Justia Civil Rights Opinion Summaries

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

Six residents of the Town of Newburgh sued the Town and its Town Board, alleging that the Board’s at-large electoral system unlawfully diluted the votes of Black and Hispanic residents, in violation of Section 17-206 of the New York Voting Rights Act (NYVRA). The plaintiffs argued that the method of electing all five Town Board members at-large prevented Black and Hispanic voters, who together made up about 40% of the population, from electing their preferred candidates or influencing election outcomes. They sought a court declaration that the at-large system violated the NYVRA and an injunction requiring the Town to implement a different electoral system.The Town of Newburgh moved for summary judgment, arguing that Section 17-206 was facially unconstitutional under the Equal Protection Clauses of the U.S. and New York Constitutions, and that its current election system complied with the NYVRA. The Supreme Court, Orange County, granted the Town’s motion, holding that the Town could challenge the statute because it allegedly could not comply with the NYVRA without violating equal protection, and declared the provision—and the entire NYVRA—unconstitutional. The Appellate Division reversed, holding that the Town lacked capacity to bring this challenge since it had not shown that compliance with the NYVRA would force it to violate equal protection, and that the Supreme Court erred in invalidating the statute.The New York Court of Appeals reviewed the case and held that the Town of Newburgh, as a political subdivision created by the State, could not bring a facial constitutional challenge to the NYVRA's vote-dilution provision. The court reaffirmed the longstanding rule that political subdivisions generally lack authority to challenge state laws unless a narrow exception applies, and found that no such exception was met here. The Appellate Division’s order was affirmed. View "Clarke v Town of Newburgh" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

A Concord police officer discovered her firearm missing from the station’s lockers in 2013. Investigation revealed that another officer, the plaintiff, had mistakenly taken the firearm while transporting a prisoner to a hospital. The plaintiff gave inconsistent accounts about when she realized the mistake, telling supervisors she noticed it at the station, while her partner reported she only realized it at the hospital. An internal affairs investigation found the plaintiff’s statements lacked credibility and concluded she had lied to colleagues and supervisors about the incident. The police chief sustained these findings, terminated her employment, and submitted her name for inclusion on the Exculpatory Evidence Schedule (EES), formerly known as the “Laurie List.”The plaintiff appealed her termination to the City of Concord’s Personnel Appeals Board, which upheld the decision, finding her lacked credibility. She then filed a complaint in the Superior Court alleging gender discrimination and wrongful termination, which was settled. The settlement required the City to remove documents related to the incident from her personnel file and maintain them in a separate investigative file, and to report her departure as a negotiated resignation.Years later, the plaintiff sued the City and the New Hampshire Department of Justice in Superior Court, seeking removal of her name from the EES under RSA 105:13-d. She argued the alleged misconduct was immaterial, the records were no longer in her personnel file, and her inclusion on the EES was unwarranted given the passage of time. The Superior Court granted summary judgment for the defendants.The Supreme Court of New Hampshire affirmed, holding that RSA 105:13-d governs EES inclusion and applies to “personnel information,” not just personnel files. The court found the plaintiff’s untruthfulness constituted potentially exculpatory evidence and that it was reasonably foreseeable her misconduct could be admissible to impeach her credibility if she were called as a witness in a future case. View "Doe v. Concord Police Department" on Justia Law

Two Lansing police officers responded to a 911 call reporting a domestic disturbance involving Stephen Romero. Although the initial caller, Stephen’s wife Ashly, stated that Stephen was unarmed and had not threatened her, a second caller reported a shooting, and a third clarified that no one had been shot, though it was unclear if the officers received this update. Upon arrival, the officers encountered Stephen outside a car, with Ashly in the driver’s seat. The officers drew their weapons and ordered Stephen to the ground. Stephen, holding two cell phones, complied by placing them on the ground and raising his hands. After further commands, Stephen got on his knees, raised his shirt to show a holstered gun, and reached for it, prompting the officers to shoot him. While wounded and lying on the ground, Stephen again reached toward his waist and the officers fired a second time. Stephen died at the scene, and the incident was recorded on body cameras.Ashly, as personal representative of Stephen’s estate, filed suit in the United States District Court for the Western District of Michigan, alleging excessive force under the Fourth Amendment, failure to intervene, and municipal liability for inadequate training under Monell v. Department of Social Services of New York City. The district court granted the defendants’ motion to dismiss, holding that the officers’ use of deadly force did not violate clearly established rights and dismissing all claims.On appeal, the United States Court of Appeals for the Sixth Circuit reversed the dismissal of the excessive-force claim, holding that Ashly plausibly alleged a violation of Stephen’s clearly established rights when the officers fired a second round of shots while he was wounded and on the ground, no longer posing an immediate threat. The court affirmed the dismissal of the failure-to-intervene and municipal liability claims, finding insufficient opportunity for intervention and inadequate factual allegations regarding city policy or training. View "Romero v. City of Lansing, Mich." on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law

Two inmates at Smith State Prison in Georgia, Miguel Jackson and Kelvin Stevenson, were involved in a prison riot on December 31, 2010, after officers discovered contraband in Jackson’s cell. The officers alleged that Jackson and Stevenson assaulted them, leading to both inmates being handcuffed and escorted away. Jackson and Stevenson claimed that, after being restrained, they were severely beaten by correctional officers. They filed suit in the United States District Court for the Southern District of Georgia against thirty-nine officers, asserting claims of excessive force and failure to intervene under the Eighth Amendment.Over the course of more than a decade, the plaintiffs voluntarily dismissed many defendants, and the district court granted partial summary judgment, leaving nine officers as defendants by the time of trial. Just before jury selection, plaintiffs moved to dismiss seven more defendants under Federal Rule of Civil Procedure 41(a)(2), which the district court granted, entering judgment in favor of those defendants and reserving the issue of costs and sanctions. The case proceeded to trial against Officers Catanzariti and Harrison. The jury found for Catanzariti on Jackson’s excessive force claim but found he failed to intervene when other officers used excessive force, awarding Jackson $1.00 in damages. Stevenson’s claims against both officers were rejected.On appeal to the United States Court of Appeals for the Eleventh Circuit, the plaintiffs challenged the district court’s grant of their Rule 41 motion and several evidentiary rulings. The Eleventh Circuit held that the district court did not abuse its discretion in granting the partial dismissal and entering judgment for the seven defendants, nor in admitting the challenged evidence. The court affirmed the district court’s final judgments. View "Jackson v. Catanzariti" on Justia Law

Several individuals, representing a class, challenged a health insurance company’s refusal to cover gender-affirming care for transgender individuals diagnosed with gender dysphoria. The company, acting as a third-party administrator for employer-sponsored, self-funded health plans, denied coverage for such treatments based on explicit plan exclusions requested by the employer sponsors. Some plaintiffs also alleged that they were denied coverage for treatments that would have been covered for other diagnoses, such as precocious puberty, but were denied solely because of the concurrent diagnosis of gender dysphoria.The United States District Court for the Western District of Washington certified the class and granted summary judgment in favor of the plaintiffs. The district court rejected the company’s arguments that it was not subject to Section 1557 of the Affordable Care Act because its third-party administrator activities were not federally funded, that it was merely following employer instructions under ERISA, and that it was shielded by the Religious Freedom Restoration Act (RFRA). The district court also found that the exclusions constituted sex-based discrimination under Section 1557.On appeal, the United States Court of Appeals for the Ninth Circuit agreed with the district court that the company is subject to Section 1557, that ERISA does not require administrators to enforce unlawful plan terms, and that RFRA does not provide a defense in this context. However, the Ninth Circuit held that the district court’s analysis of sex-based discrimination was undermined by the Supreme Court’s intervening decision in United States v. Skrmetti, which clarified the application of sex discrimination standards to exclusions for gender dysphoria treatment. The Ninth Circuit vacated the summary judgment and remanded the case for further proceedings to consider whether, under Skrmetti, the exclusions at issue may still constitute unlawful discrimination, particularly in cases involving pretext or proxy discrimination or where plaintiffs had other qualifying diagnoses. View "PRITCHARD V. BLUE CROSS BLUE SHIELD OF ILLINOIS" on Justia Law

Three men were prosecuted for their roles in the fatal shooting of Ahmaud Arbery, a Black man, in the Satilla Shores neighborhood of Glynn County, Georgia. On February 23, 2020, Arbery was running through the neighborhood and stopped at a house under construction, which he had visited before. Gregory and Travis McMichael, who lived nearby, saw Arbery and, suspecting him of recent burglaries, armed themselves and pursued him in a truck. William Bryan, a neighbor, joined the chase in his own vehicle. The men used their trucks to block and pursue Arbery through public streets, ultimately leading to a confrontation in which Travis McMichael shot and killed Arbery.After being convicted of murder and other charges in Georgia state court and sentenced to life imprisonment, the defendants were tried in the United States District Court for the Southern District of Georgia. There, they were convicted of interference with rights under 18 U.S.C. § 245(b)(2)(B), attempted kidnapping under 18 U.S.C. § 1201(a)(1), and, for the McMichaels, firearm offenses under 18 U.S.C. § 924(c)(1)(A)(iii). The district court denied their motions for acquittal, finding sufficient evidence that the defendants acted because of Arbery’s race and his use of public streets, that the streets were provided or administered by the county, and that the attempted kidnapping was for a benefit and involved an instrumentality of interstate commerce.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the sufficiency of the evidence de novo. The court held that substantial evidence supported the jury’s findings on all challenged elements, including racial motivation, use of public facilities, and use of an automobile as an instrumentality of interstate commerce. The Eleventh Circuit affirmed all convictions. View "USA v. Bryan" on Justia Law