Justia Civil Rights Opinion Summaries

At about 4:30 a.m., an anonymous 911 call reported a break-in at neighboring apartment 103, with screaming, Seven Southfield Police officers responded, entered the building, and heard screaming but could not identify the source; the door to 103 was not broken. The officers determined that the window was not a point of entry; they received no response to intermittent knocking. The dispatcher called the anonymous caller back; the caller said that she “can’t be positive what apartment it was coming from.” After about eight minutes, Mitchell opened the door to 103. She denied that there were any problems. Although none of the officer noticed any injuries on Mitchell or saw any signs of suspicious activity, they pushed their way inside, injuring Mitchell’s knee. Mitchell continued to object to the warrantless entry. The officers arrested Mitchell’s guest, Williams, allegedly employing unnecessary force. The officers found no evidence of illegal activity in the apartment. Charges against Williams for resisting arrest and obstruction of police were dismissed.Mitchell and Williams filed suit under 42 U.S.C. 1983, asserting unlawful entry and excessive force. Williams also asserted false arrest and malicious prosecution. Certain claims were dismissed. The Sixth Circuit dismissed the officers’ appeal of the grant of summary judgment to Williams on his false arrest claim for lack of jurisdiction and affirmed the denial of the officers’ qualified immunity motion for summary judgment on the unlawful entry claim and Mitchell’s excessive force claim. View "Williams v. Maurer" on Justia Law

During Castilleja's 15 years as Bexar County Community Supervision and Corrections Department (CSCD) community service officer, he had multiple reprimands and termination warnings. After Castilleja was transferred in 2014, his new manager suspected Castilleja was violating overtime rules. An investigation by Assistant Chief Kelly confirmed Castilleja was routinely taking unapproved overtime and using his work computer to send union-related emails. Castilleja only received counseling and was put on a “performance improvement plan.” Castilleja’s 2015 evaluation rated him “satisfactory” overall but gave him the lowest rating in multiple categories. In 2016, Castilleja was sworn in as president of the Bexar County Probation Officers Association (BCPOA), having served in the union since 2007. Castilleja switched units and other issues came to light, resulting in an audit of Castilleja’s former cases. Brady recommended termination, citing Castilleja’s disregard of “the basic ten[e]ts of case management,” multiple policy violations, plus two instances of conducting union business while at work, and one use of work email to send union-related emails. Meanwhile, the BCPOA issued a no-confidence petition calling for Anderson’s removal. Days later, Anderson heard Castilleja’s appeal. Anderson fired Castilleja.Castilleja and the Union sued Anderson and Brady in their individual and official capacities, claiming that Castilleja was fired in retaliation for union-related speech and association in violation of the First Amendment, 42 U.S.C. 1983, 1985. The Fifth Circuit affirmed the dismissal of all claims. The evidence established valid reasons for firing Castilleja. View "United Steel, Paper and Forestry, Rubber Manufacturing, Energy, Allied Industrial & Service Workers International Union v. Anderson" on Justia Law

For many years, a 265-acre tract in Robinson Township, Pennsylvania hosted a gun range with over 800 members. In 2008, the range’s then-owner pleaded guilty to possessing weapons as a convicted felon, and the Club closed for about a decade. In 2017, Drummond leased the property for the retail sale of firearms and a shooting range. The Township then permitted "Shooting Ranges" in Industrial and Special Conservation zoning districts; Interchange Business Districts (IBD) could host “Sportsman’s Clubs.” Residents complained that renewed “use of high power rifles” at the Club would pose a “nuisance” and a “danger.” The Board amended the IBD rules, covering Drummond's property, limiting Clubs to “pistol range, skeet shoot, trap and skeet, and rimfire rifle[]” practice; defining a “Sportsman’s Club” as a “nonprofit entity formed for conservation of wildlife or game, and to provide members with opportunities for hunting, fishing or shooting”; and switching Clubs to a “conditional use.”Drummond sued, alleging that the rules restrict his customers’ efforts to acquire firearms and maintain proficiency and were facially unconstitutional. The Third Circuit vacated the dismissal of the complaint. In identifying which rules invade the Second Amendment, courts identify historical outliers—laws that lack traditional counterparts. In applying heightened scrutiny, courts look for laws with few parallels in contemporary practice. The more “exceptional” a rule, the more likely the government has overlooked less burdensome “options that could serve its interests.” The challenged zoning rules constitute outliers, and the pleading-stage materials fail to justify their anomalous features. View "Drummond v. Robinson Township" on Justia Law

Plaintiffs challenged Indiana’s Sex Offender Registration Act (SORA) as it applies to offenders who have relocated to Indiana from other states. A 2006 SORA amendment applied its requirements to any “person who is required to register as a sex offender in any jurisdiction.” Indiana does not require any person to register if the offense occurred prior to SORA, provided that person remains a resident of Indiana. Under the amendment, persons with pre-SORA convictions who relocate to Indiana from another state where registration was required must register in Indiana, even if Indiana would not have required them to register had they committed their offenses in Indiana and never left.The Seventh Circuit initially affirmed but on rehearing, en banc, reversed. SORA does not violate the right to travel because it does not expressly discriminate based on residency, as consistently required by the Supreme Court. Plaintiffs’ ex post facto claim is likewise precluded by precedent. SORA is not “so punitive either in purpose or effect” as to surmount Indiana’s nonpunitive intent for the law. Because the district court did not address whether SORA passes rational basis scrutiny under an equal protection analysis, the court remanded for consideration of the equal protection claim. View "Hope v. Commissioner of Indiana Department of Correction" on Justia Law

Yañez was shot and killed by a U.S. Border Patrol agent while on the border fence, which is in the United States. After being shot, Yañez fell and landed across the international border. Yañez’s family filed civil claims against the government and individual federal agents.The Ninth Circuit affirmed the rejection of claims under the Alien Tort Statute (ATS) and the Federal Tort Claims Act (FTCA), and a “Bivens” claim. The court rejected an argument that the shooting and Border Patrol’s Rocking Policy, authorizing deadly force in response to rock-throwing, violated an international jus cogens norm against extrajudicial killing and was actionable under the ATS; the ATS does not waive sovereign immunity, even for jus cogens violations. Claims under the FTCA were time-barred. Plaintiff initially did not pursue an FTCA claim because she believed that, under Ninth Circuit precedent, judgment on an FTCA claim would have foreclosed her Bivens claims. Plaintiff amended the complaint to assert FTCA claims after the Supreme Court abrogated that precedent in 2016. The FTCA’s judgment bar did not foreclose a contemporaneously filed Bivens claim when the government had prevailed on the FTCA claim, so the Supreme Court’s decision was irrelevant to this situation. That mistake of law was not outside of plaintiff's control and did not qualify as an extraordinary circumstance supporting equitable tolling. Special factor counseled against extending a Bivens remedy; doing so would challenge a high-level executive policy and implicated national security. View "Quintero-Perez v. United States" on Justia Law

Trinh sued Fineman, who had been appointed by the Court of Common Pleas of Philadelphia County as a receiver in a case involving the dissolution of Trinh’s beauty school. She alleged that Fineman did not give her a proper accounting of the escrow account related to that case and accused him of theft. The district court dismissed the complaint for lack of subject matter jurisdiction, explaining that Trinh had not raised “any claims arising under federal law or [alleged] that the parties are citizens of different states.” The Third Circuit remanded to allow Trinh to amend her complaint. Her amended complaint asserted that Fineman, as the receiver, was “abusing his state power.”The Third Circuit affirmed the dismissal of the complaint. Although Trinh’s complaint arguably raised a section 1983 claim, Fineman, as a court-appointed receiver, is entitled to absolute, quasi-judicial immunity from suit when acting with the authority of the court. Erroneous, controversial, and even unfair decisions do not divest a judge of immunity. Fineman was duly appointed by the state court and the transcript of that court's hearing reflects that the judge was aware of, and approved of, all of his expenditures. View "Trinh v. Fineman" on Justia Law

Lozano, a former Marine, was discharged for medical reasons and suffers from severe asthma, impaired airway, limited motion in his knees and ankle, and total blindness in one eye. Lozano has a handicapped parking permit and a permit for tinted windows on his car. Lozano’s car was parked partly within a handicapped parking space when Sergeant Dorilus arrived. Dorilus could not see the handicapped placard on the dashboard and required Lozano to provide his license and registration, and his permits for handicapped parking and tinted windows. Dorilus claims that Lozano “reeked of alcohol.” Lozano denied having consumed any alcohol and refused to submit to the field sobriety test, claiming he was physically unable to do so. Dorilus arrested Lozano. Officer Hernandez was “present” throughout these events. At the station, Hernandez helped process Lozano. Other officers gave Lozano two breathalyzer tests, but could not provide a sufficient breath sample. During a third breathalyzer test, Lozano had an asthma attack and had to be taken to the hospital. Dorilus charged Lozano with DUI and refusal to take a breath test, After Lozano provided medical records, the charges were dismissed.Lozano subsequently sued under 42 U.S.C. 1983 and the New Jersey Civil Rights Act The district court denied the officers’ qualified immunity summary judgment motions. The Third Circuit reversed as to Officer Hernandez, who was not involved in arresting or charging Lozano and therefore is entitled to qualified immunity. View "Lozano v. New Jersey" on Justia Law

Plaintiff filed suit alleging 42 U.S.C. 1983 compensatory and punitive damage claims against paramedics for injecting her with ketamine without her consent, and against physicians who allegedly implemented ambulance protocols while conducting the second ketamine study, both in their individual and official capacities. Plaintiff also alleged claims of Monell liability against the county, several of its health care facilities, and the individual defendants for developing and implementing a countywide ketamine protocol. The complaint alleged that defendants used excessive force, violated her right to bodily integrity, and acted with deliberate indifference in violation of the Fourth Amendment and her right to substantive due process under the Fourteenth Amendment.The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims. In regard to plaintiffs' claims against the paramedics, the court concluded that the district court properly dismissed plaintiff's excessive force claims where it was not objectively unreasonable for paramedics to administer medical aid to an intoxicated, suicidal, semi-conscious woman who needed medical intervention; the district court properly dismissed the substantive due process claims where, even if the semi-conscious plaintiff was competent to refuse treatment, the paramedics did not engage in conscience shocking conduct in electing to sedate a suicidal, intoxicated woman to protect both the patient and themselves; and the paramedics were not deliberately indifferent to plaintiff.In regard to claims against the physicians, the court concluded that at minimum these defendants are entitled to qualified immunity on plaintiff's claims related to their oversight of the county's ketamine studies because they were not personally involved in the actions leading to plaintiff's emergency treatment. Finally, in regard to the Monell liability claims, the court concluded that plaintiff failed to establish that the paramedics violated her Fourth Amendment or substantive due process rights. View "Buckley v. Hennepin County" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree premeditated murder for the deaths of an adult and an infant, holding that the district court erred in failing to suppress Defendant's statement to the police, the error was harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) Defendant's statement to police should have been suppressed because Defendant unambiguously invoked his constitutional right to remain silent during the police interrogation, but the failure to do so by the district court was harmless beyond a reasonable doubt; (2) the evidence was sufficient to prove that Defendant had an intent to kill when he fired the gunshot that killed the infant; and (3) the district court did not abuse its discretion by imposing consecutive sentences. View "State v. McInnis" on Justia Law

Matias, a native of El Salvador, unlawfully entered the U.S. in 2014. El Salvadoran authorities considered him a member of MS-13, a violent gang. In Maryland, Matias pleaded guilty to assault in the first degree after being involved in a shooting that authorities determined was retaliation for MS-13 gang activity, and identified Matias as an MS-13 “affiliate.” ICE detained Matias in 2018. Matias requested to be housed with a gang aligned with MS-13. An IJ denied him bond and later denied Matias relief under the Convention Against Torture (CAT) and ordered him removed. The Board of Immigration Appeals dismissed his appeal. The Ninth Circuit denied his petition for review in 2021.Matias moved the BIA to reopen his case so that it could consider “new developments” regarding his request for CAT relief: claimed political changes in El Salvador and an alleged text from an MS-13 gang member labeling him a “snitch” and saying he will be killed if he returns to El Salvador. The BIA denied his request for an emergency stay. Matias filed a habeas petition, asking the court to enjoin the government from removing him until the BIA ruled on his motion to reopen. The district court denied his motion. The Ninth Circuit agreed with the district court, which denied Matias’s motion for a temporary restraining order, determining that 8 U.S.C. 1252(g)’s jurisdictional limits barred his claims. View "Rauda v. Jennings" on Justia Law