Justia Civil Rights Opinion Summaries

Plaintiff was cited for misuse of a vehicle horn under Section 27001 after she honked in support of protestors gathered outside a government official’s office. Although the citation was dismissed, Plaintiff filed suit to block future enforcement of 27001 against any expressive horn use―including honks not only to “support candidates or causes” but also to “greet friends or neighbors, summon children or co-workers, or celebrate weddings or victories.” She asserted that Section 27001 violates the First and Fourteenth Amendments as a content-based regulation that is not narrowly tailored to further a compelling government interest. Alternatively, she argued that even if the law is not content-based, it burdens substantially more speech than necessary to protect legitimate government interests.   The Ninth Circuit affirmed the district court’s summary judgment in favor of the State of California. The first held that Plaintiff had standing to challenge the law because, ever since she received a citation for impermissible horn use, she has refrained from honking in support of political protests to avoid being cited again. The panel determined that, at least in some circumstances, a honk can carry a message that is intended to be communicative and that, in context, would reasonably be understood by the listener to be communicative. The panel noted that Plaintiff had not alleged that the State has a policy or practice of improper selective enforcement of Section 27001, so the panel had no occasion to address that possibility here. View "SUSAN PORTER V. KELLY MARTINEZ, ET AL" on Justia Law

Over a four-day stretch during his incarceration at Walker State Prison in Georgia, Plaintiff failed to receive his prescribed seizure medication. On the fourth night, Plaintiff had two seizures that he claimed caused permanent brain damage. Proceeding under 42 U.S.C. Section 1983, Plaintiff sued five prison employees, alleging that they were deliberately indifferent to his medical needs in violation of the Eighth Amendment. The district court granted summary judgment to all five defendants on the ground that they were entitled to qualified immunity. Shortly thereafter, Plaintiff died from causes unrelated to the seizures that he suffered while in prison. His sister pursued his claims on appeal as the personal representative of his estate.   The Eleventh Circuit affirmed. The court concluded that none of them was deliberately indifferent to Plaintiff’s medical needs and, accordingly, that none of them violated the Eighth Amendment—and, accordingly, that the district court was correct to grant all of them summary judgment. The court held that a deliberate-indifference plaintiff must prove (among other things) that the defendant acted with “more than gross negligence.” The court wrote that it echoes the district court’s lament that Defendants’ “careless actions and their systemic communication failures caused Plaintiff serious suffering” and “irreparably altered his life.” And the court reiterated that “while engaged in the business of prison medicine”—no less so than on the outside, so to speak—“the essential command of the Hippocratic Oath is ‘first, do no harm.’” Even so, the bar to proving an Eighth Amendment deliberate-indifference claim is appropriately high, and the court concluded that Plaintiff hasn’t met it. View "Betty Wade v. Georgia Correctional Health, LLC, et al" on Justia Law

Plaintiff brought an action against several police officers and the City of New York, asserting various claims under 42 U.S.C. Section 1983 and New York state law based on his allegation that police officers falsely claimed that they observed him selling drugs. After his criminal trial, Plaintiff was acquitted of a drug sale charge and convicted of a drug possession charge. Plaintiff subsequently filed this civil action, and the district court dismissed all of Plaintiff’s claims.   The Second Circuit affirmed in part and vacated in part the district court’s dismissal of Plaintiff’s claims and remanded. The court wrote that it agreed with the district court’s dismissal of all of the federal claims except for the dismissal of Plaintiff’s due process claim based on the use of fabricated evidence regarding the drug sale charge of which he was acquitted. Specifically, the district court erred in concluding that because Plaintiff was arrested, detained, prosecuted, and convicted for drug possession simultaneous to the drug sale proceedings, this precludes, as a matter of law, his ability to plead a deprivation of liberty caused by the drug sale prosecution. Because the prosecution of an individual based on fabricated evidence may itself constitute a deprivation of liberty, even in the absence of custody or a conviction, Plaintiff was not required to show that his drug sale prosecution resulted in additional custody or a conviction in order to sufficiently allege a claim at the pleading stage. View "Barnes v. City of New York" on Justia Law

This qualified immunity case arises from the death of a man who was shot and killed by officers of the Stratford Police Department when he attempted to evade arrest by fleeing in a stolen car. Plaintiffs, the man’s minor child and his estate appealed the district court’s grant of summary judgment to Defendants.   The Fifth Circuit affirmed in part, reversed in part, and remanded to the district court. The court explained that the officer would have been put on notice that his conduct violated the man’s constitutional rights. The court explained that Plaintiffs have not pointed to sufficient authority clearly establishing that the officer’s conduct violated the law under the specific circumstances he was facing, and thus he is entitled to qualified immunity. However, the court held that it is not convinced that the degree of force used was objectively reasonable. A jury could reasonably find that Defendants violated the man’s Fourth Amendment right to be free from excessive force. View "Baker v. Coburn" on Justia Law

Beechler and Turner, both serving home confinement through Marion County Community Corrections (MCCC), reported separate residences. An FBI Task Force was conducting a wiretap investigation involving individuals distributing controlled substances in Indianapolis. They discovered that a target of the investigation expected a shipment of marijuana to arrive at Turner’s residence. Watching the house, agents noticed a man with an ankle monitor and reported to MCCC that it suspected that one of the occupants was on home confinement and might be engaged in drug trafficking. An MCCC employee, with Indianapolis officers, went to Turner’s address to check compliance with the home detention contract. They encountered Turner and Beechler and discovered methamphetamine in the bedroom. Officers then obtained a search warrant and seized five firearms, ammunition, methamphetamine, heroin, and $1,508 in cash. After receiving his Miranda rights, Beechler acknowledged the drugs and guns, admitting that they were there to protect the drugs.Beechler unsuccessfully moved to suppress the evidence, claiming that although police labeled the search as a community corrections compliance check, they actually conducted the search for law enforcement purposes so that the warrantless search violated his Fourth Amendment rights. Convicted of multiple counts, Beechler was sentenced to 360 months in prison—below the bottom of the 420-month Guidelines range. The Seventh Circuit affirmed. Viewing the totality of the circumstances, Beechler’s expectation of privacy was minimal; the government’s legitimate needs were significant. The search did not violate his Fourth Amendment rights. View "United States v. Beechler" on Justia Law

Plaintiff, then a conductor and now an engineer for Union Pacific Railroad (“Union Pacific”), brought this action under the Americans with Disabilities Act (“ADA”) when Union Pacific refused Plaintiff’s requests that he be allowed to bring his Rottweiler service dog on board moving Union Pacific freight trains as a reasonable accommodation to ameliorate the effects of Plaintiff’s undisputed disabilities, post-traumatic stress disorder (PTSD) and migraine headaches resulting from his prior service in the military. At the end of a week-long trial, the district court denied Union Pacific’s motion for judgment as a matter of law. The jury then returned a verdict for Plaintiff, awarding compensatory but not punitive damages. The district court granted Union Pacific’s renewed motion for judgment as a matter of law, concluding there is no legally sufficient evidentiary basis for the jury’s verdict.   The Eighth Circuit affirmed. The court agreed that “benefits and privileges of employment” (1) refer only to employer-provided services; (2) must be offered to non-disabled individuals in addition to disabled ones; and (3) does not include freedom from mental or psychological pain. Further, the court noted that mitigating pain is not an employer-sponsored program or service. As such, providing a service dog at work so that an employee with a disability has the same assistance the service dog provides away from work is not a cognizable benefit or privilege of employment. View "Perry Hopman v. Union Pacific Railroad" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law

The Supreme Court affirmed the conclusion of the court of appeals that the record refuted two of Appellant's claims of ineffective assistance of counsel for failure to object to improper evidence under Neb. Rev. Stat. 27-404, holding that, while this Court's reasoning differed from that employed by the court of appeals, there was no error in the court's ultimate judgment.After a jury trial, Appellant was convicted of possession of a firearm by a prohibited person and sentenced to a term of twenty-five to thirty years' imprisonment. The court of appeals affirmed, thus rejecting Appellant's claim of ineffective assistance of counsel for counsel's failure to object to improper rule 404 evidence. The Supreme Court affirmed, holding that, while this Court's reasoning differed from that employed by the court of appeals, this Court's conclusion on the judgment was the same. View "State v. Wheeler" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that a bylaw adopted by the Uinta County Republican Party governed who could vote in its 2021 officer and state committee-person election, holding that the voting procedure used in the election and the Party's bylaw violated the clear and unambiguous language of Wyo. Stat. Ann. 22-4-105.In making its decision, the district court ruled that the bylaw did not violate the relevant provision of the Wyoming Election Code, Wyo. Stat. Ann. 22-4-105, and that the Party's constitutional right to freedom of association would be unduly burdened if it was prohibited from adopting and utilizing the bylaw. The Supreme Court reversed, holding (1) the district court erred in concluding that the Party acted within its statutory authority by enacting the bylaw and using it for the 2021 election; and (2) the issue of whether section 22-4-15 infringed on the Party's constitutional right to freedom of political association was not properly before the Court. View "Conrad v. Uinta County Republican Party" on Justia Law

In this action brought by Utah Stream Access Coalition (USAC) after USAC members were cited for trespass for wading in the Provo River on property owned by VR Acquisitions the Supreme Court held that the district court correctly entered judgment against USAC.In its complaint, USAC claimed that the Public Waters Access Act (PWAA) violated Utah Const. art. XVII and XX and federal common law. The district court entered summary judgment against USAC on its article XVII and federal common law claims but, after a bench trial, determined that the PWAA violated article XX. On appeal, the Supreme Court determined that the district court made a threshold error in reaching its article XX determination and remanded with instruction that the court address the threshold question of whether the easement identified in Conaster v. Johnson, 194 P.3d 897 (Utah 2008), had a historical basis as a public easement at the time the Utah Constitution was framed. On remand, the district court granted summary judgment for VR Acquisitions and the State. The Supreme Court affirmed, holding that because USAC did not identify an affirmative, 19th-century legal basis for a Conaster easement, the district court correctly ruled that USAC did not make the threshold showing. View "Utah Stream Access Coalition v. VR Acquisitions, LLC" on Justia Law