Justia Civil Rights Opinion Summaries

Hamdi A. Mohamud, a plaintiff, sued Heather Weyker, a St. Paul police officer, for wrongful arrest. Weyker, while working as a cross-deputized federal agent on a federal task force, allegedly lied to protect a federal witness, Muna Abdulkadir, leading to Mohamud's arrest. Weyker falsely claimed that Mohamud and others were trying to intimidate Abdulkadir, resulting in their arrest for witness tampering. Mohamud spent about 25 months in custody before the charges were dismissed.The United States District Court for the District of Minnesota previously reviewed the case. Mohamud's claims were based on Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and 42 U.S.C. § 1983. The district court denied Mohamud's requests for limited discovery and to amend her complaint, concluding that further discovery would be futile and that the proposed amendment would not change the outcome. The court granted summary judgment in favor of Weyker, following the reasoning from a similar case, Yassin v. Weyker, which held that Weyker did not act under color of state law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgment, holding that Weyker acted under federal authority, not state law, when she protected a federal witness in a federal investigation. The court found that the new facts alleged by Mohamud did not change the analysis from the Yassin case. The court also concluded that further discovery would not have made a difference and upheld the district court's denial of Mohamud's discovery request. View "Mohamud v. Weyker" on Justia Law

Jeffrey Joseph, an inmate working in a metal plant at a Missouri prison, injured his thumb while operating a "press-brake" machine. Joseph sued his supervisor, Kurt Schmiedeskamp, under 42 U.S.C. § 1983, alleging that Schmiedeskamp subjected him to cruel and unusual punishment by instructing him not to use the machine's hand restraints, which were designed to prevent such injuries. Joseph claimed that Schmiedeskamp told him not to use the restraints because they slowed production.The United States District Court for the Eastern District of Missouri denied Schmiedeskamp's motion for summary judgment, which argued that he was entitled to qualified immunity. Schmiedeskamp then filed an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court reversed and remanded the case, holding that Schmiedeskamp was entitled to qualified immunity. The court found that Joseph failed to show that Schmiedeskamp's actions violated clearly established constitutional rights. The court distinguished this case from Ambrose v. Young, noting that Schmiedeskamp's response to Joseph's question about the hand restraints did not demonstrate that he knew the machine presented a substantial risk of harm. The court also cited other cases involving inmate injuries in industrial settings, which indicated that the law was not clearly established in this area. Consequently, the court concluded that Schmiedeskamp's conduct did not meet the standard of deliberate indifference required to overcome qualified immunity. View "Joseph v. Schmiedeskamp" on Justia Law

In this case, the Attorney General of New Jersey decided to supersede control of the Paterson Police Department following a fatal police shooting. The Attorney General appointed Isa M. Abbassi, a veteran NYPD officer, as the Officer in Charge (OIC) and reassigned the Paterson Police Chief, Engelbert Ribeiro, to the Police Training Commission in Trenton. Plaintiffs, including Paterson officials, challenged the Attorney General's authority to supersede the police department without local consent.The case was first brought to the Law Division, which transferred it to the Appellate Division. The Appellate Division consolidated the actions and ultimately reversed the Attorney General's decision, ruling that the Attorney General exceeded his statutory powers. The appellate court directed the defendants to reassign Ribeiro to Paterson, relinquish control of the department to city officials, and provide a report summarizing their actions and expenditures during the supersession.The New Jersey Supreme Court reviewed the case and found evidence that the Legislature intended to authorize the supersession in two statutes: Chapter 94, which facilitated the OIC's leadership, and the appropriations bill for the fiscal year ending June 30, 2024, which funded the Attorney General's operation of the department. The Court did not base its holding on other statutes or authorities cited by the defendants. The Court reversed the Appellate Division's judgment, finding that the Attorney General's supersession of the Paterson Police Department was not arbitrary, capricious, or unreasonable, and had fair support in the record. The Court did not address whether the Attorney General has general authority to supersede municipal police departments in other circumstances. View "Bulur v. The New Jersey Office of the Attorney General" on Justia Law

Ayla Royan, a student in Chicago State University's (CSU) Doctor of Pharmacy program, was dismissed after failing two clinical rotations. Royan, who has clinical depression and an eating disorder, claimed her dismissal was due to her disabilities. CSU had accommodated her conditions by granting exam and assignment extensions and a yearlong medical leave. Despite these accommodations, Royan failed her first clinical rotation under Dr. Patel and her second under Dr. Kerner, leading to her dismissal.The United States District Court for the Northern District of Illinois granted summary judgment in favor of CSU, finding that Royan failed to present sufficient evidence that her dismissal was solely based on her disability. The court held that CSU had accommodated her disabilities and applied its academic standards without discrimination.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Royan was not "otherwise qualified" for the program as she failed to meet the academic requirements, specifically passing the clinical rotations. The court also found no evidence of pretext in CSU's stated reasons for her dismissal. Additionally, the court concluded that no reasonable jury could find that CSU dismissed Royan solely because of her disabilities, as required under Section 504 of the Rehabilitation Act. The court emphasized that academic institutions have broad discretion in setting and enforcing academic standards, and CSU's actions were consistent with its policies and procedures. View "Royan v. Chicago State University" on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

Adam Urda attended a gathering where he attempted to start a bonfire with motor oil and racecar fuel, resulting in an explosion that injured him, another adult, and a four-year-old girl. The girl was severely injured and required extensive medical treatment. Trooper Jeffrey Sokso investigated the incident, interviewed witnesses, and filed a criminal complaint against Urda for aggravated assault, risking a catastrophe, and recklessly endangering another person. The charges were approved by an assistant district attorney. However, a magistrate judge dismissed the first two charges, and the Court of Common Pleas dismissed the third charge, finding no probable cause.Urda then sued Sokso in federal court for unlawful seizure, false arrest, malicious prosecution, abuse of process, and intentional infliction of emotional distress under 42 U.S.C. § 1983. The United States District Court for the Middle District of Pennsylvania granted summary judgment for Sokso on the abuse of process and intentional infliction of emotional distress claims but denied it on the remaining claims, rejecting Sokso's qualified immunity defense.The United States Court of Appeals for the Third Circuit reviewed the case and held that qualified immunity protects Sokso. The court found that Urda did not provide any precedent showing that Sokso's actions violated clearly established law. The court emphasized that qualified immunity shields officers unless it is clear to a reasonable officer that their conduct was unlawful. The court concluded that Sokso's actions did not rise to the level of an obvious constitutional violation and that the District Court had defined the right too abstractly. Consequently, the Third Circuit reversed the District Court's denial of summary judgment on the remaining claims, granting Sokso qualified immunity. View "Urda v. Sokso" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

William Carter, a paraplegic confined to a wheelchair, was arrested for unauthorized use of 911 and spent eight days in the Shreveport City Jail. During his incarceration, Carter, who had pre-existing bedsores, did not receive adequate medical care for his wounds, which allegedly led to their infection and his subsequent hospitalization. Carter's mother, suing on his behalf, filed claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act (RA), 42 U.S.C. § 1983, and Louisiana state negligence law.The United States District Court for the Western District of Louisiana excluded the expert testimony of Dr. Joel Nitzkin before trial. After a jury trial, the court granted the defendants' Rule 50 motion for judgment as a matter of law on the ADA/RA claim, concluding that the claim was about medical treatment rather than an actionable disability claim. The jury returned a verdict for the defendants on the § 1983 and state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, holding that the ADA/RA claim amounted to a complaint about medical negligence, which is not actionable under the ADA. The court found that the failure to change Carter's bandages was a medical treatment issue, not a failure to accommodate under the ADA. Additionally, the court held that Carter's placement in a segregated cell for his safety did not constitute intentional discrimination under the ADA. The court also did not address the exclusion of Dr. Nitzkin's testimony, as it was only relevant to the ADA claims, which failed as a matter of law. The judgment of the district court was affirmed. View "Carter v. City of Shreveport" on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law

Anthony McClendon, a Michigan prisoner, was recommended by prison officials to participate in a sex-offender program due to his past conviction for criminal sexual conduct. McClendon refused to participate in the program, leading to repeated denials of parole by the Michigan parole board. McClendon filed a lawsuit under 42 U.S.C. § 1983, claiming that the recommendation to complete the sex-offender program and the subsequent parole denials violated his due process rights under the Fourteenth Amendment.The United States District Court for the Eastern District of Michigan dismissed McClendon’s complaint. The court found that McClendon did not have a cognizable liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary parole system. The court also noted that McClendon’s past conviction for a sex offense negated any liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Sixth Circuit held that McClendon’s due process claim failed because he did not identify a cognizable liberty interest. The court determined that McClendon did not have a liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary system. Additionally, the court found that McClendon’s past conviction for a sex offense meant he did not have a liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole. The court concluded that McClendon’s due process rights were not violated and affirmed the district court’s judgment. View "McClendon v. Washington" on Justia Law