Justia Civil Rights Opinion Summaries

Three-month-old La’Mello Parker died during a confrontation between his father, Eric Smith, and law enforcement. Smith, a fugitive wanted for double homicide, used La’Mello as a human shield and fired at officers, who returned fire, killing La’Mello. La’Mello’s grandfather and brother sued various law enforcement entities and officers, alleging constitutional violations under 42 U.S.C. § 1983 and state law claims.The United States District Court for the Southern District of Mississippi dismissed the case, finding that the officers’ actions did not constitute constitutional violations and that they were protected by qualified immunity. The court also dismissed the Fourteenth Amendment claims, stating that the conduct did not shock the conscience, and declined to exercise jurisdiction over the state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the officers did not violate La’Mello’s Fourth Amendment rights as their use of force was reasonable under the circumstances. The court noted that Smith posed a grave and immediate threat, and the officers’ decision to return fire was justified. The court also found that the officers were entitled to qualified immunity because the law was not clearly established that their conduct was unconstitutional. Additionally, the court held that the Fourteenth Amendment claims failed as the officers’ actions did not shock the conscience. The court concluded that without an underlying constitutional violation, the bystander liability and municipal liability claims also failed. View "Estate of Parker v. Mississippi Department of Public Safety" on Justia Law

The case involves Deliezha Davonte Gravely, who was pulled over by a police officer for speeding. During the stop, the officer discovered that Gravely was driving with a revoked license due to a DUI and found a loaded firearm in his pocket. Gravely was subsequently indicted on multiple charges, including unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, based on his prior conviction for conspiracy to commit first-degree robbery.The Circuit Court of Mercer County ruled that Gravely's prior conviction for conspiracy to commit first-degree robbery qualified as a "felony crime of violence against the person of another" under West Virginia Code § 61-7-7(b). Gravely was convicted by a jury on all counts and sentenced to imprisonment. He appealed, arguing that the circuit court erred in classifying his conspiracy conviction as a crime of violence.The Supreme Court of Appeals of West Virginia reviewed the case de novo, focusing on whether the elements of conspiracy under West Virginia Code § 61-10-31 include a violent act against a person. The court applied the elements test from State v. Mills, which requires examining the statutory elements of the predicate offense rather than the specific conduct of the defendant. The court found that the elements of conspiracy—an agreement to commit an offense and an overt act to effect the conspiracy—do not require a violent act against a person.The Supreme Court of Appeals of West Virginia held that conspiracy to commit first-degree robbery is not a "felony crime of violence against the person of another" for the purposes of West Virginia Code § 61-7-7(b). Consequently, the court reversed Gravely's convictions for unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, and remanded the case for resentencing on his remaining convictions. View "State v. Gravely" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

Clayton Stewart was involved in a police incident where Officer Victor Garcia of the Jonesboro, Arkansas police department tased him while he was climbing a fence. Stewart fell and was paralyzed as a result. Stewart filed a 42 U.S.C. § 1983 action against Garcia, Jonesboro Chief of Police Rick Elliot, and the City of Jonesboro, alleging violations of his Fourth and Fourteenth Amendment rights. The district court granted summary judgment in favor of the defendants on all claims, and Stewart appealed.The United States District Court for the Eastern District of Arkansas granted summary judgment to the defendants, finding no genuine disputes of material fact that would preclude summary judgment. Stewart argued that Garcia lacked probable cause to arrest him, used excessive force, and was deliberately indifferent to his medical needs. He also claimed that Elliot was liable as Garcia’s supervisor and that the police department’s policies were unconstitutional.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Garcia had at least arguable probable cause to arrest Stewart for misdemeanor assault and fleeing. Regarding the excessive force claim, the court found that while tasing Stewart in an elevated position could be considered deadly force, Stewart’s right to be free from such force was not clearly established at the time of the incident, entitling Garcia to qualified immunity. On the deliberate indifference claim, the court concluded that although a reasonable jury could find Garcia was aware of Stewart’s serious medical needs, Stewart failed to show that the right was clearly established, granting Garcia qualified immunity. The court also affirmed the dismissal of the supervisory liability claim against Elliot and the municipal liability claim against the City of Jonesboro, finding no evidence of a pattern of unconstitutional acts or inadequate policies. The Eighth Circuit affirmed the district court’s judgment in full. View "Stewart v. Garcia" on Justia Law

Leslie Torgerson filed a lawsuit in federal district court against Roberts County, South Dakota, and several individuals, including County Sheriff Tyler Appel, County Deputies Zachary Angerhofer and Wesley Bowsher, his adopted son Ross Torgerson, and his ex-wife Terri Torgerson. Torgerson alleged violations of his substantive and procedural due process rights under the Fourteenth Amendment and civil conspiracy. He also asserted a Monell claim against the County, a state-law claim for common law battery against Ross, and a state-law intentional-infliction-of-emotional distress claim against Deputy Angerhofer, Deputy Bowsher, Ross, and Terri. These claims stemmed from a domestic dispute involving Torgerson, Ross, and Terri.The defendants moved for summary judgment on Torgerson’s claims. The United States District Court for the District of South Dakota granted the defendants' motions for summary judgment and declined to exercise jurisdiction over the remaining state-law claims. The court concluded that Torgerson failed to state a claim for a Fourteenth Amendment violation, as he did not plead that he possessed a constitutional interest that had been violated. The court also determined that Torgerson’s civil conspiracy claim failed due to the lack of a stated constitutional interest and insufficient facts showing a conspiracy. Consequently, Torgerson’s Monell claim against the County also failed. The court declined to exercise supplemental jurisdiction over the state-law claims, considering them to be purely state-related issues.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Torgerson did not suffer a deprivation of liberty as he was not charged or prosecuted for any crime, thus failing to establish a Fourteenth Amendment violation. The court also upheld the summary judgment on the civil conspiracy and Monell claims, as there was no underlying constitutional violation. Finally, the court found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state-law claims. View "Torgerson v. Roberts County of South Dakota" on Justia Law

Antonio Smith, an inmate at Green Bay Correctional Institution in Wisconsin, was on a prolonged hunger strike to protest prison conditions. After refusing to leave his cell for a wellness check, correctional officers used force to extract him for three consecutive days without incident. On the fourth day, Captain Jay Van Lanen used pepper spray, despite knowing Smith had a medical contraindication. Smith experienced severe respiratory distress and was placed naked in a cold cell for 23 hours.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants, concluding that there were no Eighth Amendment violations. Smith appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that a jury could determine that the use of pepper spray and the conditions of Smith's confinement violated the Eighth Amendment. However, the court ultimately affirmed the district court's decision based on qualified immunity, which protects officials from liability unless they violated clearly established statutory or constitutional rights.The court held that while the actions of Captain Van Lanen and Lieutenant Retzlaff could be seen as excessive and lacking legitimate penological purpose, the specific rights violated were not clearly established at the time. Therefore, the defendants were entitled to qualified immunity. The court also found no evidence of excessive force during Smith's escort to the health unit, affirming summary judgment for the defendants on all claims. View "Smith v Kind" on Justia Law

Media Matters for America and Eric Hananoki, a senior investigative reporter, filed a lawsuit against Warren Kenneth Paxton, Jr., in his official capacity as the Attorney General of Texas. The plaintiffs alleged that the Texas Office of the Attorney General launched a retaliatory campaign against them after they published an unfavorable article about X.com, a social media platform owned by Elon Musk. The article reported that corporate advertisements on X appeared next to antisemitic posts and that Musk endorsed an antisemitic conspiracy theory. Following the publication, the Texas Attorney General's office issued a civil investigative demand (CID) to Media Matters, requiring them to produce extensive records.The United States District Court for the District of Columbia granted the plaintiffs' motion for a preliminary injunction and denied Paxton's motion to dismiss for improper venue and lack of personal jurisdiction and subject matter jurisdiction. The court found that the investigation and CID constituted cognizable injuries sufficient to establish the plaintiffs' standing. The court concluded that the plaintiffs satisfied the requisite factors for a preliminary injunction, including a likelihood of success on the merits of their First Amendment retaliation claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the District Court's judgment. The appellate court held that Paxton was subject to personal jurisdiction in the District of Columbia because he purposefully directed actions at the plaintiffs in the District. The court also found that the plaintiffs' complaint raised a justiciable claim of First Amendment retaliation, as they alleged concrete and ongoing harms resulting from the retaliatory investigation. The court concluded that the District of Columbia was a proper venue for the action and that the District Court did not err in issuing the preliminary injunction. View "Media Matters for America v. Paxton." on Justia Law

Two Korean spas, collectively referred to as "the Spa," had a policy of granting entry only to biological women, excluding men and preoperative transgender women. The Washington State Human Rights Commission (HRC) initiated an enforcement action against the Spa, alleging that this policy violated the Washington Law Against Discrimination (WLAD), which prohibits discrimination in public facilities based on sexual orientation, including gender expression or identity. The Spa did not challenge the statute's definition or argue that their conduct did not fit within it but claimed that enforcing WLAD against their policy violated their First Amendment rights.The United States District Court for the Western District of Washington dismissed the Spa's complaint with prejudice under Rule 12(b)(6). The court held that the Spa's conduct discriminated based on gender identity, thus falling within WLAD's scope. It also found that the HRC's enforcement did not impermissibly burden the Spa's First Amendment rights to free speech, free exercise of religion, or free association.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that the Spa's entrance policy discriminated based on gender identity, which is included in WLAD's definition of sexual orientation. The court applied intermediate scrutiny to the Spa's free speech claim, concluding that WLAD imposed an incidental restriction on speech no greater than necessary to eliminate discriminatory conduct. The court also applied rational basis review to the Spa's free exercise claim, finding that WLAD was neutral and generally applicable, and that eliminating discrimination based on sex and transgender status is a legitimate government purpose. Finally, the court rejected the Spa's free association claim, determining that the Spa was neither an intimate nor an expressive association. The court affirmed the district court's dismissal of the complaint. View "Olympus Spa v. Armstrong" on Justia Law

The Heidi Group, Inc. alleged that several Texas officials violated the Fourth Amendment and Texas law by conspiring with a private citizen to steal documents from a cloud-based file storage system. The officials moved for judgment on the pleadings and asserted various immunity defenses. The district court denied the motions in relevant part.The United States District Court for the Western District of Texas reviewed the case and denied the defendants' motions for judgment on the pleadings. The defendants then appealed to the United States Court of Appeals for the Fifth Circuit. The appeal involved four distinct groups of orders: the denial of qualified immunity for individual capacity defendants on the Fourth Amendment claim, the denial of judgment on the pleadings for the official capacity Fourth Amendment claim, the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, and the denial of judgment on the pleadings for the state law religious-discrimination claim.The United States Court of Appeals for the Fifth Circuit dismissed the appeal regarding the religious-discrimination claim and declined to exercise pendent appellate jurisdiction over the official capacity Fourth Amendment claim. The court held that only Gaylon Dacus engaged in state action and was not entitled to qualified immunity for the Fourth Amendment claim. The court found that Dacus used a former employee to access Heidi's documents without proper authorization, violating clearly established Fourth Amendment rights. The court also affirmed the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, as their actions were not in good faith. The court reversed the denial of judgment on the pleadings for Johnson and Kaufman on the individual capacity Fourth Amendment claim and remanded for further proceedings. View "Heidi Group v. Texas Health and Human Services Commission" on Justia Law

Plaintiff and defendant were married in 2019 and have one son together. Plaintiff moved out of the marital home in January 2023 and initiated divorce proceedings in March 2023. In April 2023, defendant was arrested and charged with weapon offenses after threatening a process server with a handgun. Plaintiff filed a civil complaint in July 2023 under the Prevention of Domestic Violence Act (PDVA), seeking a temporary restraining order (TRO) based on allegations of stalking and harassment. The court issued a TRO prohibiting defendant from contacting plaintiff, granting her temporary custody of their son, and denying defendant parenting and visitation time.During the final restraining order (FRO) hearing, plaintiff called defendant as a witness. Defendant invoked the Fifth Amendment privilege against self-incrimination, but the trial court ordered him to testify. Defendant refused to answer questions beyond stating his name, invoking the Fifth Amendment. The trial court ruled that defendant could not invoke the privilege and that an adverse inference could be drawn from his refusal to testify. Defendant appealed the decision.The Appellate Division denied leave to appeal. While defendant's motion for leave to appeal was pending, the Appellate Division published T.B. v. I.W., addressing a similar issue. The Supreme Court of New Jersey granted defendant leave to appeal.The Supreme Court of New Jersey held that while the Fifth Amendment does not provide blanket immunity in PDVA FRO hearings, a defendant may invoke the privilege against self-incrimination in response to specific questions that pose reasonable risks of self-incrimination. The court ruled that no adverse inference may be drawn from the exercise of this right. The PDVA immunity provision in N.J.S.A. 2C:25-29(a) is not coextensive with the Fifth Amendment and does not adequately protect a defendant's rights. The trial court's ruling was reversed, and the matter was remanded for further proceedings. View "M.A. v. J.H.M." on Justia Law