Justia Civil Rights Opinion Summaries

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law

Plaintiffs Tati Abu King and Toni Heath Johnson were unable to register to vote in Virginia due to felony convictions. King was convicted of felony drug possession in 2018, and Johnson was convicted of multiple felonies, including drug possession, in 2021. Virginia's constitution disenfranchises individuals convicted of felonies unless their civil rights are restored by the Governor or other appropriate authority. King and Johnson argued that this disenfranchisement violated the Virginia Readmission Act, a federal statute from 1870, which they claimed restricted Virginia from amending its constitution to disenfranchise individuals for crimes that were not felonies at common law in 1870.The United States District Court for the Eastern District of Virginia dismissed three of the four counts in the plaintiffs' complaint for failure to state a claim but allowed one count based on the Virginia Readmission Act to proceed. The defendants, including various state election officials and the Governor of Virginia, moved to dismiss the complaint on sovereign immunity grounds, which the district court rejected.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiffs' claim met the requirements of the Ex parte Young doctrine, which allows suits for prospective relief against state officials to prevent ongoing violations of federal law. The court affirmed the district court's decision to allow the claim to proceed against most defendants but reversed the decision regarding the Governor of Virginia and the Secretary of the Commonwealth, finding that they lacked enforcement responsibility for the challenged state action. The court concluded that the Governor and Secretary must be dismissed from the case on sovereign immunity grounds. The district court's order was thus affirmed in part and reversed in part. View "King v. Youngkin" on Justia Law

Attorney Stephen Eberhardt filed a 102-page, 19-count complaint against 11 defendants, including the Village of Tinley Park, its officials, attorneys, and residents, alleging a scheme to prevent him from making public comments at Village board meetings and on Village-related Facebook pages, violating his constitutional rights. He also brought claims against the Village’s outside counsel, Patrick Walsh, under the Illinois Open Meetings Act. The district court dismissed the complaint without prejudice for being too lengthy and jumbled. Eberhardt then filed an amended complaint, which was also dismissed, and the court entered final judgment.Following the judgment, Walsh’s attorney filed a motion for sanctions under Rule 11 of the Federal Rules of Civil Procedure, arguing that Eberhardt’s claims were frivolous and filed in bad faith to harass Walsh. The district court granted the motion, ordering Eberhardt to pay $26,951.22 in attorneys’ fees, finding that his claims were frivolous and brought with inadequate investigation into the relevant law and facts. The court noted Eberhardt’s history of filing numerous lawsuits and motions, which indicated bad faith.Eberhardt appealed to the United States Court of Appeals for the Seventh Circuit, challenging the district court’s decision to sanction him and its denial of his motion to reconsider. The Seventh Circuit reviewed the case and found no abuse of discretion in the district court’s decisions. The court affirmed the sanctions order, agreeing that Eberhardt’s claims were frivolous and brought in bad faith, and that a hearing was not necessary as the record was adequate to determine the need for sanctions. The court also affirmed the denial of the motion to reconsider, finding no manifest errors of law or fact. View "Eberhardt v. Walsh" on Justia Law

The case involves a class action lawsuit filed by transgender women prisoners in Illinois, who allege that the Illinois Department of Corrections (IDOC) has been deliberately indifferent to their gender dysphoria, a serious medical condition. The plaintiffs seek injunctive relief to ensure timely evaluations and treatments, including hormone therapy, gender-affirming surgery, and appropriate support for social transitioning.The United States District Court for the Southern District of Illinois initially issued a preliminary injunction on February 7, 2022, which was intended to address the plaintiffs' claims. The court later issued further injunctions to supplement and modify the terms. However, more than a year and a half after the preliminary injunction was issued, the district court retroactively labeled it as a permanent injunction and issued a final judgment consistent with the February 7, 2022 decision. The defendants appealed several injunctions and a finding of civil contempt by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court's attempt to retroactively transform the preliminary injunction into a permanent one was not authorized. The appellate court held that under the Prison Litigation Reform Act (PLRA), the preliminary injunction issued on February 7, 2022, expired 90 days later, on May 8, 2022. Consequently, the appellate court vacated all existing injunctions and remanded the case for further proceedings consistent with its opinion. The court also dismissed the portion of the appeal challenging the finding of contempt, as the district court had not yet imposed any sanctions, which are necessary to establish appellate jurisdiction. View "Monroe v. Bowman" on Justia Law

Wayne Lozier, Jr., a licensed bounty hunter in Louisiana, traveled to Missouri to detain a fugitive, R.C., who had failed to appear for her court date in Louisiana. Lozier entered a residence in Missouri, handcuffed R.C., and transported her towards Mississippi. During this time, the residence owner alerted law enforcement, leading to an investigation by Officer Jeffrey Atkins. Lozier was found to have violated Missouri laws by not being licensed in Missouri and failing to notify local law enforcement before apprehending R.C.A federal grand jury indicted Lozier for kidnapping and conspiracy to kidnap. Lozier moved to dismiss the indictment, arguing his actions were lawful as an agent of a bail bondsman. The United States District Court for the Eastern District of Missouri denied these motions, stating Lozier's arguments were factual challenges. At trial, Lozier admitted to the Missouri law violations but contended his actions were standard fugitive apprehension. He objected to a jury instruction that he claimed deprived the jury of deciding whether his actions were unlawful. The jury found Lozier guilty on both counts, and he was sentenced to 120 months on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the jury instruction (Instruction 16) created a conclusive presumption that Lozier acted unlawfully by violating Missouri law, thus removing the jury's ability to consider justification or excuse. This violated Lozier's due process rights. The court held that this error was not harmless and vacated Lozier's convictions, remanding the case for a new trial. View "United States v. Lozier" on Justia Law

Ashleigh Gelin died by suicide in November 2013 while incarcerated at the Baltimore County Detention Center. Her parents, Edward and Deborah Gelin, sued Baltimore County and several correctional officers, alleging violations of 42 U.S.C. § 1983, the Maryland Declaration of Rights, and Maryland common law. They claimed the officers showed deliberate indifference to Ashleigh's safety and were grossly negligent.The United States District Court for the District of Maryland partially granted and partially denied the County's motion for judgment on the pleadings. The court found that the complaint did not properly allege deliberate indifference to Ashleigh's mental health needs but did plausibly allege indifference to her physical safety. The court held that the officers could not claim qualified immunity or Maryland common-law public official immunity and denied Baltimore County's claim of governmental immunity. The County's subsequent motion for reconsideration was partially addressed, but the court did not rule on whether the officers could assert public official immunity against the negligence claims.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the County's appeal was premature because the district court had not yet ruled on all issues raised in the County's motion for reconsideration. Specifically, the district court had not decided whether the officers could assert public official immunity against the negligence claims. As a result, the Fourth Circuit held the appeal in abeyance, pending the district court's resolution of the remaining issue. The court directed the parties to inform it once the district court had made a final ruling on the pending issue. View "Gelin v. Baltimore County" on Justia Law

Ohio House, LLC operates a sober-living facility in Costa Mesa, California, within a multiple-family residential (MFR) zone. The City of Costa Mesa notified Ohio House that it was subject to Ordinance 15-11, which mandates that group homes with over six residents in MFR zones obtain a conditional-use permit and meet a separation requirement. Ohio House's application for a permit was denied due to non-compliance with the separation requirement, and its request for a reasonable accommodation was also denied.The United States District Court for the Central District of California granted partial summary judgment to the City on Ohio House's disparate-impact claim and denied Ohio House's post-verdict motions. The jury found in favor of the City on Ohio House's remaining claims, including disparate treatment, discriminatory statements, interference with fair housing rights, and reasonable accommodation. The district court also ruled that Ohio House's claim under California Government Code § 65008 was time-barred.The United States Court of Appeals for the Ninth Circuit affirmed the district court's rulings. The court held that Ohio House failed to establish facial disparate treatment as a matter of law because the City's group-living regulations facially benefit disabled individuals. The court also affirmed the summary judgment for the City on the disparate-impact claim, agreeing that Ohio House did not prove a significant, adverse, and disproportionate effect on a protected group. The court upheld the jury's verdict on the discriminatory statements claim, finding no unlawful discriminatory statements by the City. The court also affirmed the denial of judgment as a matter of law on the interference claim, concluding that Ohio House failed to prove a causal link between its protected activity and the City's actions. Finally, the court affirmed the denial of judgment as a matter of law on the reasonable accommodation claim, agreeing that the requested accommodation was unreasonable as it would fundamentally alter the City's zoning scheme. The court also upheld the district court's ruling that Ohio House's § 65008 claim was time-barred. View "THE OHIO HOUSE, LLC V. CITY OF COSTA MESA" on Justia Law

After the death of George Floyd, large-scale protests occurred in Kansas City, Missouri. On May 30, 2020, the Kansas City Police Department requested assistance from the Missouri State Highway Patrol to manage the protests, which turned violent. Law enforcement used tear gas and other munitions to disperse the crowd. Sergeant Jeffrey Spire deployed various crowd control measures, including smoke grenades and projectiles. Around 11:47 p.m., Spire fired projectiles indiscriminately into the crowd, one of which allegedly struck Sean Stearns, causing him to lose vision in his left eye.Stearns sued Sergeant Spire under 42 U.S.C. § 1983 for First Amendment retaliation and excessive force under the Fourth and Fourteenth Amendments. He also brought claims under Missouri law and a Monell claim against the Board of Police Commissioners. The United States District Court for the Western District of Missouri granted summary judgment for the defendants, finding that Spire was entitled to qualified immunity and that Stearns could not establish a Monell claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Spire was entitled to qualified immunity on the First Amendment retaliation claim because Stearns failed to demonstrate a causal connection between his injury and retaliatory animus. The court also found that Stearns waived his Fourth Amendment claim by not providing a meaningful argument. Regarding the Fourteenth Amendment claim, the court concluded that Spire's actions did not shock the conscience and thus did not constitute a substantive due process violation. Consequently, the Monell claim failed due to the absence of a constitutional violation. The court affirmed the district court's decision to dismiss the state law claims without prejudice, finding no abuse of discretion. The judgment of the district court was affirmed. View "Stearns v. Dean" on Justia Law

Derrick A. Davis sued the City of Little Rock, the chief of police, and three detectives for Fourth Amendment violations under 42 U.S.C. § 1983 after a no-knock warrant was executed on his residence. The warrant was based on an email about drug activity, a controlled buy using a confidential informant (CI), and Detective Bell's affidavit. The SWAT team executed the warrant, finding marijuana inside Davis's home.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. Davis appealed, arguing that there were genuine disputes of material fact regarding the detectives' responsibility for the SWAT team's actions, the veracity of statements in the warrant affidavit, and the existence of a conspiracy to violate his Fourth Amendment rights. He also challenged the district court's handling of evidence and the imposition of sanctions for his failure to attend a deposition.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Detectives Bell and Ison were entitled to qualified immunity because the right in question was not clearly established at the time of the warrant's execution. The court also found no Franks violation, as Davis failed to show that any false statements in the affidavit were made knowingly or with reckless disregard for the truth. Additionally, the court ruled that Davis's § 1983 conspiracy claim failed because the underlying Fourth Amendment claims were properly dismissed.The court also determined that the district court did not err in considering Detective Bell's affidavit or in disregarding Davis's expert opinions. Finally, the court concluded that it lacked jurisdiction to review the sanctions award because the district court had not yet fixed the amount. The judgment was affirmed. View "Davis v. City of Little Rock" on Justia Law

The case involves Idaho's abortion trafficking statute, Idaho Code §18-623, which criminalizes procuring an abortion or obtaining an abortion-inducing drug for an unemancipated minor by recruiting, harboring, or transporting the minor with the intent to conceal the abortion from the minor’s parents or guardian. Plaintiffs, including an Idaho attorney and two advocacy organizations, sought to counsel pregnant minors and provide material support for accessing legal abortions in other states. They challenged the statute, arguing it violated the First Amendment and was void for vagueness.The United States District Court for the District of Idaho granted a preliminary injunction against the statute, finding that the plaintiffs had standing and that the Idaho attorney general was a proper defendant under Ex parte Young. The court concluded that the plaintiffs were likely to succeed on the merits of their First Amendment and void-for-vagueness claims. The district court also partially granted and denied Idaho’s motion to dismiss, dismissing only the claim regarding the right to intrastate travel.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s finding that the plaintiffs had standing and that the Idaho attorney general was a proper defendant. The Ninth Circuit held that the plaintiffs were unlikely to succeed on their claims that the statute was void for vagueness or that it infringed on their rights to expressive association. However, the court found that the plaintiffs were likely to succeed on their claim that the statute’s “recruiting” prong unconstitutionally infringed on their protected speech. The court determined that the “recruiting” provision was overbroad and could be severed from the rest of the statute. Consequently, the Ninth Circuit affirmed the preliminary injunction against enforcing the “recruiting” prong but reversed the district court’s decision regarding the other claims and remanded for modification of the preliminary injunction. View "Matsumoto v. Labrador" on Justia Law