Justia Civil Rights Opinion Summaries

Thomas moved to a cell at Pontiac Correctional Center. Thomas claimed there were feces, urine, and mold smeared on the walls, sink, and cell door; the mattress was soiled with feces and reeked of urine; there were dead flies on the bunk bed; and the sink emitted only cold, black, oily water. After Thomas complained about his mattress, prison officials got him a new one within two weeks. Thomas used his sheets and blanket to avoid contact with the soiled mattress. Thomas received gloves to remove the dead flies; he had a towel for cleaning and received a disinfectant solution several times during his eight-week stay in the cell. Thomas refused to clean the walls. While awaiting a plumbing repair, officials allowed Thomas three hot showers per week. Pontiac’s water supply underwent regular testing and met all environmental requirements. Thomas sought treatment for dry skin and a rash on his back. A health worker noted “a small clogged pore,” recommended warm moist compresses, and told Thomas to return as needed. Thomas obtained hot water for the compresses from another inmate. Thomas sought no further medical care at Pontiac.Thomas later invoked 42 U.S.C. 1983, asserting Eighth Amendment claims. The Seventh Circuit affirmed the rejection of his suit. Had the officials done nothing in response to Thomas’s complaints, they would have violated the Constitution’s prohibition on cruel and unusual punishment but the prison responded to Thomas’s concerns and medical needs. View "Thomas v. Blackard" on Justia Law

Plaintiffs owned a tenancy-in-common interest in a multi-unit San Francisco residential building. Until 2013, San Francisco accepted only 200 applications annually for conversion of such arrangements into condominium ownership. A new program allowed owners to seek conversion subject to conditions, including that nonoccupant owners had to offer their existing tenants a lifetime lease. The plaintiffs and their co-owners obtained approval for conversion. The city refused the plaintiffs’ subsequent request that the city either excuse them from executing the lifetime lease or compensate them. The plaintiffs’ suit under 42 U.S.C. 1983 alleged that the lifetime-lease requirement was an unconstitutional regulatory taking. The district court rejected this claim, citing the Supreme Court’s “Williamson County” holding that certain takings actions are not “ripe” for federal resolution until the plaintiff seeks compensation through state procedures. While an appeal was pending, the Court repudiated that Williamson County requirement. The Ninth Circuit affirmed the dismissal, concluding that the plaintiffs had not satisfied the requirement of “finality.”The Supreme Court vacated. To establish “finality,” a plaintiff need only show that there is no question about how the regulations apply to the land in question. Here, the city’s position is clear: the plaintiffs must execute the lifetime lease or face an “enforcement action.” That position has inflicted a concrete injury. Once the government is committed to a position, the dispute is ripe for judicial resolution. Section 1983 guarantees a federal forum for claims of unconstitutional treatment by state officials. Exhaustion of state remedies is not a prerequisite. While a plaintiff’s failure to properly pursue administrative procedures may render a claim unripe if avenues remain for the government to clarify or change its decision, administrative missteps do not defeat ripeness once the government has adopted its final position. Ordinary finality is sufficient because the Fifth Amendment enjoys “full-fledged constitutional status.” View "Pakdel v. City and County of San Francisco" on Justia Law

Officers arrested Gilbert for trespassing, took him to the St. Louis Metropolitan Police Department, and placed him in a holding cell. An officer saw Gilbert tie a piece of clothing around the cell bars and put it around his neck, in an apparent suicide attempt. Three officers entered Gilbert’s cell, eventually brought Gilbert to a kneeling position over a concrete bench, and handcuffed his arms behind his back. Gilbert kicked the officers and hit his head on the bench. They shackled his legs. Six officers moved Gilbert to a prone position, face down on the floor. Three officers held Gilbert down at the shoulders, biceps, and legs; at least one placed pressure on Gilbert’s back and torso. Gilbert tried to raise his chest, saying, “‘It hurts. Stop.’” After 15 minutes of struggling, Gilbert’s breathing became abnormal; he stopped moving. The officers rolled Gilbert onto his back and found no pulse; they performed chest compressions and rescue breathing. An ambulance transported Gilbert to the hospital, where he was pronounced dead. In an “excessive force” suit, the Eighth Circuit affirmed summary judgment in favor of the officers.The Supreme Court vacated. The excessive force inquiry requires careful attention to the facts and circumstances of each particular case, including the relationship between the need for the use of force and the amount of force used; the extent of the plaintiff’s injury; any effort by the officer to limit the amount of force; the severity of the underlying security problem; the threat reasonably perceived by the officer; and whether the plaintiff was actively resisting. Here, the court either failed to analyze or found insignificant, details such as that Gilbert was already handcuffed and shackled when placed in the prone position, that officers kept him in that position for 15 minutes, and that St. Louis instructs its officers that pressing down on the back of a prone subject can cause suffocation. The lower court’s opinion could be read to treat Gilbert’s “ongoing resistance” as controlling as a matter of law. Such a per se rule would contravene the careful, context-specific analysis required by precedent. View "Lombardo v. St. Louis" on Justia Law

In September 2013, Chicago Police Officers stopped a car in which Smith was a passenger. According to Smith, the officers fabricated a story that, during this stop, he made a “furtive movement” and that the officers found a bullet in the car. Smith was arrested and detained for seven months in the Cook County Jail. Smith was released on bond “on or about” March 29, 2014. While on bond, Smith was required to appear in court once per month and to request permission before leaving Illinois. Smith contends his bond conditions diminished his employment prospects and that he experienced financial stress and emotional anxiety. He was acquitted on July 21, 2016. On July 18, 2018, Smith filed suit under 42 U.S.C. 1983.The Seventh Circuit affirmed the dismissal of his suit as untimely under a two-year limitations period, rejecting Smith’s argument that his claim accrued when he was acquitted at trial. A Fourth Amendment claim such as Smith’s accrues when he is released from detention. The court also rejected Smith’s contention that his bond conditions constituted an ongoing Fourth Amendment seizure, so he was not released from custody until he was acquitted. Requirements to appear in court for a hearing and to request permission before leaving the state, taken together or separately, do not amount to Fourth Amendment seizures. View "Smith v. City of Chicago" on Justia Law

The Ninth Circuit reversed the district court's denial of petitioner's habeas corpus petition challenging his Arizona death sentence. The panel applied the appropriate standards pursuant to the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), and concluded that petitioner was denied the effective assistance of counsel at sentencing.In regard to Claim 1, the panel agreed with petitioner that his right to counsel was violated when his attorney failed to request a mental health expert in advance of the sentencing hearing. Alternatively, the panel agreed with petitioner that the PCR court used a defective fact-finding process with respect to his first claim when it denied PCR counsel's funding request for a defense neuropsychological expert, effectively preventing the factual development of this claim, and that the state court's failure to hold a hearing on his first claim resulted in an unreasonable determination of the facts. On de novo review, the panel concluded that counsel's errors prejudiced petitioner.In regard to Claim 2, the panel agreed with petitioner that trial counsel was constitutionally ineffective by failing to seek neurological or neuropsychological testing prior to sentencing, and that the failure to do so fell below prevailing professional norms at the time. The panel also agreed with petitioner's alternative argument that the PCR court's decision was based on an unreasonable determination of the facts under 28 U.S.C. 2254(d)(2). On de novo review, the panel concluded that counsel's errors prejudiced petitioner. Accordingly, the panel remanded for further proceedings. View "Jones v. Ryan" on Justia Law

Hughey, speeding, passed Michigan State Trooper Easlick, who flipped on his dashcam and stopped Hughey. Hughey’s car was uninsured and unregistered and there was an outstanding warrant for Hughey’s failure to appear. Easlick relayed that Hughey needed to pay the $400 bond on her warrant in cash immediately or he would have to take her to the courthouse. Hughey did not resist arrest. Easlick handcuffed Hughey’s hands behind her back and placed her in his car. Hughey expressed suicidal thoughts, so Easlick took her to the hospital.Hughey alleges that Easlick twisted her arm behind her back as he handcuffed her and did not check for tightness, that her shoulder hurt “[a]lmost immediately,” and that after Easlick removed the handcuffs at the hospital, a nurse observed “rings around [Hughey’s] wrists.” No part of the handcuffing is visible in the dashcam footage.Hughey sued Easlick for excessive force and deliberate indifference under 42 U.S.C. 1983. The district court granted Easlick summary judgment. The Sixth Circuit reversed. Hughey created a genuine dispute of material fact about whether Easlick violated her clearly established constitutional right to be free from excessive force. Her allegations are enough to satisfy the “handcuffing test” at summary judgment. The dashcam audio does not foreclose the possibility that Hughey repeatedly complained about pain. A plethora of excessive-force handcuffing cases put Easlick on notice that the way that he yanked Hughey’s arm, placed overly tight handcuffs, and ignored her complaints violated her right to be free from excessive force. View "Hughey v. Easlick" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of first-degree robbery and other firearm-related offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on cross-racial identification and that he was denied his right to due process when the trial court denied his motion to dismiss the State's habitual offender notice. The Supreme Court affirmed, holding (1) the trial justice did not err or abuse his discretion in failing to give Defendant's requested instruction regarding cross-racial identifications; and (2) the trial justice did not err in denying Defendant's motion to dismiss the State's habitual offender notice as untimely under R.I. Gen. Laws 12-19-21. View "State v. Hampton-Boyd" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Defendants - Brown University and two of its officials - seeking damages and equitable relief arising out of Defendants' response to Plaintiff's sexual assault allegations, holding that the trial court did not err.Plaintiff brought his suit pursuant to the Rhode Island Civil Rights Act, chapter 112 of title 42 of the general laws (RICRA) and article 1, section 2 of the Rhode Island Constitution. The hearing justice granted Defendants' motion to dismiss for failure to state a claim, concluding that issue preclusion foreclosed the claims under RICRA based on a previous decision of the federal courts and that article 1, section 2 did not grant Plaintiff a private right of action. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's complaint. View "Doe v. Brown University" on Justia Law

On remand from the Supreme Court, the Fifth Circuit certified the following questions of law to the Supreme Court of Louisiana: 1) Whether Louisiana law recognizes a duty, under the facts alleged in the complaint, or otherwise, not to negligently precipitate the crime of a third party? 2) Assuming Mckesson could otherwise be held liable for a breach of duty owed to Officer Doe, whether Louisiana's Professional Rescuer's Doctrine bars recovery under the facts alleged in the complaint? View "Doe v. Mckesson" on Justia Law

Plaintiff filed suit alleging that her former employer violated the Florida Civil Rights Act (FCRA) by discriminating against her because of her association with her son, who suffers from severe asthma. The district court dismissed plaintiff's associational discrimination claim and granted summary judgment to the employer on plaintiff's remaining claims under the FCRA and the federal Family and Medical Leave Act (FMLA).The Eleventh Circuit held, in light of the statute's plain language, that the FCRA does not support an associational-discrimination claim and no Florida court has concluded otherwise. The court also held that the district court correctly granted summary judgment in favor of the employer on plaintiff's claim for FCRA retaliation where she failed to show that any of the relevant decisionmakers knew of her protected activity or that other employees engineered her termination by manipulating the relevant decisionmakers; FMLA retaliation where plaintiff failed to show that the employer's reasons for taking adverse action were pretextual; and FMLA interference where she did not establish that she was entitled to FMLA leave. View "Matamoros v. Broward Sheriff's Office" on Justia Law