Justia Civil Rights Opinion Summaries

In this case, an individual attended the 2022 Kentucky Derby in Louisville, Kentucky, with a group to engage in expressive activities such as preaching, distributing literature, and displaying signs near the event. The area surrounding Churchill Downs was subject to a special event permit issued by the city government, which allowed Churchill Downs to restrict access to certain public streets and sidewalks to ticket holders and credentialed individuals. The plaintiff and his group entered a fenced-off, restricted area beyond posted “No Trespassing” signs, despite lacking event tickets or credentials. After repeated warnings from private security and law enforcement, the plaintiff was arrested by a Kentucky State Police trooper for criminal trespass.The plaintiff filed suit in the United States District Court for the Western District of Kentucky, asserting claims under 42 U.S.C. § 1983 for violations of his free speech, free exercise, and due process rights, as well as a Monell municipal liability claim against the city government and claims against the arresting officer. The district court granted summary judgment in favor of the defendants on all claims. It found the free speech restriction content-neutral and justified under intermediate scrutiny, concluded the free exercise claim was not properly developed, determined the permitting scheme was not unconstitutionally vague, dismissed the Monell claim for lack of an underlying constitutional violation, and granted qualified immunity to the arresting officer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the restricted area was a limited public forum and the ticketing and access restrictions were content-neutral and survived intermediate scrutiny. The court found no evidence of viewpoint discrimination, held that ample alternative channels for communication existed, and determined that the plaintiff failed to preserve his free exercise claim and did not establish a due process violation. The Monell claim failed for lack of a constitutional violation, and qualified immunity was properly granted to the officer. View "Blankenship v. Louisville-Jefferson Cnty. Metro Gov't" on Justia Law

The plaintiff claimed that Michigan had taken custody of between $200 and $600 in unclaimed property belonging to her. She alleged that, under Michigan’s Uniform Unclaimed Property Act, the state would return her property if she requested it but would not pay her any interest earned while the property was in the state’s custody, unless the property was originally interest bearing. Without first submitting a claim to reclaim her property, she brought a suit under 42 U.S.C. § 1983 against officials responsible for Michigan’s unclaimed property program, arguing that the state’s failure to pay interest amounted to an unconstitutional taking in violation of the Fifth Amendment. She sought declaratory and injunctive relief on behalf of herself and a putative class.The United States District Court for the Eastern District of Michigan dismissed her case, concluding that she lacked Article III standing because Michigan law did not grant her a property right to interest earned on her unclaimed property. The district court reasoned that, without such a property right, she could not demonstrate an injury from the state’s retention of interest.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiff had standing, as her complaint alleged a concrete financial injury: the state’s withholding of interest that she claimed was rightfully hers. The court held that the district court improperly conflated the merits of whether she was entitled to interest with the standing inquiry. The Sixth Circuit reversed the district court’s dismissal for lack of standing and remanded for further proceedings, emphasizing that the record was insufficient to resolve the merits of the takings claim at this stage. View "Hendershot v. Stanton" on Justia Law

Police investigating a fatal drive-by shooting in Philadelphia identified several suspects, including T.C., and obtained an arrest warrant for him. Detectives used multiple databases, including CLEAR and police records, to determine T.C.’s last known address, which pointed to 4838 Stenton Avenue. Believing T.C. resided there, detectives and a SWAT team executed the warrant early one morning. Instead of finding T.C., officers encountered Richard Miller and Tonya Crawley, who had lived at the residence for two years and were not connected to T.C. The officers detained Miller and Crawley briefly and then left after learning T.C. was not present. T.C. was later located and cleared of wrongdoing.Miller and Crawley sued the involved officers and the City of Philadelphia in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging that the officers lacked probable cause and violated the Fourth Amendment, and that the City failed to train or supervise its officers. The District Court dismissed the municipal-liability claim for failure to state a claim and granted summary judgment to the officers on the unlawful-entry claim, holding that they had probable cause to enter the residence.On appeal, the United States Court of Appeals for the Third Circuit reviewed both the dismissal and summary judgment de novo. The court held that, although the District Court incorrectly invoked the good-faith exception, the error was harmless because the officers had probable cause to believe T.C. lived at the address and would likely be home at the early hour. The court also held that the plaintiffs failed to allege facts sufficient to establish municipal liability, as there was no pattern of similar constitutional violations or plausible basis for single-incident liability. The Third Circuit affirmed the District Court’s decisions. View "Miller v. City of Philadelphia" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

A Black woman who had worked for a community college for nearly two decades applied for a promotion to Assistant Dean of Workforce Solutions after serving as Director of Special Populations. The position required significant experience in workforce development, including knowledge of specific funding and grant-writing. The applicant pool included her and a Hispanic male colleague who had overseen larger programs and had more direct experience with the job’s requirements. A search committee interviewed candidates, with the final hiring decision made by the Vice President of Enrollment and Outreach Initiatives.The United States District Court for the District of Maryland initially dismissed her claims of race and gender discrimination under Title VII. On appeal, the United States Court of Appeals for the Fourth Circuit reversed and remanded in part, allowing her to pursue a disparate treatment claim focused on the college’s failure to promote her and its issuance of a corrective action letter for a payroll error. Following discovery, the district court granted summary judgment for the college, finding that the plaintiff did not present sufficient evidence of intentional discrimination, and that the employer’s stated reason—selecting the more qualified candidate—was not shown to be pretextual.Reviewing the case de novo, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s grant of summary judgment. The court assumed that the plaintiff established a prima facie case of discrimination but held that she did not meet her burden to show the employer’s justification was pretext. The court found that the selected candidate’s qualifications aligned more closely with the position, and that neither evidence of preselection, circumstantial evidence of discriminatory comments, nor disparate discipline sufficed to demonstrate intentional discrimination or pretext. The court thus affirmed the judgment in favor of the college. View "Hood-Wilson v. Board of Trustees, Community College of Baltimore" on Justia Law

Jay and Kendall Nygard, who have had a long history of disputes with the City of Orono regarding property matters, became involved in a conflict when Jay replaced their driveway without obtaining a permit as required by city code. Throughout the permitting process and subsequent communications with the City, Kendall was copied on email exchanges but did not perform the driveway work herself. After efforts by city officials to secure compliance failed, both Jay and Kendall were referred for prosecution for violating the permit requirement. However, a state court later dismissed the charge against Kendall, finding that the ordinance required only the person actually performing the work to obtain the permit, and Jay, not Kendall, had done the work.Following this dismissal, Kendall and Jay brought federal claims against the City, including a malicious prosecution claim. The United States District Court for the District of Minnesota dismissed all claims, but on appeal, the United States Court of Appeals for the Eighth Circuit allowed Kendall’s malicious prosecution claim to proceed, finding her complaint sufficiently alleged the City lacked probable cause. On remand, the district court declined to exercise pendent jurisdiction. Kendall then filed a new malicious prosecution claim based on diversity jurisdiction, but the district court again granted summary judgment to the City, concluding Kendall could not prove the City acted with malicious intent.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s grant of summary judgment. The court held that Kendall failed to offer evidence that the City knowingly and willfully instituted a groundless prosecution against her, as required to establish malicious intent under Minnesota law. The court found that, even if probable cause was lacking, there was no evidence of malice, and that any deficiency in probable cause was not so blatant as to permit an inference of malicious intent. The judgment in favor of the City was therefore affirmed. View "Nygard v. City of Orono" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

During the COVID-19 pandemic, a university in Nebraska instituted a policy requiring all students to be vaccinated against COVID-19 by a specified deadline, with the only exemptions allowed for medical reasons or until a vaccine received full FDA approval. Religious exemptions were not permitted. Students who failed to comply were unenrolled and barred from campus, and some had holds placed on their accounts, preventing access to transcripts. One student complied with the mandate but suffered adverse effects and was medically exempted from further doses. Another student withdrew voluntarily before the deadline.After the university enforced the mandate, several students sought injunctive relief in the District Court for Douglas County to prevent their unenrollment, alleging breach of contract and unjust enrichment. The court denied relief, finding that any contract included the Emergency Use Authorization waiver agreements and that the students breached the contract by not being vaccinated after FDA approval. An initial appeal was dismissed by the Nebraska Supreme Court for lack of a final, appealable order. The students then consolidated their actions and filed an operative complaint alleging breach of implied contract, denial of due process, conversion, negligence, and violations of the Nebraska Consumer Protection Act (NCPA). The district court dismissed the complaint with prejudice and denied leave to amend.The Nebraska Supreme Court reviewed the district court’s dismissal de novo and found that the students plausibly alleged claims for breach of an implied contract and conversion, based on the university’s unilateral modification of conditions mid-semester and the withholding of transcripts. The court affirmed the dismissal of the negligence and NCPA claims, finding them preempted by the federal Public Readiness and Emergency Preparedness Act, and held that the due process claim was abandoned on appeal. The case was affirmed in part, reversed in part, and remanded for further proceedings on the breach of contract and conversion claims. View "Ramaekers v. Creighton University" on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law