Justia Civil Rights Opinion Summaries

A plaintiff alleged that, between 1965 and 1969, while he was a young child attending an elementary school in a California school district, he was repeatedly sexually assaulted by the school’s principal. The complaint stated that school staff and faculty were aware or suspected the abuse, and that similar abuse occurred to other students. The plaintiff claimed ongoing psychological and emotional harm as a result. He brought four negligence-based causes of action against the school district, asserting that he was not required to present a government tort claim before filing suit due to statutory changes exempting such claims.The Superior Court of Merced County sustained the school district’s demurrer without leave to amend, dismissing the complaint. The court found that the plaintiff’s failure to comply with the Government Claims Act’s claim presentation requirement was fatal to his case, and concluded that legislative changes extending the statute of limitations for childhood sexual assault did not alter the deadline for filing a claim against a public entity.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed whether Assembly Bill No. 218’s retroactive waiver of the Government Claims Act’s claim presentation requirement for claims under Code of Civil Procedure section 340.1 violated the California Constitution’s gift clause. The appellate court held that the retroactive waiver did not create a new liability or cause of action, but merely removed a procedural barrier to suit. The court further found that the legislative purpose of aiding victims of childhood sexual assault served a valid public purpose and did not constitute an unconstitutional gift of public funds. The judgment of dismissal was reversed and the case remanded for further proceedings. View "Doe R.L. v. Merced City School District" on Justia Law

Two police officers responded to a domestic battery call at a residential home. While one officer spoke with a woman at the door, the other saw a person flee over a backyard wall into a neighboring yard. Instead of immediately pursuing, the officer returned to his car, called for backup, and drove to establish a perimeter. Eighteen minutes later, a K-9 unit arrived and began searching within the perimeter. The K-9 alerted toward the plaintiffs’ backyard, which was locked and posted with a “Beware of Dog” sign. Without a warrant or consent, officers entered the backyard. The plaintiffs’ three dogs were roused, and two of them attacked the police K-9. One officer shot and killed the two dogs. The suspect was never found.The United States District Court for the District of Nevada granted summary judgment to the officers and the City of North Las Vegas, finding the officers’ entry justified under the “hot pursuit” exception to the warrant requirement and the use of force against the dogs reasonable. The court also granted summary judgment to the City on the plaintiffs’ Monell claims, and declined to exercise supplemental jurisdiction over the state law claim after dismissing the federal claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the “hot pursuit” exception did not apply because the officers lost track of the suspect for eighteen minutes, breaking the continuity required for exigent circumstances. Therefore, the officers were not entitled to qualified immunity for the warrantless search. However, the court affirmed qualified immunity for the officer’s use of force against the dogs, finding no clearly established law prohibiting his actions in the spontaneous circumstances. The court also affirmed summary judgment for the City on the Monell claims, finding insufficient evidence of a policy or deliberate indifference. The case was remanded for further proceedings. The disposition was affirmed in part, reversed in part, and remanded. View "JONES V. CITY OF NORTH LAS VEGAS" on Justia Law

A plaintiff who lost his job during the COVID-19 pandemic applied for and received regular unemployment benefits from the Washington State Employment Security Department (ESD). After exhausting those benefits, he applied for and received additional benefits under the federally funded Pandemic Emergency Unemployment Compensation (PEUC) program, created by the CARES Act. Following an audit, ESD redetermined his eligibility, reduced his weekly benefit, and assessed overpayments, sending him multiple, confusing notices with inconsistent information and deadlines. While the plaintiff appealed, ESD began offsetting his ongoing PEUC benefits to recover the alleged overpayments.An administrative law judge later found that ESD’s notices failed to provide adequate explanation or legal basis for the benefit reductions and overpayment assessments, and ordered ESD to issue a new redetermination. ESD reimbursed the plaintiff for the offset amounts, but its system continued to show a balance owed. The plaintiff, on behalf of himself and similarly situated individuals, filed a putative class action in the United States District Court for the Western District of Washington, alleging deprivation of property without due process under the Fourteenth Amendment and the Social Security Act. The district court held that while the plaintiff had a property interest in regular unemployment benefits, he did not have a constitutionally protected property interest in PEUC benefits, because state participation in the PEUC program was voluntary and could be terminated at any time.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s ruling. The Ninth Circuit held that the CARES Act’s PEUC program, once a state opted in, created a constitutionally protected property interest in PEUC benefits for eligible individuals. The Act’s mandatory language and objective eligibility criteria significantly constrained state discretion, giving rise to legitimate claims of entitlement. The case was remanded for further proceedings. View "STERLING V. FEEK" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

Nine inmates at a Connecticut correctional facility challenged their confinement in a unit known as Q-Pod, which is used to transition inmates from more restrictive housing back to the general population. The plaintiffs alleged that Q-Pod imposed harsher conditions than the general population, including extended periods of isolation, unsanitary conditions due to toilet restrictions, lack of access to medical care and counseling, limited vocational and educational opportunities, and restricted religious services. Two plaintiffs specifically claimed they were denied access to Native American religious practices, such as sweat lodge ceremonies and smudging, which are congregate religious activities.The United States District Court for the District of Connecticut granted summary judgment to the prison officials on the basis of qualified immunity for all federal claims, finding that the conditions in Q-Pod did not rise to the level of constitutional violations under the Eighth or Fourteenth Amendments, and that the officials were entitled to qualified immunity on the First Amendment free exercise claims. The court also declined to exercise supplemental jurisdiction over the state-law claims and denied injunctive relief as moot. Plaintiffs’ motion for reconsideration was denied, and they appealed.The United States Court of Appeals for the Second Circuit affirmed the district court’s judgment as to the Eighth Amendment, procedural due process, and the free exercise claims of seven plaintiffs, holding that the conditions and restrictions in Q-Pod did not violate clearly established law. However, the Second Circuit reversed as to the free exercise claims of two plaintiffs who were denied participation in Native American congregate religious services, finding that the denial, without any penological justification, violated clearly established law. The court remanded with instructions to deny summary judgment on these claims and vacated the dismissal of the related state-law claims. View "Baltas v. Chapdelaine" on Justia Law

Michael McNeil, an incarcerated individual at Ely State Prison, was accused of smuggling drugs into the facility via the mail system. During his preliminary disciplinary hearing, McNeil requested access to the evidence against him, including the mail and a positive drug test result from the envelopes’ address labels, but his request was denied. At a subsequent formal hearing, a disciplinary committee found him guilty, resulting in the loss of statutory good time credits, canteen privileges, and a referral for criminal prosecution. After his appeals through the prison’s grievance process were denied, McNeil filed a lawsuit under 42 U.S.C. § 1983, alleging that prison officials violated his Fourteenth Amendment due process rights.The United States District Court for the District of Nevada reviewed cross-motions for summary judgment. The court partially granted McNeil’s motion, finding that his due process rights were violated when he was denied access to certain evidence, but identified a genuine dispute regarding other evidence requests. The court denied the defendants’ motion for summary judgment on qualified immunity, holding that it was clearly established that McNeil had a constitutional right to access the evidence against him. The order was entered on the civil docket on May 22, 2023.The United States Court of Appeals for the Ninth Circuit reviewed the case after the defendants filed a notice of appeal 150 days following the district court’s order. The Ninth Circuit held that 28 U.S.C. § 2107(a) requires a notice of appeal to be filed within 30 days after entry of an order denying qualified immunity. The court rejected the defendants’ argument that the Federal Rules of Civil and Appellate Procedure extended the appeal period to 180 days due to the absence of a separate judgment document. The Ninth Circuit concluded that the appeal was untimely and dismissed it for lack of jurisdiction. View "MCNEIL V. GITTERE" on Justia Law

A woman who receives a housing voucher due to her disability applied to rent an apartment in a complex owned by a property management company. The monthly rent for the unit was $1,590, and her voucher would have covered $1,464, leaving her responsible for $126 per month. Her only other income was $841 per month in supplemental security income. The property owner applied its standard policy, requiring all applicants to demonstrate monthly income at least 2.5 times the full rent, aggregating all sources of income, including voucher subsidies. The applicant’s combined income and voucher fell short of the $3,975 threshold, so her application was denied.After the Maryland Commission on Civil Rights found no probable cause for her discrimination claim, the applicant sued in the Circuit Court for Baltimore County, alleging that the owner’s minimum-income requirement constituted impermissible source-of-income discrimination under Maryland’s Housing Opportunities Made Equal (HOME) Act, which prohibits discrimination based on “source of income” in housing. The owner moved for summary judgment, arguing its policy was facially neutral and applied equally to all sources of income. The circuit court granted summary judgment to the owner, finding that the policy did not discriminate based on the source of income, only the amount.On appeal, the Supreme Court of Maryland reviewed the case. The Court agreed with the circuit court that the owner was entitled to summary judgment on the disparate treatment claim, as the policy was facially neutral and applied equally. However, the Supreme Court of Maryland held that the owner was not entitled to summary judgment on the disparate impact claim. The Court explained that a facially neutral policy may still violate the HOME Act if it disproportionately affects voucher holders without a legitimate business justification. The judgment of the circuit court was vacated and the case remanded for further proceedings. View "Hare v. David S. Brown Enterprises" on Justia Law

A pretrial detainee in the St. Tammany Parish Jail, who has had a prosthetic eye for decades, reported his chronic condition to jail medical staff upon intake. In June 2022, a jail doctor prescribed antibiotics and twice-weekly wound care for an infection in the detainee’s eye socket. Although the detainee was initially scheduled for wound care, he was not taken to his appointments, and his infection worsened over several weeks. The detainee filed multiple grievances, alleging that a deputy failed to escort him to medical care and that a refusal-of-treatment form was falsely completed without his knowledge or signature. After further investigation, jail officials determined that the medical records inaccurately reflected wound care visits, which were actually medication distributions, and ultimately found the detainee’s grievance substantiated.The detainee filed a pro se civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Louisiana, naming jail officials and medical staff as defendants. The district court, through a magistrate judge, granted a motion to dismiss for some defendants and summary judgment for others, entering final judgment against the detainee and dismissing his claims with prejudice. The court denied the detainee’s motions to compel discovery and to amend his complaint, and did not address some discovery requests before entering judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the magistrate judge committed plain error by treating a report and recommendation as a final judgment before it was formally adopted, thereby denying the detainee a full and fair opportunity for discovery. The appellate court reversed the grant of summary judgment for the doctor-defendants, affirmed the dismissal of claims against most jail officials, but found that dismissal should have been without prejudice to allow for amendment. The case was remanded for further proceedings consistent with these holdings. View "James v. Smith" on Justia Law

Police officers in Bella Vista, Arkansas, responded to a home shared by the Welters and Hutchins families after a suspected drug overdose, where they found pills, including fentanyl, in areas accessible to children. A week later, another overdose occurred at the same residence, resulting in a fatality while children were present. Months later, officers discovered traces of THC in the home’s trash, and a subsequent search revealed marijuana and drug paraphernalia throughout the house, including a still-smoking bong. During an interview, one parent admitted that adults regularly smoked marijuana in the home, though they tried to keep the children out of the room. Police notified the Arkansas Department of Human Services about possible child endangerment. Shortly after, Detective Wilson and other officers took the minor children for forensic interviews without a warrant, over the parents’ objections, and warned the parents they would be arrested if they interfered. The children were later returned to their parents.The United States District Court for the Western District of Arkansas granted summary judgment to Detective Wilson on the parents’ Fourth Amendment claims, finding she was entitled to qualified immunity. The court determined that the parents had not alleged a violation of their own Fourth Amendment rights and that the claims on behalf of the children did not overcome qualified immunity. The parents appealed, focusing solely on the Fourth Amendment claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that Detective Wilson was entitled to qualified immunity because, under the totality of the circumstances, a reasonable officer could have believed there was reasonable suspicion that the children were in danger. The court also declined to adopt a new standard requiring probable cause and exigent circumstances for such removals, noting that existing precedent did not clearly establish such a right. View "Welter v. Wilson" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law