Justia Civil Rights Opinion Summaries

Diamond S.J. Enterprise, Inc., which operates a nightclub in San Jose, California, had its license suspended for thirty days by the city following a shooting outside the club. The city held an administrative hearing and found that Diamond had operated its venue in a way that caused the shooting and created a public nuisance, violating San Jose's entertainment business licensing provisions. Diamond filed a complaint in federal court, alleging First Amendment and due process violations.The case was first heard in the United States District Court for the Northern District of California, which dismissed Diamond's claims and granted summary judgment for the City of San Jose. The district court ruled that the challenged provisions did not implicate First Amendment rights and that the city had satisfied due process requirements.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's decision, holding that Diamond's facial attack on the city's public entertainment business licensing provisions failed because the provisions did not give city officials unbridled discretion that created a risk of censorship. The court also held that Diamond failed to state a procedural due process claim, as the licensing scheme provided Diamond with notice, an opportunity to be heard, the ability to present and respond to evidence, and a pre-deprivation appeal, followed by post-deprivation review by the California Superior Court. View "Diamond S.J. Enterprise, Inc. v. City of San Jose" on Justia Law

The case involves Erik A. Andrade, a former Milwaukee Police Officer, who was terminated for a series of posts and comments he made on Facebook. The posts attracted significant local and national attention following a civil rights lawsuit that brought them to light. The Milwaukee Police Department conducted an internal investigation into the posts, informed Andrade of the policies he potentially violated, and scheduled an interview. Following the internal investigation, the Department formally charged Andrade with violating two policies, both citing Andrade's posts as the basis for the violations. The Chief of Police, Alfonso Morales, determined his guilt and imposed the appropriate punishment. The Chief had internal affairs reach out to the Milwaukee County District Attorney's Office, which explained that Andrade's posts would diminish his credibility in court so severely that they would no longer use him as a witness. Given the critical importance of testifying in police work, this fact convinced the Chief that termination was appropriate.The Chief's decision was reviewed by the Board of Fire and Police Commissioners. After a full evidentiary trial, the Board issued a detailed decision determining that Andrade was guilty of the violations and the punishments he received were appropriate. Andrade then filed two actions in the circuit court. The first was a statutory appeal focused on whether there was just cause to sustain the charges. The second was a petition for a writ of certiorari alleging that the Board committed legal and jurisdictional errors. The circuit court upheld the Board's decision, Andrade appealed on his certiorari petition, and the court of appeals affirmed.Before the Supreme Court of Wisconsin, Andrade challenged his termination on procedural grounds. He contended that it fell short of the Fourteenth Amendment's due process guarantee. He argued that due process required the Department to explain why Chief Morales terminated him instead of imposing a lesser form of discipline. As such, the Department should have told him that Chief Morales made his decision based on the DA's determination that they would no longer use Andrade as a witness. Andrade insisted that the Department's failure to tell him this prior to termination means he was not given an explanation of the evidence supporting his termination in violation of the United States Supreme Court's decision in Cleveland Board of Education v. Loudermill. The Supreme Court of Wisconsin disagreed with Andrade's claim and affirmed the decision of the court of appeals. View "Andrade v. City of Milwaukee Board of Fire and Police Commissioners" on Justia Law

This case involves a lawsuit filed by the family of Bill Heeter against Officer Kenneth Bowers and the Columbus Police Department. The family alleges that Officer Bowers used excessive force and violated Mr. Heeter's constitutional rights when he shot and killed Mr. Heeter during a police response to a suicide threat. The family also alleges that Officer Bowers violated Mr. Heeter's right to adequate medical care by failing to administer first aid after the shooting.The case was initially heard in the United States District Court for the Southern District of Ohio, where the defendants claimed immunity from the lawsuit. The district court granted the defendants immunity from some claims but denied others. The two constitutional claims against Officer Bowers that survived qualified immunity in the district court are the central focus of this appeal.The United States Court of Appeals for the Sixth Circuit affirmed the district court's denial of state-law immunity and qualified immunity as to Officer Bowers in his individual capacity, allowing the Heeters’ constitutional and state-law claims against him to proceed to trial. However, the court held that the City was entitled to summary judgment on the state-law claims because of an Ohio municipal immunity statute. The court reversed solely on the issue of municipal immunity for the City, and otherwise affirmed the district court's decision. View "Heeter v. Bowers" on Justia Law

The case involves Victor Hill, the former Sheriff of Clayton County, Georgia, who was convicted under 18 U.S.C. § 242 for using his position to deprive detainees in his custody of their constitutional rights. Hill ordered individual detainees, who were neither violent nor uncontrollable, into a restraint chair for at least four hours, with their hands cuffed behind their backs and without bathroom breaks. Each detainee suffered injuries, such as “open and bleeding” wounds, lasting scars, or nerve damage.Hill was convicted by a jury in the United States District Court for the Northern District of Georgia. He appealed his conviction to the United States Court of Appeals for the Eleventh Circuit, arguing that he lacked fair warning that his conduct was unconstitutional, that the evidence was insufficient to support his conviction, and that the district court improperly handled allegations of juror misconduct.The Eleventh Circuit rejected Hill's arguments and affirmed his conviction. The court found that case law provided Hill with fair warning that his actions violated constitutional rights. The court also found that the evidence was sufficient to support the jury's conclusion that Hill's conduct had no legitimate nonpunitive purpose, was willful, and caused the detainees’ injuries. Lastly, the court found that the district court did not abuse its discretion in investigating and responding to alleged juror misconduct. View "United States v. Hill" on Justia Law

In 1989, Andrew Johnson was convicted of aggravated burglary and sexual assault. In 2013, a Wyoming state court declared Johnson innocent based on DNA evidence and vacated his convictions. Johnson then filed a lawsuit against Officer Alan Spencer, the Estate of Detective George Stanford, and the City of Cheyenne, Wyoming, alleging that they fabricated evidence, failed to produce exculpatory evidence, and failed to maintain adequate policing policies. The district court dismissed Johnson's claims, and he appealed.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that Johnson failed to plausibly allege a fabrication-of-evidence claim against Officer Spencer. Regarding Johnson's claim based on the alleged failure to produce exculpatory evidence, the court determined that Johnson failed to show that his constitutional rights were violated, and thus, Officer Spencer and Detective Stanford were entitled to qualified immunity. The court also concluded that the district court properly dismissed the claims against the City of Cheyenne because Johnson did not demonstrate that any City of Cheyenne law enforcement officer violated his constitutional rights. View "Johnson v. City of Cheyenne" on Justia Law

The case involves a group of convicted sex offenders who were confined in the Fishkill Residential Treatment Facility (RTF) while on post-release supervision (PRS). The Department of Corrections and Community Supervision (DOCCS) used the Fishkill RTF to confine these offenders past their maximum sentence expiration dates because they were unable to find housing that complied with the Sexual Assault Reform Act (SARA). The plaintiffs initiated a proceeding in 2016, seeking injunctions, declaratory relief, and class certification, arguing that DOCCS's operation of the Fishkill RTF failed to comply with the statutes governing RTFs because it did not offer adequate programming or employment opportunities.The Supreme Court dismissed part of the proceeding and converted the remaining into an action seeking a declaration that DOCCS's operation of the Fishkill RTF was non-compliant with the statutes governing RTFs. The court denied class certification, reasoning that the converted declaratory judgment action would adequately protect the interests of similarly situated offenders. After discovery, the defendants moved for summary judgment and a declaration in their favor. The Supreme Court granted defendants' motion in part, concluding that the internal programming was minimally adequate to satisfy DOCCS's statutory obligations. However, the court agreed with plaintiffs that DOCCS failed to provide adequate community-based opportunities.The Appellate Division modified the judgment by reversing the part that granted partial summary judgment to plaintiffs and granted defendants' motion in its entirety. The Court concluded that while the statute requires DOCCS to locate RTFs near a community with employment, training, and educational opportunities, there was no mandate that DOCCS offer such opportunities outside the facility.The Court of Appeals held that DOCCS's wholesale refusal to secure community-based opportunities for Fishkill RTF residents constitutes a violation of the statute. The Court concluded that DOCCS, at a minimum, must undertake reasonable efforts to secure community-based opportunities for those persons subject to its RTF programming. However, the Court agreed with the Appellate Division that the internal programming at the Fishkill RTF was at least minimally adequate. View "Alcantara v Annucci" on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law

The case involves a lawsuit filed by the family of Kyle Hart against the City of Redwood City and its police officers, following Hart's death in a police shooting. Hart, who was attempting suicide with a knife in his backyard, was shot by Officer Gomez when he approached the officers with the knife despite commands to drop it. The family alleged constitutional and state law violations arising from the shooting.The United States District Court for the Northern District of California denied Officer Gomez's claim of qualified immunity at summary judgment. The court found that the officer was not entitled to qualified immunity, relying on a previous court decision that stated it was objectively unreasonable to shoot an unarmed man who had committed no serious offense, was mentally or emotionally disturbed, had been given no warning of the imminent use of such a significant degree of force, posed no risk of flight, and presented no objectively reasonable threat to the safety of the officer or other individuals.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Officer Gomez was entitled to qualified immunity. The court found that Hart posed an immediate threat when he rapidly approached the officers brandishing a knife and refusing commands to drop it. Furthermore, even if Officer Gomez’s conduct violated the Fourth Amendment, he would still be entitled to qualified immunity because the conduct did not violate clearly established law. None of the cases the plaintiffs identified would have put Officer Gomez on notice that his actions in this case would be unlawful. View "Hart v. City of Redwood City" on Justia Law

Kevin D. Jones, an attorney, held a term position with the U.S. Department of Agriculture (USDA) before transferring to the Department of Justice’s (DOJ) Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). At the USDA, Jones primarily provided advice and counsel regarding discrimination complaints filed against the agency and litigated ensuing discrimination claims before the Equal Employment Opportunity Commission (EEOC). At the ATF, Jones served as an advisor to the Professional Review Board (PRB) as part of a team of attorneys in the Management Division of the ATF Office of General Counsel (OGC). After three months at the ATF, Jones was asked to resign due to his lack of contract law experience. Jones filed a complaint alleging discrimination and lack of due process in his termination.The Merit Systems Protection Board (MSPB) dismissed Jones's administrative appeal for lack of jurisdiction. The Administrative Judge (AJ) of the MSPB found that Jones was not an "employee" as defined by 5 U.S.C. § 7511(a)(1)(B) because his positions at the USDA and ATF were not the same or similar. The AJ noted several distinctions between the tasks Jones performed at each agency. Jones did not appeal the Initial Decision to the full Board, so the AJ’s Initial Decision became the Final Decision of the Board.The United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the AJ did not err in her determination that Jones's positions at the USDA and ATF were not similar. The court also found that the AJ's decision was supported by substantial evidence. Therefore, the court affirmed the Board's determination that it lacked jurisdiction to hear Jones's appeal. View "Jones v. Merit Systems Protection Board" on Justia Law

The case involves RaySean Barber, an inmate in the custody of the Nebraska Department of Correctional Services (DCS), who was diagnosed with a mental illness. Barber refused treatment with antipsychotic medications, leading DCS medical staff to apply for a series of involuntary medication orders (IMOs) authorizing monthly injections of the antipsychotic medication Haldol against his will. Barber filed a lawsuit against the State of Nebraska under the State Tort Claims Act (STCA), alleging that DCS employees were negligent in applying for, ordering the initiation and continuation of, and upholding the IMOs.The State moved to dismiss Barber's complaint, arguing that the claim was barred by the STCA’s exemption for any claim arising out of battery. The district court agreed and dismissed the complaint, reasoning that the unconsented and involuntary injection is the cause of Barber’s alleged injury—a battery.The Nebraska Supreme Court affirmed the district court's decision. The court concluded that Barber's claim—that DCS staff negligently subjected him to an IMO and injected him with Haldol against his will—is a claim that arises out of a battery. The court held that because Barber's claim arose out of a battery, it is barred by the exemption in the STCA. View "Barber v. State" on Justia Law