Justia Civil Rights Opinion Summaries

Johnson entered state custody in 2007. His history of prison misconduct led to his transfer in 2013 to serve accumulated segregation (solitary confinement). Johnson suffers from serious mental illness, including depression and bipolar disorder, and he was on crisis watch nine times while in segregation. Mental health professionals regularly monitored his condition and treated him with medication, which was periodically adjusted. Johnson’s misconduct continued in segregation, especially when he refused to take his medication. Many of his violations were serious enough to trigger penalties of 30-90 days of no “yard” access.Johnson sued under 42 U.S.C. 1983, alleging in his pro se complaint that the cumulative yard restrictions (totaling about three years, with 24 months consecutive) violated his Eighth Amendment right to be free from cruel and unusual punishment. He also complained of unsanitary conditions, poor ventilation, summertime heat in his cell, excessive noise, and inadequate mental health treatment. The district court granted the defendants summary judgment. Johnson obtained counsel and cited research on the harmful effects of solitary confinement. The Seventh Circuit affirmed. Johnson never sought relief for the time he spent in solitary confinement; he sued over his loss of yard access, unhealthy conditions in his cell, and his mental-health treatment. The record is entirely undeveloped on the issue of the effects of prolonged solitary confinement. Claims not raised in the district court are waived. View "Johnson v. Prentice" on Justia Law

The Estate filed suit alleging claims under 42 U.S.C. 1983 and state law after Deputy Sheriff Anthony Momphard, Jr. fatally shot Michael Knibbs while Knibbs was standing inside his home holding a loaded shotgun. The district court concluded that defendant was entitled to qualified immunity from the Estate's section 1983 claim and that the Estate's state law claims against Deputy Momphard, Macon County Sheriff Robert Holland, and the insurance companies that issued the Sheriff's Office a liability insurance policy and a surety bond necessarily failed.The Fourth Circuit vacated the district court’s award of summary judgment to Deputy Momphard on the Estate's section 1983 claim against him in his individual capacity. The court concluded that the district court erred in finding that there were no genuine issues of disputed material fact, and ultimately erred in finding that Deputy Momphard's use of force was reasonable as a matter of law at this stage in the proceedings. In this case, there is sufficient evidence for a reasonable jury to find that Knibbs never pointed his weapon at Deputy Momphard or made any furtive movements, thereby rendering unjustified the deadly force used against Knibbs. Furthermore, the court's case law demonstrates that the contours of Knibbs' constitutional right were clearly established at the time.The court also vacated the district court's summary judgment as to the wrongful death claim for both compensatory and punitive damages under North Carolina law against Deputy Momphard in his individual capacity, and the claims under the Macon County Sheriff's Office's surety bond against Deputy Momphard and Sheriff Holland in their official capacities, and against Western Surety, for up to $25,000 in damages. However, the court affirmed the district court's conclusions that the Estate's Fourteenth Amendment claim fails as a matter of law; Macon County's liability insurance policy preserves the Sheriff’s Office's governmental immunity from suit; and the Estate's claims brought directly under the North Carolina Constitution are precluded. The court remanded for further proceedings. View "Knibbs v. Momphard" on Justia Law

Karr was convicted of rape and domestic battery for his assaults on A.P., his former girlfriend. Karr then fired his attorney, hired a new one, and pursued claims of ineffective assistance of trial counsel. Those claims were rejected by the Indiana trial court and on direct appeal. Karr then sought federal habeas relief under 28 U.S.C. 2254.The Seventh Circuit affirmed the denial of his petition. The court rejected an argument that counsel was ineffective because he failed to investigate A.P.’s history of medication use, and introduced no evidence about whether Karr used his cellphone during his second assault so that A.P.’s trial testimony could have been impeached. The jury had an ample basis on which to find A.P. credible. There is no reasonable probability that any evidence Karr references would have affected the trial’s outcome. Because Karr did not raise six additional claims in Indiana state court, he procedurally defaulted them. Those procedural defaults are not excusable under a narrow equitable exception delineated by the Supreme Court, which does not apply to “insubstantial defaulted claims such as the ones Karr presents” and does not apply in this procedural posture. View "Karr v. Sevier" on Justia Law

Dr. Heyd, the prison's medical officer, treated inmate Murray, who had a heart attack in 2008, before his incarceration, and was hospitalized in 2010 for deep-vein thrombosis in his leg. Murray was prescribed a treatment regimen of Coumadin. He was hospitalized multiple times during 2011 for his deep-vein thrombosis. His hematology-consult team recommended “a fair trial of Coumadin with an (INR) [international normalized ratio] ranging between 2.5 and 3.” In 2012, Murray suffered from a cerebral blood clot that left him permanently blind.Murray filed a “deliberate indifference” claim under 42 U.S.C. 1983. His expert declaration from a hematologist stated that Heyd and his staff allowed the INR to fall into subtherapeutic levels, failed to follow the hematology recommendations, and failed to appropriately adjust the Coumadin doses; Heyd failed to personally evaluate Murray when he complained of headaches and nausea, symptoms of cerebral edema.Heyd sought qualified immunity in a motion for summary judgment, which the district court denied. The Sixth Circuit affirmed. There is sufficient evidence for a jury to find facts from which the inference of a substantial risk of serious harm to Murray’s health could be drawn, and that Heyd knew of and disregarded that substantial risk. An inmate’s rights to medical care that is not unreasonably delayed and to adherence to a prescribed treatment plan were clearly established at the time of Heyd’s conduct. View "Murray v. State of Ohio Department of Corrections" on Justia Law

The Supreme Court reversed the order of the district court affirming the justice court's denial of Defendant's motion to suppress, holding that particularized suspicion did not exist to support extending Defendant's traffic stop into a drug investigation.Defendant pleaded guilty to criminal possession of drug paraphernalia and criminal possession of marijuana. On appeal, Defendant challenged the denial of his motion to suppress the State's evidence as the product of an illegal extension of the stop, arguing that the police officer lacked particularized suspicion to justify extending the traffic stop and ordering a canine sniff search. The Supreme Court agreed and reversed, holding that the justice court erred in denying Defendant's motion to suppress. View "State v. Harning" on Justia Law

Trozzi, a pre-trial detainee, reported gastrointestinal health issues related to gastric bypass surgery. Doctors had placed Trozzi on a specialized diet and prescribed antacids to prevent ulcers. Trozzi sought help filling her prescriptions and an adjustment in her diet, twice referring to an ulcer. Nurse Snow scheduled Trozzi to meet with a doctor. During the night before her appointment, Trozzi called for help. Officer Stakich found Trozzi doubled over in pain. Stakich's supervisor instructed that Trozzi be taken to a medical holding cell for observation. Trozzi received an over-the-counter antacid; she had a normal heart rate, blood pressure, and blood oxygen saturation. Snow advised Capron to continue monitoring. Trozzi alleges that she became covered in her own urine, feces, and bloody vomit as she waited in her cell. At the scheduled visit, the doctor sent Trozzi to the hospital, where she underwent surgery for a perforated ulcer.The Sixth Circuit affirmed the summary judgment rejection of Trozzi’s 42 U.S.C. 1983 suit. An inadequate-medical-care claim requires proof that the plaintiff had an objectively serious medical need; a reasonable officer at the scene (knowing what the particular officer knew) would have understood that the detainee’s medical needs subjected the detainee to an excessive risk of harm; and the officer knew that his failure to respond would pose a serious risk to the detainee but ignored that risk. The defendants lacked the requisite knowledge. View "Trozzi v. Lake County, Ohio" on Justia Law

The Eleventh Circuit vacated the district court's dismissal of plaintiff's Americans with Disabilities lawsuit based on lack of Article III standing, concluding that plaintiff has at least alleged an Article III qualifying stigmatic injury. In this case, plaintiff alleged that she suffered a concrete injury when she viewed a hotel's website that omitted accessibility-related information required by federal regulations and as a result, she says, experienced "frustration and humiliation"—even though she admits that she had (and has) no intention to personally visit the hotel.Despite the absence of a close common-law comparator, the court concluded that under existing precedent plaintiff has alleged a concrete intangible injury. The court explained that plaintiff's allegations satisfy Article III under a narrower reading of Sierra v. City of Hallandale Beach, 996 F.3d 1110 (11th Cir. 2021). Because she claims not only that she suffered illegal discrimination but also that the discrimination resulted in "frustration and humiliation" and a "sense of isolation and segregation," the court concluded that plaintiff has adequately pleaded a concrete stigmatic injury. And because her emotional injury is her emotional injury, it affects her "in a personal and individual way" and is therefore sufficiently particularized. The court remanded for further proceedings. View "Laufer v. Arpan LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder and other crimes, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held that the trial court (1) Defendant failed to establish under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989), that the trial court violated his federal due process rights by detaining three eyewitnesses to secure their attendance at trial; and (2) did not abuse its discretion by permitting the prosecutor to read passages from the witnesses' grand jury transcripts to the jury for substantive purposes pursuant to State v. Whelan, 513 A.2d 86 (Conn. 1986). View "State v. Gray" on Justia Law

Holiman was found in possession of illegal drugs and a handgun during a traffic stop initiated after he made a right-hand turn at a stop sign, while the arresting officer’s patrol car was stopped directly behind him. Holiman did signal the turn, but the basis for the traffic stop was that he did not turn on his signal blinker early enough: for the 100 feet he drove before coming to a stop. The arresting officer cited him for violation of Vehicle Code section 22108. The trial court denied his motion to suppress the seized evidence, following which he pled guilty to two felony drug charges.The court of appeal reversed. The warrantless seizure of the evidence violated the Fourth Amendment because the police lacked objectively reasonable suspicion. Holiman’s turn did not violate the Vehicle Code, and no reasonable police officer could think that it did. The statute refers to “the giving of an appropriate signal in the manner provided in this chapter in the event any other vehicle may be affected by the movement.” The prosecution presented no evidence that the turn could have affected any vehicle, including the officer’s patrol car. View "People v. Holiman" on Justia Law

Bayon attempted to rob an Indianapolis gas station, then fled the scene in a vehicle. Numerous police officers gave chase. A high-speed pursuit through residential areas ensued. Officer Brink executed a maneuver that resulted in the Traverse spinning and crashing into a tree. Using a loudspeaker, Officer Myers ordered Bayon to exit the vehicle multiple times. Bayon took several minutes to exit the vehicle, saw 10-15 police officers, and heard commands to put his hands up and to show identification. He claims he reached for his wallet. The officers shot him. Three bullets hit Bayon; he fell face-first to the ground. Bayon claims that after he was rolled over, an officer said, “Oh, my God, he doesn’t have a weapon.” The officers claim that Bayon took several aggressive steps toward Myers and reached for something near his waistband. Two officers saw a black, hard object, and thought it was a gun. Another officer pulled “a car jack handle,” out of his pant leg.In Bayon’s suit under 42 U.S.C. 1983, the district court denied the officers summary judgment based on qualified immunity, concluding that the facts were in dispute. The Seventh Circuit dismissed an appeal for lack of appellate jurisdiction. The parties’ claims are inseparable from disputed facts. View "Bayon v. Berkebile" on Justia Law