Justia Civil Rights Opinion Summaries

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Dominique Ramsey and Travis Sammons were incarcerated for over five years for the murder of Humberto Casas. Their convictions were overturned by Michigan appellate courts due to an improper identification, leading to the dismissal of the case and their release. Ramsey and Sammons then sued David Rivard, a Michigan State Police sergeant, under federal and state law for malicious prosecution, fabrication of evidence, and unduly suggestive identification. The district court denied Rivard’s motion for summary judgment, rejecting his claims of absolute and qualified immunity for the federal claims and governmental immunity for the state law claim. Rivard appealed.The United States District Court for the Eastern District of Michigan denied Rivard’s motion for summary judgment, finding that he was not entitled to absolute or qualified immunity for the federal claims nor to governmental immunity for the state law claim. The court determined that there were genuine disputes of material fact regarding Rivard’s conduct and the reliability of the identification procedure he oversaw. Rivard then appealed to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit dismissed Rivard’s appeal regarding the denial of qualified immunity for the federal malicious prosecution and fabrication of evidence claims due to lack of appellate jurisdiction. The court affirmed the district court’s denial of summary judgment on the remaining claims. The court held that Rivard was not entitled to absolute immunity for his pretrial conduct and that there were genuine disputes of material fact regarding his good faith, precluding summary judgment on the state law malicious prosecution claim. The court also found that a jury could determine the show-up identification was unduly suggestive and unreliable, thus violating clearly established law. View "Ramsey v. Rivard" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law

Quintez Talley, a Pennsylvania inmate, filed a federal civil rights lawsuit alleging mistreatment while in restrictive custody. Talley claimed he was unable to file grievances due to lack of access to forms and writing implements from January 6 to February 8, 2018, while on suicide watch. He regained access on February 9, 2018, but did not file a grievance, instead filing the lawsuit.The United States District Court for the Eastern District of Pennsylvania dismissed Talley’s federal claims for failure to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). The court noted that Talley should have requested an extension to file a late grievance under the state prison system’s policy. Talley did not oppose the motion to dismiss and moved for a default judgment, which was denied. The court dismissed the complaint against all defendants, including those who had not appeared, because the claims were integrally related. The court also declined to exercise supplemental jurisdiction over state law claims.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The appellate court held that under the PLRA, Talley was required to request an extension to file a grievance once he regained access to the necessary materials. The court found that Talley’s failure to do so rendered his federal claims unexhausted. The court also rejected Talley’s argument that the dismissal was improper for defendants who had not appeared, noting that the failure to exhaust was apparent from the face of the complaint. The court concluded that the District Court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Talley v. Clark" on Justia Law

In 1993, Darrin Rick pleaded guilty to criminal sexual conduct involving four developmentally disabled girls and one seven-year-old boy. After failing to complete sex-offender treatment programs in prison, Hennepin County petitioned to civilly commit him as a "sexually dangerous person." Three psychologists, including two appointed by a Minnesota district court, agreed that Rick met the criteria for commitment. Consequently, he was committed to the Minnesota Sex Offender Program. In 2007, the Minnesota Supreme Court declined further review of his case. Years later, new expert reports suggested that the actuarial tools used to justify his commitment had overestimated his risk of recidivism.Rick filed a federal habeas petition, arguing that the new evidence showed he was "actually innocent" of being a sexually dangerous person. The United States District Court for the District of Minnesota entertained the petition under the actual-innocence exception, finding that the reliance on outdated expert reports and actuarial data violated his due-process rights. The court granted habeas relief, allowing Rick to bypass the one-year statute of limitations for filing the petition.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on whether the actual-innocence exception could apply to civil commitments. The court concluded that the exception, traditionally used in criminal cases to address wrongful convictions, does not extend to civil commitments. The court emphasized that the exception is meant for cases involving criminal guilt or innocence, not predictions of future dangerousness. Consequently, the Eighth Circuit reversed the district court's grant of habeas relief and remanded the case for denial of Rick's petition. View "Rick v. Harpstead" on Justia Law

John Doe, a student at Emory University, was accused of sexual misconduct by Jane Roe following an encounter in April 2019. Roe alleged that Doe engaged in nonconsensual intercourse and choked her. Doe denied the allegations, asserting that the encounter was consensual. Emory conducted an investigation, during which Roe changed parts of her story. Despite inconsistencies in Roe's account, Emory found Doe responsible for sexual misconduct and suspended him for a semester. Doe appealed internally without success.Doe then filed a lawsuit in the United States District Court for the Northern District of Georgia, claiming that Emory violated Title IX by discriminating against him based on sex and breached a contractual obligation to conduct the investigation fairly. The district court dismissed Doe's Title IX claim, reasoning that his allegations suggested pro-complainant bias rather than gender bias. The court also dismissed his contract claims, finding no mutual assent to the terms of the university's sexual misconduct policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the dismissal of Doe's Title IX claim, holding that his allegations did not plausibly indicate gender bias but rather suggested pro-complainant bias, which is not prohibited under Title IX. However, the court reversed the dismissal of Doe's breach-of-contract claims. It concluded that Doe plausibly alleged mutual assent to an implied contract based on Emory's sexual misconduct policy and found no basis to determine that Emory retained a unilateral right to amend the policy that would preclude mutual assent. The case was remanded for further proceedings on the contract claims. View "Doe v. Emory University" on Justia Law

In January 2019, Detective Lori Russ searched Connie Reguli’s private Facebook records, allegedly due to Russ’s dislike of Reguli’s criticism of the police. Reguli discovered the search a year later while preparing for her criminal trial but did not sue at that time. In July 2022, during her sentencing, Russ seemed to admit that Reguli’s speech motivated the search. Reguli then filed a First Amendment retaliation claim against Russ and her employer in November 2022 under 42 U.S.C. § 1983.The United States District Court for the Middle District of Tennessee dismissed Reguli’s claim as untimely, reasoning that the claim accrued when Reguli learned of the search in January 2020, not when she learned of Russ’s motivation in July 2022. The court applied Tennessee’s one-year statute of limitations for § 1983 claims, concluding that Reguli’s lawsuit was filed too late.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Reguli’s First Amendment retaliation claim accrued when she discovered the search in January 2020, as she knew of the injury and its cause at that time. The court rejected Reguli’s argument that the claim accrued only when she learned of Russ’s retaliatory motive, stating that the statute of limitations begins when the plaintiff knows or should know of the injury, not necessarily the motive behind it. The court also noted that Reguli did not renew her tolling argument on appeal, thus forfeiting it. View "Reguli v. Russ" on Justia Law

Roland McCarthy, a white man, was hired as Finance Director by the City Commission of Cordele, Georgia, in 2017 and promoted to City Manager in January 2021. During his tenure, Joshua Deriso campaigned for chairman of the City Commission, expressing intentions to replace white employees with African Americans and to have an all-black City Commission. After winning the election, Deriso and other black commissioners voted to fire McCarthy and replace him with a black City Manager, Angela Henderson Redding. McCarthy was warned by Deriso and another commissioner, Royce Reeves, that he would be replaced due to his race and could not return to his former position because he did not "look like" them.The United States District Court for the Middle District of Georgia dismissed McCarthy's complaint, ruling that he failed to state plausible claims of racial discrimination against the City. The court found that McCarthy did not sufficiently allege that the Commission acted with a racially discriminatory motive, as only one voting commissioner was alleged to have racial animus. The court also dismissed claims against Deriso in his official capacity as duplicative of claims against the City and dismissed claims against Deriso in his individual capacity, citing qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's dismissal of McCarthy's claims against the City. The appellate court found that McCarthy plausibly alleged that the Commission discriminated against him because of his race, based on Deriso's and Reeves's statements and the racial composition of the vote. However, the court affirmed the dismissal of claims against Deriso in his individual capacity, as he did not have the authority to make the official decision to fire McCarthy. The case was remanded for further proceedings. View "McCarthy v. City of Cordele Georgia" on Justia Law

James Setchfield, a 68-year-old man, filed a lawsuit against St. Charles County Police Department officers Nicholas Seiverling and Scott Ronald, alleging they used excessive force during an incident in a parking lot. The incident began when Setchfield arrived to pick up his son, who had been arrested for driving under the influence. A confrontation ensued between Setchfield and Corporal Ronald, during which Setchfield was allegedly beaten by the officers while still seated in his car. Setchfield claimed he did not threaten or resist the officers, but was nonetheless pulled from his car, beaten, and arrested, resulting in various injuries and subsequent PTSD.The United States District Court for the Eastern District of Missouri dismissed claims against St. Charles County and one officer, John Williams, but denied summary judgment for Corporal Ronald and Officer Seiverling on Setchfield’s excessive force and unlawful arrest claims. The court found that material factual disputes remained, precluding summary judgment based on qualified immunity for the officers.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of summary judgment, holding that the officers were not entitled to qualified immunity. The court found that, viewing the facts in the light most favorable to Setchfield, the officers used unreasonable force against a non-threatening, non-resisting individual. Additionally, the court determined that the officers lacked probable cause or arguable probable cause to arrest Setchfield for interfering with police duties or resisting arrest. The court concluded that the officers’ actions violated clearly established constitutional rights, thus denying them qualified immunity. View "Setchfield v. Ronald" on Justia Law

Eddie Humes was arrested on October 19, 2017, and booked into the White County Detention Center. The next day, he was bitten by a spider, causing his hand and arm to swell significantly. Over three days, Humes repeatedly asked Lieutenant Misty Jones and Deputy Stephanie Gray for medical help, showing them his worsening condition. Despite their assurances, they took no action. By October 25, Humes's hand and arm had swollen to the size of a small watermelon and were oozing pus. He filed a grievance and was taken to the emergency room, where he was diagnosed with a staph infection and treated. The next day, he developed a high fever and was diagnosed with an abscess, requiring emergency surgery.Humes filed a civil-rights lawsuit against several defendants, including Jones and Gray, alleging deliberate indifference to his serious medical needs. The United States District Court for the Eastern District of Arkansas granted summary judgment to all defendants except Jones and Gray in their individual capacities, denying them qualified immunity. Jones and Gray appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity de novo. The court considered whether Jones and Gray violated a constitutional right and whether that right was clearly established. The court found that the district court correctly determined that a reasonable jury could find Jones and Gray were deliberately indifferent to Humes's serious medical needs, as they ignored his worsening condition. The court also held that the right to medical care for serious conditions was clearly established, referencing precedents like Hartsfield v. Colburn and Dadd v. Anoka County. Consequently, the Eighth Circuit affirmed the district court’s denial of qualified immunity and remanded the case for trial. View "Humes v. Jones" on Justia Law