Justia Civil Rights Opinion Summaries

Ann Tierney Smith owned real property in West Virginia but failed to pay the assessed real estate taxes for 2016. As a result, the Mercer County Sheriff sold a tax lien on the property to Ed Boer. Boer sought a tax deed and provided the West Virginia State Auditor’s Office with a list of individuals to be notified about the right to redeem the property, including Smith. However, Boer did not include Smith’s current mailing address, which was available in county records. Notices sent by mail were returned as undeliverable, and attempts at personal service were unsuccessful, leading to notices being posted at the property and other addresses. After the redemption deadline passed, G. Russell Rollyson, Jr., an employee of the State Auditor’s Office, issued a tax deed to Boer. Smith learned of the deed in late 2020.Smith, and later her estate representatives, sued Rollyson and Boer under 42 U.S.C. § 1983, alleging deprivation of property without due process. The United States District Court for the Southern District of West Virginia granted summary judgment to Rollyson, finding him entitled to qualified immunity. The court determined that while Rollyson could have directed Boer to search county records for Smith’s address after the mailed notices were returned, the duty to do so was not clearly established at the time. The estate representatives appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment and qualified immunity rulings de novo. The Fourth Circuit held that it was not clearly established on April 1, 2019, that Rollyson was required to have Boer search county records anew for Smith’s address after the mailed notices were returned. The court found that existing precedent did not prescribe a specific follow-up measure and that Rollyson’s actions did not violate clearly established law. The judgment of the district court was affirmed. View "Ann deWet v. G. Russell Rollyson, Jr." on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

A county public guardian filed a petition in February 2023 to establish a conservatorship over an individual, A.H., under the Lanterman-Petris-Short (LPS) Act, alleging grave disability due to mental disorder. The trial court imposed a temporary conservatorship, which was extended as A.H. demanded a trial. However, the trial did not begin within the statutory 10-day period and was repeatedly continued, often due to court and counsel unavailability. While the first petition was still pending and as the initial temporary conservatorship was expiring, the public guardian filed a second petition and obtained a new temporary conservatorship, further extending A.H.’s involuntary confinement. A.H. opposed the continuances and requested dismissal of both petitions, but the court denied these requests. The first petition was eventually dismissed at the public guardian’s request, and trial on the second petition began about ten weeks after the statutory deadline. In January 2024, the court found A.H. gravely disabled and ordered a one-year conservatorship, which was not renewed after expiration.The Superior Court of Contra Costa County presided over the initial proceedings, including the imposition of temporary conservatorships, the granting of continuances, and the eventual trial and conservatorship order. A.H. appealed, arguing that statutory amendments required dismissal for untimely trial, that the court abused its discretion in granting continuances, and that the delays violated his due process rights.The California Court of Appeal, First Appellate District, Division Five, held that the statutory amendment to section 5350, subdivision (d)(2), does not mandate dismissal for untimely trial but gives the court discretion. The court found no reversible error in the continuances or denial of dismissal under the statute. However, the appellate court concluded that the cumulative 10-month delay in adjudicating the conservatorship petitions, none of which was attributable to A.H., violated his due process rights. The order of conservatorship was therefore reversed. View "In re Conservatorship of A.H." on Justia Law

Patrick Jones Jr. was hired as a probationary deputy sheriff by the Lake County Sheriff’s Office and sent to a police training academy. During his training, Jones obtained a document from his girlfriend, believing it to be a study guide, and offered to share it with classmates. The document was actually a cheat sheet for a prior version of the Illinois state law enforcement exam. After an investigation by the training institute, which concluded Jones likely did not understand the document’s true nature, the Sheriff’s Office nonetheless terminated his employment. The termination letter, authored by Undersheriff Lawrence Oliver, cited Jones’s conduct as violating the office’s code of conduct and was distributed internally and to the office’s Merit Commission. Jones later struggled to find new law enforcement employment, attributing this difficulty to the termination letter.Jones filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the termination letter was defamatory and that it deprived him of occupational liberty in violation of the Fourteenth Amendment. The district court granted summary judgment for the Sheriff’s Office and Undersheriff Oliver, finding that Jones failed to show it was virtually impossible for him to find new employment and that the statements in the letter were either true or opinion, and that Oliver was entitled to absolute immunity under Illinois law.The United States Court of Appeals for the Seventh Circuit affirmed. The court held that the Sheriff’s Office was not a proper defendant under 42 U.S.C. § 1983 because Jones did not allege a policy or custom as required for municipal liability. The court further held that Jones’s occupational liberty claim failed because there was no evidence that Undersheriff Oliver publicly disclosed the termination letter. Finally, the court held that Undersheriff Oliver was entitled to absolute immunity under Illinois law for statements made within the scope of his official duties. View "Jones v. Lake County Sheriff's Office" on Justia Law

A prisoner at a Michigan correctional facility was involved in a physical altercation with another inmate, after which he was subdued and handcuffed by corrections officers. Two officers then escorted him through a hallway and into a prison yard. Upon entering the yard, the officers performed a takedown maneuver, throwing the prisoner to the ground and fracturing his foot. The prisoner claimed he did not resist or act aggressively before the takedown, while the officers asserted that he had lunged away, prompting their response. Surveillance footage captured much of the incident, but some key moments were obscured or unclear. The prisoner suffered significant injury as a result of the takedown.Following the incident, a prison misconduct hearing was held, and the hearing officer found the prisoner guilty of assaulting staff, relying heavily on the video evidence, which the prisoner was not permitted to view. The prisoner did not seek judicial review of this administrative finding. He then filed a lawsuit in the United States District Court for the Eastern District of Michigan under 42 U.S.C. § 1983, alleging excessive force in violation of the Eighth Amendment. The district court granted summary judgment to the officers, holding they were entitled to qualified immunity. The court reasoned that the hearing officer’s factual findings should have preclusive effect and that the video evidence clearly contradicted the prisoner’s account.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the hearing officer’s findings should not have preclusive effect because the prisoner lacked a full and fair opportunity to litigate the facts, particularly due to his inability to access crucial evidence. The court also found that the video evidence did not so clearly contradict the prisoner’s version as to warrant summary judgment. The court concluded that there was a genuine dispute of material fact regarding whether the officers used excessive force, and that the officers had forfeited the “clearly established” prong of their qualified immunity defense. The case was remanded for further proceedings. View "Nash v. Bryce" on Justia Law

An inmate at the Louisiana State Penitentiary participated in the Angola Prison Rodeo from 1996 to 2019, selling leather belts and earning approximately $80,000. He alleged that prison officials confiscated about $16,000 of his earnings, claiming the deductions were for taxes, commissions, and maintenance fees. The inmate filed a grievance through the prison’s administrative process, arguing that the deductions were unauthorized and that he was denied a due process hearing regarding the seizure of his property. The prison denied his grievance, explaining the deductions, and the inmate exhausted his administrative remedies. He then sought relief in Louisiana state court through a petition for writ of mandamus, which remained unresolved for over a year.Subsequently, the inmate filed a pro se complaint in the United States District Court for the Middle District of Louisiana under 42 U.S.C. § 1983, alleging that various prison officials conspired to deny him due process in connection with the confiscation of his property. The defendants moved to dismiss the complaint, asserting qualified immunity and failure to state a claim. A magistrate judge recommended dismissing any standalone claims regarding the denial of the prison grievance but allowed the conspiracy and due process claims to proceed. The district court adopted this recommendation, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the defendants were entitled to qualified immunity. The court found that the inmate’s complaint did not adequately allege a pre-deprivation due process claim and that, at the time of the alleged conduct, it was not clearly established that the inmate had a protected property interest in the proceeds from the sale of crafts made and sold under prison auspices. The Fifth Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Savage v. Westcott" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

Jill Esche, who was seven months pregnant, was admitted to Renown Regional Medical Center in Nevada with severe hypertension and erratic behavior. Hospital staff, believing she was mentally ill and a danger to herself and her fetus, petitioned for her involuntary commitment under Nevada law. While the petition was pending, Esche was kept in the hospital, given psychiatric and medical treatment against her will, restricted from visitors and phone use, and not informed that a public defender had been appointed for her. After giving birth by C-section, the hospital decided to withdraw the commitment petition but allowed Esche to leave while she was still in fragile condition. She died outside near the hospital that night. Her estate and survivors sued the hospital and several staff members, alleging violations of her constitutional rights under 42 U.S.C. § 1983 and Nevada law.The United States District Court for the District of Nevada granted summary judgment to the defendants on some claims, including unreasonable seizure and procedural due process claims, but denied summary judgment on others, such as substantive due process, conspiracy, and failure-to-train-or-supervise claims. The court also denied the defendants’ assertion of a good-faith defense to § 1983 liability, finding that the defense did not apply because the hospital was not required by law or directed by a public official to hold Esche involuntarily. Both sides appealed: the defendants challenged the denial of the good-faith defense, and the plaintiffs cross-appealed the dismissal of other constitutional claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court’s denial of the good-faith defense was not immediately appealable under the collateral order doctrine, as the defense is a defense to liability, not an immunity from suit. The court dismissed both the defendants’ appeals and the plaintiffs’ cross-appeal for lack of jurisdiction. View "Estate of Esche v. Bunuel-Jordana" on Justia Law

Rodriquez D’Aundre Pam was shot and killed by Evansville police officers responding to a 911 call reporting that a man matching Pam’s description was in a backyard with a handgun, allegedly pointing it at a dog and at the caller. Officers arrived, encountered Pam on the property, and repeatedly ordered him to show his hands and get on the ground. Pam did not comply, appeared to reach for the doorknob, then moved along the house, put his hands in his pockets, and removed them when ordered. As officers continued to issue commands, Pam raised his left hand and kept his right hand at his side. Officers then fired multiple shots, killing him. A handgun was found near Pam’s body. Body camera footage captured the incident, but the video was unclear as to whether Pam was holding a gun at the moment he was shot.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the officers, finding it undisputed that Pam pointed a gun at them before they fired. Pam’s estate appealed, challenging the grant of summary judgment for Officers Offerman and McQuay.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering the evidence in the light most favorable to the estate. The court found that, while the video did not conclusively show Pam pointing a gun, the officers’ belief that Pam was threatening them with a firearm was objectively reasonable given the circumstances, including the 911 report, Pam’s actions, and the recovery of a gun. The Seventh Circuit held that the officers were entitled to qualified immunity because their perception and response did not violate clearly established law. The court affirmed the district court’s grant of summary judgment. View "Pam v. City of Evansville" on Justia Law

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law