Justia Civil Rights Opinion Summaries

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

An Arkansas inmate, Steven Pinder, filed a lawsuit under 42 U.S.C. § 1983, alleging that various defendants, including Wellpath, LLC, and its employees, were deliberately indifferent to his serious medical needs, violating his Eighth Amendment rights. Pinder sought declaratory and injunctive relief and substantial damages for several medical issues, including severe glaucoma, peptic ulcers, acid reflux, diabetes, and an orthopedic condition in his right shoulder. The district court granted summary judgment to two defendants on the shoulder claim and dismissed other claims for failure to establish in forma pauperis (IFP) status.The United States District Court for the Eastern District of Arkansas initially denied Pinder's IFP status due to his "three strikes" under the Prison Litigation Reform Act (PLRA), which bars prisoners with three prior dismissals for frivolous or malicious claims from proceeding IFP unless they are in imminent danger of serious physical injury. Pinder filed a declaration asserting imminent danger, which the magistrate judge partially accepted, allowing some claims to proceed. The district court adopted these recommendations but later revoked IFP status for most claims based on new evidence, ultimately granting summary judgment on the remaining shoulder claim.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court remanded the motion to revoke Pinder's IFP status to the district court for further consideration, particularly in light of new medical evidence. The appellate court also remanded the issue of whether the interlocutory dismissals were proper, given a recent Eighth Circuit opinion. The court did not rule on the summary judgment at this time, vacating the district court's judgment and remanding for further proceedings consistent with its opinion. View "Pinder v. WellPath" on Justia Law

In 1984, Richard Wershe, Jr., at fourteen, was recruited by the FBI as a drug informant. Over the next few years, he was involved in dangerous drug operations under the direction of federal and state officers. In 1987, Wershe was arrested and convicted of possessing a large quantity of cocaine, receiving a life sentence without parole, which was later amended to allow parole eligibility. While incarcerated, he cooperated with law enforcement in various investigations, including "Operation Backbone" and a grand jury against the "Best Friends" gang, based on promises of assistance with his parole. Despite his cooperation, Wershe was denied parole in 2003 and was only released in 2017, subsequently serving time in Florida for an unrelated charge until his release in 2020.Wershe filed two lawsuits: one in July 2021 against the City of Detroit and various federal and state officials under 42 U.S.C. § 1983 and Bivens, and another in October 2022 against the United States under the Federal Tort Claims Act (FTCA). He alleged constitutional violations and tort claims related to his time as a juvenile informant and subsequent parole denial. The United States District Court for the Eastern District of Michigan dismissed both lawsuits with prejudice, ruling that Wershe’s claims were time-barred and not subject to equitable tolling.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Wershe’s claims were indeed time-barred under the applicable statutes of limitations and that he was not entitled to equitable tolling. The court found that Wershe had constructive knowledge of the filing deadlines, did not diligently pursue his claims, and that the defendants would be prejudiced by the delay. Additionally, the court ruled that the district court did not err in dismissing the complaints with prejudice or in its handling of materials outside the pleadings. View "Wershe v. City of Detroit" on Justia Law

In 2021, Ellva Slaughter was charged with illegally possessing a firearm while knowing he had previously been convicted of a felony, violating 18 U.S.C. § 922(g)(1). Slaughter moved to dismiss the indictment, arguing that the jury selection plan of the Southern District of New York (SDNY) systematically underrepresented Black and Hispanic or Latino people, violating his Sixth Amendment right and the Jury Selection and Service Act of 1968 (JSSA). The district court assumed the underrepresentation was significant but denied the motion, finding Slaughter failed to prove systematic exclusion in the jury selection process.The United States District Court for the Southern District of New York denied Slaughter's motion to dismiss the indictment. The court assumed without deciding that there was significant underrepresentation of Black and Hispanic or Latino people but concluded that Slaughter did not establish that this underrepresentation was due to systematic exclusion. The court found that Slaughter's expert did not provide evidence that the identified practices caused the disparities and noted that many of the challenged practices were authorized by the Second Circuit. The court also found that any disparities were due to external factors outside the SDNY's control.The United States Court of Appeals for the Second Circuit reviewed the case. The court applied the framework from Duren v. Missouri, assuming without deciding that the underrepresentation was significant. However, it concluded that Slaughter did not meet his burden of proving systematic exclusion. The court found that Slaughter's expert did not provide sufficient evidence that the SDNY's practices caused the underrepresentation. The court affirmed the district court's judgment, holding that Slaughter failed to establish a prima facie violation of the fair cross-section requirement under the Sixth Amendment and the JSSA. View "United States v. Slaughter" on Justia Law

Three plaintiffs, planning to participate in protests during the Democratic National Convention in Chicago, challenged the constitutionality of a city ordinance listing prohibited items within security perimeters. The list includes items such as laptops, large bags, drones, bicycles, and pointed objects, among others. Plaintiffs argued that the ordinance is unconstitutionally vague, particularly concerning the prohibition of "pointed object(s)," which they feared could include everyday items like ballpoint pens and buttons.The United States District Court for the Northern District of Illinois denied the plaintiffs' request for a preliminary injunction, finding that the ordinance was not unconstitutionally vague. The plaintiffs then appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the ordinance has a core of ascertainable meaning, covering items that pose clear safety risks, such as weapons and explosives. The court noted that while the plaintiffs raised concerns about potential overreach, they had not demonstrated that a substantial number of the ordinance's applications were unconstitutional. The court concluded that the plaintiffs' facial challenge to the ordinance lacked merit, as the potentially problematic applications were not substantial in relation to the valid ones. The court also found that the plaintiffs had standing to challenge the ordinance but ultimately ruled against them on the merits. View "Thayer v. City of Chicago" on Justia Law

Jane Doe, a student in a dual enrollment program with the University of Kentucky, reported being raped by John Doe (JD) in her dorm room. The University held four student conduct hearings. The first three hearings resulted in JD's expulsion or suspension, but each decision was overturned by the University’s appeals board due to procedural errors. After the third reversal, Doe filed a Title IX lawsuit against the University. In the fourth hearing, the panel ruled against her, and Doe claimed the University mishandled this hearing in retaliation for her lawsuit.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University, concluding that Doe could not establish a prima facie case of retaliation under Title IX. The court found that Doe was no longer a student at the time of the fourth hearing and thus could not claim adverse school-related actions. It also limited its analysis to the allegations in Doe’s complaint, excluding additional evidence presented in opposition to summary judgment.The United States Court of Appeals for the Sixth Circuit reversed and remanded the case. The court held that Doe could suffer adverse school-related actions even if she was not a current student and that the University’s disciplinary proceedings are educational programs under Title IX. The court found that the University’s delays, procedural errors, and failure to adequately prosecute JD could dissuade a reasonable person from pursuing a Title IX claim. The court also held that Doe presented sufficient evidence to establish a causal connection between her lawsuit and the adverse actions. The case was remanded for further proceedings consistent with this opinion. View "Doe v. University of Kentucky" on Justia Law

La Dell Grizzell, acting on behalf of her minor children, sued San Elijo Elementary School and the San Marcos Unified School District, alleging that the school violated her children's federal and state civil rights. The complaint included claims of racial discrimination and other civil rights violations, such as racial epithets, physical assaults, and discriminatory disciplinary measures. Grizzell sought to proceed without legal representation.The United States District Court for the Southern District of California dismissed the case without prejudice, citing the "counsel mandate," which precludes nonlawyer parents from representing their children pro se. The court emphasized that regardless of the merits of the case, Grizzell could not represent her children without an attorney. The district court instructed that the minor plaintiffs could only proceed through a licensed attorney.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that it was bound by its precedent in Johns v. County of San Diego, which prohibits nonattorney parents from representing their children in court. Despite Grizzell's arguments that this rule impedes access to justice for children from low-income families, the panel concluded that it could not deviate from established precedent. The court acknowledged the serious implications of the counsel mandate but affirmed the dismissal without prejudice, indicating that only en banc review could potentially alter the rule. View "GRIZZELL V. SAN ELIJO ELEMENTARY SCHOOL" on Justia Law

Devon Arseneau and her ex-husband were involved in a child custody dispute in the St. Louis County Circuit Court. The court appointed Elaine Pudlowski and Brian Dunlop as guardians ad litem to represent the child's best interests and James Reid to conduct psychological evaluations. Following their testimonies, the court awarded sole legal custody to Arseneau’s ex-husband and joint physical custody to both parents. Arseneau subsequently filed a lawsuit under 42 U.S.C. § 1983 against Pudlowski, Dunlop, and Reid, alleging that their actions during the custody proceedings violated her constitutional rights.The United States District Court for the Eastern District of Missouri dismissed Arseneau’s complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court concluded that the defendants were entitled to absolute immunity and had not acted under color of state law. The district court did not address the defendants' arguments regarding Younger abstention or the Rooker-Feldman doctrine.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court determined that Younger abstention did not apply because there were no ongoing state proceedings. It also bypassed the Rooker-Feldman issue, finding that the merits of the case warranted dismissal. The court held that the defendants, as guardians ad litem and a court-appointed psychologist, were entitled to absolute immunity for actions within the scope of their judicial duties, even if those actions were alleged to be wrongful or illegal. Consequently, the court affirmed the dismissal of Arseneau’s § 1983 claims. View "Arseneau v. Pudlowski" on Justia Law

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

A.D., a student with disabilities, attended Sparta High School and was designated as having a disability under the IDEA. In early 2019, Sparta informed A.D. that he was in danger of failing several classes, leading to a period of home instruction. A.D.'s parents withdrew him from school, and he subsequently passed the GED, receiving a State-issued high school diploma in April 2019. Despite re-enrolling at Sparta High School and receiving home instruction again, A.D. faced academic challenges and was withdrawn from school multiple times. In May 2021, Sparta denied A.D.'s re-enrollment request, citing his receipt of the State-issued diploma.M.N., A.D.'s mother, requested a due process hearing with the New Jersey Department of Education (DOE). The Administrative Law Judge (ALJ) ruled that A.D.'s State-issued diploma was a "regular high school diploma" under federal regulations, thus ending his entitlement to a FAPE. The Commissioner of the DOE upheld the ALJ's decision, and the Appellate Division affirmed, agreeing that the State-issued diploma met state standards and ended A.D.'s entitlement to a FAPE.The Supreme Court of New Jersey reviewed the case and held that a New Jersey State-issued diploma based on passing the GED is not a "regular high school diploma" under 34 C.F.R. § 300.102(a)(3)(iv). Therefore, a student who receives such a diploma remains entitled to a free appropriate public education under the IDEA. The Court reversed the Appellate Division's decision, concluding that A.D. remains entitled to receive a FAPE, and Sparta must provide it. View "Board of Education of the Township of Sparta v. M.N." on Justia Law