Justia Civil Rights Opinion Summaries

The case involves plaintiffs Tabatha Washington and Donte Howard who were charged with first-degree murder. They were detained for over a year before being acquitted. They then filed a suit against the City of Chicago and three police detectives, alleging unlawful pretrial detention under the Fourth Amendment and malicious prosecution under Illinois law. The district court granted summary judgment in favor of the defendants.Previously, the Circuit Court of Cook County had found probable cause to detain both plaintiffs without bail. A few weeks later, a grand jury indicted them on charges of first-degree murder, including a felony-murder theory premised on felony mob action. The plaintiffs argued that the detectives deliberately misled judges and the grand jury to secure these determinations of probable cause.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that even if the detectives' alleged misrepresentations and omissions were accepted as true, the prosecutors' independent fact-gathering and the remaining undisputed evidence still supported probable cause to detain the plaintiffs. Therefore, the judicial determinations of probable cause were presumed to be valid, and the pretrial detention of the plaintiffs did not violate the Fourth Amendment. The court also held that the plaintiffs' malicious prosecution claims failed for the same reason. View "Washington v. City of Chicago" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction. View "Chaney-Snell v. Young" on Justia Law

In 2018, Maryland State Trooper Kevin Caraballo used force while arresting 15-year-old Cameron Lewis. Lewis sued Caraballo for excessive force and battery. Caraballo sought summary judgment, arguing he was entitled to qualified and statutory immunity. The district court denied his motion, leading to this appeal.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that there were disputes of material fact that precluded summary judgment. Specifically, a reasonable jury could find that Caraballo struck Lewis when the teenager did not pose a threat, was not actively resistant, and was subdued. The court held that Lewis’s constitutional right to be free from excessive force in the form of head strikes was clearly established at the time of his arrest. Furthermore, the court held that there was a genuine dispute of material fact as to whether Caraballo’s actions amounted to gross negligence or malice, precluding summary judgment in his favor on his statutory immunity defense. View "Lewis v. Caraballo" on Justia Law

The case involves the family of Joseph Perez, who died after law enforcement officers, under the direction of a paramedic, used their body weight to restrain him while he was prone to secure him to a backboard for hospital transport. The family sued the City and County of Fresno, individual law enforcement officers, and the paramedic, alleging violations of the Fourth and Fourteenth Amendments and municipal liability under Monell v. Department of Social Services of the City of New York.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants, finding that the officers and paramedic were entitled to qualified immunity. The court held that at the time of Perez's death in 2017, the law did not clearly establish that the officers' actions would be unconstitutional. The court also found that the paramedic was entitled to qualified immunity because the law did not clearly establish that a paramedic acting in a medical capacity to restrain a person for medical transport could be held liable for a constitutional violation. The court dismissed the plaintiffs' Monell claims, finding insufficient evidence that the City and County were deliberately indifferent to their duty to properly train their officers.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the law did not clearly establish, nor was it otherwise obvious, that the officers' actions, directed by medical personnel, would violate Perez's constitutional rights. The court also held that the paramedic was acting in a medical capacity during the incident, and the law did not clearly establish that medical personnel are liable for constitutional torts for actions taken to provide medical care or medical transport. The court concluded that the plaintiffs produced insufficient evidence to support their municipal liability claim against the City and the County based on a failure-to-train theory. View "PEREZ V. CITY OF FRESNO" on Justia Law

The case revolves around Lori Vogt, a deputy court clerk, who was fired by Lisa Rodebush, the McIntosh County Court Clerk, for not publicly supporting Rodebush's reelection campaign. Vogt had worked with Rodebush for thirteen years and had supported her in the past. However, during the 2020 reelection campaign, Vogt's best friend, a former employee of the County Court Clerk’s Office, ran against Rodebush. Vogt decided to support Rodebush privately but not publicly to maintain her friendship with Rodebush's opponent. Despite this, Vogt campaigned for Rodebush and provided advice for her campaign. Rodebush, however, was not satisfied with Vogt's level of support and eventually fired her after winning the election. Vogt then filed a lawsuit alleging that Rodebush violated her First Amendment rights of free speech and political affiliation.The United States District Court for the Eastern District of Oklahoma denied Rodebush's motion for summary judgment, where she asserted qualified immunity. Rodebush appealed this decision.The United States Court of Appeals for the Tenth Circuit affirmed the lower court's decision. The court found that a public official cannot condition a subordinate’s employment on her political beliefs, affiliation, or non-affiliation, unless the government has a vital interest in doing so. The court held that Rodebush violated Vogt's First Amendment right to political affiliation by firing her for not publicly supporting her reelection campaign. The court also found that Vogt's right was clearly established at the time of the violation, thus defeating Rodebush's claim of qualified immunity. View "Vogt v. McIntosh County Board" on Justia Law

The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief. View "Corrigan v. Boston University" on Justia Law

Two campus police officers at Shepherd University, Jay Longerbeam and Donald Buracker, were terminated due to alleged "misconduct" and "unprofessionalism" during two incidents in 2018 and 2019. The officers claimed that their termination was a result of age and disability discrimination, retaliation under the West Virginia Human Rights Act (HRA), violation of the West Virginia Whistle-blower Law, and common law wrongful discharge. The Circuit Court of Jefferson County granted summary judgment against both officers on all claims.The officers appealed the decision, arguing that the lower court erred in finding no genuine issues of material fact and in its handling of the burden-shifting paradigm. They contended that their conduct during the incidents was legally proper and that the court failed to consider intervening acts of reprisal which were more temporally proximate to their protected activity than their discharge.The Supreme Court of Appeals of West Virginia found that the lower court erred in its handling of the "temporal proximity" issue and the burden-shifting paradigm. The court also found that the officers offered more than sufficient evidence upon which a rational trier of fact could find retaliatory motivation. Therefore, the court reversed the lower court's grant of summary judgment as to the officers’ whistle-blower and Harless claims and remanded for further proceedings. However, the court affirmed the lower court's grant of summary judgment as to Buracker’s HRA disability discrimination claim, finding his evidence insufficient to create an inference of disability discrimination. View "Jay Longerbeam v. Shepherd University" on Justia Law

Two members of the Lipan-Apache Native American Church, Gary Perez and Matilde Torres, sued the City of San Antonio over its development plan for Brackenridge Park. They claimed that the plan, which involved tree removal and bird deterrence measures, would prevent them from performing religious ceremonies in the park, violating their rights under the First Amendment, the Texas Religious Freedom Restoration Act, and the Texas Constitution. They sought an injunction requiring the city to grant them access to the park for worship, minimize tree removal, and allow cormorants to nest.The district court granted them access to the park for religious ceremonies but declined to enjoin the city's planned tree removal and bird deterrence measures. Both parties appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the city's development plan did not substantially burden the appellants' religious exercise. The court also found that the city's plan served two compelling interests: public health and safety, and compliance with federal law. The court concluded that the city's tree removal and bird deterrence plans were the least restrictive means to advance these interests. Therefore, the appellants failed to show a likelihood of success on the merits of their claims. The court also denied the appellants' emergency motion for an injunction pending appeal. View "Perez v. City of San Antonio" on Justia Law