Justia Civil Rights Opinion Summaries

Gilead Community Services, Inc. and Connecticut Fair Housing Center, Inc. sued the Town of Cromwell and several of its officials for discrimination and retaliation under the Fair Housing Act (FHA) and Americans with Disabilities Act (ADA). Gilead had purchased a house in Cromwell to be used as a group home for individuals with mental health disabilities. Following significant opposition from town residents and officials, including discriminatory statements and actions by the town's mayor and manager, Gilead was forced to close the group home. The town's actions included petitioning the Department of Public Health to deny a license for the home, issuing a cease-and-desist letter, and denying a tax exemption application.The United States District Court for the District of Connecticut found the Town of Cromwell liable for violating the FHA and ADA, awarding $181,000 in compensatory damages and $5 million in punitive damages. The town appealed, arguing that the district court erred in applying a motivating-factor causation test to FHA claims, in subjecting the municipality to vicarious liability and punitive damages under the FHA, and that the punitive damages were unconstitutionally excessive.The United States Court of Appeals for the Second Circuit reviewed the case. The court rejected Cromwell's arguments regarding the causation standard, vicarious liability, and the availability of punitive damages under the FHA. The court held that motivating-factor causation applies to FHA claims, municipalities can be held vicariously liable under the FHA, and the FHA allows for punitive damages against municipalities. However, the court found the $5 million punitive damages award to be unconstitutionally excessive, given the high ratio of punitive to compensatory damages and the disparity with civil penalties for similar conduct.The Second Circuit affirmed the district court's judgment in part, vacated the punitive damages award, and remanded the case for further proceedings, instructing the district court to grant a new trial on punitive damages unless Gilead agrees to a remittitur reducing the punitive damages to $2 million. View "Gilead Community Services, Inc. v. Town of Cromwell" on Justia Law

In this case, the plaintiff, Basel Soukaneh, alleged that during a routine traffic stop, Officer Nicholas Andrzejewski of the Waterbury, Connecticut police department unlawfully handcuffed and detained him in a police vehicle for over half an hour and conducted a warrantless search of his vehicle. Soukaneh had presented a valid firearms permit and disclosed the presence of a firearm in his vehicle. Andrzejewski argued that the presence of the firearm gave him probable cause to detain Soukaneh and search his vehicle.The United States District Court for the District of Connecticut partially granted and partially denied Andrzejewski’s motion for summary judgment. The court found that the initial stop was justified based on reasonable suspicion of a traffic violation. However, it denied summary judgment regarding the handcuffing and prolonged detention of Soukaneh, as well as the searches of the vehicle and trunk, concluding that Andrzejewski did not have the requisite probable cause and was not entitled to qualified immunity for these actions.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Andrzejewski violated Soukaneh’s Fourth Amendment rights by detaining him in a manner and for a length of time that constituted a de facto arrest without probable cause. The court also found that the warrantless searches of Soukaneh’s vehicle and trunk were not justified under the automobile exception or as a Terry frisk, as there was no reasonable suspicion or probable cause to believe that the vehicle contained contraband or evidence of a crime. Consequently, Andrzejewski was not entitled to qualified immunity for his actions. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Soukaneh v. Andrzejewski" on Justia Law

Three individuals, Jamarr Smith, Thomas Iroko Ayodele, and Gilbert McThunel, were convicted of robbery and conspiracy to commit robbery. The convictions were based on evidence obtained through a geofence warrant, which collected location data from Google to identify suspects. The robbery involved the theft of $60,706 from a U.S. Postal Service route driver, Sylvester Cobbs, who was attacked with pepper spray and a handgun. Video footage and witness testimony linked the suspects to the crime scene, but no arrests were made immediately. Investigators later used a geofence warrant to gather location data from Google, which led to the identification of the suspects.The United States District Court for the Northern District of Mississippi denied the defendants' motion to suppress the evidence obtained through the geofence warrant. The defendants argued that the warrant violated their Fourth Amendment rights due to lack of probable cause and particularity, and that the government did not follow proper legal procedures in obtaining additional information from Google. The district court found that law enforcement acted in good faith and denied the motion to suppress. The defendants were subsequently convicted by a jury and sentenced to prison terms ranging from 121 to 136 months.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that geofence warrants, as used in this case, are unconstitutional under the Fourth Amendment because they resemble general warrants, which are prohibited. However, the court affirmed the district court's decision to deny the motion to suppress, citing the good-faith exception. The court concluded that law enforcement acted reasonably given the novelty of the geofence warrant and the lack of clear legal precedent. Therefore, the convictions were upheld. View "United States v. Smith" on Justia Law

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

An Arkansas inmate, Steven Pinder, filed a lawsuit under 42 U.S.C. § 1983, alleging that various defendants, including Wellpath, LLC, and its employees, were deliberately indifferent to his serious medical needs, violating his Eighth Amendment rights. Pinder sought declaratory and injunctive relief and substantial damages for several medical issues, including severe glaucoma, peptic ulcers, acid reflux, diabetes, and an orthopedic condition in his right shoulder. The district court granted summary judgment to two defendants on the shoulder claim and dismissed other claims for failure to establish in forma pauperis (IFP) status.The United States District Court for the Eastern District of Arkansas initially denied Pinder's IFP status due to his "three strikes" under the Prison Litigation Reform Act (PLRA), which bars prisoners with three prior dismissals for frivolous or malicious claims from proceeding IFP unless they are in imminent danger of serious physical injury. Pinder filed a declaration asserting imminent danger, which the magistrate judge partially accepted, allowing some claims to proceed. The district court adopted these recommendations but later revoked IFP status for most claims based on new evidence, ultimately granting summary judgment on the remaining shoulder claim.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court remanded the motion to revoke Pinder's IFP status to the district court for further consideration, particularly in light of new medical evidence. The appellate court also remanded the issue of whether the interlocutory dismissals were proper, given a recent Eighth Circuit opinion. The court did not rule on the summary judgment at this time, vacating the district court's judgment and remanding for further proceedings consistent with its opinion. View "Pinder v. WellPath" on Justia Law

In 2021, Ellva Slaughter was charged with illegally possessing a firearm while knowing he had previously been convicted of a felony, violating 18 U.S.C. § 922(g)(1). Slaughter moved to dismiss the indictment, arguing that the jury selection plan of the Southern District of New York (SDNY) systematically underrepresented Black and Hispanic or Latino people, violating his Sixth Amendment right and the Jury Selection and Service Act of 1968 (JSSA). The district court assumed the underrepresentation was significant but denied the motion, finding Slaughter failed to prove systematic exclusion in the jury selection process.The United States District Court for the Southern District of New York denied Slaughter's motion to dismiss the indictment. The court assumed without deciding that there was significant underrepresentation of Black and Hispanic or Latino people but concluded that Slaughter did not establish that this underrepresentation was due to systematic exclusion. The court found that Slaughter's expert did not provide evidence that the identified practices caused the disparities and noted that many of the challenged practices were authorized by the Second Circuit. The court also found that any disparities were due to external factors outside the SDNY's control.The United States Court of Appeals for the Second Circuit reviewed the case. The court applied the framework from Duren v. Missouri, assuming without deciding that the underrepresentation was significant. However, it concluded that Slaughter did not meet his burden of proving systematic exclusion. The court found that Slaughter's expert did not provide sufficient evidence that the SDNY's practices caused the underrepresentation. The court affirmed the district court's judgment, holding that Slaughter failed to establish a prima facie violation of the fair cross-section requirement under the Sixth Amendment and the JSSA. View "United States v. Slaughter" on Justia Law

Three plaintiffs, planning to participate in protests during the Democratic National Convention in Chicago, challenged the constitutionality of a city ordinance listing prohibited items within security perimeters. The list includes items such as laptops, large bags, drones, bicycles, and pointed objects, among others. Plaintiffs argued that the ordinance is unconstitutionally vague, particularly concerning the prohibition of "pointed object(s)," which they feared could include everyday items like ballpoint pens and buttons.The United States District Court for the Northern District of Illinois denied the plaintiffs' request for a preliminary injunction, finding that the ordinance was not unconstitutionally vague. The plaintiffs then appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the ordinance has a core of ascertainable meaning, covering items that pose clear safety risks, such as weapons and explosives. The court noted that while the plaintiffs raised concerns about potential overreach, they had not demonstrated that a substantial number of the ordinance's applications were unconstitutional. The court concluded that the plaintiffs' facial challenge to the ordinance lacked merit, as the potentially problematic applications were not substantial in relation to the valid ones. The court also found that the plaintiffs had standing to challenge the ordinance but ultimately ruled against them on the merits. View "Thayer v. City of Chicago" on Justia Law

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

In May 2020, following the death of George Floyd, several individuals participated in or were near protests in downtown Houston. They allege that they were falsely arrested by City of Houston police officers who used "kettle maneuvers" to confine and arrest protesters. The plaintiffs claim that then-Chief of Police Art Acevedo implemented a policy of "kettling" and arresting protesters. They sued the City and Acevedo under 42 U.S.C. § 1983, alleging violations of the First, Fourth, Fifth, and Fourteenth Amendments, based on the assertion that there was no probable cause for their arrests under section 42.03 of the Texas Penal Code, which prohibits obstructing passageways.The United States District Court for the Southern District of Texas found that there was probable cause to arrest the plaintiffs under section 42.03 and dismissed the claims against both the City and Acevedo. The plaintiffs appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that two previous panels had addressed similar issues with conflicting outcomes. In Utley v. City of Houston, the panel found probable cause for arrest and affirmed the dismissal of the plaintiff’s § 1983 lawsuit. Conversely, in Herrera v. Acevedo, the panel found that the plaintiffs had plausibly alleged false arrest and denied the defendants' motion to dismiss. The current panel agreed with the Utley decision, holding that there was probable cause to arrest the plaintiffs for obstructing a passageway under section 42.03. The court found that the size and location of the protests provided sufficient probable cause for the arrests, thus negating any First, Fourth, or Fourteenth Amendment violations. Consequently, the claims against the City and Acevedo were dismissed due to the lack of an underlying constitutional violation. The judgment of the district court was affirmed. View "Wade v. City of Houston" on Justia Law

Law enforcement responded to the defendant's home after his ex-girlfriend reported that he had threatened suicide during a phone call. The officers, aware of his history of alcohol abuse and mental health issues, entered his home without a warrant after he failed to respond to their attempts to contact him. Inside, an officer shot the defendant, believing he was armed. The defendant was charged with Assault on a Peace Officer.The District Court of the Third Judicial District denied the defendant's pretrial motions to dismiss and suppress evidence obtained from the warrantless entry. The court also denied his motion for a new trial based on an alleged Brady violation, where the defendant claimed the State failed to disclose that the officer who shot him had been shot at in a prior incident. The jury found the defendant guilty.The Supreme Court of Montana reviewed the case and affirmed the lower court's decisions. The court held that the officers' warrantless entry was justified under the community caretaker doctrine, given the exigent circumstances of a potential suicide. The court also found no Brady violation, as the undisclosed evidence about the officer's prior incident would not have changed the trial's outcome. The court concluded that the officers acted reasonably in their entry and subsequent actions, and the defendant's conviction was upheld. View "State v. Case" on Justia Law