Justia Civil Rights Opinion Summaries

The plaintiff, who worked for a bank that operated a branch inside a public high school, was terminated from her employment after she publicly criticized the local school district’s mask mandate on social media and at school events. The bank’s operation at the school was part of a partnership in which the bank provided funds and services to the school district. The plaintiff’s children attended schools in the district, and she was active in school-related activities. After a series of confrontations and a critical Facebook post about a school board member, the school superintendent communicated with the bank’s branch manager, expressing disapproval of the plaintiff’s conduct and requesting that she be barred from school property. The bank subsequently suspended and then fired the plaintiff, citing her conduct and the school’s ban.The United States District Court for the District of Minnesota granted summary judgment to all defendants, finding that the plaintiff’s First Amendment rights were not violated and that there was insufficient evidence of a conspiracy or tortious interference. The court applied the Pickering balancing test, treating the plaintiff as a government contractor, and found no actionable retaliation. It also found no evidence of a meeting of the minds between the bank and the school district, and held that the superintendent and other officials were entitled to qualified immunity.The United States Court of Appeals for the Eighth Circuit reversed in part and affirmed in part. The court held that the plaintiff was not a government employee or contractor for First Amendment purposes and was entitled to ordinary citizen protections. It found that there was sufficient evidence for a jury to decide whether the superintendent, the bank, and the branch manager retaliated against the plaintiff for protected speech, and whether the superintendent tortiously interfered with her employment. However, the court affirmed summary judgment for the school board chair and the school district, finding insufficient evidence of their direct involvement or policy liability. The case was remanded for further proceedings. View "McNeally v. HomeTown Bank" on Justia Law

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

The plaintiff, who is civilly committed as a sexually violent predator at the Texas Civil Commitment Center, brought a pro se lawsuit under 42 U.S.C. § 1983 against the Commissioner of the Texas Department of Family Protective Services and the Executive Commissioner of the Texas Health and Human Services Commission. He alleged that these agencies failed to investigate his reports of misconduct and abuse at the facility, claiming violations of his Fourteenth Amendment rights to equal protection and due process, as well as rights under the Bill of Rights for Mental Health Patients. The plaintiff asserted that he should be able to file complaints with these agencies rather than being required to use the internal grievance procedure of the Texas Civil Commitment Office.The United States District Court for the Western District of Texas screened the complaint under 28 U.S.C. § 1915(e)(2)(B) because the plaintiff was proceeding in forma pauperis. The district court found that the plaintiff failed to state a claim for relief and that amendment would be futile, so it dismissed the complaint without prejudice. The plaintiff appealed, arguing that he had adequately stated equal protection and due process claims, that he should have been allowed to amend his complaint, and that the district court was biased.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to state an equal protection claim because he was not similarly situated to other Texas citizens and the different grievance procedures had a rational basis. The court also found no protected liberty or property interest to support a due process claim and concluded that the alleged conduct did not rise to the level of a substantive due process violation. The court further held that amendment would have been futile and found no evidence of judicial bias. The plaintiff’s motion for appointment of counsel was denied. View "Dunsmore v. Muth" on Justia Law

Amy Hadley’s home in South Bend, Indiana, was significantly damaged when law enforcement officers executed a search warrant in pursuit of a murder suspect they believed was inside her residence. The officers, acting on information that the suspect had accessed his Facebook account from Hadley’s IP address, obtained a warrant and forcefully entered the home, causing extensive property damage, including the use of tear gas and destruction of personal items. Hadley, who had no connection to the suspect, was denied compensation by both the City of South Bend and St. Joseph County for the $16,000 in damages.After her request for compensation was denied, Hadley filed suit in Indiana state court, seeking relief under 42 U.S.C. § 1983 for violations of her Fifth and Fourteenth Amendment rights, specifically invoking the Takings Clause. The case was removed to the United States District Court for the Northern District of Indiana, South Bend Division. The defendants moved to dismiss, arguing that Seventh Circuit precedent, particularly Johnson v. Manitowoc County, foreclosed her claim. The district court agreed and dismissed the complaint, finding that the Takings Clause did not entitle her to compensation for property damage resulting from the execution of a lawful search warrant.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that, under its precedent in Johnson v. Manitowoc County, the Fifth Amendment does not require the government to compensate property owners for damage caused by law enforcement executing a valid search warrant. The court declined to overrule Johnson and found that Hadley’s arguments did not warrant revisiting the established rule. View "Hadley v. City of South Bend" on Justia Law

A transgender inmate serving a lengthy sentence in the Connecticut prison system was diagnosed with gender dysphoria after several years of incarceration. The inmate requested various treatments, including stronger hormone therapy and a vaginoplasty, but was initially denied hormone therapy due to a prison policy that only allowed continuation, not initiation, of such treatment. After a policy change, the inmate received hormone therapy, mental health counseling, antidepressants, and some lifestyle accommodations. Despite these measures, the inmate continued to request additional treatments, including surgery, and expressed dissatisfaction with the care provided, alleging it was inadequate and not delivered by specialists in gender dysphoria.The United States District Court for the District of Connecticut reviewed the inmate’s claims of deliberate indifference to serious medical needs under the Eighth Amendment. The district court found that the corrections officials had deprived the inmate of adequate care by providing mental health treatment from unqualified providers, delaying and inadequately administering hormone therapy, and denying surgical intervention. The court denied the defendants’ motion for summary judgment on qualified immunity grounds, holding that the right to be free from deliberate indifference to serious medical needs was clearly established.On appeal, the United States Court of Appeals for the Second Circuit reversed the district court’s decision. The Second Circuit held that there is no clearly established constitutional right for inmates to receive specific treatments for gender dysphoria or to be treated by gender-dysphoria specialists. The court found that reasonable officials could disagree about the adequacy and legality of the care provided, which included talk therapy, antidepressants, and hormone therapy. The Second Circuit concluded that the defendants were entitled to qualified immunity and remanded the case with instructions to grant summary judgment in their favor. View "Clark v. Valletta" on Justia Law

Ann Tierney Smith owned real property in West Virginia but failed to pay the assessed real estate taxes for 2016. As a result, the Mercer County Sheriff sold a tax lien on the property to Ed Boer. Boer sought a tax deed and provided the West Virginia State Auditor’s Office with a list of individuals to be notified about the right to redeem the property, including Smith. However, Boer did not include Smith’s current mailing address, which was available in county records. Notices sent by mail were returned as undeliverable, and attempts at personal service were unsuccessful, leading to notices being posted at the property and other addresses. After the redemption deadline passed, G. Russell Rollyson, Jr., an employee of the State Auditor’s Office, issued a tax deed to Boer. Smith learned of the deed in late 2020.Smith, and later her estate representatives, sued Rollyson and Boer under 42 U.S.C. § 1983, alleging deprivation of property without due process. The United States District Court for the Southern District of West Virginia granted summary judgment to Rollyson, finding him entitled to qualified immunity. The court determined that while Rollyson could have directed Boer to search county records for Smith’s address after the mailed notices were returned, the duty to do so was not clearly established at the time. The estate representatives appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment and qualified immunity rulings de novo. The Fourth Circuit held that it was not clearly established on April 1, 2019, that Rollyson was required to have Boer search county records anew for Smith’s address after the mailed notices were returned. The court found that existing precedent did not prescribe a specific follow-up measure and that Rollyson’s actions did not violate clearly established law. The judgment of the district court was affirmed. View "Ann deWet v. G. Russell Rollyson, Jr." on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law