Justia Civil Rights Opinion Summaries

AAC, a company that finances motorcycle purchases and holds security interests in the vehicles, acquired installment contracts for two motorcycles owned by individuals involved in a criminal case. After one owner, Brock, was killed during a gang shootout, and the other, Andrzejewski, was arrested and charged in connection with the incident, the Lexington County Sheriff’s Department seized both motorcycles as evidence. AAC was not notified of the seizures or the motorcycles’ location and learned about the events through news reports. AAC contacted the Sheriff’s Department seeking information and access to the motorcycles but was told that the vehicles would not be returned until the criminal proceedings concluded.AAC initially filed claim and delivery actions in the Lexington County Circuit Court, but the court dismissed these actions for improper service, noting it would not order release of evidence during a pending murder case. AAC then brought suit in the Lexington County Court of Common Pleas under state law and 42 U.S.C. § 1983, alleging procedural due process violations. The Sheriff’s Department removed the case to the United States District Court for the District of South Carolina, which dismissed AAC’s federal claim, holding that the seizure was lawful and that AAC’s property interests must yield to the state’s duty to preserve evidence for criminal proceedings. The district court remanded the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit held that when property is seized in connection with a criminal investigation, the Fourth Amendment defines the process that is due, and compliance with its requirements satisfies procedural due process. The court found the seizures lawful and determined that no additional process was required for AAC as a lienholder. The court affirmed the district court’s order granting the defendants’ motion to dismiss. View "American Acceptance Corporation of SC v. Gietz" on Justia Law

The case concerns a police shooting in Seattle involving an officer and an individual named Shaun Fuhr. Fuhr threatened the mother of his infant daughter, fired a handgun in a public park, and then fled on foot with the child. Despite police commands to stop and a search involving a helicopter and SWAT officers, Fuhr continued to evade authorities for over thirty minutes while still holding his daughter. Eventually, SWAT officers, including Noah Zech, encountered Fuhr in a residential alley. As Fuhr appeared from behind bushes, advancing with the infant in his arms, Zech fired a single shot, killing Fuhr. The baby was unharmed, and Fuhr’s gun was later found nearby.Prior to this appeal, the United States District Court for the Western District of Washington granted summary judgment in favor of Zech and the City of Seattle. The district court held that Zech was entitled to qualified immunity on the excessive force claim under 42 U.S.C. § 1983 and dismissed the plaintiffs’ other claims, including negligence, wrongful death, and claims under state law. The plaintiffs appealed these rulings.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that, even when viewing the facts in the light most favorable to the plaintiffs, Zech did not violate clearly established law by shooting Fuhr under these circumstances. The court found no precedent clearly establishing a Fourth Amendment violation in a case involving a fleeing, possibly armed suspect holding a child after firing a gun and ignoring police commands. Accordingly, Zech was entitled to qualified immunity. The court also affirmed the dismissal of the plaintiffs’ remaining claims. View "FUHR V. CITY OF SEATTLE" on Justia Law

During a December 2023 election recount at the Oakland County Courthouse in Michigan, Andrew Hess, serving as an observer, raised concerns about ballot-box tampering with the county’s director of elections, Joseph Rozell. Following a tense exchange, Hess left the recount room and, in the courthouse lobby, remarked to another member of the public, “hang Joe for treason.” The comment was overheard by a county receptionist, who later reported it to law enforcement. Although Hess was not removed from the event, months later Oakland County prosecutors charged him with a felony under Michigan’s terrorist-threat statute for this statement. The charge was initially dismissed after the Michigan Court of Appeals found the statute facially unconstitutional, but the Michigan Supreme Court later vacated that decision, and the potential for prosecution was revived.In response, Hess filed a civil action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan, seeking declaratory and injunctive relief, as well as damages, primarily arguing that the prosecution violated his First Amendment rights. He also sought a preliminary injunction to prevent any renewed prosecution under the statute. The district court denied the preliminary injunction, finding Hess unlikely to succeed on his constitutional claims and failing to demonstrate irreparable harm.Upon appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the preliminary injunction. The appellate court held that while Hess was likely to succeed on the merits of his as-applied First Amendment claim—concluding his statement did not constitute a true threat—he had not shown irreparable harm because any threatened prosecution targeted only his past speech, not future speech. Furthermore, Michigan’s state-court procedures offered him a fair and prompt opportunity to litigate his First Amendment defense. Accordingly, the Sixth Circuit affirmed the district court’s denial of the preliminary injunction. View "Hess v. Oakland County" on Justia Law

In June 2020, following the murder of George Floyd, protestors established the Capitol Hill Occupied Protest (CHOP), occupying a sixteen-block area in Seattle’s Capitol Hill neighborhood. In response, the Seattle Police Department abandoned its East Precinct and significantly reduced police presence in the affected area, including Cal Anderson Park. The protests and encampments continued to cause disruption, vandalism, and crime for months, with CHOP forcibly disbanded on July 1, 2020, but neighborhood disturbances persisting until December 2020. Two businesses located near Cal Anderson Park, one a restaurant and the other a property owner, claimed that the City’s actions and inaction led to severe economic losses, including lost revenue, property damage, and tenant departures.Previously, these businesses were absent putative class members in the Hunters Capital, LLC v. City of Seattle class action in the United States District Court for the Western District of Washington, which raised similar claims. After class certification was denied and the case settled, the businesses filed individual lawsuits in April and June 2023, consolidated in the district court. The district court dismissed the state-created danger and Takings Clause claims, and found their nuisance claims untimely under the applicable two-year statute of limitations, but did not initially decide on equitable tolling pending further guidance from the Washington Supreme Court. After the Campeau v. Yakima HMA, LLC decision, the district court dismissed the nuisance claims and entered final judgment.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of the state-created danger and Takings Clause claims, holding that the state-created danger doctrine does not extend to purely economic harm and that the cessation of police services did not constitute a compensable taking. However, the appellate court reversed the dismissal of the nuisance claims, holding that equitable tolling under American Pipe is available under Washington law, and remanded for further proceedings on those claims. View "3PAK LLC V. CITY OF SEATTLE" on Justia Law

An adjunct clinical professor at a university dental school supervised students in a clinic that, during the summer of 2022, required faculty and students to wear heavy protective equipment as part of its COVID-19 response. Ongoing building renovations left the clinic without adequate air conditioning, making the protective gear uncomfortable and allegedly hazardous due to heat. The professor expressed his opposition to the policy through mass emails, a formal health complaint to the Michigan Occupational Safety and Health Administration (MiOSHA), and remarks at a school meeting. Some colleagues agreed with his concerns, while others found his communications unprofessional. After an internal investigation found his behavior violated university policies, the professor was asked to complete educational modules on workplace conduct. When he refused, he was terminated.The United States District Court for the Eastern District of Michigan reviewed the professor’s First Amendment retaliation claim brought under 42 U.S.C. § 1983 against various dental school administrators. The district court granted summary judgment for the defendants, ruling that neither the MiOSHA complaint nor the professor’s statements at the meeting addressed matters of public concern and that his meeting remarks were made in his capacity as a public employee.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court held that neither the MiOSHA complaint nor the meeting speech involved matters of public concern as required for First Amendment protection in the public employment context. The court emphasized that the professor’s speech focused on workplace conditions and employee grievances rather than broader issues of public import or patient safety. Because the professor failed to show he spoke on a matter of public concern, the court affirmed summary judgment for the defendants. View "Stanalajczo v. Perry" on Justia Law

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him.J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses.The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law

Iowa enacted a statute, Iowa Code § 727.8A, which imposes heightened criminal penalties for using cameras or electronic devices to record or transmit images or data while trespassing on private property. Five animal-welfare organizations challenged this law, alleging it violates their members’ First Amendment rights by chilling their ability to record protests and activities, especially in spaces generally open to the public where they may be asked to leave but not specifically told to stop recording.Previously, the United States District Court for the Southern District of Iowa found the statute facially unconstitutional and permanently enjoined its enforcement. However, the United States Court of Appeals for the Eighth Circuit reversed that decision, noting that the statute could be constitutionally applied in some circumstances and remanded the case for further proceedings. On remand, two groups, including Iowa Citizens for Community Improvement (ICCI), pursued as-applied challenges, contending that the law chills their speech when it is used to prevent them from recording after being asked to leave premises otherwise open to the public. The district court dismissed these as-applied challenges, finding that the statute could be applied to their conduct without violating the First Amendment.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether ICCI had standing, whether the case was ripe, and whether applying the statute in these circumstances violated the First Amendment. The court found that ICCI had standing and the case was ripe. It held that applying § 727.8A to prohibit recording while trespassing—even in spaces otherwise open to the public—does not violate the First Amendment because the statute is a content-neutral, narrowly tailored time, place, and manner restriction serving Iowa’s substantial interests in protecting property and privacy rights. The court affirmed the district court’s dismissal of ICCI’s as-applied challenge. View "Iowa Citizens for Community Improvement v. Reynolds" on Justia Law

During demonstrations in Denver protesting police brutality following George Floyd’s death, a police officer shot a pepperball at a protestor, Elisabeth Epps, who was alone, unarmed, and not acting aggressively. The officer fired without warning as Epps crossed a street while recording police on her phone. The pepperball caused physical injury, but Epps complied with police instructions after being shot. The incident was captured on multiple video sources.Epps brought a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado, alleging that the officer’s conduct violated her First and Fourth Amendment rights. Her claims were part of a larger action involving other protestors and the City and County of Denver. The officer moved for summary judgment based on qualified immunity and for a separate trial (bifurcation), but both motions were denied by the district court. At trial, the jury found the officer liable for violating Epps’s Fourth Amendment rights but not her First Amendment rights, awarding her compensatory and punitive damages. The court later reduced the punitive damages, which Epps accepted.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity, concluding that Epps’s Fourth Amendment rights were violated under clearly established law because she was not committing a serious crime, posed no threat, and was not fleeing. The appellate court also held that the district court did not abuse its discretion by refusing to bifurcate the trial, and it found sufficient evidence to support punitive damages based on the officer’s conduct and statements. Accordingly, the Tenth Circuit affirmed the verdict and all rulings against the officer. View "Packard v. City and County of Denver" on Justia Law

A federal inmate brought an action for damages against several officials at a federal prison, claiming they provided delayed or inadequate medical treatment and used excessive force against him during his incarceration. His allegations included delayed dental care, insufficient response to rectal bleeding, denial of participation in a mental health class, and the use of restraints and physical force during an incident involving his cellmate. He asserted that these actions violated his constitutional rights under the Eighth, Fourth, and Fifth Amendments.The United States District Court for the Western District of Virginia dismissed his complaint, holding that a damages remedy under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics was not available for his claims. The court reasoned that his claims, both for inadequate medical care and excessive force, presented new contexts beyond those recognized in previous Supreme Court cases and that special factors counseled against extending a judicially implied damages remedy. The inmate appealed from the district court’s judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the inmate’s inadequate medical treatment claims presented a new context distinct from Carlson v. Green, as the facts involved less severe circumstances and implicated broader, systemic prison management issues rather than deliberate malfeasance. The court further found that special factors, including Congress’s silence and provision of alternative remedies, counseled against extending Bivens. Regarding the excessive force claims, the Fourth Circuit found that the Supreme Court’s intervening decision in Goldey v. Fields expressly foreclosed recognizing a Bivens remedy in this context. Thus, the Fourth Circuit affirmed the district court’s dismissal, holding that a Bivens remedy was unavailable for the plaintiff’s claims. View "Spivey v. Breckon" on Justia Law