Justia Civil Rights Opinion Summaries

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Shawn Riley, a former prisoner at the Wisconsin Secure Program Facility (WSPF), filed a lawsuit under 42 U.S.C. § 1983 against WSPF’s Health Services Manager, Jolinda Waterman, and Nurse Practitioner Sandra McArdle. Riley alleged that they were deliberately indifferent to his serious medical needs, violating the Eighth Amendment. Riley experienced chronic pain and sought specific medical treatments, including high-top shoes recommended by specialists. Despite receiving various treatments, including medications, physical therapy, and custom orthotics, Riley claimed that his pain persisted and that the defendants ignored specialist recommendations.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants and denied Riley’s motions to appoint counsel. The court found that the defendants were not deliberately indifferent to Riley’s medical needs, noting that they provided extensive medical care and followed many of the specialists' recommendations. The court also concluded that Riley’s requests for special shoes were reviewed and denied by the Special Needs Committee (SNC) and that the defendants' actions did not amount to deliberate indifference.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the defendants did not ignore the specialists' recommendations and provided adequate medical care. The court also found that the defendants' refusal to allow Riley to purchase shoes from outside the approved catalog did not constitute deliberate indifference. Additionally, the court upheld the denial of Riley’s motion to appoint counsel, determining that Riley was competent to litigate his case and that the case did not present complexities that necessitated appointed counsel. The judgment of the district court was affirmed. View "Riley v. Waterman" on Justia Law

Three inmates in a California state prison jointly filed a lawsuit under 42 U.S.C. § 1983, alleging Eighth Amendment violations and false imprisonment due to being forced to stand in unsanitary conditions for nearly nine hours. One inmate also claimed excessive force. They applied to proceed in forma pauperis (IFP).The United States District Court for the Eastern District of California denied their request for joinder and severed their claims, requiring each inmate to file separately. The court reasoned that the Prison Litigation Reform Act (PLRA) required each prisoner to pay the full filing fee, and allowing joint actions would result in fees exceeding statutory limits. The court also cited practical issues with pro se prisoner lawsuits, such as potential transfers and communication difficulties, as reasons for denying joinder.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the PLRA does not prohibit prisoners from proceeding together in lawsuits, but it does require each prisoner to pay the full filing fee. The district court erred by interpreting the PLRA's fee provisions in isolation and failing to harmonize them. The Ninth Circuit also found that the district court abused its discretion in denying permissive joinder under Rule 20 of the Federal Rules of Civil Procedure based on hypothetical concerns not supported by the record.The Ninth Circuit reversed the district court's decision, allowing the inmates to proceed jointly under the PLRA, provided each pays the full filing fee. View "JOHNSON V. HDSP" on Justia Law

In February 2018, two men invaded a home in Rockford, Illinois, resulting in the death of Julian Young, Jr. and the escape of Jasmine Meneweather. Meneweather initially provided general descriptions of the assailants but no specific identities. Later, she sent a photo of one perpetrator to Detective Eric Harris, but the person was not identified. Over a year later, Harris received another photo from Young’s aunt, identifying the assailants as brothers Cortez and Shawnqiz Lee. Meneweather later identified Shawnqiz Lee in a photo array. Despite Lee’s alibi of being at work during the crime, he was arrested in November 2019 based on a criminal complaint and a judge-issued arrest warrant. A grand jury indicted Lee, but subsequent DNA evidence did not match him. Lee was released in December 2020 after the charges were dismissed.The United States District Court for the Northern District of Illinois granted summary judgment to the police officers, reasoning that probable cause existed based on Meneweather’s identification, which is an absolute defense to Lee’s claims. Lee appealed, arguing that the officers lacked probable cause and that they recklessly withheld material facts.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that probable cause existed based on Meneweather’s identification, which was sufficient to support the arrest warrant. The court also found that the officers did not recklessly withhold material facts that would have negated probable cause. Additionally, the grand jury indictment provided prima facie evidence of probable cause, which Lee failed to rebut. Consequently, the court affirmed the summary judgment in favor of the police officers, concluding that probable cause was an absolute defense to Lee’s Fourth Amendment and state-law claims. View "Lee v Harris" on Justia Law

The Commonwealth sought to civilly commit a prisoner, previously convicted of a sexual offense, as a "sexually dangerous person" (SDP) under Massachusetts law. The process required expert testimony to establish probable cause and qualified examiners to determine if the case should proceed to trial. The plaintiff, George Mackie, was initially adjudicated as an SDP based on expert reports and testimony, but this decision was later vacated on appeal due to prejudicial error.Mackie then filed separate civil actions against Dr. Katrin Rouse-Weir, a probable cause expert, and Dr. Robert Joss, a qualified examiner, alleging they submitted false reports and testimony. Both defendants moved to dismiss the complaints, claiming immunity. Superior Court judges granted the motions, concluding that the defendants were entitled to absolute quasi-judicial immunity. Mackie appealed these decisions.The Appeals Court reversed the dismissals, ruling that the experts were entitled only to qualified immunity, not absolute quasi-judicial immunity. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court held that qualified examiners like Joss are entitled to absolute quasi-judicial immunity due to their essential and independent role in the judicial process. The court also concluded that probable cause experts like Rouse-Weir are protected by the litigation privilege, which shields them from liability for their statements made during judicial proceedings. Consequently, the court affirmed the Superior Court judgments dismissing Mackie's complaints against both experts. View "Mackie v. Rouse-Weir" on Justia Law

Caroline Retzios was terminated by Epic Systems Corporation after she refused to be vaccinated against COVID-19, citing religious objections. She filed a lawsuit under Title VII of the Civil Rights Act of 1964, claiming that Epic was required to accommodate her religious beliefs. Epic requested the district court to compel arbitration based on an agreement Retzios had signed, which the court granted, subsequently dismissing the suit.The United States District Court for the Northern District of Illinois dismissed the case after referring it to arbitration, despite Epic's request for a stay. According to the Federal Arbitration Act, a stay should have been issued instead of a dismissal when arbitration is requested. This dismissal allowed Retzios to appeal the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and determined that the district court erred in dismissing the suit instead of staying it. However, the appellate court proceeded with the case due to the district court's actions. The appellate court found that Retzios's claims fell within the scope of the arbitration agreement she had signed with Epic. The court rejected Retzios's arguments against the enforceability of the arbitration agreement, including her claims of promissory estoppel and waiver. The court also found her objections to arbitration to be frivolous and granted Epic's motion for sanctions, directing Retzios to reimburse Epic for its legal expenses incurred on appeal. The decision of the district court was affirmed, with sanctions imposed on Retzios. View "Retzios v Epic Systems Corp." on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

Blake Stewardson was arrested for driving under the influence on January 1, 2018, and taken to Cass County Jail. While intoxicated, he directed profanities at police and resisted during intake, leading Officer Titus to slam his head against a wall twice, causing a cut. Titus then performed a leg sweep, causing Stewardson to fall and hit his head. Later, Titus opened a cell door into Stewardson and performed a hip toss. Stewardson sued Titus and Biggs, alleging excessive force and failure to intervene.The United States District Court for the Northern District of Indiana granted summary judgment to the defendants on many claims but allowed two to proceed to trial: one against Titus for excessive force and one against Biggs for failing to intervene. The jury found Titus liable and awarded $400,000 in compensatory damages and $850,000 in punitive damages. Biggs was found not liable for failing to intervene. Titus appealed the punitive damages award, and Stewardson cross-appealed the summary judgment decisions.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the jury's punitive damages award against Titus, finding it not unconstitutionally excessive given the reprehensibility of his conduct, the ratio of punitive to compensatory damages, and comparable cases. The court also affirmed the district court's summary judgment in favor of Biggs, concluding that he did not violate clearly established law regarding excessive force or failure to intervene. Additionally, the court upheld the summary judgment on Stewardson's Monell claim against Cass County, finding insufficient evidence of an unconstitutional custom. View "Stewardson v. Titus" on Justia Law

Glorianna Moore was stopped by Officer Brian Wilson for speeding in Pontiac, Michigan. When Moore refused to show her license and moved her hands towards the center console, Wilson reached into her car, grabbed her arm, and ordered her to shut off the car. Moore resisted by screaming and twisting her body. Wilson restrained her by holding her arm and head until backup arrived. Moore was subsequently handcuffed and placed in Wilson's patrol car. Although an initial test indicated the presence of cocaine in Moore's car, further testing revealed it was not cocaine, leading to the dismissal of all charges against her.Moore filed a § 1983 action against Wilson and other officers, alleging excessive force in violation of her Fourth Amendment rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Wilson, who appealed the denial of his motion for summary judgment based on qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Officer Wilson did not violate clearly established Fourth Amendment principles. The court reasoned that Wilson's actions were reasonable given Moore's refusal to show her license, her movement towards the center console, and her active resistance. The court concluded that no clearly established law indicated that Wilson's use of force was excessive under the circumstances, thus entitling him to qualified immunity. View "Moore v. Oakland County" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law