Justia Civil Rights Opinion Summaries

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

Juan Mendez was approached by two Chicago police officers investigating a gunshot detected near his home early one morning. As the officers arrived and questioned Mendez and a juvenile on the porch, Mendez suddenly fled, jumping a fence and running down an alley. The officers pursued him, with one warning that Mendez had something in his waistband and then in his hand. During the chase, Mendez fell, got up, and turned toward the officers with an object in his hand. One officer, perceiving a threat, shot Mendez three times, resulting in paralysis from the waist down.Mendez filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the City of Chicago and the two officers, alleging excessive force in violation of the Fourth Amendment, battery under Illinois law, and seeking indemnification from the City. Both parties moved for summary judgment. The district court granted summary judgment to the defendants, finding that, based on body-camera footage and the circumstances, a reasonable officer would have had probable cause to believe Mendez posed a threat to the officers’ safety. The court also found that, without a Fourth Amendment violation, Mendez could not prevail on his state law claims. Mendez appealed.The United States Court of Appeals for the Seventh Circuit reviewed the record independently and affirmed the district court. The Seventh Circuit held that Officer Szczur had probable cause to believe that Mendez posed a threat of serious physical harm under the totality of the circumstances, making the use of deadly force reasonable under the Fourth Amendment. The court also held that the state law battery and indemnification claims failed for the same reasons. The judgment for the defendants was affirmed. View "Mendez v City of Chicago" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

An Indian professor employed at a public university in North Carolina applied for tenure after a probationary period, but his initial application was denied following negative evaluations from colleagues concerning his teaching, mentorship, and administrative performance. Several years later, the same professor reapplied and was granted tenure. After receiving tenure, he sued various university officials, alleging that the original denial was the result of racial discrimination in violation of the Equal Protection Clause and 42 U.S.C. § 1981, as well as retaliation for his non-traditional teaching methods in violation of the First Amendment. His complaint focused on negative statements and actions by two specific colleagues, while also asserting that other officials enabled or failed to remedy alleged bias.The United States District Court for the Eastern District of North Carolina dismissed the complaint for failure to state a claim under Rule 12(b)(6). The court found that the plaintiff’s allegations of racial discrimination were unsupported by facts connecting any defendant’s actions to race, and that his First Amendment retaliation claim failed to identify protected speech or a causal link between such speech and the tenure decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that the plaintiff’s allegations did not plausibly suggest he was treated differently than similarly situated colleagues because of his race, as required for Equal Protection and § 1981 claims. The court also concluded that the complaint failed to plausibly allege protected speech or retaliation under the First Amendment. The Fourth Circuit emphasized the limited judicial role in reviewing academic tenure decisions and declined to address qualified immunity, as no plausible claim was stated. Thus, the district court’s judgment was affirmed. View "Katti v. Arden" on Justia Law

The plaintiff, a community advocate, posted a lengthy video—obtained from internal office security footage of a local police department—on his Facebook page. Only a few department employees had access to this footage. In response, a special agent from the Virginia State Police investigated how the plaintiff obtained the video, suspecting possible computer trespass under Virginia law. The agent sought and obtained warrants to search the plaintiff’s Facebook and Gmail accounts, believing these accounts might contain evidence relevant to the investigation. Although the plaintiff moved to quash both warrants for lack of probable cause, a state court denied the motions, and the Supreme Court of Virginia refused his appeal. Ultimately, the local prosecutor determined there was insufficient evidence to charge anyone with computer trespass.Following these events, the plaintiff filed a federal lawsuit in the United States District Court for the Western District of Virginia, alleging that the searches violated his First and Fourth Amendment rights and were conducted in retaliation for his criticism of local government. After amending his complaint once, the plaintiff sought to amend it a second time. The district court dismissed his claims, concluding that his failure to plead the absence of probable cause was fatal, and denied leave to amend as futile.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that, in order to state a First Amendment retaliatory search claim, the plaintiff was required to plead the absence of probable cause or show he qualified for a narrow exception, and he had done neither. The court further held that the same requirement applied to his Fourth Amendment claim. The court also agreed that denying leave to amend was proper, as the proposed amendment would not have stated a valid claim. View "Stanley v. Bocock" on Justia Law