Justia Civil Rights Opinion Summaries

Two Philadelphia police officers responded to reports of drug dealing and observed what they believed to be a drug transaction. When the suspected dealer, Tahir Ellison, saw the officers, he fled in his SUV. The officers pursued Ellison, initially at normal speeds, but the chase escalated when Ellison ran a red light, drove the wrong way down a one-way street, and sped up significantly. The officers followed, also running red lights and reaching high speeds. The chase lasted less than a minute and ended when Ellison crashed into another car, killing an uninvolved bystander, Virgen Martinez. Ellison later pleaded guilty to criminal charges relating to the incident.After the incident, Joshua Otero, as administrator of Martinez’s estate, filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania. The suit alleged that the officers, by engaging in a high-speed chase in a densely populated area, violated Martinez’s Fourteenth Amendment rights under 42 U.S.C. § 1983. The officers moved for partial summary judgment based on the absence of intent to harm and on qualified immunity. The magistrate judge found no evidence of intent to harm but denied summary judgment on both the constitutional and qualified immunity arguments, certifying the case for interlocutory appeal.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that police officers engaged in a high-speed chase are constitutionally liable for injuries to bystanders only if they acted with intent to harm. Because the officers did not intend to harm anyone, they could not be liable under the Fourteenth Amendment. The court also held that qualified immunity applied, as no clearly established law prohibited the officers’ conduct under these circumstances. The Third Circuit reversed the district court and instructed it to enter partial summary judgment for the officers. View "Otero v. Kane" on Justia Law

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

A Palestinian American tenant displayed a Palestinian flag in her apartment window to express solidarity with her heritage. In response to a complaint from another resident, the property manager, following a building-wide “neutrality” policy regarding the Israel-Palestine conflict, instructed her to remove the flag. The tenant informed management that her actions reflected pride in her heritage, but was told this was “unacceptable” and warned of eviction if she did not comply. After refusing to remove the flag, she received a notice terminating her tenancy, which cited a lease violation for hanging the flag outside the window. The tenant alleged this justification was pretextual, as management had indicated the flag would not be allowed anywhere, even inside the window. She also claimed other tenants displayed flags or decorations in their windows without consequence, but did not specify that any involved the Israel-Palestine conflict.She filed suit in the Circuit Court of Cook County, alleging violations of the Fair Housing Act (FHA) and state laws. The defendants removed the case to the United States District Court for the Northern District of Illinois, Eastern Division, and moved to dismiss most claims. The district court granted the motion, holding that her complaint did not plausibly allege national origin discrimination, as it did not show the policy was motivated by her national origin or that it had a disparate impact on Palestinians.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the tenant failed to allege facts showing intentional national origin discrimination or disparate impact under the FHA. The court also found her interference claim under § 3617 of the FHA insufficient, and determined that the district court properly dismissed the state law claims without prejudice after dismissing the federal claims. View "Farhan v. 2715 NMA LLC" on Justia Law

A detainee at the St. Louis County jail, Jovon Mitchell, developed severe symptoms including vomiting, a severe headache, dizziness, difficulty standing and walking, and slurred speech over the course of December 23–25, 2019. Various jail nurses and staff responded to his complaints with minimal or delayed medical care, despite jail policies requiring prompt attention for such symptoms. Jovon was ultimately found unresponsive and died from a stroke after being transferred to a hospital. His brother, Juan Mitchell, filed suit under 42 U.S.C. § 1983, alleging deliberate indifference to Jovon’s serious medical needs by individual medical staff and correctional officers, as well as failure-to-train and unconstitutional policy claims against supervisory staff and St. Louis County. State law claims were also asserted.The United States District Court for the Eastern District of Missouri granted the defendants' motions to dismiss the federal claims for failure to state a claim and declined to exercise supplemental jurisdiction over the state law claims, thereby dismissing them as well. The district court did not address the issue of qualified immunity. Juan Mitchell appealed the dismissal as to certain defendants.The United States Court of Appeals for the Eighth Circuit held that the complaint plausibly alleged deliberate indifference to Jovon’s serious medical needs by three nurses, but not by the physician assistant or correctional officers involved. The Court also found that the failure-to-train claim against St. Louis County was plausibly stated but concluded that the claims against the individual supervisors did not sufficiently allege notice of a pattern of unconstitutional acts. The Court affirmed the dismissal in part and reversed in part, remanding for further proceedings. The Court instructed the district court to exercise supplemental jurisdiction over the state law claims, given the reinstatement of certain federal claims. View "Mitchell v. Saint Louis County" on Justia Law

A disabled individual, who uses a wheelchair, visited a toy store owned by a business entity in Los Angeles. He claimed that the sales counter was too high for him to use comfortably, allegedly deterring him from making a purchase. The individual subsequently filed lawsuits under both federal and state law, alleging violations of the Americans with Disabilities Act (ADA) and the Unruh Civil Rights Act. The federal court dismissed the ADA claim as moot after the store remedied the alleged violation, and the state court tried the Unruh Act claim. During trial, the plaintiff testified about his intent to shop and the difficulties encountered, but the store presented evidence that no such customer was seen and that employees would have greeted him.The Superior Court of Los Angeles County presided over the state Unruh Act action. The judge found the plaintiff's testimony not credible, determining that he entered the store solely to look for ADA violations rather than to shop, and did not suffer any difficulty or denial of access. Judgment was entered for the store, and the plaintiff did not appeal. The store then filed a malicious prosecution action against the plaintiff and his attorneys, alleging they pursued claims knowing essential facts refuted their allegations. The defendants moved for summary judgment, arguing they had probable cause and acted without malice. The trial court granted summary judgment for all defendants, declining to apply issue preclusion to the prior judge’s factual findings.Upon appeal, the Court of Appeal of the State of California, Second Appellate District, Division Three, held that the prior judge’s findings regarding the plaintiff’s intentions and actions were entitled to preclusive effect and sufficient to raise triable issues of fact about probable cause and malice as to the plaintiff. However, the appellate court found no similar evidence against the attorneys, as they relied on information provided by the plaintiff. The judgment was reversed as to the plaintiff and affirmed as to the attorneys. View "Landis' Labyrinth v. Whitaker" on Justia Law

Juan Mendez was approached by two Chicago police officers investigating a gunshot detected near his home early one morning. As the officers arrived and questioned Mendez and a juvenile on the porch, Mendez suddenly fled, jumping a fence and running down an alley. The officers pursued him, with one warning that Mendez had something in his waistband and then in his hand. During the chase, Mendez fell, got up, and turned toward the officers with an object in his hand. One officer, perceiving a threat, shot Mendez three times, resulting in paralysis from the waist down.Mendez filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the City of Chicago and the two officers, alleging excessive force in violation of the Fourth Amendment, battery under Illinois law, and seeking indemnification from the City. Both parties moved for summary judgment. The district court granted summary judgment to the defendants, finding that, based on body-camera footage and the circumstances, a reasonable officer would have had probable cause to believe Mendez posed a threat to the officers’ safety. The court also found that, without a Fourth Amendment violation, Mendez could not prevail on his state law claims. Mendez appealed.The United States Court of Appeals for the Seventh Circuit reviewed the record independently and affirmed the district court. The Seventh Circuit held that Officer Szczur had probable cause to believe that Mendez posed a threat of serious physical harm under the totality of the circumstances, making the use of deadly force reasonable under the Fourth Amendment. The court also held that the state law battery and indemnification claims failed for the same reasons. The judgment for the defendants was affirmed. View "Mendez v City of Chicago" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

An Indian professor employed at a public university in North Carolina applied for tenure after a probationary period, but his initial application was denied following negative evaluations from colleagues concerning his teaching, mentorship, and administrative performance. Several years later, the same professor reapplied and was granted tenure. After receiving tenure, he sued various university officials, alleging that the original denial was the result of racial discrimination in violation of the Equal Protection Clause and 42 U.S.C. § 1981, as well as retaliation for his non-traditional teaching methods in violation of the First Amendment. His complaint focused on negative statements and actions by two specific colleagues, while also asserting that other officials enabled or failed to remedy alleged bias.The United States District Court for the Eastern District of North Carolina dismissed the complaint for failure to state a claim under Rule 12(b)(6). The court found that the plaintiff’s allegations of racial discrimination were unsupported by facts connecting any defendant’s actions to race, and that his First Amendment retaliation claim failed to identify protected speech or a causal link between such speech and the tenure decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that the plaintiff’s allegations did not plausibly suggest he was treated differently than similarly situated colleagues because of his race, as required for Equal Protection and § 1981 claims. The court also concluded that the complaint failed to plausibly allege protected speech or retaliation under the First Amendment. The Fourth Circuit emphasized the limited judicial role in reviewing academic tenure decisions and declined to address qualified immunity, as no plausible claim was stated. Thus, the district court’s judgment was affirmed. View "Katti v. Arden" on Justia Law

The plaintiff, a community advocate, posted a lengthy video—obtained from internal office security footage of a local police department—on his Facebook page. Only a few department employees had access to this footage. In response, a special agent from the Virginia State Police investigated how the plaintiff obtained the video, suspecting possible computer trespass under Virginia law. The agent sought and obtained warrants to search the plaintiff’s Facebook and Gmail accounts, believing these accounts might contain evidence relevant to the investigation. Although the plaintiff moved to quash both warrants for lack of probable cause, a state court denied the motions, and the Supreme Court of Virginia refused his appeal. Ultimately, the local prosecutor determined there was insufficient evidence to charge anyone with computer trespass.Following these events, the plaintiff filed a federal lawsuit in the United States District Court for the Western District of Virginia, alleging that the searches violated his First and Fourth Amendment rights and were conducted in retaliation for his criticism of local government. After amending his complaint once, the plaintiff sought to amend it a second time. The district court dismissed his claims, concluding that his failure to plead the absence of probable cause was fatal, and denied leave to amend as futile.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that, in order to state a First Amendment retaliatory search claim, the plaintiff was required to plead the absence of probable cause or show he qualified for a narrow exception, and he had done neither. The court further held that the same requirement applied to his Fourth Amendment claim. The court also agreed that denying leave to amend was proper, as the proposed amendment would not have stated a valid claim. View "Stanley v. Bocock" on Justia Law