Justia Civil Rights Opinion Summaries

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

During the COVID-19 pandemic, an employer instituted a company-wide vaccine mandate that applied to all employees, including those working remotely. Two remote employees requested religious exemptions from the vaccine requirement. One objected on the basis of her Christian beliefs regarding the use of fetal cell lines in vaccine development, while the other cited her conscience and faith, referencing Catholic teachings. Both exemption requests were denied, and the employees were subsequently terminated.After their terminations, the two employees initiated a lawsuit in the United States District Court for the District of Maryland. Their claims included religious discrimination under Title VII of the Civil Rights Act and two disability discrimination claims under the Americans with Disabilities Act (ADA): one for unlawful medical inquiry and one for being “regarded as” disabled due to their unvaccinated status. The district court dismissed all claims, concluding that the plaintiffs had not sufficiently pleaded that their objections were based on religious beliefs and finding that neither ADA theory was viable because vaccination status is not equivalent to a disability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs’ complaints plausibly alleged that their opposition to the vaccine mandate was an essential part of their religious faith and that their refusal to be vaccinated was connected to those beliefs. Therefore, the court found that the district court erred in dismissing the Title VII religious discrimination claims at the pleading stage. However, the Fourth Circuit affirmed the dismissal of both ADA claims, holding that an inquiry into vaccination status is not a disability-related inquiry and that being unvaccinated does not constitute a physical or mental impairment under the ADA. The case was affirmed in part, vacated in part, and remanded for further proceedings on the Title VII claims. View "Finn v. Humane Society of the United States" on Justia Law

David Ray Gunter, who had a mechanical heart valve and required daily anticoagulant medication (Coumadin), was arrested and detained at two North Carolina county jails. During his detention, Gunter did not consistently receive his prescribed medication, missing doses over several days due to failures by the contracted medical provider and jail staff. After his release, he suffered serious medical complications, including blood clots and subsequent surgeries. Gunter alleged these injuries were the result of inadequate medical care during his incarceration.The United States District Court for the Middle District of North Carolina granted summary judgment for defendants on Gunter’s constitutional claims under 42 U.S.C. § 1983, including deliberate indifference and Monell claims, finding insufficient evidence that jail officials or contracted medical providers acted with deliberate indifference or that county policies caused the deprivation. The district court also granted summary judgment to Southern Health Partners, Inc. (SHP) on the medical malpractice claim, finding that Gunter’s expert testimony did not establish a breach of the standard of care by SHP, and excluded expert evidence it found speculative. However, the district court found genuine disputes of fact regarding medical malpractice claims against two individual medical providers, but ultimately found no proximate cause. The district court denied Gunter’s motion to compel deposition of the defendants’ expert as untimely and granted a motion to strike a post-deposition declaration from Gunter’s expert.The United States Court of Appeals for the Fourth Circuit reversed the district court’s dismissal of Gunter’s deliberate indifference claim against the medical provider defendants, the Monell claim against the counties, and the medical malpractice claims against SHP and two medical providers, holding that genuine disputes of material fact remained. The appellate court also reversed the exclusion of certain expert testimony and the grant of the motion to strike, but affirmed the denial of the motion to compel. The case was remanded for further proceedings. View "Swink v. Southern Health Partners Inc." on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

Six residents of the Town of Newburgh sued the Town and its Town Board, alleging that the Board’s at-large electoral system unlawfully diluted the votes of Black and Hispanic residents, in violation of Section 17-206 of the New York Voting Rights Act (NYVRA). The plaintiffs argued that the method of electing all five Town Board members at-large prevented Black and Hispanic voters, who together made up about 40% of the population, from electing their preferred candidates or influencing election outcomes. They sought a court declaration that the at-large system violated the NYVRA and an injunction requiring the Town to implement a different electoral system.The Town of Newburgh moved for summary judgment, arguing that Section 17-206 was facially unconstitutional under the Equal Protection Clauses of the U.S. and New York Constitutions, and that its current election system complied with the NYVRA. The Supreme Court, Orange County, granted the Town’s motion, holding that the Town could challenge the statute because it allegedly could not comply with the NYVRA without violating equal protection, and declared the provision—and the entire NYVRA—unconstitutional. The Appellate Division reversed, holding that the Town lacked capacity to bring this challenge since it had not shown that compliance with the NYVRA would force it to violate equal protection, and that the Supreme Court erred in invalidating the statute.The New York Court of Appeals reviewed the case and held that the Town of Newburgh, as a political subdivision created by the State, could not bring a facial constitutional challenge to the NYVRA's vote-dilution provision. The court reaffirmed the longstanding rule that political subdivisions generally lack authority to challenge state laws unless a narrow exception applies, and found that no such exception was met here. The Appellate Division’s order was affirmed. View "Clarke v Town of Newburgh" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

A Concord police officer discovered her firearm missing from the station’s lockers in 2013. Investigation revealed that another officer, the plaintiff, had mistakenly taken the firearm while transporting a prisoner to a hospital. The plaintiff gave inconsistent accounts about when she realized the mistake, telling supervisors she noticed it at the station, while her partner reported she only realized it at the hospital. An internal affairs investigation found the plaintiff’s statements lacked credibility and concluded she had lied to colleagues and supervisors about the incident. The police chief sustained these findings, terminated her employment, and submitted her name for inclusion on the Exculpatory Evidence Schedule (EES), formerly known as the “Laurie List.”The plaintiff appealed her termination to the City of Concord’s Personnel Appeals Board, which upheld the decision, finding her lacked credibility. She then filed a complaint in the Superior Court alleging gender discrimination and wrongful termination, which was settled. The settlement required the City to remove documents related to the incident from her personnel file and maintain them in a separate investigative file, and to report her departure as a negotiated resignation.Years later, the plaintiff sued the City and the New Hampshire Department of Justice in Superior Court, seeking removal of her name from the EES under RSA 105:13-d. She argued the alleged misconduct was immaterial, the records were no longer in her personnel file, and her inclusion on the EES was unwarranted given the passage of time. The Superior Court granted summary judgment for the defendants.The Supreme Court of New Hampshire affirmed, holding that RSA 105:13-d governs EES inclusion and applies to “personnel information,” not just personnel files. The court found the plaintiff’s untruthfulness constituted potentially exculpatory evidence and that it was reasonably foreseeable her misconduct could be admissible to impeach her credibility if she were called as a witness in a future case. View "Doe v. Concord Police Department" on Justia Law

Two Lansing police officers responded to a 911 call reporting a domestic disturbance involving Stephen Romero. Although the initial caller, Stephen’s wife Ashly, stated that Stephen was unarmed and had not threatened her, a second caller reported a shooting, and a third clarified that no one had been shot, though it was unclear if the officers received this update. Upon arrival, the officers encountered Stephen outside a car, with Ashly in the driver’s seat. The officers drew their weapons and ordered Stephen to the ground. Stephen, holding two cell phones, complied by placing them on the ground and raising his hands. After further commands, Stephen got on his knees, raised his shirt to show a holstered gun, and reached for it, prompting the officers to shoot him. While wounded and lying on the ground, Stephen again reached toward his waist and the officers fired a second time. Stephen died at the scene, and the incident was recorded on body cameras.Ashly, as personal representative of Stephen’s estate, filed suit in the United States District Court for the Western District of Michigan, alleging excessive force under the Fourth Amendment, failure to intervene, and municipal liability for inadequate training under Monell v. Department of Social Services of New York City. The district court granted the defendants’ motion to dismiss, holding that the officers’ use of deadly force did not violate clearly established rights and dismissing all claims.On appeal, the United States Court of Appeals for the Sixth Circuit reversed the dismissal of the excessive-force claim, holding that Ashly plausibly alleged a violation of Stephen’s clearly established rights when the officers fired a second round of shots while he was wounded and on the ground, no longer posing an immediate threat. The court affirmed the dismissal of the failure-to-intervene and municipal liability claims, finding insufficient opportunity for intervention and inadequate factual allegations regarding city policy or training. View "Romero v. City of Lansing, Mich." on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.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 no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law