Justia Civil Rights Opinion Summaries

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

The case involves a class action lawsuit filed by transgender women prisoners in Illinois, who allege that the Illinois Department of Corrections (IDOC) has been deliberately indifferent to their gender dysphoria, a serious medical condition. The plaintiffs seek injunctive relief to ensure timely evaluations and treatments, including hormone therapy, gender-affirming surgery, and appropriate support for social transitioning.The United States District Court for the Southern District of Illinois initially issued a preliminary injunction on February 7, 2022, which was intended to address the plaintiffs' claims. The court later issued further injunctions to supplement and modify the terms. However, more than a year and a half after the preliminary injunction was issued, the district court retroactively labeled it as a permanent injunction and issued a final judgment consistent with the February 7, 2022 decision. The defendants appealed several injunctions and a finding of civil contempt by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court's attempt to retroactively transform the preliminary injunction into a permanent one was not authorized. The appellate court held that under the Prison Litigation Reform Act (PLRA), the preliminary injunction issued on February 7, 2022, expired 90 days later, on May 8, 2022. Consequently, the appellate court vacated all existing injunctions and remanded the case for further proceedings consistent with its opinion. The court also dismissed the portion of the appeal challenging the finding of contempt, as the district court had not yet imposed any sanctions, which are necessary to establish appellate jurisdiction. View "Monroe v. Bowman" on Justia Law

Wayne County foreclosed on Tonya Bowles's property to satisfy her tax debt and sold it, keeping the surplus proceeds. Bowles filed a § 1983 lawsuit against the county and its treasurer, seeking to recover the surplus and to certify a class of similarly affected former property owners. The district court certified the class without discovery, relying on a similar case's decision.The United States District Court for the Eastern District of Michigan certified the class in 2022. However, subsequent legal developments, including decisions in Fox v. Saginaw County and other cases, highlighted the need for a rigorous analysis under Federal Rule of Civil Procedure 23. These decisions emphasized the necessity of proving, rather than merely alleging, compliance with Rule 23's requirements and questioned the manageability of class actions in takings cases.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court did not conduct the required rigorous analysis of Rule 23's requirements. The court noted that the district court relied on an incomplete record and did not address several critical issues, such as the calculation of damages, potential unique defenses, and the role of third-party lienholders. Additionally, the court highlighted that Bowles's proposed class definition included claims for surplus equity, which are unmanageable in class actions and not permissible under recent case law.The Sixth Circuit vacated the district court's class certification order and remanded the case for further proceedings. The court instructed the district court to conduct a thorough analysis of Rule 23's requirements, considering recent legal developments and ensuring that Bowles can prove numerosity, commonality, typicality, adequacy, and superiority. The court emphasized the need for a complete evidentiary record and a detailed forecast of how the litigation would proceed as a class action. View "Bowles v. Sabree" on Justia Law

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

The case involves two groups of Montgomery residents who were jailed for failing to pay traffic fines. They sued the City of Montgomery, a private contractor (Judicial Correction Services, Inc.), and a lawyer (Branch D. Kloess), alleging that the process of converting fines into jail sentences violated the U.S. Constitution and Alabama law. The plaintiffs sought to certify their claims as class actions, arguing that the City and its contractors systematically failed to conduct proper inquiries into their ability to pay before jailing them.The U.S. District Court for the Middle District of Alabama denied class certification in both cases. The court found that the plaintiffs failed to meet the requirements of Federal Rule of Civil Procedure 23, particularly the predominance and superiority requirements under Rule 23(b)(3). The court concluded that the claims would require individualized inquiries into each probationer's circumstances, such as whether they were given proper hearings and whether the City or its contractors acted wrongfully or in bad faith.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The appellate court affirmed the lower court's denial of class certification. It agreed that the plaintiffs' claims necessitated individualized proof, making it difficult to resolve the issues on a class-wide basis. The court emphasized that the evidence required to prove the claims, such as records of what happened at individual probation hearings, was not available on a common, class-wide basis. The court also noted that the plaintiffs' claims involved a variety of individual incidents rather than a single, systemic issue that could be addressed collectively.In summary, the Eleventh Circuit held that the district court did not abuse its discretion in denying class certification, as the plaintiffs' claims required individualized inquiries that did not satisfy the predominance requirement of Rule 23(b)(3). The decision to deny class certification was affirmed. View "Carter v. The City of Montgomery" on Justia Law