Justia Civil Rights Opinion Summaries

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation. View "Doe v. Charter Communications" on Justia Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects. View "Alexander v. City of Syracuse" on Justia Law

Keith Paul Bird, a prisoner at High Desert State Prison in Nevada, requested a cell transfer due to concerns about his cellmate, fearing a potential fight. Officer Bruce Huinker, the officer in charge, called for assistance, and Officers Paryga and Atherton responded. Bird explained his concerns, and Officer Paryga allegedly threatened him. The officers then instructed Bird to gather his belongings for a move but later changed their minds, leading to a confrontation. Bird's property was confiscated, and he claimed this was in retaliation for his request. Bird filed grievances, which were denied at all levels.Bird then filed a pro se complaint in federal court against the officers and other prison administrators, alleging retaliation and other claims. The district court found that only the retaliation claim survived screening and was properly exhausted. The district court denied the prison officials' motion for summary judgment on the retaliation claim, holding that they were not entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Bird's request for a cell transfer based on concerns with his cellmate did not constitute "protected conduct" under clearly established law. The court noted that neither the Supreme Court nor the Ninth Circuit had ever held that retaliation for complaints against other prisoners violated the First Amendment right to petition for redress of grievances. Consequently, the prison officials were entitled to qualified immunity. The Ninth Circuit reversed the district court's denial of qualified immunity and remanded with instructions to grant summary judgment on Bird's retaliation claim. View "BIRD V. DZURENDA" on Justia Law

Pollyann Sorcan, a member of the Rock Ridge School District board, was excluded from committee assignments and meetings by the board. The board alleged that Sorcan undermined the District’s mission and violated policies and data privacy laws. Sorcan filed a 42 U.S.C. § 1983 action against the District and Bill Addy, the board chair, claiming retaliation for her protected speech under the First Amendment.The United States District Court for the District of Minnesota dismissed Sorcan’s case. The court concluded that Addy was entitled to legislative immunity and that Sorcan failed to state a claim against the District under Monell v. Department of Social Services, 436 U.S. 658 (1978). The court found that Sorcan did not identify a persistent pattern of unconstitutional behavior by the District.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Addy, sued in his official capacity, was not entitled to legislative immunity because such immunity does not extend to local officials in their official capacities. The court also found that the district court erred in requiring Sorcan to identify a persistent pattern of unconstitutional misconduct. Instead, a single decision by authorized decisionmakers can represent an official policy under Monell. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Sorcan v. Rock Ridge School District" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

Steven D’Braunstein was involved in a serious single-vehicle accident, resulting in his car being totaled. California Highway Patrol Officer Samantha Diaz-Durazo arrived at the scene and found D’Braunstein disoriented and in physical distress. Despite his evident symptoms, she did not call for medical assistance. Instead, she arrested him for driving under the influence of drugs and took him to jail. A nurse at the jail refused to admit D’Braunstein due to his medical condition, prompting Durazo to finally take him to the hospital, where he was diagnosed with a stroke. The delay in receiving medical treatment allegedly led to permanent injuries for D’Braunstein.The United States District Court for the Central District of California granted summary judgment in favor of Officer Durazo, holding that although she violated D’Braunstein’s Fourth Amendment rights by failing to provide reasonable medical care, she was entitled to qualified immunity. The court reasoned that the constitutional violation was not clearly established, as D’Braunstein’s injury was sustained prior to his arrest and not during the arrest process.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that a reasonable jury could find that Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, given the serious nature of the collision and his symptoms. The court further held that Durazo’s failure to provide medical care was a violation of clearly established law, which requires officers to seek medical assistance for an injured detainee or arrestee facing a substantial and obvious risk of serious harm. The case was remanded for further proceedings. View "D’Braunstein v. California Highway Patrol" on Justia Law

Two professors of Indian descent and adherents to the Hindu religion challenged California State University's (CSU) anti-discrimination and harassment policy, which included "caste" as a protected class. They argued that this inclusion stigmatized their religion and caused them to self-censor certain religious practices. They filed a lawsuit alleging violations of the Due Process Clause, Free Exercise Clause, and Establishment Clause of the U.S. Constitution, as well as equivalent claims under the California Constitution.The United States District Court for the Central District of California dismissed the professors' Equal Protection claim and the equivalent state law claim for lack of standing. The court also dismissed the Free Exercise claim for failing to state a claim without deciding on standing. The Due Process and Establishment Clause claims proceeded to a bench trial, where the court ultimately dismissed these claims as well, finding that the professors lacked sufficient injury for a pre-enforcement challenge and that the policy did not express government disapproval of Hinduism.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the professors lacked Article III standing for their Due Process claim because they failed to show that they intended to engage in any religious practice that could reasonably constitute caste discrimination or harassment. The court also found that the professors lacked standing for their Free Exercise claim, as they did not demonstrate any injury to their ability to exercise their religion. Finally, the court held that the professors lacked standing for their Establishment Clause claim, as the district court's factual finding that the policy had no hostility toward religion was not clearly erroneous. The court affirmed the judgment for the defendants and remanded for entry of judgment of dismissal without prejudice. View "Kumar v. Koester" on Justia Law

Lars Jensen, a math professor at Truckee Meadows Community College (TMCC), voiced concerns about a policy change to the math curriculum standards. He criticized the new co-requisite policy, which placed students needing remedial instruction in college-level classes, arguing it lowered academic standards. Following his criticism, Jensen faced several adverse actions, including reprimands, negative performance reviews, and a termination hearing.The United States District Court for the District of Nevada dismissed Jensen’s claims, including First Amendment retaliation, procedural due process, and equal protection violations. The court held that Jensen’s First Amendment claim was barred by qualified immunity and that his official capacity claim was barred by sovereign immunity. The court also found that Jensen failed to identify a protected interest for his due process claim and did not allege membership in a discrete class for his equal protection claim. The court dismissed all claims with prejudice and denied leave to amend.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Jensen’s First Amendment retaliation claim. The appellate court held that Jensen’s criticism of the curriculum changes addressed a matter of public concern and was protected speech related to scholarship or teaching. The court found that the adverse actions against Jensen were motivated by his speech and that the state had not shown a substantial disruption to outweigh his First Amendment rights. The court also held that the Administrators were not entitled to qualified immunity and that Jensen’s official capacity claim for prospective relief was not barred by sovereign immunity. The court affirmed the dismissal of Jensen’s due process and equal protection claims but reversed the denial of leave to amend, remanding for further proceedings. View "JENSEN V. BROWN" on Justia Law

Defendant-Appellant Kenston Harry was convicted of possessing controlled substances with intent to distribute and conspiracy to distribute the same. The case centers on the use of a stationary pole camera by the Drug Enforcement Administration (DEA) to monitor the exterior of Harry's business, Action Audio, for approximately 50 days without a warrant. The camera captured footage of the business's exterior, parking lot, and occasionally the interior when the garage door was open. Harry was arrested after investigators found narcotics and firearms at Action Audio and his residence.The United States District Court for the District of Connecticut denied Harry's motion to suppress the pole-camera evidence, which was introduced at trial. The jury convicted Harry, and the district court sentenced him to ten years for the fentanyl- and cocaine-related charges, including conspiracy, and five years for the marijuana charge, to run concurrently. The court also denied Harry's request for safety-valve relief from the mandatory minimum sentence under 18 U.S.C. § 3553(f).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the use of the stationary pole camera did not constitute a Fourth Amendment search, as Harry did not have a reasonable expectation of privacy in the publicly visible areas of his business. The court also found that the district court did not err in denying Harry safety-valve relief, as he failed to prove that the firearms found were not connected to his drug-trafficking activities. The Second Circuit affirmed the judgment of the district court. View "United States v. Harry" on Justia Law