Justia Civil Rights Opinion Summaries

T.W. was the subject of two involuntary commitment petitions filed by the State of Montana in August 2022. The first petition was based on reports that T.W. was suffering from severe psychosis, including paranoid delusions, hallucinations, suicidal ideations, and self-starvation, which rendered her unable to meet her basic needs and posed a threat to herself and others. At the jury trial for the first petition, T.W. waived her right to be present due to emotional distress and was permitted to observe the proceedings remotely with her video and audio off. The jury found that T.W. suffered from a mental disorder but did not require commitment, and the District Court dismissed the petition.Shortly after her release, T.W. experienced further mental health crises, including a 911 call and subsequent hospitalization, which led the State to file a second, nearly identical commitment petition. T.W. moved to dismiss the second petition, arguing it was barred by res judicata and collateral estoppel, as it relied on evidence similar to that presented in the first trial. The Montana Nineteenth Judicial District Court denied the motion, finding that the second petition was based on new events and that preclusion doctrines did not apply. At the second trial, T.W. again sought to waive her presence and requested to observe the proceedings remotely with her video and audio off, but the court required her to appear via two-way audio-video with both on, over her objection.The Supreme Court of the State of Montana held that the State’s second commitment petition was not barred by res judicata or collateral estoppel, as the issues and evidence were sufficiently distinct and the statutory scheme allows for subsequent petitions when new facts arise. However, the Court found that the District Court erred by compelling T.W.’s remote appearance over her valid waiver and objection, violating her statutory and constitutional rights. The Supreme Court affirmed in part and reversed in part, vacating the commitment order. View "In re T.W." on Justia Law

Amy Hadley’s home in South Bend, Indiana, was significantly damaged when law enforcement officers executed a search warrant in pursuit of a murder suspect they believed was inside her residence. The officers, acting on information that the suspect had accessed his Facebook account from Hadley’s IP address, obtained a warrant and forcefully entered the home, causing extensive property damage, including the use of tear gas and destruction of personal items. Hadley, who had no connection to the suspect, was denied compensation by both the City of South Bend and St. Joseph County for the $16,000 in damages.After her request for compensation was denied, Hadley filed suit in Indiana state court, seeking relief under 42 U.S.C. § 1983 for violations of her Fifth and Fourteenth Amendment rights, specifically invoking the Takings Clause. The case was removed to the United States District Court for the Northern District of Indiana, South Bend Division. The defendants moved to dismiss, arguing that Seventh Circuit precedent, particularly Johnson v. Manitowoc County, foreclosed her claim. The district court agreed and dismissed the complaint, finding that the Takings Clause did not entitle her to compensation for property damage resulting from the execution of a lawful search warrant.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that, under its precedent in Johnson v. Manitowoc County, the Fifth Amendment does not require the government to compensate property owners for damage caused by law enforcement executing a valid search warrant. The court declined to overrule Johnson and found that Hadley’s arguments did not warrant revisiting the established rule. View "Hadley v. City of South Bend" on Justia Law

Marian Hudak was charged with two federal hate crimes after separate assaults on two men in North Carolina. The first victim, J.D., was a Mexican-American neighbor whom Hudak had repeatedly harassed with racial slurs and threats, culminating in a physical attack. The second victim, J.S., was a Black man whom Hudak confronted in traffic, using racial epithets and threats, and physically attacked his vehicle before chasing him to his apartment complex and threatening further violence. Evidence showed Hudak possessed Nazi and Ku Klux Klan memorabilia and had a history of expressing racist views.The United States District Court for the Middle District of North Carolina presided over Hudak’s trial. The government presented evidence of Hudak’s racist motives, including testimony about his Nazi memorabilia and prior racist conduct. Hudak conceded intent to injure and intimidate but argued his actions were due to road rage and mental illness, not racial animus. The district court excluded expert testimony about Hudak’s mental illness, finding it unreliable and irrelevant under Federal Rule of Evidence 702 and the Insanity Defense Reform Act, since Hudak did not plead insanity. The court also admitted evidence of Nazi memorabilia after Hudak testified about his interest in military history, determining he had “opened the door” to its relevance.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The Fourth Circuit held that the district court properly excluded the mental health evidence and correctly admitted the Nazi memorabilia after Hudak’s own testimony. The court affirmed the jury’s verdict, holding that the government only needed to prove the victims’ race or national origin was a but-for cause of the assaults, and that Hudak received a fair trial. The judgment of the district court was affirmed. View "United States v. Hudak" on Justia Law

A black man was hired as the first black city manager of a Texas city and led several major development initiatives. His tenure became contentious, especially after two new city council members, who opposed his policies, were elected. The conflict allegedly took on a racial character, and the city manager reported race-based discrimination. Eventually, the city council voted to part ways with him “without cause,” entering into a separation agreement that included a severance payment and a non-disparagement clause. After his departure, some council members publicly criticized him and later persuaded the council to rescind the separation agreement, citing a legal opinion that it was invalid. The city demanded the return of the severance payment, prompting the former city manager to sue, alleging racial discrimination under 42 U.S.C. § 1981 and breach of contract under Texas law.The United States District Court for the Western District of Texas granted summary judgment to the plaintiff on the validity of the separation agreement and denied the city’s motions for judgment as a matter of law. The case proceeded to trial, where a jury found for the plaintiff on both claims, awarding substantial damages. The district court entered judgment accordingly, later suggesting remittitur due to statutory limits on damages for breach of contract, which the plaintiff accepted.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the plaintiff failed to establish municipal liability for racial discrimination under § 1981 and § 1983 because he could not show that a majority of the city council acted with discriminatory intent, nor could he use the “cat’s paw” theory to impute animus under Monell. However, the court affirmed the district court’s judgment that the separation agreement was valid and enforceable, and that the city breached the contract by attempting to rescind it. The court reversed the judgment on the civil rights claim, affirmed the breach of contract ruling, and remanded for consideration of attorney’s fees. View "Jones v. City of Hutto" on Justia Law

A group of more than 80 former at-will employees of a nonprofit healthcare system in Washington were terminated after refusing to comply with a COVID-19 vaccination mandate issued by their employer, which was in response to an August 2021 proclamation by the state’s governor requiring healthcare workers to be vaccinated. The employees alleged that, at the time, only an “investigational” vaccine authorized for emergency use was available, and they claimed their rights were violated when they were penalized for refusing it. They also argued they were not adequately informed of their right to refuse the vaccine.The United States District Court for the Western District of Washington first dismissed all claims against the governor, then dismissed the federal claims against the healthcare system, and denied the employees’ motions for leave to amend and reconsideration. The district court also declined to exercise supplemental jurisdiction over the remaining state-law claims against the healthcare system.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 none of the employees’ statutory or non-constitutional claims, which were based on various federal statutes, regulations, agreements, and international treaties, alleged specific and definite rights enforceable under 42 U.S.C. § 1983. The court also found that the employees’ constitutional claims failed: the Fourteenth Amendment substantive due process claim was foreclosed by Jacobson v. Massachusetts and Health Freedom Defense Fund, Inc. v. Carvalho; the procedural due process claim failed because at-will employment is not a constitutionally protected property interest; and the equal protection claim failed because the mandate survived rational-basis review. The court further held that amendment of the federal claims would be futile and upheld the district court’s dismissal of the state law claims against the governor and its decision to decline supplemental jurisdiction over the state law claims against the healthcare system. View "Curtis v. Inslee" on Justia Law

A transgender inmate serving a lengthy sentence in the Connecticut prison system was diagnosed with gender dysphoria after several years of incarceration. The inmate requested various treatments, including stronger hormone therapy and a vaginoplasty, but was initially denied hormone therapy due to a prison policy that only allowed continuation, not initiation, of such treatment. After a policy change, the inmate received hormone therapy, mental health counseling, antidepressants, and some lifestyle accommodations. Despite these measures, the inmate continued to request additional treatments, including surgery, and expressed dissatisfaction with the care provided, alleging it was inadequate and not delivered by specialists in gender dysphoria.The United States District Court for the District of Connecticut reviewed the inmate’s claims of deliberate indifference to serious medical needs under the Eighth Amendment. The district court found that the corrections officials had deprived the inmate of adequate care by providing mental health treatment from unqualified providers, delaying and inadequately administering hormone therapy, and denying surgical intervention. The court denied the defendants’ motion for summary judgment on qualified immunity grounds, holding that the right to be free from deliberate indifference to serious medical needs was clearly established.On appeal, the United States Court of Appeals for the Second Circuit reversed the district court’s decision. The Second Circuit held that there is no clearly established constitutional right for inmates to receive specific treatments for gender dysphoria or to be treated by gender-dysphoria specialists. The court found that reasonable officials could disagree about the adequacy and legality of the care provided, which included talk therapy, antidepressants, and hormone therapy. The Second Circuit concluded that the defendants were entitled to qualified immunity and remanded the case with instructions to grant summary judgment in their favor. View "Clark v. Valletta" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

Ann Tierney Smith owned real property in West Virginia but failed to pay the assessed real estate taxes for 2016. As a result, the Mercer County Sheriff sold a tax lien on the property to Ed Boer. Boer sought a tax deed and provided the West Virginia State Auditor’s Office with a list of individuals to be notified about the right to redeem the property, including Smith. However, Boer did not include Smith’s current mailing address, which was available in county records. Notices sent by mail were returned as undeliverable, and attempts at personal service were unsuccessful, leading to notices being posted at the property and other addresses. After the redemption deadline passed, G. Russell Rollyson, Jr., an employee of the State Auditor’s Office, issued a tax deed to Boer. Smith learned of the deed in late 2020.Smith, and later her estate representatives, sued Rollyson and Boer under 42 U.S.C. § 1983, alleging deprivation of property without due process. The United States District Court for the Southern District of West Virginia granted summary judgment to Rollyson, finding him entitled to qualified immunity. The court determined that while Rollyson could have directed Boer to search county records for Smith’s address after the mailed notices were returned, the duty to do so was not clearly established at the time. The estate representatives appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment and qualified immunity rulings de novo. The Fourth Circuit held that it was not clearly established on April 1, 2019, that Rollyson was required to have Boer search county records anew for Smith’s address after the mailed notices were returned. The court found that existing precedent did not prescribe a specific follow-up measure and that Rollyson’s actions did not violate clearly established law. The judgment of the district court was affirmed. View "Ann deWet v. G. Russell Rollyson, Jr." on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

A county public guardian filed a petition in February 2023 to establish a conservatorship over an individual, A.H., under the Lanterman-Petris-Short (LPS) Act, alleging grave disability due to mental disorder. The trial court imposed a temporary conservatorship, which was extended as A.H. demanded a trial. However, the trial did not begin within the statutory 10-day period and was repeatedly continued, often due to court and counsel unavailability. While the first petition was still pending and as the initial temporary conservatorship was expiring, the public guardian filed a second petition and obtained a new temporary conservatorship, further extending A.H.’s involuntary confinement. A.H. opposed the continuances and requested dismissal of both petitions, but the court denied these requests. The first petition was eventually dismissed at the public guardian’s request, and trial on the second petition began about ten weeks after the statutory deadline. In January 2024, the court found A.H. gravely disabled and ordered a one-year conservatorship, which was not renewed after expiration.The Superior Court of Contra Costa County presided over the initial proceedings, including the imposition of temporary conservatorships, the granting of continuances, and the eventual trial and conservatorship order. A.H. appealed, arguing that statutory amendments required dismissal for untimely trial, that the court abused its discretion in granting continuances, and that the delays violated his due process rights.The California Court of Appeal, First Appellate District, Division Five, held that the statutory amendment to section 5350, subdivision (d)(2), does not mandate dismissal for untimely trial but gives the court discretion. The court found no reversible error in the continuances or denial of dismissal under the statute. However, the appellate court concluded that the cumulative 10-month delay in adjudicating the conservatorship petitions, none of which was attributable to A.H., violated his due process rights. The order of conservatorship was therefore reversed. View "In re Conservatorship of A.H." on Justia Law