Justia Civil Rights Opinion Summaries

Bureau Chief Korza received a complaint regarding Snowden’s handling of a claim. Korza found discrepancies in Snowden’s records. Korza and a division administrator met with Snowden and her union representative and gave Snowden copies of the records. Korza continued his review and found many additional problems. Korza consulted with the Department’s Labor Relations office. Korza lacked the authority to discharge anyone and was advised that discharge was an appropriate penalty for the falsification of records. Korza summarized his findings for the director of the Division and recommended termination. At a later pre-disciplinary meeting, Snowden and her union representative were given a statement of charges. Korza stated that the discipline was undetermined because Snowden had not had an opportunity to respond, but that the charged violations were subject to discipline including discharge. Snowden’s written rebuttal did not contest the factual basis for the charges but noted arguable shortcomings in the investigation. At a final meeting, Korza advised Snowden that she was being placed on suspension pending discharge. Director Hoffman later signed a form terminating Snowden. Snowden pursued a grievance, which resulted in Snowden being allowed to resign without reinstatement rights.Snowden filed suit, asserting due process violations, claiming that Korza had decided to discharge her before the pre-disciplinary meeting and was not the impartial decision-maker. The Third Circuit affirmed the summary judgment rejection of the suit. Korza was not the decision-maker. Snowden was given notice and the opportunity to respond before that decision was made, plus a post-discharge grievance process. View "Snowden v. Illinois Department of Human Services" on Justia Law

Luster was buying a house on contract and had already paid the owner at least 20 percent of the price of the home. The village contacted Luster to obtain the property to create a municipal park. Luster rebuffed this offer. The village then contacted the seller. Luster claims the village knew of his contract but convinced the seller to convey a warranty deed to the village without notifying Luster. The village then sent a letter to Luster demanding immediate possession of the property. According to Luster, he was unable to insure the house because of the ownership dispute. The house burned down while Luster was attempting to quiet title, destroying his family’s possessions and leaving them homeless. Luster sued the village under 42 U.S.C. 1983, seeking damages for his lost property and the village’s “malicious conduct.” He alleged that the village took the home without adequate notice and an opportunity to be heard.The Seventh Circuit vacated the dismissal of the complaint. Luster’s complaint does not allege or permit a reasonable inference that he was deprived of his property by the random, unauthorized acts of any village employee. Absent any obvious reason why the village could not have provided advance notice and a pre-deprivation hearing before it seized Luster’s property interest, the adequacy of a post-deprivation remedy is irrelevant. View "Luster v. Village of Ashmore" on Justia Law

This consolidated case concerns three appeals from orders entered by magistrate judges in the Western District of Pennsylvania in cases filed under 42 U.S.C. 1983. One case was involuntarily dismissed without prejudice for failure to prosecute; in the others, magistrates entered summary judgment for all defendants.Under 28 U.S.C. 636, precise limits govern a magistrate judge’s jurisdiction absent parties’ consent. A magistrate judge can oversee pretrial discovery even without the consent of the parties, but he cannot grant summary judgment or involuntarily dismiss a case; those limits dissolve if the parties voluntarily consent to a magistrate judge’s final judgment jurisdiction.The Third Circuit dismissed one appeal for lack of jurisdiction because all parties did not consent and, therefore, the magistrate judge lacked the power to involuntarily dismiss the case. However, the magistrate judges were empowered to enter summary judgment in the other cases because all parties either expressly or impliedly consented. The court then affirmed summary judgment based on the plaintiffs’ failure to exhaust administrative remedies. View "Prater v. Pennsylvania Department of Corrections" on Justia Law

The plaintiffs, three transgender boys, were denied access to the boys’ bathrooms at school. The boys sued the districts and the school principals, alleging sex discrimination under Title IX of the Education Amendments Act of 1972 and the Equal Protection Clause of the Fourteenth Amendment. The boys requested preliminary injunctions that would order the schools to grant them access to the boys’ bathrooms and, in the case of two boys, access to the boys’ locker rooms when changing for gym class. The district courts granted the preliminary injunctions.The Seventh Circuit affirmed, noting that litigation over transgender rights is occurring all over the country and that at some point the Supreme Court will likely step in with more guidance than it has furnished so far. The district courts appropriately followed Circuit precedent in crafting narrowly tailored and fact-bound injunctions. There was no abuse of discretion in the balancing of the equities and the public interest. The records showed only speculative harms, which are not enough to tip the balance. View "A.C. v. Kutruff" on Justia Law

Plaintiffs asserted claims in district court under Section 1983 against various officials for failing to protect a man in custody, claiming violations of the Eighth and Fourteenth Amendments. They also have claims against individual defendants under a theory of bystander liability and a claim against the Sheriff for supervisory liability. And, against Culberson County, Plaintiffs asserted a claim under Section 1983 and Monell v. Department of Social Services of New York City, 436 U.S. 658 (1978), on the basis that its policies related to jail-suicide prevention caused a violation of Schubert’s constitutional rights. But, this interlocutory appeal concerns only the failure-to-protect claims against Appellants.   The Fifth Circuit vacated the district court’s judgment and held that Plaintiffs failed to plausibly allege Appellants possessed the requisite subjective knowledge. The court explained that although Plaintiffs alleged that the man in custody was cooperative and appeared truthful in his responses, Plaintiffs also alleged: the Sheriff was still required to conduct a mental-health screening form in accordance with TCJS; and, because “the form had not been completed,” the Sheriff “had to operate on the belief that the man was suicidal” and “was required to put the man on suicide watch.” The court explained that it requires that a defendant have “actual knowledge of the substantial risk of suicide.” Plaintiffs failed to allege that the man did or said anything to indicate he was suicidal. Because Plaintiffs failed to allege sufficient facts to plausibly show the Sheriff was subjectively aware of the risk of suicide, their allegations do not state a failure-to-protect claim against him. View "Edmiston v. Borrego" on Justia Law

This action under 42 U.S.C. Section 1983 arises out of a man’s death while in pretrial detention in the Callahan County, Texas, Jail. Plaintiffs’ challenged the adverse summary judgments, including contesting evidentiary rulings.   The Fifth Circuit affirmed. The court explained that Plaintiffs failed to show the requisite genuine dispute of material fact for whether the four defendants had subjective knowledge of a substantial risk of suicide; therefore, they fail to show a constitutional violation. Further, the court wrote that even assuming the court abused its discretion, the contested exhibits concern only Defendants’ knowledge regarding the risk of telephone cords as ligatures; they do not bear on Defendants’ subjective knowledge regarding whether the man was a substantial suicide risk. Accordingly, the court’s sustaining Defendants’ objections did not affect Plaintiffs’ substantial rights. Therefore, this assumed error was harmless. View "Crandel v. Hastings" on Justia Law

The Second Circuit vacated and remanded the district court’s ruling granting summary judgment for Defendants, a former Immigration and Customs Enforcement officer. Plaintiff, Jane Doe, alleged she was sexually and psychologically abused by Defendant, a former Immigration and Customs Enforcement officer. Four years after the abuse ended, Doe initiated this action against Rodriguez and various government defendants. Defendants moved for summary judgment, arguing Doe’s claims were untimely. Doe asked the district court to equitably toll the applicable statutes of limitations. The court granted summary judgment to Defendants.   The Second Circuit vacated and remanded. The court explained that in this case, the district court denied equitable tolling as a matter of law, purporting to draw every inference in favor of Doe. The court vacated its judgment because the record allows for a finding that Doe faced extraordinary circumstances and acted with reasonable diligence. On remand, the district court should act in a fact-finding capacity and determine whether Doe has demonstrated extraordinary circumstances and reasonable diligence. The court explained that if the court determines that she has established these prerequisites for equitable tolling, then it should engage in the discretionary determination of whether to grant her request for equitable tolling. View "Doe v. United States" on Justia Law

The district court preliminarily enjoined Kentucky’s ban on sex-transition care for minors. The court later stayed its injunction in light of a recent Sixth Circuit decision in which the court balanced the likelihood of success on the merits, irreparable harm, the balance of harms, and the public interest and held that those factors favored allowing Tennessee to enforce its law. Kentucky bans the same conduct as in that case; the plaintiffs bring the same Equal Protection and Due Process claims that the Sixth Circuit held were unlikely to succeed. The Sixth Circuit declined to lift the stay. As a sovereign state, Kentucky has an interest in creating and enforcing its own laws. The people of Kentucky enacted the ban through their legislature. View "Doe v. Thornbury" on Justia Law

Plaintiff, a Florida prisoner, says that he deserves a religious exemption from a Florida Department of Corrections rule that beards can only be a half-inch long. The district court agreed with him, and the Secretary of the Department does not push back on that substantive ruling. Instead, the Secretary argues that the decision was procedurally improper because an inmate must file a “Petition to Initiate Rulemaking” to satisfy the Prison Litigation Reform Act’s pre-suit exhaustion requirements. Plaintiff responds that the Secretary did not preserve the issue. 
 The Eleventh Circuit rejected both parties’ arguments and affirmed the district court. The court explained that though it was an open question when the parties argued this case, the Supreme Court has since unanimously clarified that a “purely legal issue resolved at summary judgment” is reviewable on appeal even if the losing party failed to renew its arguments at or after trial.   Further, when a state sets up a grievance procedure for its prisoners, as Florida has done, a prisoner must file a grievance and exhaust the remedies available under that procedure before he can initiate a lawsuit. But a prisoner need not do anything else. Florida’s three-step grievance procedure for settling prisoner complaints does not include filing a rulemaking petition, so a Florida prisoner need not seek rulemaking before he can sue. View "Durell Sims v. Secretary, Florida Department of Corrections" on Justia Law

In this murder case, the Supreme Court established a standard a defendant must satisfy to compel extraction of GPS data by a defendant's third-party agent from a crime victim's automobile for the trial court's in camera inspection and held that remand was required in the instant case.Defendant was charged with the second-degree murder of Grant Draper, making his brother Lane Draper a victim by virtue of Ariz. Rev. Stat. 13-4401(12), a statute that implements the Arizona Constitution's Victims' Bill of Rights. During plea negotiations and without notice to Lane, Defendant obtained a court order to access GPS data to support his third-party defense identifying Lane as the possible killer and for cross-examination regarding the time Defendant argued he was asleep. The trial court allowed the data to be extracted for a limited in camera interview. Lane filed a petition for special action, which the court of appeals denied. The Supreme Court held (1) a defendant is entitled to discovery from a victim if the defendant seeks evidence of a constitutional dimension and the defendant establishes that the requested discovery is very likely to contain such evidence; and (2) remand was required in this case. View "Draper v. Honorable Gentry" on Justia Law