Justia Civil Rights Opinion Summaries

Edward Flynn was killed when a fleeing suspect, James Shirley, crashed into his car during a high-speed police pursuit. The incident began when Indianapolis police officers attempted to investigate a potentially stolen truck. Shirley, the suspect, backed into a patrol car and nearly struck two officers before fleeing. Multiple officers engaged in a pursuit that lasted about five and a half minutes, during which Shirley drove recklessly, including turning off his lights, running stop signs and red lights, and reaching high speeds. The chase ended when Shirley ran a red light and collided with Edward Flynn’s vehicle, resulting in Flynn’s death.Gayl Flynn, representing Edward’s estate, filed suit in the United States District Court for the Southern District of Indiana against the City and five officers. She alleged violations of Edward’s Fourteenth Amendment substantive due process rights and claimed the City failed to properly train its officers, invoking Monell v. Department of Social Service of New York. The district court granted summary judgment for the defendants, applying the “intent to harm” standard for Fourteenth Amendment liability in emergency situations and finding no such intent by the officers.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the facts presented an emergency situation, making the “intent to harm” standard appropriate. The court found that the officers did not act with intent to harm and that the circumstances did not support a claim under a deliberate indifference standard. Because there was no underlying constitutional violation, the Monell claim against the City also failed. The Seventh Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Flynn v Consolidated City of Indianapolis and Marion County" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

A Christian humanitarian organization offered a remote customer service representative position to an applicant who was openly in a same-sex marriage. After the applicant disclosed her marital status while inquiring about parental leave, the organization rescinded the job offer, citing its policy that limits employment to those who comply with its religious standards, including a prohibition on sexual conduct outside of marriage between a man and a woman. The applicant, who identifies as Christian and is active in LGBTQ advocacy, sued the organization for discrimination based on sex, sexual orientation, and marital status under federal and state law.The United States District Court for the Western District of Washington initially granted summary judgment to the organization, finding that the church autonomy doctrine barred judicial inquiry into the religiously motivated employment decision. Upon reconsideration, the district court reversed itself, holding that the church autonomy doctrine did not apply because the organization’s hiring policy was facially discriminatory and could be evaluated using neutral legal principles. The district court also rejected the organization’s ministerial exception defense and other constitutional and statutory defenses, ultimately granting summary judgment to the applicant and entering judgment for stipulated damages.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The Ninth Circuit held that the ministerial exception applies because customer service representatives at the organization perform key religious functions central to its mission, such as communicating its ministries to donors, engaging in prayer with supporters, and inviting participation in its religious mission. The court concluded that these duties are vital to the organization’s religious purpose, and therefore, the ministerial exception bars the applicant’s employment discrimination claims. The Ninth Circuit remanded the case for entry of summary judgment in favor of the organization. View "MCMAHON V. WORLD VISION INC." on Justia Law

Michael Hurd, Jr. was sentenced in 2005 to 15 months in prison for a felony firearm charge and an additional 27 months for four misdemeanor firearm and drug possession charges. After serving his felony sentence in federal custody, Hurd was mistakenly released instead of being transferred to serve his misdemeanor sentence. He completed his supervised release and, years later, was reincarcerated by the District of Columbia Department of Corrections when the error was discovered during a subsequent, unrelated incarceration. Hurd was not given a hearing before being required to serve the remainder of his original sentence.After his reincarceration, Hurd filed a habeas petition in the Superior Court of the District of Columbia, which was denied. His appeal was dismissed as moot after he completed his sentence. Hurd then brought a civil action in the United States District Court for the District of Columbia under 42 U.S.C. § 1983, alleging violations of his substantive and procedural due process rights under the Fifth Amendment. The district court granted summary judgment to the District, finding no substantive due process violation and holding that his procedural due process claim was barred by the Supreme Court’s decision in Heck v. Humphrey.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court’s judgment. The court held that reincarcerating a person to serve the remainder of a lawfully imposed sentence after an erroneous release does not violate substantive due process, as such action does not “shock the conscience.” The court also held that Hurd’s procedural due process claim for damages was barred by Heck v. Humphrey because a judgment in his favor would necessarily imply the invalidity of his confinement, which had not been set aside. View "Hurd v. DC" on Justia Law

In 2021, Ralph Marcus Hardy, an inmate at Adams County Detention Facility (ACDF) in Colorado, fell from his wheelchair and suffered serious injuries. Despite his repeated requests for medical attention, jail officials allegedly ignored his pleas. Hardy claims that Detention Specialist Daniel DeHerrera ignored emergency distress signals from his cell, and Deputy Dennis Rabie, who later found Hardy in pain, also failed to provide medical assistance.The United States District Court for the District of Colorado reviewed the case. Deputy Rabie and Detention Specialist DeHerrera moved to dismiss Hardy’s claims, asserting qualified immunity. The district court denied their motion, finding that Hardy plausibly alleged violations of his Fourteenth Amendment rights. The court held that the defendants were not entitled to qualified immunity, leading to this appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Hardy sufficiently alleged that both Deputy Rabie and Detention Specialist DeHerrera acted with deliberate indifference to his medical needs. The court found that Hardy’s constitutional rights were violated and that these rights were clearly established at the time of the incident. The court concluded that both defendants were aware of Hardy’s serious medical needs and failed to take reasonable measures to address them, thus denying them qualified immunity. View "Hardy v. Rabie" on Justia Law

During a protest in Seattle on June 7-8, 2020, Taylor Cheairs was filming the event when Officer Anderson of the Seattle Police Department (SPD) threw a blast ball grenade that exploded and struck Cheairs in the groin, causing serious injury. Cheairs sued the City of Seattle, the SPD, and unnamed officers under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment and retaliation in violation of the First Amendment.The United States District Court for the Western District of Washington granted summary judgment in favor of the defendants. The court concluded that there was no Fourth Amendment violation because Cheairs was not seized, and no First Amendment violation because there was no evidence of retaliation. The court also ruled that without a constitutional violation, there could be no municipal liability under Monell v. Department of Social Services.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The Ninth Circuit held that although a reasonable fact finder could conclude that Cheairs was seized when Officer Anderson struck him with the blast ball, the use of force was reasonable under the circumstances. The court noted that the protesters near Cheairs posed an immediate threat to the safety of officers, citizens, and property. The court also held that Cheairs failed to establish a viable First Amendment retaliation claim because he did not provide evidence that his filming was a substantial or motivating factor in the use of force against him. Consequently, without a viable constitutional claim, Cheairs could not establish a claim for municipal liability. View "CHEAIRS V. CITY OF SEATTLE" on Justia Law

Officer Mason Roth shot and killed Bobby Jo Klum, who was walking through a residential neighborhood with a gun to his head, evading arrest, and ignoring officer commands to drop the weapon. Klum’s spouse and mother sued Officer Roth and the City of Davenport under 42 U.S.C. § 1983, alleging a violation of Klum’s Fourth Amendment right against unreasonable seizure. The district court granted qualified immunity to Officer Roth and concluded the City of Davenport was not liable under Monell v. Department of Social Services.The United States District Court for the Southern District of Iowa granted summary judgment to Officer Roth and the City of Davenport on all claims. The court concluded that Klum’s Fourth Amendment right against unreasonable seizure was not violated and that Klum did not possess a clearly established right against seizure by deadly force under the circumstances. Plaintiffs appealed the district court’s grant of summary judgment based on qualified immunity as to their excessive force claim against Officer Roth and the City of Davenport.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that any right was not clearly established at the time, and therefore, Officer Roth was entitled to qualified immunity. The court found that the totality of the circumstances, including Klum’s non-compliance, evasion, and proximity to bystanders, justified the use of deadly force. The court also upheld the district court’s grant of summary judgment on the Monell claim, concluding that Plaintiffs failed to raise a genuine issue as to whether the City of Davenport had a policy that directly caused the use of deadly force. View "Klum v. City of Davenport" on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law

Evy Orellana suffered serious injuries when a tactical canine bit her leg as a U.S. Marshals fugitive task force executed an arrest warrant for her boyfriend, Eric Trinidad. Orellana, Trinidad, and their baby lived in the basement of Trinidad’s mother’s home. The officers breached a sealed door to access the basement, and the dog bit Orellana during the search. Orellana sued the officers under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, claiming a violation of her Fourth Amendment rights due to unreasonable search and seizure.The United States District Court for the District of Maryland denied the officers' motion to dismiss, reasoning that the case was similar enough to Bivens to apply its cause of action. The court also denied the officers' motion for summary judgment on the grounds of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that this case presented a new context for Bivens because the officers were part of a specialized federal-state task force operating under a warrant. The court emphasized that the Supreme Court has cautioned against extending Bivens to new contexts, particularly when Congress is better suited to create a cause of action. The court concluded that special factors, including federalism concerns and the existence of alternative remedial procedures, counseled against extending Bivens in this situation. Therefore, the appellate court reversed the district court's decision, denying Orellana a Bivens remedy. View "Orellana v. Deputy United States Marshal Godec" on Justia Law

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law