Justia Civil Rights Opinion Summaries

The Supreme Court answered in the affirmative two questions certified by the United States District Court for the Southern District of West Virginia, holding that there is no separate cause of action for excessive force by police officers during the course of arrest within the plain language of W. Va. Const. Art. III, 10.Specifically, the Supreme Court held (1) West Virginia applies to its constitution the rule established in Graham v. Connor, 490 U.S. 386 (1989), and United States v. Lanier, 520 U.S. 259 (1997), which requires a constitutional claim that is covered by a specific constitutional provision to be analyzed under the standard specific to that provision and not under substantive due process; and (2) in light of Fields v. Mellinger, 851 S.E.2d 789 (W. Va. 2020), a claim for excessive force by police officers brought under W. Va. Const. art. III, 10 is redundant to a claim brought under Article III, Section 6. View "Stepp v. Cottrell" on Justia Law

Plaintiff, a former Federal Public Defender, was subject to sexual harassment by a supervisor. After attempting to pursue her administrative remedies, Plaintiff claimed she was constructively discharged and resigned. Plaintiff then filed claims under the Due Process and Equal Protection clauses, as well as under 42 U.S.C. Sections 1985(3) and 1986, against various executive and judicial officers. The district court dismissed all of Plaintiff's claims based on her failure to state a claim and Defendant's sovereign immunity.The panel held that Plaintiff's Due Process claim sufficiently plead a deprivation of her property interests, but failed to plead a deprivation of her liberty interest. The panel also held Plaintiff's Equal Protection claim adequately plead sex discrimination; however, her claims under 42 U.S.C. Sections 1985(3) and 1986 failed to state a claim upon which relief could be granted. Finally, the court determined that Plaintiff could only pursue back-pay benefits from all Defendant's named in their official capacity and that all Defendant's named in their individual capacity were entitled to dismissal under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). Thus, the court affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Caryn Strickland v. US" on Justia Law

Plaintiff filed a federal action against the State of Connecticut, a colonel in his official capacity, and a retired detective in her individual capacity, alleging three constitutional claims under 42 U.S.C. Sec. 1983. Plaintiff alleged that those provisions of Connecticut’s sex offender registration statute that required him to disclose his email address and other internet communication identifiers and periodically to verify his residence violated the First Amendment and the Ex Post Facto Clause. Plaintiff further alleged that the detective engaged in malicious prosecution in violation of the Fourth Amendment by seeking an arrest warrant for Plaintiff’s alleged failure to disclose one of his email addresses. The district court dismissed all of Plaintiff’s claims.The Second Circuit reversed the district court’s dismissal of Plaintiff’s First Amendment claim and affirmed the district court’s dismissal of his Post Facto Clause and malicious prosecution claims. The court concluded that the burden of demonstrating that the disclosure requirement satisfied intermediate scrutiny fell on the government and the government must show that the challenged law advances important governmental interests and is narrowly tailored to those interests. The court found that the government did not make the showing.The court further found that because the residence verification provision has not been applied to Plaintiff retroactively, the Ex Post Facto Clause is not implicated. Finally, although the history between Plaintiff and the Sex Offender Registry Unit suggests a motivation to harass him, an officer cannot be liable for a vexatious motivation as long as she acts with arguable probable cause. View "Cornelio v. Connecticut" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint alleging a First Amendment claim and seeking a preliminary injunction, holding that Plaintiffs plausibly alleged a First Amendment violation.At issue was the electronic case filing system piloted by the Maine Supreme Judicial Court (SJC) for the state's trial courts, which resulted in delayed access. Plaintiffs, state and federal news agencies, sued Defendants, state court officials, alleging violations of their First Amendment rights. Thereafter, the SJC changed its rules. The district court held that Plaintiffs had failed to state a claim, dismissed the complaint, and denied the motion for a preliminary injunction as moot. The Supreme Court reversed, holding that Plaintiffs plausibly alleged a First Amendment violation. View "Courthouse News Service v. Quinlan, Bangor Publishing Co., Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute forty grams or more of fentanyl, holding that the district court did not err in denying Defendant's motion to suppress evidence seized during a stop and warrantless search of his vehicle.After Defendant was indicted he filed a motion to suppress the evidence obtained a result of the stop and search in this case. The district court denied the motion and found Defendant guilty. On appeal, Defendant argued that the district court abused its discretion in failing to hold an evidentiary hearing on his motion to suppress and that, alternatively, the district court erred in denying his motion to suppress because he was de facto placed under arrest without probable cause. The First Circuit affirmed, holding (1) if there was an arrest it was a lawful one; and (2) no evidentiary hearing was necessary in this case. View "United States v. Batista" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing this complaint alleging violations of the West Virginia Human Rights Act (WVHRA), W. Va. Code 5-11-1 to -20, holding that Respondent was not entitled to qualified immunity under the WVHRA, and Petitioner's complaint sufficiently stated her claims.Petitioner, a former commercial driver's license instructor for Respondent, Eastern West Virginia Community and Technical College, filed a complaint alleging that Respondent's decision to terminate her employment was predicated upon illegal age and sex discrimination. The circuit court granted Respondent's motion to dismiss, concluding that Respondent was entitled to qualified immunity and that Petitioner had failed to satisfy the heightened pleading standard. The Supreme Court reversed, holding that Petitioner's complaint pleaded sufficient facts to survive a W. Va. R. Civ. P. 12(b)(6) motion to dismiss. View "Judy v. Eastern West Virginia Community & Technical College" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress and convicting him of possession of methamphetamine, second offense, holding that law enforcement acted reasonably under the Fourth Amendment and Iowa Const. art. I, 8 by ordering Defendant out of the vehicle.Defendant was the passenger in a vehicle that was stopped for speeding. Officers asked Defendant to exit the vehicle in order to facilitate the lawful arrest of the back-seat passenger. Officers then asked if they could check Defendant for weapons. The officer's pat-down revealed a methamphetamine pipe and a baggie containing methamphetamine. Defendant moved to suppress the evidence obtained after the exit order, which the district court denied. The Supreme Court affirmed, holding (1) Defendant's consent was voluntary based on the totality of the circumstances; and (2) the Iowa Constitution does no require that subjects of a search must be informed of their right to decline the search in order for their consent to be voluntary. View "State v. Hauge" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress and convicting him of being a felon in possession of a firearm, holding that there was no error in the denial of the motion to suppress.Defendant was a passenger in a Lyft vehicle that was stopped for traffic violations. The officers recognized Defendant from past eluding incidents and ordered him out of the vehicle to conduct a pat-down for weapons. Defendant moved to suppress the evidence, arguing that the officer lacked reasonable and articulable facts to justify ordering him out of the vehicle and patting him down. The district court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that the officer had reasonable suspicion to justify ordering Defendant out of the vehicle and subsequently patting him down for weapons. View "State v. Williams" on Justia Law

Appellee sued officers asserting various Section 1983 claims including excessive force, unreasonable seizure due to an arrest without probable cause, malicious prosecution, violation of her First Amendment rights for arresting her in retaliation for filming the officers, and violation of her Fourteenth Amendment rights. The district court held that disputed issues of material fact barred summary judgment on the excessive force claim and that, viewing the facts in Appellee’s favor, the officers violated a clearly established right.   The Fifth Circuit denied Appellee’s motion to dismiss, reversed the district court’s order denying Appellant’s motion for summary judgment, and remanded with instructions that Appellee’s claims be dismissed.                                                                                        The court analyzed the officers’ actions and found that their conduct was not so objectively unreasonable as to violate Appellee’s constitutional rights. First, Appellee’s minor injuries weigh in favor of finding qualified immunity. Second, qualified immunity can apply even when only one factor weighs against the plaintiff. Finally, it was reasonable of Appellants to believe that, in light of Appellee’s interjections, comments, resistance, and indignation, some degree of force would be necessary to subdue her. The court further held that even if the officers violated Appellee’s constitutional rights, the right was not clearly established at the time of the alleged violation. View "Solis v. Serrett" on Justia Law

Plaintiff alleged that law enforcement officers used excessive force in apprehending him after he escaped from a County Jail highway work crew and lived on the lam for three weeks.   The Ninth Circuit affirmed in part and reversed in part the district court’s summary judgment in favor of law enforcement officials. The court held that the bodycam footage and audio did not blatantly contradict all of Plaintiff’s testimony. The court viewed the facts blatantly contradicted by the bodycam footage in the light depicted by the videotape and its audio to conclude that Plaintiff did not attempt to surrender to the officers. However, the court viewed all other facts, including Plaintiff’s allegation of the post-handcuff beating, in the light most favorable to Plaintiff on summary judgment.   The court found that there were genuine issues of material fact regarding whether the alleged post-handcuff beating and dog-biting were proportional to the threat the officer reasonably perceived by Plaintiff while handcuffed. The court also found that the officer was not entitled to qualified immunity under Sec. 1983 as to the claimed post-handcuff beating and dog-biting because it was clearly established law that beating a handcuffed convict violates the Eighth Amendment. Finally, the court found that the excessive force claims based on failure to intervene and failure to intercede against the other defendants failed. View "COREY HUGHES V. MICHAEL RODRIGUEZ" on Justia Law