Justia Civil Rights Opinion Summaries

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision to grant summary judgment in favor of Officer Andrei Nikolov, who had been sued for excessive force under 42 U.S.C. § 1983. The case arose from an incident in which the officer shot Jennifer Morgan-Tyra multiple times after responding to a domestic-disturbance call. Upon arrival at the scene, the officer encountered an angry Morgan-Tyra holding a gun and shouting expletives at someone out of his view. When she did not comply with a command to drop the gun, Officer Nikolov fired at least nine shots, several of which struck Morgan-Tyra and caused severe and lasting injuries.In affirming the district court's judgment, the appeals court found that, even if Officer Nikolov's decision to shoot without warning was objectively unreasonable under the circumstances, he did not violate a clearly established right. The court noted that officers may use deadly force when there is probable cause to believe that a suspect poses a threat of serious physical harm, either to the officer or to others, and that a warning is less likely to be feasible in a high-pressure situation that requires a split-second judgment. The court also found that a reasonable officer in Nikolov's position would not have known whether Morgan-Tyra was the initial aggressor or a victim who had fought back, and that it was not clearly unreasonable to shoot her under the circumstances. Even considering Morgan-Tyra's version of facts, the court held that she was wielding the gun in a menacing fashion and appeared ready to shoot. Thus, the court concluded that Officer Nikolov is entitled to qualified immunity. View "Jennifer Morgan-Tyra v. Andrei Nikolov" on Justia Law

In 2015, Brian McNeal was found guilty of possessing cocaine and drug paraphernalia in Louisiana. He was given a five-year suspended sentence with five years of probation. In 2017, McNeal was arrested for violating probation and subsequently sentenced to serve 90 days at an in-patient substance abuse program. The Louisiana Department of Public Safety and Corrections (DPSC) determined McNeal's release date was to be November 1, 2017. However, McNeal was not released until December 12, 2017, 41 days after his proper release date. In 2018, McNeal sued James LeBlanc, the DPSC Secretary, in his individual capacity for wrongfully detaining him after his sentence expired. LeBlanc filed a motion to dismiss on the grounds of qualified immunity, which the district court denied. LeBlanc then appealed this decision to the United States Court of Appeals for the Fifth Circuit.The Court of Appeals affirmed the district court's decision, finding that McNeal's claims were not barred by Heck v. Humphrey, 512 U.S. 477 (1994), a case that limits certain legal claims if they would imply the invalidity of a conviction or sentence. The court reasoned that McNeal did not challenge his conviction or attendant sentence, but rather the 41 days he was imprisoned beyond his release date. Therefore, Heck did not apply.The court also rejected LeBlanc's argument that he was entitled to qualified immunity, a legal doctrine that shields government officials from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights. The court determined that McNeal had sufficiently alleged that LeBlanc was deliberately indifferent to a pattern of overdetention in the DPSC. Furthermore, the court found that the right to a timely release from prison was clearly established at the time of McNeal's overdetention. Consequently, the court concluded that LeBlanc was not entitled to qualified immunity in this case. View "McNeal v. LeBlanc" on Justia Law

In this case, plaintiffs Kewon English and Earl Powell were arrested for sexual assault and burglary and detained for over a year before their cases were nolle prossed and they were released. They sued Senior Investigator Joseph Clarke of the Richland County Sheriff’s Department, alleging that he had coerced them into signing false confessions. They also sued Sheriff Leon Lott and the Richland County Sheriff's Department for damages under § 1983, claiming their constitutional rights under the First, Fourth, Fifth, Sixth, and Fourteenth Amendments were violated. The United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment on English’s claims and dismissed Clarke’s cross-appeal. The court determined that there was probable cause to arrest English based on the victim’s identifications. Regarding English's malicious prosecution claim, the court held that even assuming probable cause was negated, Clarke cannot be held responsible for English’s continued detention. The court found no evidence that the Richland County Sheriff's Department had any unconstitutional policy or custom, and that Clarke could not be held liable for the continued detention of English. Furthermore, the court dismissed Clarke's cross-appeal, ruling that the appeal turned on a question of fact and was therefore not suitable for interlocutory treatment. View "English v. Clarke" on Justia Law

In this case, the United States Court of Appeals for the Eleventh Circuit reviewed an appeal of a lower court's denial of qualified immunity to a jail intake officer, Keyvon Sellers. The case arose from an incident in which a black man, Jayvon Hatchett, attacked and killed his white cellmate, Eddie Nelson, in county jail. Before the attack, Hatchett had told Sellers that he had previously stabbed a white man after watching videos of white police officers shooting black men. Despite this admission, Sellers did not inform other jail staff of Hatchett's racially motivated violence. Nelson's survivors sued Sellers, alleging that his failure to share this information constituted deliberate indifference to a substantial risk of serious harm to Nelson, in violation of the Fourteenth Amendment.The Court of Appeals affirmed the district court's decision, finding that a reasonable jury could conclude that Sellers violated Nelson's clearly established constitutional right by failing to protect him from a known risk of harm. The court concluded that Sellers had fair warning that his inaction was unconstitutional. Therefore, he was not entitled to qualified immunity. View "Nelson v. Sellers" on Justia Law

In a case before the United States Court of Appeals for the Fifth Circuit, Jessica Banks sued the Texas Department of Family and Protective Services (DFPS) for removing her four-year-old son R.B. from her custody without parental consent or a court order, alleging violations of the Fourth and Fourteenth Amendments. The district court denied DFPS's motion for summary judgment, finding that its employees were not entitled to qualified immunity as they had violated clearly established law.DFPS appealed the decision, but the appellate court affirmed in part and reversed in part. The court found that the removal of R.B. violated the constitutional rights of both the child and Banks, as there were no exigent circumstances that justified a warrantless removal from his mother. The court emphasized that the mere possibility of danger in the future was not enough to constitute exigent circumstances. The court also held that the law was clearly established that removing a child from their home without consent, a court order, or exigent circumstances was a constitutional violation.However, the court reversed the district court's denial of qualified immunity for Linda Juarez, an Investigation Supervisor at DFPS. The court ruled that Juarez was not the ultimate decision-maker and was not actively involved in the decision to remove R.B., thereby entitling her to qualified immunity. View "Banks v. Herbrich" on Justia Law

In this case, Jordan Jones, a prisoner at North Carolina’s Avery-Mitchell Correctional Institution, sued multiple prison officials under § 1983. The suit challenged the conditions of his confinement and a transfer to another prison that he alleged was retaliatory. The United States Court of Appeals for the Fourth Circuit affirmed in part and reversed in part the district court's grant of summary judgment to the defendants.Jones had been placed in a “dry” cell, with the water turned off, for about 17 hours after he was suspected of having ingested contraband. He was allowed to clean himself only with toilet paper, despite having to defecate three times in a portable toilet. He also had to eat a meal with his hands, which he was unable to wash. The court concluded that while the conditions of Jones's confinement were deplorable, the officials were entitled to qualified immunity on this claim because it was not clearly established in April 2015 that these conditions posed a substantial risk of serious harm in violation of the Eighth Amendment.However, the court reversed the district court's grant of summary judgment to defendant Gregory Taylor on Jones's claim that his transfer to another prison was in retaliation for his filing of grievances. The court concluded that a reasonable jury could find that Taylor ordered the transfer in retaliation for Jones's grievances, and that Taylor was not entitled to qualified immunity on this claim because it was clearly established at the time of the transfer that such retaliation violated the First Amendment. The court remanded for further proceedings on this claim. View "Jones v. Solomon" on Justia Law

In the case brought before the Court of Appeal of the State of California, First Appellate District, Division Three, the petitioners, First Amendment Coalition and KQED Inc., sought public access to certain records in the possession of the Attorney General and the Department of Justice, relating to peace officers and custodial officers. The records primarily pertained to instances of use of force, discharge of firearms, and sustained findings of dishonesty or sexual assault by an officer, which were considered nonconfidential under section 832.7(b) of the Penal Code.However, the Department withheld certain records citing exemptions under the California Public Records Act (CPRA) due to other state laws prohibiting their disclosure. The petitioners filed a motion for judgment compelling disclosure of these withheld documents but were denied by the trial court.The court, applying rules of statutory construction, concluded that section 832.7(b) of the Penal Code supersedes state law disclosure exemptions that conflict with its decree that records within its scope are not confidential and shall be made available to the public. As such, the court ordered a directive for the respondent court to vacate its judgment to the extent it denies the petitioners’ motion for judgment based on Government Code section 11183, which prohibits the disclosure of subpoenaed records. In all other respects, the petition for writ of mandate was denied. View "First Amendment Coalition v. Super. Ct." on Justia Law

The case involves Brandon Peterson, an inmate at Washington County Jail (WCJ), who filed a lawsuit alleging violations of his constitutional rights by various jail officials. The United States Court of Appeals for the Eighth Circuit, reviewing the case, had to decide on numerous instances of alleged excessive force, failure to intervene, and deliberate indifference to serious medical needs, as well as constitutional and state law claims.The court found that on several occasions of alleged excessive force, the officers' actions were justified given Peterson's disruptive and threatening behavior. Consequently, the court granted qualified immunity to the officers involved in these incidents. In the case of the failure to intervene claims, the court decided that without an underlying constitutional violation, there can be no liability for failure to intervene, resulting in the officers being granted qualified immunity for these claims as well.On the issue of deliberate indifference to Peterson's mental health condition, the court found that the prison officials had made efforts to address his condition and had not acted with deliberate disregard for his health. Therefore, the court reversed the district court's denial of qualified immunity to the officials involved.Regarding Peterson's claim of being subjected to unconstitutional conditions of confinement, the court remanded the case to the district court for it to address this issue. The court also remanded the case to the district court to decide on the state law and Monell claims. As such, the Appeals Court reversed in part, dismissed in part, and vacated in part the district court's decision, remanding the case for further proceedings consistent with the court’s opinion. View "Peterson v. Heinen" on Justia Law

In the Supreme Court of the State of Alaska, the case involved a self-represented prisoner who sued the Department of Corrections (DOC) for intentional and negligent infliction of emotional distress. The prisoner alleged that DOC held him in administrative segregation (solitary confinement) for 504 days and that corrections officers denied him any meaningful opportunity to appeal or be heard regarding his segregation. The prisoner contended that the corrections officers’ actions amounted to extreme and outrageous conduct that caused him severe emotional distress. The superior court granted summary judgment in favor of DOC, reasoning that DOC’s conduct was not extreme and outrageous and that the prisoner’s distress was not severe enough to give rise to liability.On appeal, the Supreme Court of the State of Alaska concluded that the superior court abused its discretion in dismissing the prisoner's claim of intentional infliction of emotional distress. The Supreme Court reversed the superior court’s grant of summary judgment in DOC’s favor as to the prisoner’s intentional infliction of emotional distress claim. The Supreme Court also vacated the superior court’s order approving the attorney general’s certification that individual corrections officers acted within the scope of their employment, reversed the court’s denial of the prisoner’s request to compel certain discovery, and remanded for further proceedings consistent with this decision. However, the Supreme Court affirmed the superior court’s grant of summary judgment with respect to the prisoner’s negligent infliction of emotional distress claim. View "Watkinson v. State of Alaska" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit affirmed a district court's decision to grant summary judgment in favor of the defendants on all federal claims made by the plaintiff. The plaintiff, Lamont Moore, was an inmate who filed a suit against a prison guard and the prison where he was subsequently sent to, alleging failure to protect him from another inmate's attack, violation of his rights under the Americans with Disabilities Act (ADA), and a conspiracy among the investigating officers to falsify the official report of the incident.The court found that Moore was unable to demonstrate that the prison guard was aware of and disregarded an excessive risk to his safety, a requirement for a successful claim of failure to protect. Moore's testimony indicated that his complaints to the guard about the other inmate were about annoyance and horseplay, not a fear for his safety.Regarding his ADA claim, the court found that Moore failed to demonstrate that any disability-based discrimination was intentional. Moore complained about the distance to the healthcare unit but never alerted anyone at any prison that he required an accommodation in order to access services. He was able to access every service in prison, albeit more slowly due to his loss of vision in one eye. There was no evidence that any defendant knew that he could not access any services or made a deliberate choice to deny him access to services.After resolving all of the federal claims, the court declined to exercise supplemental jurisdiction over the state law claims. View "Moore v. Western Illinois Correctional Center" on Justia Law