Justia Civil Rights Opinion Summaries

While incarcerated at Ellsworth Correctional Institution in Wisconsin, the plaintiff was sexually assaulted and physically abused by a correctional officer, James Faulkner. Faulkner was later criminally convicted for these acts and sentenced to a lengthy prison term. The plaintiff subsequently filed a civil suit under 42 U.S.C. §1983 seeking damages from Faulkner and three supervisory officials, alleging violations of her constitutional rights.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the supervisory officials, finding no evidence that they knew or should have known of Faulkner’s risk to inmates. The plaintiff did not appeal these rulings, effectively abandoning her claims against those defendants. Faulkner, having failed to answer the complaint, was found in default. The district court held a hearing to determine damages and ultimately awarded the plaintiff $1 million for pain and suffering and $3 million in punitive damages, but denied additional damages for lost income and future medical expenses due to insufficient and improperly presented evidence.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings and the plaintiff’s arguments regarding the scope of Faulkner’s employment. The appellate court held that the district judge did not abuse his discretion or commit legal error in excluding the plaintiff’s evidence on future damages, as the submissions failed to comply with statutory requirements and evidentiary rules. The court also rejected the plaintiff’s arguments concerning employer liability, noting that the employer was not named as a party and that such issues were not properly before the court. The Seventh Circuit affirmed the judgment of the district court. View "Dotson v. Faulkner" on Justia Law

Plaintiffs, the widows of five men killed during peaceful rallies in Nigeria, sued Willie Obiano, the former Governor of Anambra State, under the Torture Victim Protection Act of 1991 (TVPA). They alleged that Obiano ordered Nigerian military forces to shoot and kill their husbands at the rallies. Obiano, who now resides in Texas, served as Governor from March 17, 2014, to March 17, 2022. The plaintiffs sought compensatory and punitive damages, claiming the killings were extrajudicial and occurred under Obiano's command.The United States District Court for the Southern District of Texas dismissed the suit, citing the common-law principle of foreign official immunity. The court agreed with the magistrate judge's recommendation, concluding that Obiano was entitled to conduct-based immunity for actions taken in his official capacity as a Nigerian official. The court also rejected the plaintiffs' argument for a ius cogens exception to foreign official immunity, which would have allowed for immunity to be forfeited for heinous acts such as torture or extrajudicial killings.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the TVPA does not implicitly abrogate foreign official immunity. The court reasoned that the TVPA's language does not clearly indicate Congress's intent to eliminate existing common-law immunities. The court also noted that the TVPA covers a field previously governed by common law, and thus, it should be interpreted with the presumption that Congress intended to retain the substance of the common law. Consequently, the court concluded that Obiano was protected by conduct-based immunity for his official actions as a Nigerian governor. View "Jane Does 1-5 v. Obiano" on Justia Law

Two Korean spas, collectively referred to as "the Spa," had a policy of granting entry only to biological women, excluding men and preoperative transgender women. The Washington State Human Rights Commission (HRC) initiated an enforcement action against the Spa, alleging that this policy violated the Washington Law Against Discrimination (WLAD), which prohibits discrimination in public facilities based on sexual orientation, including gender expression or identity. The Spa did not challenge the statute's definition or argue that their conduct did not fit within it but claimed that enforcing WLAD against their policy violated their First Amendment rights.The United States District Court for the Western District of Washington dismissed the Spa's complaint with prejudice under Rule 12(b)(6). The court held that the Spa's conduct discriminated based on gender identity, thus falling within WLAD's scope. It also found that the HRC's enforcement did not impermissibly burden the Spa's First Amendment rights to free speech, free exercise of religion, or free association.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that the Spa's entrance policy discriminated based on gender identity, which is included in WLAD's definition of sexual orientation. The court applied intermediate scrutiny to the Spa's free speech claim, concluding that WLAD imposed an incidental restriction on speech no greater than necessary to eliminate discriminatory conduct. The court also applied rational basis review to the Spa's free exercise claim, finding that WLAD was neutral and generally applicable, and that eliminating discrimination based on sex and transgender status is a legitimate government purpose. Finally, the court rejected the Spa's free association claim, determining that the Spa was neither an intimate nor an expressive association. The court affirmed the district court's dismissal of the complaint. View "Olympus Spa v. Armstrong" on Justia Law

A private fencing coach alleged that during a flight, a university’s assistant fencing coach sexually harassed and assaulted her. She reported the incident to the university’s head coach, who discouraged her from reporting it further and, along with the assistant coach, allegedly retaliated against her within the fencing community. The university later investigated and confirmed the harassment but found no policy violation. The coach sued the university, the two coaches, and the Title IX coordinator, claiming violations of Title IX and state-law torts.The United States District Court for the Middle District of North Carolina transferred the case to the Middle District of Pennsylvania due to improper venue and judicial efficiency. After the transfer, the plaintiff amended her complaint, and the defendants moved to dismiss. The transferee court dismissed the entire suit, holding that the plaintiff, as neither a student nor an employee, was outside the zone of interests protected by Title IX. It also dismissed the state-law tort claims as untimely or implausible.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the zone-of-interests test applies to Title IX claims and that the plaintiff’s claims related to her exclusion from university-hosted fencing events and retaliation manifesting on campus were within that zone. The court affirmed the dismissal of the state-law tort claims against the university and its employees, except for the claims against the assistant coach, which were not time-barred under North Carolina’s three-year statute of limitations. The case was vacated in part, affirmed in part, and remanded for further proceedings. View "Oldham v. Penn State University" on Justia Law

Michael Molson was arrested by Kent County officers during a search warrant execution for crack cocaine. Molson attempted to swallow a bag of drugs, which officers forced him to expel. Despite being asked multiple times, Molson denied swallowing any more drugs. He showed no symptoms of drug ingestion and was taken to jail, where he underwent two medical evaluations and continued to deny swallowing drugs. The next day, Molson was found unresponsive and later died from acute cocaine toxicity, with an autopsy revealing a bag of cocaine in his stomach.The United States District Court for the Western District of Michigan denied the officers' motions for summary judgment based on qualified immunity, finding that there was a genuine issue of material fact regarding whether the officers were deliberately indifferent to Molson's serious medical needs. The court concluded that Molson's need for medical attention was clearly established at the time of his arrest.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's denial of qualified immunity. The Sixth Circuit held that Molson's medical need was not sufficiently serious or obvious to the officers, as he showed no symptoms and repeatedly denied swallowing drugs. The court found that the officers acted reasonably by taking Molson to jail, where he received medical evaluations that did not indicate any immediate health risk. Consequently, the officers were entitled to qualified immunity, and the case was remanded for entry of judgment in favor of the defendants. View "Hodges v. Abram" on Justia Law

A woman from North Carolina was found raped and murdered in a Washington, D.C. apartment in March 2017. The victim’s body was discovered bound and stabbed, with evidence of sexual assault. Surveillance footage and ATM records showed her car and credit cards being used in the days following her death. The investigation led to the arrest of El Hadji A. Toure, whose DNA was found at the crime scene and on items used to bind the victim. Video evidence placed Toure near the victim’s apartment shortly before the crime, and he was later seen using her credit and debit cards, always entering the correct PIN. After the murder, Toure’s financial situation improved markedly, as he paid cash for a hotel stay and a car.A jury in the Superior Court of the District of Columbia convicted Toure of multiple offenses, including first-degree murder, sexual abuse, kidnapping, and related charges. He was sentenced to life without release. While his appeal was pending, Toure moved for a new trial, arguing that the government failed to timely disclose disciplinary records (QCARs) for forensic witnesses, in violation of Brady v. Maryland. The Superior Court denied the motion, finding that, even assuming suppression of favorable evidence, there was no reasonable probability the outcome would have been different given the strength of the other evidence.The District of Columbia Court of Appeals reviewed both the convictions and the denial of a new trial. The court held that, although the government failed to timely disclose impeachment evidence, the suppressed material was not material under Brady because the remaining evidence against Toure was overwhelming. The court also found that the prosecutor’s conduct in eliciting certain testimony violated Toure’s confrontation and due process rights, but concluded that any error was harmless beyond a reasonable doubt. The convictions and denial of a new trial were affirmed, with a remand for merger and resentencing as necessary. View "Toure v. United States" on Justia Law

A shelter providing housing to individuals experiencing homelessness terminated a client's services on an emergency basis, alleging that the client posed an imminent threat to the health or safety of others. The client, who had previously been removed from the shelter without proper notice, returned to the shelter and was involved in a confrontation with security officers. The shelter claimed the client was hostile, pushed a security officer, and made threats. The client challenged the termination, leading to an evidentiary hearing.The Office of Administrative Hearings (OAH) reviewed the case. The administrative law judge (ALJ) found that the shelter had previously attempted to terminate the client without proper notice and that the client was within his rights to be at the shelter at the time of the incident. The ALJ determined that the security officers escalated the situation by provoking the client, who only pushed the officer after being provoked. The ALJ did not credit the shelter's witness's testimony that the client made threats, finding it uncorroborated and inconsistent with video evidence.The District of Columbia Court of Appeals reviewed the case. The court upheld the ALJ's decision, agreeing that the ALJ correctly applied the law and that the client's actions were not severe enough to warrant emergency termination under the Homeless Services Reform Act. The court found that the ALJ's credibility determinations were supported by substantial evidence and that the shelter's arguments regarding the client's prior misconduct were unpreserved for appeal. The court affirmed the OAH's order, rejecting the shelter's arguments. View "Catholic Charities--801 East Men's Shelter v. Byrd" on Justia Law

The Heidi Group, Inc. alleged that several Texas officials violated the Fourth Amendment and Texas law by conspiring with a private citizen to steal documents from a cloud-based file storage system. The officials moved for judgment on the pleadings and asserted various immunity defenses. The district court denied the motions in relevant part.The United States District Court for the Western District of Texas reviewed the case and denied the defendants' motions for judgment on the pleadings. The defendants then appealed to the United States Court of Appeals for the Fifth Circuit. The appeal involved four distinct groups of orders: the denial of qualified immunity for individual capacity defendants on the Fourth Amendment claim, the denial of judgment on the pleadings for the official capacity Fourth Amendment claim, the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, and the denial of judgment on the pleadings for the state law religious-discrimination claim.The United States Court of Appeals for the Fifth Circuit dismissed the appeal regarding the religious-discrimination claim and declined to exercise pendent appellate jurisdiction over the official capacity Fourth Amendment claim. The court held that only Gaylon Dacus engaged in state action and was not entitled to qualified immunity for the Fourth Amendment claim. The court found that Dacus used a former employee to access Heidi's documents without proper authorization, violating clearly established Fourth Amendment rights. The court also affirmed the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, as their actions were not in good faith. The court reversed the denial of judgment on the pleadings for Johnson and Kaufman on the individual capacity Fourth Amendment claim and remanded for further proceedings. View "Heidi Group v. Texas Health and Human Services Commission" on Justia Law

A motorist on Interstate 10 near Deming, New Mexico, reported a man in the median with a firearm who may have fired shots. Police officers encountered Gilbert Valencia in a nearby mesquite field, matching the description and holding what appeared to be an AR-style rifle. Valencia did not consistently comply with officers' commands and moved his hand on the weapon, prompting five officers to shoot him. Valencia died from his wounds. His estate brought federal and state law claims against the City of Deming, individual officers, Luna County, and the New Mexico Department of Public Safety.The United States District Court for the District of New Mexico granted summary judgment for the officers, asserting qualified immunity, and dismissed the Estate’s claims under the New Mexico Tort Claims Act. The Estate appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, concluding that the officers were entitled to qualified immunity because their use of lethal force was objectively reasonable based on the circumstances. The court found that the Estate failed to identify a dispute of material fact that precluded summary judgment on the state law claims. The court held that the officers' actions were reasonable given the perceived threat and the totality of the circumstances, including Valencia's non-compliance and the officers' belief that he was armed and dangerous. The court also determined that the New Mexico Tort Claims Act did not apply to the City of Deming, as it only applies to law enforcement officers. View "Cruz v. City Of Deming" on Justia Law

Carey Jackson was found guilty by a DeKalb County jury of felony murder, aggravated assault, first-degree criminal damage to property, and a violation of the Street Gang Terrorism and Prevention Act in connection with the shooting death of Arnold Leslie and the assaults of seven other individuals. The crimes occurred on April 6, 2020, and Jackson was indicted on December 1, 2020. The jury found Jackson not guilty of malice murder and possession of a firearm during the commission of a felony but guilty of the remaining counts. Jackson was sentenced to life in prison with the possibility of parole for felony murder, along with additional consecutive and concurrent prison terms for the other charges.Jackson filed a motion for a new trial on January 18, 2022, which was amended through new counsel on April 9, 2024. The trial court denied the motion on June 26, 2024. Jackson then filed a notice of appeal on July 16, 2024, and the case was docketed in the Supreme Court of Georgia for the term beginning in December 2024.The Supreme Court of Georgia reviewed Jackson's claim that his trial counsel was ineffective for failing to object to a jury instruction related to the Street Gang Act. Jackson argued that the instruction created a constitutionally impermissible mandatory presumption. The court found that the instruction did not create a mandatory presumption or shift the burden of proof to the defendant. Instead, it explained the meaning of the phrase "further the interests of the gang" and required the jury to find beyond a reasonable doubt that the crime committed was the sort of crime the gang engaged in. Consequently, the court held that Jackson's trial counsel was not deficient for failing to object to the instruction and affirmed the trial court's decision. View "JACKSON v. THE STATE" on Justia Law