Justia Civil Rights Opinion Summaries

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

A North Carolina police officer, Clarence Belton, was shot multiple times by fellow officer Heather Loveridge during the execution of a search warrant. The incident, which resulted in serious injuries to Belton and ended his law enforcement career, was captured on video and body camera footage. Belton sued Loveridge and the City of Charlotte, alleging excessive force and other claims. During the litigation, both parties moved to seal the video exhibits related to the shooting, and the district court granted these motions, placing the footage under seal.After the district court denied Loveridge’s motion for summary judgment, which was later vacated and remanded by the United States Court of Appeals for the Fourth Circuit, a local television station, WBTV, sought to intervene in the case to unseal the video footage. Belton supported WBTV’s motion, but Loveridge opposed it, arguing that unsealing would jeopardize her right to a fair trial. The United States District Court for the Western District of North Carolina denied WBTV’s motion to intervene, citing lack of jurisdiction due to the pending appeal, and also denied the motion to unseal, finding no right of access under the common law or the First Amendment and concluding that Loveridge’s fair trial rights outweighed any public interest.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of WBTV’s motion to intervene, agreeing that the district court lacked jurisdiction at that stage. However, the appellate court treated WBTV’s appeal regarding the sealing order as a petition for a writ of mandamus. The Fourth Circuit held that the district court’s order sealing the video exhibits violated the First Amendment right of access to judicial records. The court vacated the sealing order and remanded with instructions to unseal the video footage, finding that Loveridge had not met her burden to justify continued sealing. View "Gray Media Group, Inc. v. Loveridge" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law

A man incarcerated in Texas state prison was classified as a member of a security threat group and placed in administrative segregation, a form of solitary confinement, for sixteen years. The only way for him to return to the general prison population was to complete a gang renunciation program, which required him to renounce his gang affiliation and participate in an interview. During the interview, he was questioned by prison and law enforcement officials about criminal activities that occurred during his incarceration. He refused to answer questions that could incriminate him, after which his application to the renunciation program was terminated for failure to cooperate. He filed grievances challenging the process, but they were denied or dismissed.He then filed suit in the United States District Court for the Western District of Texas against several prison officials, alleging violations of his Fifth, First, and Fourteenth Amendment rights. The district court initially dismissed his claims, but the United States Court of Appeals for the Fifth Circuit vacated and remanded for further proceedings. After further litigation, including the appointment of counsel and discovery, the district court again granted summary judgment for the defendants, finding no constitutional violations and holding that the officials were entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the officials were entitled to qualified immunity on the Fifth Amendment self-incrimination and First Amendment compelled speech claims because there was no clearly established law making their conduct unlawful in this context. Regarding the Fourteenth Amendment procedural due process claim, the court assumed a liberty interest but found that the periodic classification reviews provided by the prison satisfied due process requirements. The court affirmed summary judgment in favor of the defendants. View "Ballentine v. Broxton" on Justia Law

Brandon Velez was stopped by Manchester, New Hampshire police officers for vehicle equipment violations. After parking near his residence, Velez did not immediately comply with officers’ orders to exit his car. When he verbally refused and reached for his phone, officers attempted to physically remove him, leading to a struggle. During the altercation, one officer struck Velez multiple times and tased him twice. Velez was arrested and charged with misdemeanors and a traffic violation, ultimately pleading guilty only to the traffic violation. He later sued the officers and the City of Manchester, alleging wrongful arrest, false imprisonment, excessive force, assault and battery, and failure to train.The case was removed from state court to the United States District Court for the District of New Hampshire. The defendants moved for summary judgment, which the district court granted, finding that the officers had probable cause for the arrest and that the force used was not excessive. Velez appealed the decision.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that the officers had probable cause to arrest Velez for resisting detention under New Hampshire law, defeating his wrongful arrest and false imprisonment claims. The court also found that, although one officer’s use of force was excessive under the Fourth Amendment, qualified immunity shielded the officer from liability because the law was not clearly established in the specific context. The court further held that Velez’s state-law assault and battery claim failed under the same immunity standard, and that his claims against the City for failure to train were unsupported by evidence of a municipal policy or deliberate indifference. The First Circuit affirmed the district court’s judgment in favor of the defendants on all counts. View "Velez v. Eutzy" on Justia Law

A woman experiencing a mental health crisis called 911 and requested that police come to her home to shoot her. Three officers responded and found her holding a bat and a pickaxe. The officers maintained a distance of about fifteen feet and attempted to de-escalate the situation, with one officer assuring her that she would not be harmed. After several minutes, and following an interaction with the woman’s mother, one officer tased her, and another officer shot her multiple times as she moved in the direction of the officers. The woman survived but suffered severe injuries.The plaintiff, acting on the woman’s behalf, filed suit in the United States District Court for the Middle District of Tennessee against the two officers and the Metropolitan Government of Nashville and Davidson County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment, and also brought a negligence claim against the municipality. The officers moved to dismiss the complaint on qualified immunity grounds, and the municipality sought judgment on the pleadings. The district court granted the officers’ motion to dismiss the excessive force claims and the municipality’s motion on the negligence claim, but initially denied the municipality’s motion as to the § 1983 claim. Later, the district court granted the municipality’s motion for judgment on the pleadings on the § 1983 claim as well.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the complaint plausibly alleged that both officers violated the woman’s clearly established Fourth Amendment rights by tasing and shooting her under the circumstances described. The court also held that the district court erred in dismissing the municipal liability claim. Accordingly, the Sixth Circuit reversed the dismissal of the claims against the officers, vacated the judgment for the municipality, and remanded for further proceedings. View "Chrestman v. Metropolitan Government of Nashville and Davidson County" on Justia Law

A man was arrested by city police officers in Rainsville, Alabama, after exhibiting erratic behavior and resisting arrest. The Chief of Police directed Officer White to transport the arrestee to the county jail in Fort Payne, which had better medical facilities. Upon arrival at the county jail, jailers became frustrated with the arrestee during booking and began to beat him. Officer White witnessed the beating from a few feet away but did not attempt to intervene or protest. The beating continued for several minutes after White left the room, resulting in significant injuries to the arrestee. The jailers involved were later criminally prosecuted and convicted for their conduct.The arrestee filed a lawsuit under 42 U.S.C. § 1983 against Officer White and others, alleging, among other claims, that White’s failure to intervene violated his Fourth Amendment rights. The United States District Court for the Northern District of Alabama granted summary judgment to the officers on the false arrest claim but denied summary judgment to White on the failure to intervene claim, rejecting his qualified immunity defense. White appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, under clearly established law as of March 2020, an arresting officer who delivers a helpless arrestee to jailers and witnesses those jailers immediately begin to beat the arrestee in his presence violates the Fourth Amendment if he remains silent and leaves the scene while the assault is ongoing. The court further held that the duty to intervene is not discharged by a phone call to a supervisor who is not in a position to stop the assault. The Eleventh Circuit affirmed the district court’s denial of summary judgment to Officer White on the failure to intervene claim. View "Nute v. White" on Justia Law

A car leasing company leased a vehicle to an individual who defaulted on payments soon after the lease began. Despite having the right to repossess the car, the company did not do so. Two years later, the lessee was stopped by police in Butler, New Jersey, for driving with a suspended license, suspended registration, and no insurance. The police seized the car and had it towed by a contractor, Malanga’s Automotive. The lessee was informed of the tow but did not retrieve the vehicle. The towing company did not notify the leasing company that it possessed the car until nearly a year later, at which point it demanded payment of towing and storage fees before releasing the vehicle.The leasing company filed suit in the Superior Court of New Jersey against the towing company, later adding the Borough of Butler as a defendant and asserting claims under 42 U.S.C. § 1983 for violations of the Fourteenth Amendment’s Due Process Clause, the Fourth Amendment, and the Fifth Amendment. The case was removed to the United States District Court for the District of New Jersey, which granted summary judgment to Butler on all claims. The District Court found that the company had a property interest in the vehicle but concluded that Butler’s policies provided sufficient notice and opportunity to be heard, and that the seizure and retention of the vehicle were reasonable and did not constitute a taking.On appeal, the United States Court of Appeals for the Third Circuit held that Butler’s policies violated the Fourteenth Amendment’s Due Process Clause because they failed to require prompt notice to all holders of property rights in seized vehicles and did not provide an opportunity for a hearing to challenge the lawfulness of the tow or the fees. The court reversed and remanded the due process claim. However, it affirmed the District Court’s judgment on the Fourth and Fifth Amendment claims, finding no unreasonable seizure or unconstitutional taking. View "Honda Lease Trust v. Malanga's Automotive" on Justia Law