Justia Civil Rights Opinion Summaries

The dispute arose after a citizen, Sanderson, served a summons and complaint on Kelley Cole, the Walsh County State’s Attorney, alleging that Cole failed to investigate crimes as required by law and deprived him of constitutional rights. Sanderson later claimed the complaint was mistakenly served and was only a draft, not intended for court filing. Cole, upon being served, filed the summons and complaint with the district court, moved to dismiss for failure to state a claim, and sought attorney’s fees, arguing the action was frivolous and barred by prosecutorial immunity.The District Court of Walsh County, Northeast Judicial District, reviewed the matter. Cole’s motion to dismiss was based on North Dakota’s procedural rules, which allow an action to commence upon service of summons, and permit a defendant to file the complaint. Sanderson responded by agreeing to dismiss but contested the court’s jurisdiction and objected to the lack of a hearing. The district court determined it had jurisdiction, found Sanderson had commenced the action, and concluded the complaint lacked factual allegations and was barred by absolute prosecutorial immunity. The court dismissed the action, denied Sanderson’s subsequent motions, and awarded Cole attorney’s fees, finding the claims frivolous.The Supreme Court of North Dakota affirmed the district court’s judgment. It held that jurisdiction was proper since Sanderson initiated the action by serving process, and procedural irregularities in filing did not affect substantial rights or deprive the court of jurisdiction. The Supreme Court agreed that the complaint failed to state a claim and that absolute prosecutorial immunity applied. It further upheld the finding of frivolousness and the award of attorney’s fees, determining there was no abuse of discretion or violation of procedural rights. View "Sanderson v. Cole" on Justia Law

A female custodian employed by a public university filed a Title IX complaint alleging physical assault and a pattern of sexual harassment by a male co-worker, both of whom were members of the same union. The university, which receives federal funding, initiated a Title IX grievance process compliant with 2020 federal Title IX Regulations. After an investigation and hearing in which both parties participated, university decision-makers found the accused violated university policy and determined there was just cause for his termination. The accused’s appeal within the Title IX process was unsuccessful, and he was terminated.The union representing the accused employee filed a grievance under its 2019 collective negotiation agreement (CNA) with the university, seeking arbitration to determine whether the termination was for just cause. The university denied the grievance, arguing that the federal Title IX Regulations preempted the CNA’s grievance procedure. The union sought arbitration through the New Jersey Public Employment Relations Commission (PERC), which denied the university’s request to restrain arbitration and held, applying state preemption law, that the Title IX Regulations did not preempt arbitration. The Superior Court, Appellate Division, affirmed, finding no conflict precluding the union’s grievance procedure.The Supreme Court of New Jersey reviewed the case and reversed the lower courts. The Court held that the CNA’s grievance procedure is preempted by the 2020 federal Title IX Regulations because those regulations require that any grievance or appeal process must apply equally to both complainant and respondent. The CNA’s arbitration process excluded the alleged victim from participation, granting rights only to the accused. The Court concluded that this inequality creates a direct conflict with federal law, which therefore preempts the CNA’s arbitration provision in this context. The decision is limited to this particular CNA and does not preempt all union grievance procedures. View "In the Matter of Rutgers, the State University of New Jersey v. AFSCME Local 888" on Justia Law

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" on Justia Law

In April 2019, a man was arrested by Chicago police officers after he refused to leave the area of an active crime scene despite repeated orders. During his transport to the police station, he declined to wear a seatbelt. While handcuffed in the backseat, he was injured when the transporting officer braked suddenly, causing him to hit his head on the divider. He was later treated for a cut lip. The disorderly conduct charges brought against him were subsequently dropped.The individual brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging constitutional violations under 42 U.S.C. § 1983—specifically, false arrest, state-created danger, excessive force, and failure to provide adequate medical care. He also asserted a state-law claim for malicious prosecution. The District Court granted summary judgment in favor of the officers on all claims, finding either no constitutional violation or that qualified immunity applied. The plaintiff appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the District Court’s grant of summary judgment de novo. The appellate court affirmed the lower court’s judgment, holding that the officers were entitled to qualified immunity on all federal claims, as there was at least arguable probable cause for the arrest and no clearly established constitutional right was violated in the circumstances presented. The court also affirmed the dismissal of the malicious prosecution claim, concluding the plaintiff failed to demonstrate malice by the officers, a required element under Illinois law. Thus, judgment for the officers was affirmed in its entirety. View "O'Neal Johnson v Edwards" on Justia Law

Joshua Steeb was severely injured after intervening to save his friend, Teresa Fitzgerald, from a violent dog attack at the home of Linda Motter, Fitzgerald’s relative. The dog, known for its aggressive history and previously quarantined by local authorities, was reported to animal control for removal. Officer Mike Ehart, aware of the dog’s past behavior, arrived on the scene but instead of personally handling the dog, he instructed Fitzgerald to retrieve and secure the animal in his truck. Despite Fitzgerald’s apprehension and knowledge of the dog’s dangerous tendencies, she attempted the task and was attacked. Steeb’s attempt to rescue her resulted in the dog mauling him, causing permanent injuries.The United States District Court for the Western District of Michigan reviewed Steeb’s claims under 42 U.S.C. § 1983, which were based on the “state-created-danger” theory of substantive due process. Steeb argued that Officer Ehart’s conduct created or increased the risk that led to the attack and that the City of Battle Creek failed to properly train and equip Ehart. The district court dismissed all federal claims, finding that Steeb had not alleged a plausible constitutional violation. As a result, the court declined to exercise jurisdiction over the related state law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that Steeb failed to plausibly allege that Officer Ehart took an “affirmative act” sufficient to invoke the state-created-danger doctrine, primarily because Fitzgerald voluntarily assumed the risk of handling the dangerous dog. Without a constitutional violation, the municipal liability claim against the City of Battle Creek also failed. The appellate court thus affirmed the dismissal of Steeb’s claims. View "Steeb v. Ehart" on Justia Law

While serving a portion of his sentence at the Federal Correctional Complex in Terre Haute, Indiana, Derek Thomas was repeatedly assaulted by his cellmate, suffering serious physical and psychological harm. Thomas initially sought protective custody after other inmates threatened him due to his conviction as a sex offender. Despite being placed in the Special Housing Unit, he experienced continued threats, food tampering, and was eventually housed with an inmate who violently assaulted and allegedly raped him. Thomas reported these incidents through notes to prison staff and verbally to counselors and psychologists, yet he was not removed from his cell until after the alleged rape. Following his removal, Thomas sought medical and psychological care, but claims his injuries and trauma were not adequately addressed.After filing a pro se complaint in the United States District Court for the Southern District of Indiana, Thomas was allowed to proceed with claims that certain prison officials failed to protect him and were deliberately indifferent to his serious medical needs, both in violation of the Eighth Amendment. The defendants moved for summary judgment, raising qualified immunity as a defense. Thomas’s counsel did not address qualified immunity in the response to the motion, and Thomas later confirmed reliance on counsel’s submission. The district court granted summary judgment to the defendants, concluding Thomas’s claims either presented a new Bivens context not recognized by precedent or failed because Thomas did not overcome the qualified immunity defense.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that Thomas’s failure-to-protect claim could not proceed because it sought to expand Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics beyond existing precedent. Regarding the deliberate indifference claim, the court held that Thomas forfeited his opposition to qualified immunity by not raising it in the district court and did not meet the criteria for appellate review of a forfeited argument. View "Thomas v. Carmichael" on Justia Law

Michael Victor was detained overnight in an Otsego County, Michigan jail after being arrested for disorderly conduct and resisting an officer. Victor, who has epilepsy, did not receive his prescribed anti-seizure medication while in custody, despite his mother delivering it to the jail and officers being informed of his medical needs. The jail’s procedures required officers to contact an on-call medical provider from Advanced Correctional Healthcare (ACH) before administering any medication. After his release the next morning, Victor suffered a seizure, resulting in significant injuries.The United States District Court for the Eastern District of Michigan heard Victor’s civil rights suit against ACH and Nurse Kimberly Reynolds. At trial, Victor presented evidence including testimony from officers and medical staff, but no one recalled making or receiving a call to ACH regarding his medication, and no records indicated any such contact. The jury found in favor of Reynolds but against ACH, awarding Victor economic, noneconomic, and punitive damages. ACH moved for judgment as a matter of law or a new trial, arguing insufficient evidence that any officer contacted ACH. The district court granted ACH’s motions, holding there was not enough evidence for a reasonable jury to find that contact occurred, and also denied Victor’s request for sanctions related to alleged discovery violations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Victor had presented sufficient evidence to allow a reasonable jury to find that an officer had contacted ACH about his medication needs. The court held that the absence of any records and the lack of recollection from all involved witnesses meant Victor had not met his burden. Testimony indicating intent to call, without corroboration, was not enough. The Sixth Circuit affirmed the district court’s judgment as a matter of law for ACH and found no abuse of discretion in denying sanctions. View "Victor v. Reynolds" on Justia Law

Louis Alford was stopped by Cannon County Sheriff’s Deputies outside Woodbury, Tennessee for minor traffic violations. During the stop, Deputy Deffendoll observed a syringe filled with clear liquid inside Alford’s truck. A subsequent search revealed additional empty syringes, powder in a baggie, paper with residue, empty baggies, prescription pills not belonging to either occupant, and digital scales. Alford was arrested and charged with three state drug offenses. He spent time in jail, and his parole was revoked, resulting in over a year in prison. The drug charges were later dismissed. Forensic analysis showed the powder contained methamphetamine, but other items either contained noncontrolled substances or were not tested.Alford filed suit in the United States District Court for the Middle District of Tennessee against Deputies Deffendoll and Smith, and Cannon County, asserting false arrest, malicious prosecution, and Monell liability under 42 U.S.C. § 1983. After discovery, the district court granted summary judgment to the defendants on the federal claims, finding no genuine issue of material fact as to Smith’s involvement, and that Deffendoll had probable cause for arrest and prosecution. The court also rejected the Monell claim, finding no underlying constitutional deprivation. Alford appealed only the federal claims.On review, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The court held that Smith was not personally involved in the arrest, and Deffendoll had probable cause to arrest and charge Alford for simple possession and possession of drug paraphernalia. The court applied the proper summary judgment and qualified immunity standards, and clarified that probable cause existed for the charges that led to Alford’s seizure. Without a constitutional violation, Alford’s Monell claim failed. The court affirmed summary judgment for all defendants. View "Alford v. Deffendoll" on Justia Law

The defendant was charged with two counts of aggravated battery of a police officer following an incident at Longview Park in Rock Island, Illinois. The events began after the defendant’s ex-wife contacted police out of concern for their daughter’s welfare, based on alarming statements made by the defendant. Police arrived and, after deciding the child should leave with her mother, the defendant became upset and tried to approach his daughter, prompting police intervention. An altercation ensued: one officer pushed the defendant, who pushed the officer’s arm away, and another officer tackled the defendant, after which the defendant wrapped his arm around the officer’s neck. The defendant was charged based on these physical contacts.The case was tried in the Circuit Court of Rock Island County. During trial, the defendant requested the jury be instructed on self-defense, arguing his actions were a response to excessive force by the officers. The court denied this request, finding the evidence did not support each element required for a self-defense instruction. The jury acquitted the defendant of battery against one officer but convicted him as to the other. The defendant’s posttrial motion challenging the lack of a self-defense instruction was denied.On appeal, the Appellate Court, Fourth District, affirmed the conviction, applying a two-step inquiry: first, whether there was sufficient evidence of excessive force by police, and second, whether all six elements of self-defense were supported. The appellate court found no abuse of discretion in refusing the instruction, focusing on the defendant’s subjective belief element.The Supreme Court of Illinois reviewed the case to resolve a conflict among appellate courts regarding self-defense instructions in cases involving alleged excessive police force. The court held that the long-standing six-element test for self-defense applies, and found there was some evidence for each element in the record. The trial court abused its discretion by refusing the instruction. The Supreme Court reversed the lower courts’ judgments and remanded for further proceedings. View "People v. Vesey" on Justia Law