Justia Civil Rights Opinion Summaries

Plaintiff brought a 42 U.S.C. Section 1983 action after her son was shot and killed by a City of Minneapolis Police Officer. The district court found Defendant was entitled to qualified immunity as to his initial use of deadly force but not the continued use of force after Jordan dropped his knife and had fallen to the ground. In this interlocutory appeal, Defendant asserted he is entitled to qualified immunity as to the entire encounter, which lasted a total of about two seconds.   The Eighth Circuit reversed the denial of qualified immunity. The court explained that its review of the videos of the incident establishes that Defendant never paused during the shooting, which lasted less than two seconds, and he continued shooting for only approximately one second after Plaintiff’s son fell to the ground, dropping the knife. Given the swift and continuous progression of the incident and Defendant’s limited time to observe and process the circumstances, a jury could not find Defendant had sufficient time to reassess the threat presented before he stopped firing. Further, the court explained that even if Plaintiff’s son’s emotional condition perhaps mitigated the threat he posed to the responding officers, a question we need not reach, this detail does not sufficiently distinguish this case from Cook such that Defendant would have had “fair warning” that his conduct violated a constitutional right. View "Florine Ching v. Ofc. Neal Walsh" on Justia Law

This case was brought by a class of sex offenders (Appellants) civilly committed to the Minnesota Sex Offender Program (MSOP) pursuant to the Minnesota Civil Commitment and Treatment Act: Sexually Dangerous Persons and Sexual Psychopathic Personalities, codified at Minnesota Statute Section 253D (MCTA). Appellants filed this action against various MSOP managers and officials, as well as the Commissioner of the Minnesota Department of Human Services (collectively, Appellees). On remand after a second appeal to this Court, the district court granted judgment in favor of Appellees on all of Appellants’ claims. Appellants appeal, challenging the district court’s judgment.   The Eighth Circuit affirmed. The court explained that Appellants contend that the district court erred by declining to address their treatment-related claims, alleging that the district court found them to be duplicative of previously decided counts. The court wrote that in making this finding, the district court did not dismiss or otherwise ignore any of the counts before it, which were all conditions-of-confinement and inadequate medical care claims. While Appellants attempted to “reanimate” these claims in a Fourth Amended Complaint, the district court denied the amendment, and Appellants do not challenge that decision on appeal. Accordingly, the court perceived no error in the district court’s treatment of Appellants’ treatment-related claims. Appellants additionally attacked the district court’s conclusion that the MSOP’s Behavioral Expectation Report policy is constitutional. But Appellants focused only on the impact of the policy on their treatment and fail to address the other legitimate government objectives it addresses—such as preserving institutional order at the MSOP. View "Kevin Karsjens v. Jodi Harpstead" on Justia Law

In this case regarding the removal of a prospective juror based solely on his or her gender the Supreme Court held that when a party objecting to a peremptory challenge offers a bare allegation of gender discrimination without offering other relevant circumstances to support an inference of gender discrimination, that party fails to establish a prima facie case of purposeful gender discrimination.After a jury trial, Defendant was found guilty of the crime of sexual imposition. On appeal, Defendant argued that the prosecutor sought to exclude male jurors because they would tend to sympathize with him. The court of appeals reversed, holding that Defendant established a prima facie case of purposeful discrimination when the state exercised its peremptory challenge on a prospective juror and did not provide a gender-neutral explanation for its challenge. The Supreme Court reversed, holding that the trial court erred when it failed to recognize that Batson v. Kentucky, 476 U.S. 79 (1986), applied to Defendant's objections to the state's peremptory challenges, but the error was immaterial because Defendant failed to establish a prima facie case of discrimination. View "State v. Stalder" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing this action in mandamus brought by Appellant, an inmate at the London Correctional Institution, against Ohio Attorney General Dave Yost asking Yost to provide him with names of Ohio Department of Rehabilitation and Correction (ODRC) employees who worked on a case Appellant had previously filed against the ODRC, holding that there was no error.In 2016, Appellant filed a pro se lawsuit alleging excessive force during an altercation with ODRC staff. After the parties settled, Appellant unsuccessfully requested from the attorney general's (AG) office the name of the ODRC employee who communicated with the attorney general's office during settlement negotiations. Appellant then filed the current action requesting an order requiring the AG to provide the ODRC employees' who made decisions regarding his settlement. The attorney general dismissed the action for failure to state a claim. The Supreme Court affirmed, holding that Appellant failed to show that he had a clear legal right to the requested information or that the AG had a clear legal duty to provide that information. View "State ex rel. Russell v. Yost" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its authority to grant extraordinary relief, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial judge erred in excluding evidence that law enforcement officers found illegal narcotics in a vehicle occupied by the victim and in the victim's clothing and that the judge's ruling "deprived the defense of the plausible alternative theory that rival drug dealers committed the murder." The Supreme Judicial Court disagreed and affirmed, holding (1) there was no evidentiary error in the proceedings below; (2) as to the firearm conviction, the trial court's failure to instruct the jury on licensure requirements was harmless beyond a reasonable doubt; and (3) the verdict of murder in the first degree was consonant with justice and should stand. View "Commonwealth v. Bookman" on Justia Law

Three installers of window blinds sued FS Blinds, L.L.C., the company for which they worked. The district court granted summary judgment to FS Blinds, determining that Plaintiffs had not met their prima facie burden to show they worked overtime. The court dismissed the case, and Plaintiffs appealed.   The Fifth Circuit reversed. The court held that Plaintiffs have met the lenient standard under Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680, 686–88 (1946), and therefore survive summary judgment, at least as to whether, if employees, Plaintiffs worked overtime. The court declined to reach whether Plaintiffs were employees or independent contractors and instead remand for the district court to consider that question anew. The court explained that, based on the record, Plaintiffs have presented enough to satisfy their “lenient” prima facie burden under Mt. Clemens. This is so even though Plaintiffs’ testimony offers only an estimated average of hours worked. In addition to their testimony, though, Plaintiffs offered supporting work orders and some corroborating testimony from FS Blinds. The court wrote that all told, this record evidence hurdles Plaintiffs’ Mt. Clemens burden. View "Flores v. FS Blinds" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Puerto Rico Highways and Transportation Authority (PRHTA) and its executive directors (collectively, Appellees) and dismissing this complaint brought by sixty-nine current and former employees of the PRHTA (collectively, Appellants), holding that the district court did not err or abuse its discretion.Appellants brought this action challenging the PRHTA's decision no longer to give effect to a regulation providing Appellants with additional compensation. Specifically, Appellants claimed that the decision was contrary to P.R. Act No. 66-2014, giving rise to violations of the Contracts Clause and Due Process Clause. The district court granted summary judgment for the PRHTA on the federal constitutional claims and declined to exercise supplemental jurisdiction over Appellants' claims under Puerto Rico law. The First Circuit affirmed, holding that the district court (1) did not err in concluding that Appellants could not establish their federal constitutional claims; and (2) did not abuse its discretion in declining to exercise jurisdiction over Appellants' remaining Puerto Rico law claims. View "Vazquez-Velazquez v. P.R. Highway & Transportation Authority" on Justia Law

Plaintiff appealed the district court’s decision ordering him to pay a $100 partial filing fee in his civil action. Plaintiff, an unemployed non-prisoner with approximately $1,000 in cash, filed a pro se complaint against the United States Department of Interior (DOI) asserting violations of federal contracting law and financial assistance law. Plaintiff filed an application to proceed in forma pauperis (IFP), i.e., without prepaying fees or costs. A magistrate judge granted Plaintiff’s application in part and ordered Plaintiff to pay a partial filing fee totaling $100. Plaintiff moved for reconsideration. The magistrate judge issued a report and recommendation, which recommended denying the motion to reconsider. The district court adopted the report and recommendation and ordered Plaintiff to pay the $100 partial filing fee within fourteen days. Plaintiff appealed. On appeal, Plaintiff argued that district courts may either make a plaintiff pay the full fee or waive the fee entirely but may not impose a partial fee.   The Ninth Circuit affirmed the district court’s decision. The panel held that district courts have the authority to impose partial filing fees on non-prisoner civil litigators under 28 U.S.C. Section 1915(a)(1). The panel rejected Plaintiff’s argument that the holding in Olivares v. Marshall, 59 F.3d 109, 111 (9th Cir. 1995), was limited to IFP applications brought by prisoners. The panel also rejected Plaintiff’s argument that the Prison Litigation Reform Act superseded the holding in Olivares. View "JAY HYMAS V. USDOI" on Justia Law

Plaintiff alleged was assaulted by his daughter’s ex-boyfriend and the ex-boyfriend’s cousin outside his house in Camden County, Missouri, in December 2011. He reported the assault to the Camden County Sheriff’s Department the following May. After no charges were brought, Plaintiff filed a civil suit against the alleged assailants. While pursuing his civil suit, Plaintiff claimed he discovered that the sheriff’s department refused to investigate the assault because the assailants were related to the county’s clerk of court. This refusal meant that Plaintiff could obtain very little evidence of the assault. Plaintiff then filed an action against officials in the sheriff’s department for claims under 42 U.S.C. Section 1983 and the Missouri Constitution. He claimed that Defendants’ inadequate investigation deprived him of his equal protection and due process rights. Defendants moved to dismiss Plaintiff’s complaint for lack of standing. They also moved for summary judgment. The district court granted summary judgment to the Defendants and denied their motion to dismiss as moot. Plaintiff appealed.   The Eighth Circuit vacated the district court’s grant of summary judgment as to Plaintiff’s federal claims and remanded with instructions to dismiss these claims for lack of standing. The court affirmed to Plaintiff’s state law claims.  The court explained that it has not yet addressed whether a crime victim has standing to sue a government official for an inadequate investigation. However, the court has held that a crime victim cannot sue a government official for failing to prosecute his assailant. View "Jeffery Pratt v. Tony Helms" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Plaintiff's Mass. Gen. Laws ch. 151B claims, holding that tolling does not apply to the time limits established in Mass. Gen. Laws ch. 151B, 5, including the requirement that claims be pursued by first filing a complaint with the Massachusetts Commission Against Discrimination (MCAD) "within 300 days after the alleged act of discrimination."Approximately one year after his termination, Plaintiff filed a complaint with the MCAD alleging sexual harassment, in violation of Mass. Gen. Laws ch. 151B, 4 (16A), and retaliation, in violation of Mass. Gen. Laws ch. 151B, 4. Plaintiff later amended his complaint to add his chapter 151B claims. The motion judge granted Defendants' motion to dismiss, reasoning that this Court's emergency orders issued during the early months of the COVID-19 pandemic applied only to courts, not the MCAD, and that equitable tolling did not apply. The Supreme Judicial Court affirmed, holding that tolling did not apply to the time limits in this case. View "Dunn v. Langevin" on Justia Law