Justia Civil Rights Opinion Summaries

A federal inmate diagnosed with diabetes was initially prescribed medication and given certain accommodations while incarcerated. After being transferred to a new facility, his new medical provider discontinued his diabetes medication and accommodations based on a single blood test result, despite the inmate’s objections that the result was not representative of his condition. The inmate’s health deteriorated, leading to severe diabetic ulcers and ultimately the amputation of his toe. He alleged that medical staff repeatedly denied or delayed necessary care, and that his requests for treatment were falsely documented as refusals. The inmate later filed administrative claims with the Bureau of Prisons (BOP) and, after those were denied or not fully addressed, brought suit alleging deliberate indifference to his medical needs under the Eighth Amendment and also asserted a claim under the Rehabilitation Act.The United States District Court for the District of New Jersey screened the complaint and dismissed the Rehabilitation Act claim. The defendants moved to dismiss the Eighth Amendment claim brought under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The District Court granted the motion, reasoning that the case presented a new context from prior Supreme Court precedent because the injuries were not fatal and that the existence of the BOP’s administrative remedy program was a special factor counseling against extending Bivens. The inmate appealed.The United States Court of Appeals for the Third Circuit affirmed. The court held that the availability of the BOP’s administrative remedy program constituted a special factor not present in Carlson v. Green, and thus created a new context under the Bivens analysis. Because an alternative remedial structure existed and was available to the inmate, the court declined to extend a Bivens remedy. The court also affirmed dismissal of the Rehabilitation Act claim, as sovereign immunity barred damages claims against the federal government under that statute. View "Muniz v. United States" on Justia Law

A firefighter in Forrest City, Arkansas, was terminated after posting a provocative anti-abortion image on his personal Facebook page. The image, intended to express his pro-life views, was interpreted by some as racially insensitive, particularly because it included the caption “I can’t breathe!”—a phrase associated with protests following George Floyd’s death. After complaints from a retired fire supervisor and others, the firefighter deleted the post. However, the mayor placed him on administrative leave and, following a brief investigation, fired him, citing the public outcry and concerns about the city’s ability to provide public services. The firefighter, who had served over four years without prior incident, learned of his termination through a press release.The firefighter filed suit in the United States District Court for the Eastern District of Arkansas, alleging First Amendment retaliation against the mayor in both his individual and official capacities, and against the city for an alleged unwritten policy allowing officials to censor employee speech. The district court granted summary judgment for the defendants, holding that the mayor was entitled to qualified immunity and that there was no evidence of an unwritten policy justifying the official-capacity and policy-based claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the firefighter’s Facebook post addressed a matter of public concern and was made as a private citizen. The court found insufficient evidence of actual or reasonably predicted disruption to the fire department’s operations to justify summary judgment for the defendants. The court reversed the district court’s grant of summary judgment on the First Amendment retaliation claims against the mayor and the city, affirmed the dismissal of the unbridled-discretion claim, and remanded for further proceedings. View "Melton v. City of Forrest City, Arkansas" on Justia Law

A group of foster children in Oregon, through their representatives, brought a class action lawsuit against the Oregon Department of Human Services (ODHS) and state officials, alleging violations of their substantive due process rights due to serious abuses experienced while in ODHS’s legal custody. The plaintiffs sought relief on behalf of all children for whom ODHS had or would have legal responsibility, including those in ODHS’s legal custody but physically placed with their parents, either because they had not been removed from their homes or because they were on a temporary “Trial Home Visit” after removal.The United States District Court for the District of Oregon certified a general class that included all children in ODHS’s legal or physical custody. After extensive litigation, the parties reached a settlement agreement, but disagreed on whether the term “Child in Care” in the agreement included children in ODHS’s legal custody who were physically with their parents (the “Disputed Children”). The district court concluded that these children were not covered by the settlement, reasoning that children living with their biological parents did not have substantive due process rights to be free from serious abuses while in ODHS’s legal custody.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the settlement agreement and the scope of substantive due process protections. The Ninth Circuit held that the Disputed Children—those in ODHS’s legal custody but physically with their parents—are entitled to substantive due process protections. The court found that once the state assumes legal custody, it has an affirmative duty to provide reasonable safety and minimally adequate care, regardless of the child’s physical placement. The Ninth Circuit reversed the district court’s order and remanded for further proceedings. View "WYATT B. V. KOTEK" on Justia Law

The petitioner was convicted by an Arizona jury of child molestation after he helped bathe young girls who were in his and his wife’s care through the foster system. The relevant Arizona statute defined child molestation as any direct or indirect touching of a child’s private parts, and, at the time, allowed a defendant to raise an affirmative defense by proving he was not motivated by sexual interest. The petitioner admitted to the touching but argued he lacked sexual motivation.After his first trial ended in a mistrial, the Arizona Supreme Court decided State v. Holle, which held that sexual motivation was not an element of the crime and that the lack of sexual interest was an affirmative defense the defendant must prove by a preponderance of the evidence. At the petitioner’s second trial, the court instructed the jury accordingly, and he was convicted on some counts. The Arizona Court of Appeals affirmed, relying on Holle, and the Arizona Supreme Court denied review. The United States Supreme Court also denied certiorari. The petitioner then sought federal habeas relief in the United States District Court for the District of Arizona, arguing that the statutory scheme unconstitutionally shifted the burden of disproving an essential element of the crime to him. The district court denied relief, finding the state courts’ application of federal law was not objectively unreasonable.The United States Court of Appeals for the Ninth Circuit reversed. It held that Arizona’s statutory scheme violated the Due Process Clause of the Fourteenth Amendment by shifting to the defendant the burden of disproving sexual motivation, which is the critical fact distinguishing criminal from innocent conduct. The court concluded that the Arizona Court of Appeals’ decision upholding the conviction was an objectively unreasonable application of clearly established Supreme Court precedent. The Ninth Circuit ordered the district court to grant the writ of habeas corpus. View "BIEGANSKI V. SHINN" on Justia Law

Michael and Susan Mockeridge purchased a remote 40-acre property in northern Michigan, where they installed five prefabricated mini-cabins near their main cabin for family use. After neighbors became concerned that the property was being operated as a public campground, they filed complaints with local authorities. In response, three government officials—Harry Harvey, David Schmidt, and Kenneth Gibson—entered the Mockeridges’ property without a warrant or consent, inspected the mini-cabins and their surroundings, and gathered information regarding potential code violations. The officials’ entry was not via the customary driveway but through adjacent private land and dense woods, and at the time, the cabins were unoccupied.The Mockeridges subsequently received a letter from the county classifying their property as a campground and requiring licensing. After applying for permits and being told they would face penalties for prior unpermitted work, the Mockeridges filed suit in the United States District Court for the Eastern District of Michigan, alleging a violation of their Fourth Amendment rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of the Mockeridges on liability, denied qualified immunity to the officials, and found the only remaining issue was damages. The officials appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that the officials’ warrantless entry into the curtilage of the Mockeridges’ mini-cabins for the purpose of gathering information about code compliance constituted an unreasonable search under the Fourth Amendment. The court further held that the right to be free from such a warrantless search was clearly established at the time of the officials’ conduct. The court dismissed the Mockeridges’ cross-appeal and denied as moot a motion by Alcona County. View "Mockeridge v. Harvey" on Justia Law

Edward Flynn was killed when a fleeing suspect, James Shirley, crashed into his car during a high-speed police pursuit. The incident began when Indianapolis police officers attempted to investigate a potentially stolen truck. Shirley, the suspect, backed into a patrol car and nearly struck two officers before fleeing. Multiple officers engaged in a pursuit that lasted about five and a half minutes, during which Shirley drove recklessly, including turning off his lights, running stop signs and red lights, and reaching high speeds. The chase ended when Shirley ran a red light and collided with Edward Flynn’s vehicle, resulting in Flynn’s death.Gayl Flynn, representing Edward’s estate, filed suit in the United States District Court for the Southern District of Indiana against the City and five officers. She alleged violations of Edward’s Fourteenth Amendment substantive due process rights and claimed the City failed to properly train its officers, invoking Monell v. Department of Social Service of New York. The district court granted summary judgment for the defendants, applying the “intent to harm” standard for Fourteenth Amendment liability in emergency situations and finding no such intent by the officers.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the facts presented an emergency situation, making the “intent to harm” standard appropriate. The court found that the officers did not act with intent to harm and that the circumstances did not support a claim under a deliberate indifference standard. Because there was no underlying constitutional violation, the Monell claim against the City also failed. The Seventh Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Flynn v Consolidated City of Indianapolis and Marion County" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

A Christian humanitarian organization offered a remote customer service representative position to an applicant who was openly in a same-sex marriage. After the applicant disclosed her marital status while inquiring about parental leave, the organization rescinded the job offer, citing its policy that limits employment to those who comply with its religious standards, including a prohibition on sexual conduct outside of marriage between a man and a woman. The applicant, who identifies as Christian and is active in LGBTQ advocacy, sued the organization for discrimination based on sex, sexual orientation, and marital status under federal and state law.The United States District Court for the Western District of Washington initially granted summary judgment to the organization, finding that the church autonomy doctrine barred judicial inquiry into the religiously motivated employment decision. Upon reconsideration, the district court reversed itself, holding that the church autonomy doctrine did not apply because the organization’s hiring policy was facially discriminatory and could be evaluated using neutral legal principles. The district court also rejected the organization’s ministerial exception defense and other constitutional and statutory defenses, ultimately granting summary judgment to the applicant and entering judgment for stipulated damages.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The Ninth Circuit held that the ministerial exception applies because customer service representatives at the organization perform key religious functions central to its mission, such as communicating its ministries to donors, engaging in prayer with supporters, and inviting participation in its religious mission. The court concluded that these duties are vital to the organization’s religious purpose, and therefore, the ministerial exception bars the applicant’s employment discrimination claims. The Ninth Circuit remanded the case for entry of summary judgment in favor of the organization. View "MCMAHON V. WORLD VISION INC." on Justia Law

Michael Hurd, Jr. was sentenced in 2005 to 15 months in prison for a felony firearm charge and an additional 27 months for four misdemeanor firearm and drug possession charges. After serving his felony sentence in federal custody, Hurd was mistakenly released instead of being transferred to serve his misdemeanor sentence. He completed his supervised release and, years later, was reincarcerated by the District of Columbia Department of Corrections when the error was discovered during a subsequent, unrelated incarceration. Hurd was not given a hearing before being required to serve the remainder of his original sentence.After his reincarceration, Hurd filed a habeas petition in the Superior Court of the District of Columbia, which was denied. His appeal was dismissed as moot after he completed his sentence. Hurd then brought a civil action in the United States District Court for the District of Columbia under 42 U.S.C. § 1983, alleging violations of his substantive and procedural due process rights under the Fifth Amendment. The district court granted summary judgment to the District, finding no substantive due process violation and holding that his procedural due process claim was barred by the Supreme Court’s decision in Heck v. Humphrey.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court’s judgment. The court held that reincarcerating a person to serve the remainder of a lawfully imposed sentence after an erroneous release does not violate substantive due process, as such action does not “shock the conscience.” The court also held that Hurd’s procedural due process claim for damages was barred by Heck v. Humphrey because a judgment in his favor would necessarily imply the invalidity of his confinement, which had not been set aside. View "Hurd v. DC" on Justia Law

In 2021, Ralph Marcus Hardy, an inmate at Adams County Detention Facility (ACDF) in Colorado, fell from his wheelchair and suffered serious injuries. Despite his repeated requests for medical attention, jail officials allegedly ignored his pleas. Hardy claims that Detention Specialist Daniel DeHerrera ignored emergency distress signals from his cell, and Deputy Dennis Rabie, who later found Hardy in pain, also failed to provide medical assistance.The United States District Court for the District of Colorado reviewed the case. Deputy Rabie and Detention Specialist DeHerrera moved to dismiss Hardy’s claims, asserting qualified immunity. The district court denied their motion, finding that Hardy plausibly alleged violations of his Fourteenth Amendment rights. The court held that the defendants were not entitled to qualified immunity, leading to this appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Hardy sufficiently alleged that both Deputy Rabie and Detention Specialist DeHerrera acted with deliberate indifference to his medical needs. The court found that Hardy’s constitutional rights were violated and that these rights were clearly established at the time of the incident. The court concluded that both defendants were aware of Hardy’s serious medical needs and failed to take reasonable measures to address them, thus denying them qualified immunity. View "Hardy v. Rabie" on Justia Law