Justia Civil Rights Opinion Summaries

Michael Chapman, an Alabama inmate, sued prison officials and staff for deliberate indifference to his medical needs, violating the Eighth Amendment. Chapman alleged that an untreated ear infection led to severe injuries, including mastoiditis, a ruptured eardrum, and a brain abscess. He also claimed that the prison's refusal to perform cataract surgery on his right eye constituted deliberate indifference. The district court granted summary judgment for all defendants except the prison’s medical contractor, which had filed for bankruptcy.The United States District Court for the Middle District of Alabama found Chapman’s claim against nurse Charlie Waugh time-barred and ruled against Chapman on other claims, including his request for injunctive relief against Commissioner John Hamm, citing sovereign immunity. The court also concluded that Chapman’s claims against other defendants failed on the merits and dismissed his state-law claims without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court reversed the district court’s determination that Chapman’s claim against Waugh was time-barred, finding that Chapman’s cause of action accrued within the limitations period. The court vacated the district court’s judgment for Waugh and remanded for reconsideration in light of the recent en banc decision in Wade, which clarified the standard for deliberate indifference claims. The court also vacated the judgment for Hamm on Chapman’s cataract-related claim for injunctive relief, as sovereign immunity does not bar such claims. Additionally, the court vacated the summary judgment for all other defendants due to procedural errors, including inadequate notice and time for Chapman to respond, and remanded for further consideration. View "Chapman v. Dunn" on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law

Stanley Felton, also known as G’esa Kalafi, was incarcerated at the Wisconsin Secure Program Facility from 2007 to 2015. He filed a pro se complaint under 42 U.S.C. § 1983 against several prison employees, alleging Eighth and Fourteenth Amendment violations due to his prolonged solitary confinement and First Amendment violations for the confiscation of his outgoing mail. Felton claimed that Warden Tim Haines and his successor Gary Boughton were responsible for his continued solitary confinement, and that three other officials, Lebbeus Brown, Joseph Cichanowicz, and Daniel Winkleski, illegally confiscated his mail.The United States District Court for the Western District of Wisconsin dismissed Felton’s Eighth and Fourteenth Amendment claims after screening the complaint and denied his motion to file an amended complaint. After discovery, the court granted summary judgment against Felton on his First Amendment claims, concluding that the prison officials were entitled to qualified immunity and that the confiscation of Felton’s mail did not violate his First Amendment rights.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decisions, holding that Felton did not adequately allege a Fourteenth Amendment due process violation, as the delayed review of his administrative confinement did not constitute a constitutional violation. The court also found that Felton had waived his Eighth Amendment claim on appeal by not sufficiently developing the argument. Regarding the First Amendment claims, the court concluded that the confiscation of Felton’s letter containing threatening language was justified and that the defendants were entitled to qualified immunity for retaining the state court order that accompanied the letter. The court emphasized that the defendants’ actions did not violate clearly established law. View "Felton v Brown" on Justia Law

Raquel Haro was arrested at a college party and subjected to a strip search, including a visual cavity inspection, during the booking process at Porter County Jail. The jail uses a body scanner for all arrestees, and Haro's scan revealed a small, unidentified object in her pelvic region. Haro admitted that the scan justified a strip search but argued that the search became unreasonable once it was revealed that she was wearing a bodysuit with metal snaps. She sued Porter County, the sheriff’s department, and the officer who conducted the search under 42 U.S.C. § 1983, claiming the search violated her Fourth and Fourteenth Amendment rights.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants, concluding that the strip search was justified and reasonable in scope. Haro appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that the strip search was justified by reasonable suspicion due to the anomaly on the body scan. The court also found that it was reasonable for the officer to complete the strip search, including the visual cavity inspection, even after discovering the metal snaps on Haro's bodysuit. The court emphasized the deference given to jail officials in maintaining security and found no constitutional violation in the manner or scope of the search. Consequently, the court did not address the qualified immunity defense or the liability of the Porter County Sheriff’s Department under Monell. The decision of the district court was affirmed. View "Haro v. Porter County" on Justia Law

A deputy sheriff from Doña Ana County, New Mexico, fatally shot Diego Eguino-Alcala during a standoff. The personal representative of Eguino-Alcala’s estate (the “Estate”) filed a lawsuit alleging excessive force and municipal liability under 42 U.S.C. § 1983, along with state-law claims. The district court granted summary judgment in favor of Deputy Sheriff Arturo Ortega, awarding him qualified immunity and dismissing the federal claims against him and the Board of County Commissioners of Doña Ana County. The Estate appealed.The United States District Court for the District of New Mexico found that Deputy Ortega’s use of deadly force was reasonable under the circumstances. The court emphasized that Eguino-Alcala’s sudden movement, which appeared to be a draw-like motion, caused Deputy Ortega to reasonably perceive an immediate and lethal threat. The court also concluded that Deputy Ortega’s actions did not violate clearly established law, thus granting him qualified immunity.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that Deputy Ortega’s use of deadly force was reasonable, given the totality of the circumstances. The court noted that Eguino-Alcala’s failure to comply with commands, his sudden movement, and the information that he might be armed justified the deputy’s actions. The court concluded that the Estate failed to provide sufficient evidence to create a genuine dispute of material fact regarding the reasonableness of the use of force. Consequently, the Tenth Circuit upheld the summary judgment and the dismissal of the § 1983 claims. View "Alcala v. Ortega" on Justia Law

Amelia Baca, a 75-year-old woman with dementia, was fatally shot by Officer Jared Cosper in Las Cruces, New Mexico. On April 16, 2022, Baca's daughter called 911, reporting that Baca had become aggressive and threatened to kill her and her daughter. Officer Cosper, who was nearby, responded to the call. Upon arrival, he saw Baca holding knives and ordered her to drop them. Baca did not comply and took two slow steps towards Cosper, who then shot her twice, resulting in her death.The Estate of Amelia Baca filed a complaint in the United States District Court for the District of New Mexico, alleging that Officer Cosper used excessive force in violation of the Fourth Amendment. The district court granted summary judgment in favor of Cosper on qualified immunity grounds, concluding that the Estate had not raised a genuine dispute of material fact regarding Cosper's perception of an immediate threat.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court concluded that the district court erred in granting summary judgment. Viewing the evidence in the light most favorable to the Estate, the Tenth Circuit determined that a reasonable jury could find a Fourth Amendment excessive-force violation. The court also held that such a violation was clearly established under controlling law at the time of the shooting. Consequently, the Tenth Circuit reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Baca v. Cosper" on Justia Law

A man on probation was subject to a domestic violence protective order (DVPO) requiring him to give a day's notice to security personnel before visiting the medical center where his former girlfriend worked. The woman alleged that the man violated this notice provision multiple times over three years, causing her severe emotional distress and job loss. The probation officer investigated the alleged violations but decided not to revoke the man's probation or penalize him.The Superior Court of Alaska, Third Judicial District, Anchorage, granted summary judgment for the State, finding no genuine issues of material fact, that the probation officer fulfilled her duty of reasonable care, and that her actions were shielded by discretionary function immunity. The woman appealed the decision.The Supreme Court of the State of Alaska reviewed the case and concluded that there was no genuine issue of material fact to preclude summary judgment for the State regarding whether the probation officer fulfilled her operational duty to investigate the alleged violations. The court further concluded that the probation officer's subsequent decisions were shielded from suit by discretionary function immunity. The Supreme Court affirmed the superior court's grant of summary judgment. View "Smith v. Department of Corrections" on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

Jason Waterhouse, high on methamphetamine, barricaded himself in his sister's basement and started a fire when Lakewood Police Department officers arrived. After an hour of failed negotiations, seven officers entered the basement to extract him and locate the fire. Sergeant Marc Direzza, providing lethal cover, was among the last two officers in the basement when Waterhouse burst out of a bedroom and rushed towards them. Another officer fired a beanbag shotgun, and Direzza fired his pistol, killing Waterhouse with a shot to the back.The Estate of Jason Waterhouse filed a Fourth Amendment excessive-force claim under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado. The district court granted summary judgment in favor of Sergeant Direzza, concluding he was entitled to qualified immunity. The court found that Direzza's use of lethal force was reasonable under the circumstances and did not violate clearly established law. The district court also dismissed a state-law wrongful-death claim without prejudice.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's summary judgment, holding that Sergeant Direzza was entitled to qualified immunity. The court determined that Direzza's use of lethal force was objectively reasonable given the dangerous circumstances, including the fire and smoke, and the perceived threat posed by Waterhouse. The court also affirmed the dismissal of the wrongful-death claim, as it was contingent on the outcome of the excessive-force claim. View "Estate of Jason Waterhouse v. Direzza" on Justia Law