Justia Civil Rights Opinion Summaries

Plaintiffs, Carvin Thomas and Terrell Lawrence, filed a class-action lawsuit against members of the Tennessee Board of Parole, alleging that the use of a computer test, STRONG-R, to determine parole eligibility violated their constitutional right to due process. They claimed that the test produced inaccurate results due to inadequate training of correctional employees and that the results were kept secret, preventing inmates from challenging them effectively. Both plaintiffs experienced changes in their STRONG-R scores without any new negative behavior, leading to parole denials based on these scores.The United States District Court for the Middle District of Tennessee dismissed the complaint, concluding that the plaintiffs failed to state a plausible claim for relief. The court found that Tennessee’s parole statutes do not confer a protected liberty interest in parole, as they do not create a legitimate expectation of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Tennessee’s parole statutes do not sufficiently constrain the Board’s discretion to deny parole, thus not creating a constitutionally recognized entitlement to parole. The court noted that while the plaintiffs identified serious issues with the STRONG-R test, the lack of a protected liberty interest in parole precluded their due process claims. Consequently, the court affirmed the dismissal of the plaintiffs' complaint. View "Thomas v. Montgomery" on Justia Law

Planned Parenthood of Montana and Dr. Samuel Dickman challenged three laws passed by the 2021 Montana Legislature regulating abortion care. The laws included a 20-week ban on abortions (HB 136), restrictions on medication abortions and requirements for informed consent (HB 171), and a mandate for providers to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone before an abortion (HB 140).The Thirteenth Judicial District Court granted a preliminary injunction against the enforcement of these laws, which was affirmed by the Montana Supreme Court. Following discovery, the District Court granted summary judgment to the plaintiffs, concluding that the laws violated the Montana Constitution's guarantees of individual privacy, equal protection, and free speech. The court permanently enjoined the enforcement of all three laws.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court held that the 20-week ban on abortions (HB 136) violated the right to privacy because it prohibited pre-viability abortions and was not justified by a compelling state interest. The Court also found that the restrictions on medication abortions and the informed consent requirements (HB 171) infringed on the right to privacy and free speech, as they imposed unnecessary burdens on patients and providers without addressing a bona fide health risk. Lastly, the Court held that the mandate to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone (HB 140) violated the right to privacy by interfering with the patient-provider relationship without a compelling state interest.The Montana Supreme Court affirmed the District Court's judgment, permanently enjoining the enforcement of the challenged laws. View "Planned Parenthood v. State" on Justia Law

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law

DeShawn Gervin was on probation in Georgia with the sole condition that he not return to the South Georgia Judicial Circuit. He moved to North Carolina but was later imprisoned there for various crimes. A Georgia probation officer, Pamela Florence, learned of his North Carolina offenses and sought a warrant for his arrest in Georgia, falsely claiming he had violated probation by failing to report. Gervin was arrested in North Carolina and extradited to Georgia, where he spent 104 days in jail before a court found he had not violated his probation and ordered his release.Gervin sued Florence and another probation officer, Tandria Milton, under 42 U.S.C. § 1983, alleging violations of his Fourth, Eighth, and Fourteenth Amendment rights. The United States District Court for the Middle District of Georgia granted summary judgment for the defendants on the Eighth and Fourteenth Amendment claims but denied it on the Fourth Amendment claim, characterizing it as a malicious-prosecution claim.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's ruling. The court held that Gervin presented enough evidence to support his Fourth Amendment malicious-prosecution claim. The court found that Florence and Milton recklessly made false statements and omissions that led to Gervin's arrest and prolonged detention, violating his Fourth and Fourteenth Amendment rights. The court also concluded that the probation officers were not entitled to qualified immunity because the constitutional violations were clearly established at the time of their actions. View "Gervin v. Florence" on Justia Law

Three-month-old La’Mello Parker died during a confrontation between his father, Eric Smith, and law enforcement. Smith, a fugitive wanted for double homicide, used La’Mello as a human shield and fired at officers, who returned fire, killing La’Mello. La’Mello’s grandfather and brother sued various law enforcement entities and officers, alleging constitutional violations under 42 U.S.C. § 1983 and state law claims.The United States District Court for the Southern District of Mississippi dismissed the case, finding that the officers’ actions did not constitute constitutional violations and that they were protected by qualified immunity. The court also dismissed the Fourteenth Amendment claims, stating that the conduct did not shock the conscience, and declined to exercise jurisdiction over the state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the officers did not violate La’Mello’s Fourth Amendment rights as their use of force was reasonable under the circumstances. The court noted that Smith posed a grave and immediate threat, and the officers’ decision to return fire was justified. The court also found that the officers were entitled to qualified immunity because the law was not clearly established that their conduct was unconstitutional. Additionally, the court held that the Fourteenth Amendment claims failed as the officers’ actions did not shock the conscience. The court concluded that without an underlying constitutional violation, the bystander liability and municipal liability claims also failed. View "Estate of Parker v. Mississippi Department of Public Safety" on Justia Law

The case involves Deliezha Davonte Gravely, who was pulled over by a police officer for speeding. During the stop, the officer discovered that Gravely was driving with a revoked license due to a DUI and found a loaded firearm in his pocket. Gravely was subsequently indicted on multiple charges, including unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, based on his prior conviction for conspiracy to commit first-degree robbery.The Circuit Court of Mercer County ruled that Gravely's prior conviction for conspiracy to commit first-degree robbery qualified as a "felony crime of violence against the person of another" under West Virginia Code § 61-7-7(b). Gravely was convicted by a jury on all counts and sentenced to imprisonment. He appealed, arguing that the circuit court erred in classifying his conspiracy conviction as a crime of violence.The Supreme Court of Appeals of West Virginia reviewed the case de novo, focusing on whether the elements of conspiracy under West Virginia Code § 61-10-31 include a violent act against a person. The court applied the elements test from State v. Mills, which requires examining the statutory elements of the predicate offense rather than the specific conduct of the defendant. The court found that the elements of conspiracy—an agreement to commit an offense and an overt act to effect the conspiracy—do not require a violent act against a person.The Supreme Court of Appeals of West Virginia held that conspiracy to commit first-degree robbery is not a "felony crime of violence against the person of another" for the purposes of West Virginia Code § 61-7-7(b). Consequently, the court reversed Gravely's convictions for unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, and remanded the case for resentencing on his remaining convictions. View "State v. Gravely" on Justia Law

Lazerek Austin, a state prisoner, filed a lawsuit under 42 U.S.C. § 1983 against three medical providers, alleging deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Austin, representing himself, requested the court to recruit counsel due to his severe mental illness and lack of access to legal resources. The district court initially granted his motion for recruited counsel but was unable to find a volunteer attorney despite extensive efforts. Consequently, Austin continued to litigate his case pro se, participating in discovery and responding to motions.The United States District Court for the Central District of Illinois eventually granted summary judgment in favor of the defendants, concluding that a reasonable jury could not find that they violated Austin’s constitutional rights. Austin appealed, arguing that the district court erred by not continuing to search for counsel after initially granting his motion.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court noted that federal courts cannot compel attorneys to provide free services to civil litigants and that the district court made reasonable efforts to recruit counsel. The court emphasized that the district court was not required to search indefinitely for a volunteer attorney and that it reasonably concluded Austin was capable of litigating his case pro se. The appellate court affirmed the district court's decision, finding no abuse of discretion in its handling of Austin's motion for recruited counsel and its determination that Austin could proceed without counsel. View "Austin v. Hansen" on Justia Law

Edward B. Spencer, an indigent and incarcerated individual, filed multiple lawsuits against various California prison officials. He initially proceeded in forma pauperis (IFP) in each case. Spencer had previously filed numerous lawsuits while incarcerated, and he conceded that two of those actions resulted in strikes under the Prison Litigation Reform Act (PLRA). However, he disputed whether two other actions, which he voluntarily dismissed, should count as strikes.The United States District Court for the Eastern District of California revoked Spencer's IFP status in four cases, finding that he had four strikes, including the two voluntary dismissals. The district court adopted the magistrate judge's findings and recommendations, which concluded that the voluntary dismissals counted as strikes under the PLRA.The United States Court of Appeals for the Ninth Circuit reviewed the district court's revocation of Spencer's IFP status. The Ninth Circuit held that voluntary dismissals under Federal Rule of Civil Procedure 41(a)(1) do not constitute strikes under the PLRA. The court reasoned that the "on the grounds that" clause in 28 U.S.C. § 1915(g) requires grounds to be decided by a court, and voluntary dismissals do not have grounds decided by a court. Therefore, Rule 41(a)(1) voluntary dismissals cannot count as strikes because they are never "on the grounds that" the case was frivolous, malicious, or failed to state a claim.The Ninth Circuit reversed the district court's revocation of Spencer's IFP status in each of the four cases on appeal and remanded for further proceedings. The court did not address any other issues urged by the parties. View "Spencer v. Milan" on Justia Law

A custodian for a city police department sued the city and some of its employees, claiming she experienced sexual harassment and retaliation in violation of the Iowa Civil Rights Act (ICRA). The custodian alleged that a deputy chief made her uncomfortable with his behavior and comments, and that after she reported this, she faced retaliation from her administrative manager, who threatened her and her coworkers.The Iowa District Court for Linn County denied the defendants' motions for summary judgment on the custodian's claims of sexual harassment and retaliation, except for the claim of constructive discharge. The defendants then sought interlocutory review.The Iowa Supreme Court reviewed the case and found that the alleged harassment by the deputy chief was not sufficiently severe or pervasive to support an ICRA claim. The court also determined that the alleged acts of retaliation by the administrative manager did not amount to a materially adverse action as required for an ICRA claim. Consequently, the court reversed the district court's decision and remanded the case for dismissal of the custodian's claims. View "Rheeder v. Gray" on Justia Law

James Dunbar was serving a suspended sentence for criminal mischief and was on probation for being a felon in possession of a dangerous weapon. A protection order prohibited him from contacting the victim in any form. Despite this, Dunbar posted messages on his public Facebook page that referred to the victim and her deceased husband using aliases similar to their names. Some posts included threats and were intended to notify the victim. Facebook users saw these posts and informed the victim, who then viewed them.Dunbar was arrested and charged with violating the protection order and stalking. He was found not guilty on all charges. However, his probation officer alleged that these actions violated the terms of his probation, and the State moved to impose his suspended sentence. The Superior Court found that Dunbar's Facebook posts violated the protection order, thus violating his probation and suspended sentence terms. The court imposed a portion of his suspended sentence and sentenced him to twelve months in the house of corrections, all suspended, for the probation violation. Dunbar's motion for reconsideration was denied, leading to this appeal.The Supreme Court of New Hampshire reviewed the case. The court held that Dunbar's Facebook posts constituted indirect contact with the victim, violating the protection order. The court also determined that the posts were true threats and not protected by the First Amendment. Consequently, the court affirmed the Superior Court's decision that Dunbar violated the terms of his probation and suspended sentence, and upheld the imposed punishments. View "State v. Dunbar" on Justia Law