Justia Civil Rights Opinion Summaries

Marcus D. Evans, an inmate at the Varner Supermax Unit in Arkansas, was placed in full restraints to attend a prison program. After returning to his cell, officers removed his hand restraints but refused to remove his leg restraints, despite his repeated requests. Evans remained in leg restraints for approximately 15 hours, during which he experienced pain, had difficulty sleeping, and was forced to cut off his clothing to shower. Medical records indicated he reported significant pain but showed no serious physical injury. Evans alleged that the officers’ refusal to remove the restraints was intentional and stemmed from prior altercations and threats.Evans filed suit in the United States District Court for the Eastern District of Arkansas, asserting an excessive force claim under 42 U.S.C. § 1983 against the officers. The officers moved for summary judgment, arguing qualified immunity. A magistrate judge recommended granting summary judgment, finding that while a jury could find a constitutional violation, the right was not clearly established. The district court declined to adopt this recommendation, holding that existing precedent clearly established that prolonged restraints without penological justification could constitute excessive force, and denied qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo. The court held that the officers’ refusal to remove the leg restraints constituted a use of force, and that Evans’s pain and discomfort, even absent serious injury, were sufficient to support an excessive force claim. The court further found that existing case law clearly established that subjecting an inmate to prolonged restraints without penological justification could violate the Eighth Amendment. Therefore, the Eighth Circuit affirmed the district court’s denial of qualified immunity to the officers. View "Evans v. Smith" on Justia Law

A man who was previously convicted of a felony in Virginia sought to have his voting rights restored after his release from prison. Under Virginia’s Constitution, individuals convicted of felonies lose the right to vote, but the Governor has the sole discretion to restore those rights. The restoration process requires applicants to submit a form, after which the Office of the Secretary of the Commonwealth reviews the application and makes a recommendation to the Governor, who then decides whether to grant restoration. The applicant in this case, who had never voted due to his conviction as a minor, submitted at least one application for restoration, but the Governor declined to restore his rights.The United States District Court for the Eastern District of Virginia reviewed the applicant’s claims, which were brought under 42 U.S.C. § 1983. The applicant argued that the Governor’s unfettered discretion in restoring voting rights, and the lack of a definite time limit for the process, violated the First Amendment’s unfettered-discretion doctrine. The district court granted summary judgment in favor of the Governor and Secretary, finding that the doctrine did not apply because the restoration process determines eligibility to reenter the franchise, rather than regulating the exercise of an existing right.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that Virginia’s discretionary system for restoring voting rights, which is rooted in the executive clemency power, does not facially violate the First Amendment’s unfettered-discretion doctrine. The court reasoned that the clemency power is fundamentally different from a licensing scheme subject to First Amendment prior restraint analysis, and that judicial review of such executive discretion is limited to narrow circumstances not present here. The judgment of the district court was affirmed. View "Hawkins v. Youngkin" on Justia Law

The plaintiff, a former police officer in Dermott, Arkansas, alleged that he was forced to resign in retaliation for reporting a fellow officer’s excessive use of force. The incident in question involved the other officer grabbing an arrestee by the neck while the arrestee was restrained. Subsequently, the officer accused the plaintiff of taking money from a parolee, which the parolee confirmed in a statement. The police chief referred the matter to a prosecutor, who initiated a state police investigation. During this period, the plaintiff’s employment status became unclear, with conflicting statements about whether he was fired or resigned. The plaintiff ultimately resigned after a job offer from another police department was rescinded due to the ongoing investigation. He was later charged with abuse of office and witness bribery, but the charges were dismissed when the parolee could not be located.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants on all claims. The court found that the plaintiff had voluntarily resigned and had not suffered an adverse employment action, which was necessary for his First Amendment retaliation claim. The court also determined that the plaintiff was not “seized” within the meaning of the Fourth Amendment for his malicious prosecution claim, as a summons to appear in court did not constitute a seizure. The court exercised supplemental jurisdiction over the state law claims and found that they failed on the merits, including claims under the Arkansas Whistle Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the plaintiff’s voluntary resignation did not amount to an adverse employment action, and that he was not seized under the Fourth Amendment. The court also agreed that the state law claims failed as a matter of law. View "Brown v. City of Dermott Arkansas" on Justia Law

The plaintiff was stopped by New York State Troopers in Oneida County, New York, on September 4, 2017, after a report of erratic driving. During the stop, Trooper Colton claimed the plaintiff failed field sobriety tests and later registered a high blood alcohol content on a breathalyzer. The plaintiff disputed these findings, alleging the tests were improperly administered and that he passed them. He was arrested and charged with a felony for aggravated unlicensed operation of a motor vehicle, multiple DWI-related misdemeanors, and a traffic infraction. The felony charge was later amended to a misdemeanor before a suppression hearing, after which the city court suppressed evidence due to concerns about Trooper Colton’s credibility. The plaintiff ultimately pled guilty to the traffic infraction, and the remaining DWI-related charges were dismissed.The United States District Court for the Northern District of New York dismissed the plaintiff’s federal lawsuit under 42 U.S.C. § 1983, which alleged false arrest, malicious prosecution, and fabrication of evidence. The district court found that the guilty plea to the traffic infraction established probable cause for the arrest, defeating the false arrest claim. It also held that the plaintiff could not show favorable termination for the malicious prosecution claim because the DWI-related charges were dismissed as part of a plea agreement. The fabrication of evidence claim was dismissed as conclusory and contradicted by Trooper Colton’s testimony.The United States Court of Appeals for the Second Circuit affirmed the dismissal of the false arrest claim and the malicious prosecution claim as to the DWI-related charges dismissed in the plea agreement, holding that a guilty plea to one charge bars a malicious prosecution claim for other charges dismissed as part of the same plea. However, the court vacated the dismissal of the malicious prosecution claim as to the terminated felony charge, finding it plausibly terminated favorably because its dismissal was not clearly part of the plea. The court also reinstated the fabrication of evidence claim, concluding the plaintiff had sufficiently alleged intentional fabrication. The case was remanded for further proceedings on these claims. View "Carruthers v. Colton" on Justia Law

A student organization at West Texas A&M University, focused on supporting LGBT+ students, planned a charity drag show to raise funds for a suicide prevention initiative. The event was to be held in a university venue that had previously hosted a wide range of student and community events, including a prior drag show. The organizers took steps to ensure the show would be appropriate for a general audience, restricting lewd content and requiring minors to be accompanied by adults. Shortly before the event, the university president canceled the show, citing concerns that drag performances were discriminatory against women and did not align with the university’s values.Following the cancellation, the student group and two of its officers filed suit in the United States District Court for the Northern District of Texas, seeking a preliminary injunction to allow future drag shows on campus. The district court denied the injunction, holding that drag shows were not inherently expressive conduct protected by the First Amendment and that the university president was entitled to qualified immunity. The court also found that the plaintiffs had standing against certain university officials but not others, and rejected the claim of irreparable harm.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of the preliminary injunction de novo. The Fifth Circuit held that the planned drag show was expressive conduct protected by the First Amendment, as it conveyed a clear message of support for the LGBT+ community in its context. The court determined that the university venue was a designated public forum, making the content-based restriction on the drag show subject to strict scrutiny, which the university did not attempt to justify. The court found the plaintiffs faced irreparable harm from the ongoing ban and that the balance of equities and public interest favored an injunction. The Fifth Circuit reversed the district court’s denial of a preliminary injunction against the university president and a vice president, affirmed the denial as to the chancellor for lack of standing, and remanded for entry of the injunction. View "Spectrum WT v. Wendler" on Justia Law

A nonprofit Christian ministry that provides youth programs in Oregon applied for state grant funding from the Oregon Department of Education’s Youth Development Division. The Division had recently added a rule requiring all grant applicants to certify that they do not discriminate based on religion in employment, vendor selection, subcontracting, or service delivery. The ministry, whose mission is to share Christian teachings, requires all employees and volunteers to affirm a Christian Statement of Faith and be involved in a local church. After initially awarding the ministry a conditional grant, the Division withdrew the award upon discovering the ministry’s religious hiring requirements.The United States District Court for the District of Oregon denied the ministry’s request for a preliminary injunction to reinstate the grant and enjoin enforcement of the rule, finding the ministry unlikely to succeed on the merits of its First Amendment claims. The court also dismissed all claims, including those for damages, based on qualified immunity, even though the defendants had only moved to dismiss the damages claims.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The Ninth Circuit held that the rule, as applied to grant-funded initiatives, is likely neutral and generally applicable, thus not violating the Free Exercise Clause, and is a reasonable, viewpoint-neutral condition for participation in the grant program. The court also found that the ministry’s religious autonomy claims were unlikely to succeed, as the relevant doctrines are affirmative defenses, not standalone claims. However, the court held that applying the rule to the ministry’s non-grant-funded initiatives likely imposes an unconstitutional condition on expressive association. The Ninth Circuit directed the district court to enjoin enforcement of the rule as to non-grant-funded initiatives, affirmed the dismissal of damages claims due to qualified immunity, and reversed the dismissal of claims for declaratory and injunctive relief. View "YOUTH 71FIVE MINISTRIES V. WILLIAMS" on Justia Law

Two New York residents applied for concealed carry firearm licenses under the state’s licensing laws. Their applications were reviewed by a county court judge acting as a statutory licensing officer, who denied both applications. The judge found that one applicant’s criminal arrest history and failure to disclose it demonstrated a lack of maturity and responsibility, while the other applicant’s criminal history, including a youthful-offender adjudication for robbery, similarly indicated he was not qualified for a license.After their applications were denied, the applicants filed a lawsuit in the United States District Court for the Northern District of New York. They sued the judge in both his individual and official capacities under 42 U.S.C. § 1983, alleging violations of their Second and Fourteenth Amendment rights. The district court dismissed the claims against the judge in his individual capacity, holding that absolute judicial immunity applied because the judge was acting in a judicial role. The court also dismissed the official-capacity claims for injunctive and declaratory relief, finding that Article III’s case-or-controversy requirement and § 1983’s limitations barred such claims against a judge acting in this capacity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The Second Circuit held that judges deciding firearms license applications under New York law act in a judicial capacity and are therefore entitled to absolute immunity from individual-capacity suits for damages. The court further held that Article III’s case-or-controversy requirement bars claims for injunctive and declaratory relief against state court judges in their official capacity when they act as neutral adjudicators without a personal or institutional stake in the challenged law. The judgment of the district court was affirmed. View "Kellogg v. Nichols" on Justia Law

Evan Norman visited a bar where he consumed several alcoholic drinks and fell asleep. At the request of the establishment, Deputy Ingle removed Norman and instructed him to go home, warning that he could be arrested for public intoxication. Norman repeatedly asked for the deputies’ names and badge numbers and made comments to them. As the deputies returned to the bar, Norman followed and continued to engage with them. The situation escalated when Norman reached over Deputy Sutton’s arm and pointed at Deputy Ingle, leading to physical shoving. Norman then attempted to punch Deputy Ingle and placed him in a headlock. In response, the deputies used force to subdue Norman, including multiple punches to his head. Norman was arrested and left facedown for about ten minutes while awaiting medical assistance, during which he suffered significant facial injuries.Norman filed suit in the United States District Court for the Southern District of Texas against the deputies and others, alleging excessive force, denial of medical care, failure to intervene, wrongful arrest, malicious prosecution, and First Amendment violations. The district court dismissed claims against the county and sheriff but allowed claims against the deputies to proceed. The deputies moved for summary judgment, asserting qualified immunity. The district court denied their motions, finding genuine disputes of material fact regarding the use of force, resistance, and medical care, and ruled that the deputies were not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo, considering video evidence of the incident. The court held that the video evidence resolved any material factual disputes and showed that the deputies’ actions did not violate clearly established constitutional rights. The court found the use of force reasonable under the circumstances, no denial of medical care, and no basis for failure to intervene or other claims. The Fifth Circuit reversed the district court’s judgment, holding the deputies were entitled to qualified immunity. View "Norman v. Ingle" on Justia Law

A police officer with the Cambridge Police Department, who had served in both patrol and special investigations roles, posted a comment on his personal Facebook page criticizing the naming of a federal police reform bill after George Floyd. In his post, he referred to Floyd as a "career criminal, a thief and druggie," and expressed pessimism about the country's future. The post was made from home, visible only to his Facebook friends, but was quickly screenshotted and shared with community members, including the local NAACP. The police commissioner was alerted, and the department initiated an internal investigation. The officer was placed on administrative leave and, after the investigation concluded that his post violated department policies on courtesy and professionalism, he was suspended without pay for four days.The officer filed suit in the United States District Court for the District of Massachusetts, alleging that his suspension was unconstitutional retaliation for exercising his First Amendment rights. Both parties moved for summary judgment. The district court granted summary judgment in favor of the department, finding that the department’s interest in maintaining public trust and effective service outweighed the officer’s and the public’s interest in his speech, particularly given the context of heightened scrutiny and protest following George Floyd’s death.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The First Circuit held that, while the officer’s speech addressed a matter of public concern, its mocking and disparaging nature diminished its First Amendment value. The court further held that the department’s prediction that the post could undermine public trust was reasonable, especially in the context of ongoing public unrest and the department’s need to maintain community confidence. The court found no evidence of impermissible viewpoint discrimination. The First Circuit affirmed the district court’s grant of summary judgment for the department. View "Hussey v. City of Cambridge" on Justia Law

Two Black celebrities brought suit after being stopped by Clayton County, Georgia police officers on the jet bridge while boarding flights at Hartsfield-Jackson Atlanta International Airport. The officers, as part of a drug interdiction program, stopped passengers after they had cleared security and boarding checks, requested and retained their identification and boarding passes, questioned them about drugs, and asked to search their luggage. Both plaintiffs alleged they felt coerced, were not free to leave, and believed they had no choice but to comply. They further alleged that the program disproportionately targeted Black passengers and that the stops were neither random nor consensual.The United States District Court for the Northern District of Georgia dismissed all claims. It found the encounters were voluntary and not seizures under the Fourth Amendment, that any searches were consensual, and that the plaintiffs failed to plausibly allege racial discrimination or a policy supporting municipal liability. The court also granted qualified immunity to the individual officers.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the plaintiffs plausibly alleged they were subjected to unreasonable seizures and, in one case, an unreasonable search, in violation of the Fourth Amendment. The court found that the circumstances—officers blocking the plaintiffs’ paths, retaining their documents, and questioning them in a confined space—amounted to seizures, and that the search was not voluntary. However, the court affirmed qualified immunity for the individual officers, as the law was not clearly established. The court also found that the plaintiffs plausibly alleged a policy or custom by Clayton County that could support municipal liability under Monell. The court affirmed dismissal of the equal protection claims, finding insufficient allegations of discriminatory intent. The court reversed in part, allowing the Fourth Amendment claims against Clayton County to proceed. View "Andre v. Clayton County" on Justia Law