatchers were required to conduct searches of female arrestees, even when female officers were available, exposing them to health and safety risks. The department did not have a similar policy for male dispatchers. In 2020, the dispatcher and several colleagues filed a lawsuit alleging sex discrimination. Eleven days after filing, the dispatcher became the subject of an Internal Affairs investigation, which ultimately led to her termination for violating department policy by using a case-management system for personal reasons. She later settled with the department, resulting in her reinstatement with a demotion, suspension, and loss of promotion eligibility.Following these events, the dispatcher filed a second lawsuit in the United States District Court for the Eastern District of Michigan, claiming that the city and its police commissioner retaliated against her for exercising her First Amendment rights by filing the original lawsuit. She also brought a claim under Michigan’s Elliott-Larsen Civil Rights Act. The district court granted summary judgment to the city on the retaliation claim, finding no municipal liability, but denied summary judgment to the commissioner in his individual capacity, holding that there was a genuine issue of material fact regarding causation. The commissioner appealed, asserting qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that the dispatcher alleged legally cognizable adverse actions and that her right to be free from retaliation for protected speech was clearly established. The court affirmed the district court’s denial of qualified immunity to the commissioner and dismissed the remainder of the appeal for lack of appellate jurisdiction over factual disputes. The court declined to exercise pendent appellate jurisdiction over the state-law claims. View "DeVooght v. City of Warren" on Justia Law

Richard Mabee died from a methamphetamine overdose while confined in the Wheatland County Jail. He had traveled from Washington to Montana, violating his probation, and was arrested after a traffic stop. During booking, officers did not observe signs of drug use or find contraband, but video footage later showed Mabee disposing of a small object in his cell. Early the next morning, Mabee exhibited signs of methamphetamine intoxication, which were observed by Deputy Sweet, who monitored him via video but did not physically check on him until he was found unresponsive. Despite attempts at CPR, Mabee was pronounced dead from an overdose. The source of the methamphetamine was unclear, but the County theorized Mabee had concealed it prior to his confinement.The Estate of Richard Mabee sued Wheatland County for negligence, alleging the jailers failed to provide adequate medical care. The County asserted that Mabee’s own negligence contributed to his death and should diminish or bar recovery. The Fourteenth Judicial District Court, Wheatland County, allowed the County to present a comparative negligence defense and approved a special verdict form for the jury to apportion fault. The jury found both parties negligent, attributing 95% of the fault to Mabee and 5% to the County. As a result, the District Court entered judgment for the County, denying damages to the Estate.The Supreme Court of the State of Montana reviewed whether the District Court erred in permitting the comparative negligence defense. The Court held that, absent “special circumstances” where a jailer knows or should know a detainee is at risk of harm, comparative negligence applies and the factfinder may apportion fault. The Court affirmed the District Court’s judgment, concluding the Estate did not preserve any error regarding jury instructions on “special circumstances” and failed to show reversible error. View "Est. of Mabee v. Wheatland County" on Justia Law

In 2004, Clemente Javier Aguirre-Jarquin was arrested and later convicted for the murders of his neighbors, Cheryl Williams and Carol Bareis, in Altamonte Springs, Florida. The investigation by Seminole County Sheriff’s Office (SCSO) focused on Aguirre after bloody clothing and a knife were found near his residence, and forensic analysis by Donna Birks, a latent print examiner, identified Aguirre’s palm print on the murder weapon. Aguirre was tried and sentenced to death in 2006. Over the next decade, new evidence emerged: a 2007 investigation revealed misconduct in the SCSO Latent Print Unit, undermining the reliability of the fingerprint identification, and post-conviction DNA testing failed to link Aguirre to the crime scene but implicated Samantha Williams, the victims’ daughter and granddaughter, who later confessed to involvement in the murders.The Seminole Circuit Court denied Aguirre’s initial motion for a new trial, finding the evidence against him overwhelming. The Supreme Court of Florida affirmed this denial. However, after further post-conviction investigation and new DNA evidence, the Supreme Court of Florida vacated Aguirre’s convictions and ordered a new trial. In 2018, the State dropped all charges against Aguirre.Aguirre then filed suit in the United States District Court for the Middle District of Florida against Birks, lead investigator Robert Hemmert, crime scene analyst Jacqueline Grossi, and the Seminole County Sheriff, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and state law claims. The District Court denied qualified immunity to Birks, Hemmert, and Grossi on several counts and denied state-law immunity to Hemmert and Grossi.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of qualified immunity to Birks on the fabrication of evidence claim and affirmed the denial of state-law immunity to Hemmert and Grossi for intentional infliction of emotional distress. However, the court reversed the denial of qualified immunity to Birks and Hemmert on the malicious prosecution claim and to Hemmert and Grossi on the claim of inadequate investigation, finding no clearly established law requiring the investigation to eliminate all doubts. The case was remanded for further proceedings. View "Aguirre-Jarquin v. Hemmert" on Justia Law