Justia Civil Rights Opinion Summaries

James King sued the United States under the Federal Tort Claims Act (FTCA) and individual government employees under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging physical abuse by U.S. officials. The district court granted summary judgment to the defendants on both claims. King appealed only the Bivens claim, making the FTCA judgment final. The individual defendants argued that the FTCA's "judgment bar" precluded the Bivens claim. The Supreme Court ultimately ruled in favor of the defendants, stating that the FTCA judgment barred the Bivens claim.King then filed a Rule 60(b) motion in the district court to reopen the FTCA judgment to withdraw his FTCA claim and avoid the judgment bar. The district court denied the motion, reasoning that attorney error or strategic miscalculation is not a valid basis for reopening under Rule 60. King appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The court held that the district court did not abuse its discretion, as attorney error or strategic miscalculation does not justify reopening a final judgment under Rule 60. The court emphasized the public policy favoring the finality of judgments and noted that Rule 60(b)(6) relief is only available in exceptional or extraordinary circumstances, which were not present in this case. View "King v. United States" on Justia Law

Joseph Heid filed a lawsuit under 42 U.S.C. § 1983 against Orange County Sheriff's Deputies Mark Rutkoski and Forrest Best, alleging they used unreasonable force in violation of the Fourth Amendment. The incident occurred after Heid had a domestic dispute, left his house, and later returned armed with a rifle. He engaged in a gunfight with deputies in his backyard and then re-entered his house. When he exited the house again, Deputies Rutkoski and Best, believing he was still armed, shot him multiple times.In the Circuit Court of the Ninth Judicial Circuit, Heid was found guilty of several charges, including Attempted Second Degree Murder of a Law Enforcement Officer and Resisting an Officer with Violence. Heid then filed a civil lawsuit, and the United States District Court for the Middle District of Florida denied the deputies' motion for summary judgment, which asserted qualified immunity. The District Court found there was a genuine factual dispute regarding whether the deputies used excessive force and whether Heid posed a threat when he exited the house.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that Deputies Rutkoski and Best did not violate Heid's Fourth Amendment rights. The court reasoned that the deputies reasonably believed Heid was armed and dangerous based on the information they had, including Heid's recent gunfight with other deputies and his rapid exit from the house. The court held that the use of force was reasonable under the circumstances and that the deputies were entitled to qualified immunity. The judgment of the District Court was reversed, and the case was remanded. View "Heid v. Rutkoski" on Justia Law

Abdul Malik Muhammad was convicted of first-degree murder in 2001 for the 1999 shooting death of Damone Mims. Muhammad was interrogated by Chicago police detectives and allegedly made incriminating statements, which he later denied. He was sentenced to 50 years in prison. Muhammad's conviction and sentence were affirmed on direct appeal, and his subsequent postconviction petition and habeas corpus petition were denied.Muhammad later filed a claim with the Illinois Torture Inquiry and Relief Commission (TIRC), alleging he was tortured by police during his interrogation. The TIRC found sufficient evidence of torture to merit judicial review and referred the case to the Cook County Circuit Court. The court appointed the Office of the Special State’s Attorney, including Robert Milan, as special prosecutor. After two years of discovery, Milan moved to terminate the judicial review proceedings, arguing the TIRC acted outside its authority. The circuit court granted the motion to terminate and denied Muhammad's motions to rescind Milan's appointment as special prosecutor.Muhammad appealed, and the appellate court reversed the circuit court's orders, finding the TIRC's definition of "tortured confession" was reasonable and that Muhammad's statements qualified as such. The appellate court also found an actual conflict of interest with Milan's appointment and remanded the case for an evidentiary hearing.The Illinois Supreme Court reviewed the case and affirmed the appellate court's decision to reverse the termination of the proceedings under the TIRC Act, agreeing that the TIRC's definition of "tortured confession" was appropriate. However, the Supreme Court reversed the appellate court's decision regarding Milan's appointment, finding no actual conflict of interest. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Muhammad" on Justia Law

Shawn Bell was charged with several violent crimes. During jury selection, the State used a peremptory challenge to exclude juror 39, prompting an objection from the defense under GR 37, which addresses potential racial or ethnic bias in jury selection. The prosecutor justified the challenge by claiming juror 39 was inattentive, while the defense argued that the COVID-19 mask requirement made it difficult for jurors to follow the questioning. The trial court denied the GR 37 objection, relying on the juror's admission of inattention and the judge's own observations. Bell was subsequently convicted.Bell appealed, and the Washington Court of Appeals reversed his convictions, finding that the trial court had violated GR 37 by allowing the peremptory challenge against juror 39. The appellate court concluded that the trial court's decision was incorrect and warranted a reversal of Bell's convictions.The Supreme Court of the State of Washington reviewed the case and held that a de novo standard of review is required for GR 37 objections. The court emphasized that the analysis must consider whether an objective observer could view race or ethnicity as a factor in the peremptory challenge. The court found that the trial judge's subjective impressions of juror 39's demeanor were insufficient to justify the challenge. The court also noted that similar responses from other jurors who were not challenged raised concerns about potential bias.The Supreme Court affirmed the Court of Appeals' decision, concluding that an objective observer could view race as a factor in the State's peremptory challenge against juror 39. The court reversed Bell's convictions and remanded the case for a new trial. View "State v. Bell" on Justia Law

Plaintiff Karim Codrington was subjected to an unlawful traffic stop, search, and arrest by Louisville Metro Police Department officers. During the criminal proceedings, a Kentucky state court suppressed the evidence seized from his vehicle and dismissed the charges. Over three years later, Codrington filed a 42 U.S.C. § 1983 lawsuit, alleging that the officers planted drugs on him, provided those drugs to prosecutors, and stole thousands of dollars from him.The United States District Court for the Western District of Kentucky granted summary judgment in favor of the defendants on all claims, finding that Codrington’s claims were either barred by the statute of limitations or failed on their merits. Specifically, the court found that the unlawful search and seizure, selective enforcement, and false arrest/imprisonment claims were time-barred. The court also found that Codrington failed to provide sufficient evidence to support his fabrication-of-evidence and malicious-prosecution claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment on the unlawful search and seizure, selective enforcement, false arrest/imprisonment, malicious prosecution, and state-law conversion claims. However, the court reversed the district court’s grant of summary judgment on the fabrication-of-evidence claim, finding that there was a genuine dispute of material fact regarding whether the officers fabricated evidence. The court also vacated the district court’s judgment on Codrington’s Monell claims and remanded for further proceedings. View "Codrington v. Dolak" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

Plaintiff Jere Eaton sued the City of Stamford and police officer Steven Estabrook, alleging that Estabrook used excessive force during a protest on August 8, 2020. Eaton claimed that Estabrook lifted her by her bra strap, drove her backward several feet, and dropped her on the ground without warning, violating her Fourteenth Amendment rights and committing assault and battery under Connecticut state law. Estabrook and the City of Stamford moved for summary judgment on the grounds of qualified immunity and state governmental immunity.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants. The court found that while there were genuine disputes of material fact regarding whether Estabrook used excessive force, Estabrook was entitled to qualified immunity because it was not clearly established at the time that his actions were unconstitutional. The court also granted summary judgment on Eaton’s state law claims, concluding that Estabrook was entitled to state governmental immunity.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that there were genuine disputes of material fact regarding the use of excessive force. However, the appellate court concluded that Estabrook was not entitled to qualified immunity at this stage because the same factual disputes also affected whether his actions were clearly established as unconstitutional at the time. The court affirmed the district court’s judgment in part, vacated it in part, and remanded the case for further proceedings. The appellate court upheld the district court’s decision regarding state governmental immunity for the state law claims. View "Eaton v. Estabrook" on Justia Law

Plaintiff, a person with quadriplegia, purchased cellular service from an Altice retail store in 2019. He was not shown any documents containing arbitration provisions at the time of purchase. Instead, he received a receipt stating that all documents and agreements would be sent electronically to his email. A week later, he bought a phone from the same store and signed a Retail Installment Contract (RIC) that incorporated the terms of the customer service agreement (CSA), which included arbitration provisions. In June 2021, during the COVID-19 pandemic, plaintiff was denied access to an Altice store for not wearing a face mask and the police were called. Plaintiff filed a complaint in October 2022, alleging discrimination and harassment under the New Jersey Law Against Discrimination.The trial court dismissed the complaint and compelled arbitration based on an affidavit from Altice's Senior Director of Business Process Management, which claimed that the CSA would have been emailed to the plaintiff. The Appellate Division affirmed, finding that the parties' conduct evidenced a binding agreement.The Supreme Court of New Jersey reviewed the case and held that under N.J.R.E. 406, evidence of a specific, repeated, and regular business habit or practice is admissible to establish a rebuttable presumption that a business acted in conformity with that habit or practice. However, the court found that Altice produced insufficient evidence of such a habit or practice. The affidavit provided by Altice lacked the necessary specificity to establish that the CSA was emailed to the plaintiff. Consequently, the court did not reach the issue of mutual assent to arbitrate. The judgment of the Appellate Division was reversed, and the case was remanded for trial. View "Fazio v. Altice USA" on Justia Law

Robin Niceta, a former caseworker with the Arapahoe County Department of Human Services, was assigned to investigate allegations of child abuse against Paul Berryman. Niceta allegedly made false statements during the investigation and custody proceedings, which led to the removal of Berryman’s daughters from his custody for a year and a half. After the Berrymans regained custody, they sued Niceta under 42 U.S.C. § 1983, claiming her conduct violated their procedural and substantive due process rights under the Fourteenth Amendment.The United States District Court for the District of Colorado denied Niceta’s motion to dismiss the claim, rejecting her assertions of qualified immunity and absolute testimonial immunity for statements made at a custody hearing. Niceta then filed an interlocutory appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court agreed with the district court that Niceta was not entitled to qualified immunity because she failed to adequately raise the defense. However, the Tenth Circuit disagreed with the district court regarding absolute testimonial immunity. The court held that Niceta is entitled to absolute immunity for statements made during her testimony at the custody hearing but not for statements made outside of that hearing.The Tenth Circuit vacated the district court’s judgment and remanded the case for the district court to determine whether any of the Berrymans’ claims could survive without considering Niceta’s testimonial statements made at the custody hearing. View "Berryman v. Niceta" on Justia Law

In 2002, Tracy Allen Hampton was convicted of killing Charles Findley, Tanya Ramsdell, and Ramsdell’s unborn child. A jury sentenced him to death. The Arizona Supreme Court affirmed Hampton’s convictions and sentences on direct appeal and denied his petition for state post-conviction relief. Hampton then filed a federal habeas petition under 28 U.S.C. § 2254, which the district court denied.Hampton raised four certified claims on appeal. The United States Court of Appeals for the Ninth Circuit held that each lacked merit. The court found that the State did not violate Brady v. Maryland or Napue v. Illinois in connection with the testimony of a jailhouse informant, George Ridley. Hampton was not prejudiced by his trial counsel’s alleged failure to obtain evidence that could have been used to impeach Ridley. The court also held that Hampton’s defense counsel were not constitutionally ineffective at the guilt or sentencing phases of his trial. Additionally, the district court acted within its discretion in denying Hampton’s request for evidentiary development on his Brady, Napue, and ineffective assistance of counsel claims. The court declined to expand the certificate of appealability to include Hampton’s uncertified claims.The Ninth Circuit affirmed the district court’s denial of Hampton’s federal habeas petition. The court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law, nor was it based on an unreasonable determination of the facts. The court also denied Hampton’s motion for reconsideration as moot. View "HAMPTON V. SHINN" on Justia Law