Justia Civil Rights Opinion Summaries

A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law

This case involves a minor, Kodi Gaines, who was injured during a police standoff that resulted in the death of his mother, Korryn Gaines. The standoff occurred when Baltimore County police officers attempted to serve arrest warrants on Ms. Gaines and her boyfriend at her apartment. When officers entered the apartment, they found Ms. Gaines seated on the floor with a shotgun. A six-hour standoff ensued, during which Ms. Gaines acted erratically, sometimes negotiating with officers, at other times threatening them. Corporal Royce Ruby, a member of the SWAT team, fired a shot at Ms. Gaines when he observed her raise her shotgun into a firing position. The shot passed through Ms. Gaines, ricocheted off a refrigerator, and hit Kodi.The case was initially heard in the Circuit Court for Baltimore County, which found in favor of the defendants, Baltimore County and Corporal Ruby. The court ruled that the evidence at trial could not sustain a verdict on Kodi’s claim of violation of his right to substantive due process under the Fourteenth Amendment. The Appellate Court affirmed the lower court's decision on two grounds: that Kodi had waived his claim by not pursuing it during the first round of appellate proceedings, and that qualified immunity barred Kodi’s claim.The case was then heard by the Supreme Court of Maryland. The court disagreed with the Appellate Court’s decision on waiver but agreed that under the standard established by the United States Supreme Court, qualified immunity precludes Kodi’s claim. Therefore, the court affirmed the decision of the Appellate Court. View "Cunningham v. Baltimore County" on Justia Law

The case involves Xingfei Luo, who twice sought a restraining order against Professor Eugene Volokh under the Code of Civil Procedure section 527.6. Luo wanted to prevent Volokh from identifying her in his writings. After the trial court dismissed the first petition, Luo moved to "strike" exhibits she filed in support of that failed petition. The trial court denied that motion and granted Volokh’s motion to preclude her from proceeding pseudonymously in that case. Luo appealed these orders. The second case involves Luo’s second petition for a restraining order where the trial court granted Volokh’s anti-SLAPP (strategic lawsuit against public participation) motion and dismissed Luo’s second petition. Luo also appealed from a subsequent order granting Volokh’s motion to preclude Luo from proceeding pseudonymously in her second petition.The Superior Court of Los Angeles County denied Luo's first petition for a restraining order, concluding that the alleged harmful conduct was "likely protected free speech." The court also found that the alleged facts did not comprise acts of violence, threats of violence, or a course of conduct that seriously alarmed, annoyed, or harassed the petitioner and caused substantial emotional distress. Luo did not appeal from the order discharging that petition. However, Luo filed an "ex parte application for an order to strike and withdraw improperly filed exhibits." The trial court denied Luo’s ex parte motion to “strike” her exhibits because Luo had not completed the proper forms for submitting an ex parte motion. Luo filed a new motion and Volokh again opposed it, and also filed a separate motion to preclude Luo from proceeding pseudonymously in that case. The trial court denied Luo’s motion to strike her exhibits and granted Volokh’s motion to preclude Luo from proceeding pseudonymously.In the Court of Appeal of the State of California Second Appellate District Division One, the court affirmed the order granting Volokh’s anti-SLAPP motion and dismissing Luo’s second petition. The court dismissed Luo’s appeals as to the trial court’s ruling on her motion to strike exhibits in her first petition and the court’s granting of Volokh’s motions in both cases to use her actual name. The court concluded that these rulings are based on nonappealable orders. View "Luo v. Volokh" on Justia Law

The case involves Smith & Wesson Brands, Inc., Smith & Wesson Sales Company, and Smith & Wesson Inc. (collectively, “Smith & Wesson”) and the Attorney General of the State of New Jersey and the New Jersey Division of Consumer Affairs. The New Jersey Attorney General issued a subpoena to Smith & Wesson under the New Jersey Consumer Fraud Act, seeking documents related to the company's advertising practices. Smith & Wesson filed a federal lawsuit to enjoin enforcement of the subpoena, alleging it violated various constitutional provisions. The New Jersey Attorney General then filed a subpoena enforcement action in state court. The state court rejected Smith & Wesson’s objections and ordered the company to comply with the subpoena.The state court proceedings concluded before the federal case, with the state court ordering Smith & Wesson to comply with the subpoena. The federal court then dismissed Smith & Wesson’s civil rights action on claim preclusion grounds, giving preclusive effect to the state court’s order. The state appellate court later affirmed the state court judgment. Smith & Wesson appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court should not have given preclusive effect to the state court order.The United States Court of Appeals for the Third Circuit affirmed the District Court’s order. The court found that all elements of New Jersey’s claim preclusion test were satisfied. The court also rejected Smith & Wesson’s argument that it had reserved its right to litigate in federal court, finding that such reservation was unavailable in this case. The court emphasized that litigants get one opportunity to make their arguments, not two, and they cannot file a federal lawsuit to hedge against a potentially unfavorable state ruling. View "Smith & Wesson Brands Inc. v. Attorney General of the State of New Jersey" on Justia Law

The case revolves around the death of Daryl Clinton, who died in the Oklahoma County Jail four days after being booked. Clinton was arrested for driving under the influence and was evaluated at a hospital before being discharged and sent to jail. Despite reporting several health issues, including an inability to move his arms or upper body, Clinton's complaints were largely dismissed by medical personnel. He was found unresponsive in his cell and later pronounced dead at the hospital. The cause of death was listed as blunt force trauma to the cervical spine.The case was initially heard in the United States District Court for the Western District of Oklahoma. Equlla M. Brothers, the personal representative of Clinton's estate, filed a lawsuit against Tommie Johnson III, the Oklahoma County Sheriff, alleging that Johnson was deliberately indifferent to Clinton's serious medical needs, violating his Fourteenth Amendment rights. The district court denied Johnson's motion for summary judgment, and the case proceeded to trial. The jury returned a verdict in favor of Johnson.Upon appeal to the United States Court of Appeals for the Tenth Circuit, Brothers argued that the evidence at trial was insufficient to support the verdict, the jury instructions misled the jury on the systemic failure claim, and the district court erred in denying her motion to contact the jury. However, the appellate court found that Brothers had waived her challenge to the sufficiency of the evidence by failing to raise a Rule 50(a) or 50(b) motion or argue plain error. The court also found that Brothers' objections to the jury instructions were waived as she had not distinctly stated her objections and grounds for them at the district court. Lastly, the court found no abuse of discretion by the district court in denying Brothers' motion to contact the jury. The judgment of the district court was affirmed. View "Brothers v. Johnson" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

This case arose from a raid by U.S. Immigration and Customs Enforcement (ICE) at Abel Ramirez-Peñaloza’s family home in Heber City, Utah. After Mr. Ramirez-Peñaloza was indicted for unlawful entry into the U.S., ICE officials attempted to arrest him at his home. During two searches of his home, officials detained and questioned his family members. The plaintiffs, some of Mr. Ramirez-Peñaloza’s family members who were detained during the searches, filed claims against the U.S. and the agents alleging Fourth Amendment and state law violations.The district court dismissed most of the plaintiffs’ claims, but allowed three claims to go to trial, where a jury returned a verdict in favor of the officers. The plaintiffs appealed the district court’s grant of summary judgment in favor of the officers on the excessive use of force and false arrest claims.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the dismissed claims were barred by the Federal Tort Claims Act’s (FTCA) judgment bar, which precludes suits against federal employees after the entry of final judgment on a claim against the U.S. for an analogous cause of action. Since the district court entered final judgment in favor of the U.S. on the plaintiffs’ analogous FTCA claims, the claims against the individual defendants were barred. View "Ramirez v. Reddish" on Justia Law

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

Randal Hall filed a civil rights case against Officer Travis Trochesset and the City of League City, Texas, alleging constitutional violations following his arrest for interference with a police investigation. The incident began when Hall's wife was involved in a minor car accident. The other driver reported the incident as a hit-and-run, leading to an investigation by Officer Trochesset. When Trochesset arrived at the Halls' home to gather information, Hall, who was not present, instructed his wife over the phone not to provide the requested information to Trochesset. As a result, Trochesset obtained an arrest warrant for Hall for interfering with public duties.The United States District Court for the Southern District of Texas dismissed Hall's suit, ruling in favor of Trochesset and the City of League City. Hall appealed the decision.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that probable cause existed for Hall's arrest, as Hall had interfered with Trochesset's investigation. The court also applied the independent intermediary doctrine, which states that an officer who presents all relevant facts to an impartial intermediary (in this case, a justice of the peace) is not liable if the intermediary's independent decision leads to an arrest. The court found that Trochesset had not withheld any relevant information from the justice of the peace. Furthermore, the court ruled that Hall failed to establish that Trochesset violated the Fourth or Fourteenth Amendments. The court also dismissed Hall's claim against the City of League City, as there was no constitutional violation by Trochesset, and Hall failed to identify an official policy or custom that led to the alleged violation. The court rejected Hall's argument to discontinue the application of the qualified immunity doctrine, stating that it is bound by the Fifth Circuit rule of orderliness to follow established precedent. View "Hall v. Trochessett" on Justia Law

Three Black citizens of Caddo Parish, Louisiana, Darryl Carter, Diane Johnson, and Theresa Hawthorne, were struck from jury duty during voir dire in 2015. They alleged that their removal violated the Fourteenth Amendment's Equal Protection Clause, claiming that the Caddo Parish prosecutors peremptorily struck them based on their race. The plaintiffs joined an ongoing litigation challenging the Caddo District Attorney's alleged custom of racially biased peremptory strikes. They sued District Attorney James E. Stewart, in his official capacity, under 42 U.S.C. § 1983.The district court dismissed all plaintiffs except Carter, Johnson, and Hawthorne. The District Attorney then moved for summary judgment, which the district court granted. The plaintiffs appealed this decision, leading to a de novo review by the United States Court of Appeals for the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the plaintiffs could not establish a predicate constitutional violation, which is necessary for a Monell claim. The prosecutors had provided race-neutral explanations for each plaintiff's dismissal. For Carter, the prosecutor noted his expressed bias against evidence from Shreveport. For Johnson, the prosecutor highlighted her potential bias against the police department due to a family member's felony conviction. For Hawthorne, the prosecutor found her colloquies with defense counsel problematic due to her preconceived notions about firearm possession. The court found these explanations sufficient and not merely pretexts for race-based dismissals. The court also noted that the plaintiffs' statistical evidence did not prove discriminatory motive. Without an underlying Equal Protection claim, the plaintiffs' Monell claim failed. View "Pipkins v. Stewart" on Justia Law