Justia Civil Rights Opinion Summaries

David Hieber, who led Oakland County’s Equalization Department for nearly twenty years, was terminated after an employee reported him for creating a hostile work environment. Hieber sued Oakland County and his supervisor, Kyle Jen, under 42 U.S.C. § 1983 for deprivation of pretermination and post-termination due process, political-affiliation retaliation, and age discrimination. He also brought state-law claims for defamation and age discrimination. Oakland County and Jen moved for summary judgment, which the district court granted.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of Oakland County and Jen on all claims. Hieber appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment to Oakland County and Jen, in his official capacity, on Hieber’s pretermination due-process claim, finding that there was a genuine dispute of material fact about whether Hieber received a meaningful opportunity to respond to the charges against him. The court affirmed the district court’s judgment on Hieber’s post-termination due-process claim, political-affiliation retaliation claim, age discrimination claims, and defamation claim. The court also affirmed the district court’s grant of qualified immunity to Jen in his individual capacity on the due-process claims.The main holding of the Sixth Circuit was that Hieber’s pretermination due-process rights may have been violated, warranting further proceedings on that claim. The court found that the investigatory interview and the pretermination hearing may not have provided Hieber with adequate notice of the charges and a meaningful opportunity to respond. The court remanded the case for further proceedings consistent with its opinion. View "Hieber v. Oakland County, Mich." on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Kevin Niedzialek died after being restrained by Riverside County Sheriff’s Department deputies. The deputies responded to a 911 call reporting a man having a psychotic episode. Upon arrival, they found Niedzialek bleeding from the head and acting erratically. After he advanced towards one of the deputies, they used a taser to subdue him and handcuffed him while he was prone. Niedzialek continued to struggle but eventually became unresponsive. The deputies did not move him into a recovery position or perform CPR before paramedics arrived. Niedzialek died the next day.In the United States District Court for the Central District of California, a civil jury found that the deputies did not use excessive force under the Fourth Amendment but acted negligently under California law. The jury awarded $1.5 million to Niedzialek’s successor-in-interest, Tracy Alves. The defendants moved for judgment as a matter of law, arguing that the jury’s mixed verdicts were irreconcilable because the legal standard for reasonableness was the same for both claims. The district court denied the motion, stating that California’s negligence standard is broader than the Fourth Amendment’s reasonableness standard.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the jury’s verdicts were reconcilable because California’s “reasonable care” standard considers the totality of circumstances more broadly than the Fourth Amendment’s reasonableness standard. The jury could have found that the deputies did not use excessive force but still breached their duty of care by failing to monitor Niedzialek’s condition or place him in a recovery position. The court concluded that it was possible to reconcile the jury’s verdicts based on the evidence and theories presented at trial. View "Alves v. Riverside County" on Justia Law

Kenya Watkins, a Black woman, was employed by Genesh, Inc., d/b/a Burger King, from August 2014 to August 2015. She alleged that her manager verbally, physically, and sexually harassed her, including forcing her into a freezer, groping her, simulating sex with her, and stating she would not be promoted unless she had sex with him. Watkins filed an employment discrimination charge with the Kansas Human Rights Commission and the EEOC in early 2016. In December 2018, she alleged that Genesh admonished her then-employer, Church’s Chicken, for hiring her, leading to a second EEOC charge in 2019.In August 2019, Watkins sued Genesh in the United States District Court for the District of Kansas under 42 U.S.C. § 1981 for race discrimination. The district court dismissed her complaint, finding her allegations did not plausibly support racial harassment. The court noted that Watkins had pending EEOC charges and could file her Title VII claims once the EEOC proceedings concluded. In July 2021, the EEOC issued a right-to-sue letter for her 2019 charge, which Watkins did not pursue. In April 2022, the EEOC issued a right-to-sue letter for her 2016 charge, leading Watkins to file a second lawsuit in July 2022, raising claims under Title VII and other statutes.The United States District Court for the District of Kansas dismissed Watkins’s 2022 complaint as untimely. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the dismissal on claim preclusion grounds. The court held that Watkins’s Title VII claims were precluded by the final judgment in her 2019 lawsuit, as both suits arose from the same employment relationship. The court reaffirmed that the absence of a right-to-sue letter did not deprive Watkins of a full and fair opportunity to litigate her Title VII claims in the initial suit. View "Watkins v. Genesh" on Justia Law

Clifton White, the plaintiff, claimed that officials from the New Mexico Corrections Department unlawfully detained him beyond his release date. White argued that his sentence for violating probation was wrongfully entered and that he informed the prison officials of this error. Despite acknowledging the potential mistake, the officials continued to detain him based on a facially valid court order.The United States District Court for the District of New Mexico reviewed the case and denied the prison officials' motion to dismiss, which was based on qualified immunity. The district court concluded that it was clearly established law that prison officials violate constitutional rights when they continue to imprison individuals without a lawful basis or are deliberately indifferent to such a prospect.The United States Court of Appeals for the Tenth Circuit reviewed the case and reversed the district court's decision. The Tenth Circuit held that the prison officials were entitled to qualified immunity. The court found that no controlling Tenth Circuit law clearly established that prison officials act unlawfully when they rely on a facially valid judicial sentencing order, even if they believe the order was made in error. The court emphasized that prison officials are not required to ignore or correct a judicial sentencing order if they suspect it is flawed. The proper recourse for a defendant who disagrees with a judicial order is to appeal through the state or federal judicial process. Thus, the Tenth Circuit concluded that the law was not clearly established that the prison officials' conduct in this case was unconstitutional. View "White v. Lucero" on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

In July 2019, Indiana Department of Child Services (DCS) workers encountered a two-month-old infant, L.M., with a severe skull fracture and extensive brain damage. The infant's parents, Erika and Brian Mabes, had taken him to the emergency room after finding him unresponsive. This led to child abuse and custody proceedings against the Mabeses. They eventually regained custody and sued nine DCS workers and a consultant doctor, alleging violations of their Fourth and Fourteenth Amendment rights under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana denied the defendants' motions for summary judgment, finding unresolved factual disputes that precluded their requests for qualified immunity. The defendants appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court reversed the district court's decision, granting qualified immunity to all defendants. The court found that the DCS workers and the consultant doctor acted reasonably under the circumstances and did not violate clearly established constitutional rights. The court emphasized the urgency and severity of the situation faced by the DCS workers and the consultant doctor, concluding that their actions were lawful and reasonable. The court also noted that the plaintiffs failed to provide evidence that the defendants acted with intent to misrepresent facts or ignored exculpatory evidence. The court remanded the case for entry of judgment in favor of the defendants. View "Mabes v McFeeley" on Justia Law

Mark Eugene Ricks, a Texas state prisoner, filed a pro se lawsuit under 42 U.S.C. § 1983 against employees of the University of Texas Medical Branch (UTMB), alleging violations of his Eighth Amendment rights. Ricks claimed that he was denied treatment for chronic hepatitis C virus (HCV) based on nonmedical reasons and that the TDCJ HCV Policy was the driving force behind this unconstitutional denial of treatment. He sought injunctive and declaratory relief, as well as damages.The United States District Court for the Southern District of Texas granted the defendants' motion to dismiss Ricks's complaint for failure to state a claim, concluding that his allegations did not support a claim for deliberate indifference. The district court also denied Ricks's motion for appointment of counsel. Ricks filed a timely appeal, and the district court denied him leave to proceed in forma pauperis (IFP) on appeal, certifying that any appeal would not be taken in good faith.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and found that the district court erred in dismissing Ricks's complaint without allowing him an opportunity to amend his pleadings. The appellate court held that Ricks's allegations, when liberally construed, could potentially raise a viable claim of deliberate indifference. The court also found that the district court abused its discretion in denying Ricks's motion for appointment of counsel without considering the relevant factors set out in Ulmer v. Chancellor.The Fifth Circuit vacated the district court's orders granting the motion to dismiss and denying the appointment of counsel. The case was remanded with instructions for the district court to allow Ricks to amend his pleadings and to appoint counsel to represent him. View "Ricks v. Khan" on Justia Law

Jeremy Mooney, a former deputy in the Pike County Sheriff’s Office, was convicted of two counts of depriving an inmate, Thomas Friend, of his civil rights under color of law, in violation of 18 U.S.C. § 242. The incidents occurred on November 17-18, 2019, when Mooney pepper sprayed and punched Friend multiple times while Friend was restrained in a chair. Surveillance footage captured these events. Mooney claimed his actions were in response to Friend spitting on him and that he was instructed by his supervisor to use pepper spray.The United States District Court for the Southern District of Ohio denied Mooney’s motion to dismiss the indictment, which argued that the government destroyed exculpatory video evidence in bad faith. The court found no bad faith or exculpatory value in the lost footage. At trial, the jury found Mooney guilty on both counts. The court also excluded evidence of Friend’s Hepatitis C, ruling it irrelevant and potentially prejudicial. Mooney was sentenced to 100 months in prison, with an enhancement for obstruction of justice based on allegedly false trial testimony.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Mooney’s conviction, finding sufficient evidence that Mooney acted willfully to deprive Friend of his constitutional rights. The court also upheld the district court’s evidentiary rulings, including the exclusion of the Hepatitis C evidence and the admission of testimony from Deputy Jonathan Chandler about police training.However, the Sixth Circuit vacated Mooney’s sentence and remanded the case for further proceedings regarding the obstruction of justice enhancement. The court found that the district court failed to make specific findings necessary to establish perjury, as required for the enhancement. The case was sent back to the district court to either resentence Mooney or make the required factual findings. View "United States v. Mooney" on Justia Law

Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law