Justia Civil Rights Opinion Summaries

Officer Henry Volentine, a deputy of the Hardin County Office of Sheriff (HCOS), initiated a traffic stop of Maurice Green on October 14, 2014, after noticing Green's vehicle had an expired license plate belonging to a different vehicle. Green initially pulled over but then drove off, prompting Volentine to pursue him. During the pursuit, Volentine believed Green had committed assault and wanton endangerment by nearly hitting two pedestrians. The pursuit ended in a head-on collision with Susan Sheehy’s vehicle, leading to the present litigation.The Hardin Circuit Court denied Volentine’s and HCOS’ motion for summary judgment based on qualified and governmental immunity. The court found that Volentine did not have a reasonable basis to believe a violent felony had occurred to justify the pursuit and that his actions were not in good faith. The court also determined that Volentine violated ministerial duties by failing to terminate the pursuit when it posed an extreme safety hazard and by not obtaining approval from a supervisor to continue the pursuit.The Kentucky Court of Appeals reversed the trial court’s decision, holding that Volentine was entitled to qualified official immunity and that HCOS was entitled to governmental immunity. The Court of Appeals reasoned that Volentine’s belief that he witnessed a felony was reasonable and that his actions during the pursuit were discretionary.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals. The Supreme Court held that Volentine was not entitled to qualified official immunity because he failed to abide by ministerial duties and lacked good faith in exercising his discretion to initiate the pursuit. Consequently, HCOS’ governmental immunity was waived by operation of KRS 70.040. The case was remanded to the Hardin Circuit Court for further proceedings consistent with the Supreme Court’s opinion. View "SHEEHY V. VOLENTINE" on Justia Law

Enriqueta Diaz, a former county judge and resident of Maverick County, opposed the issuance of certificates of obligation for water and sewer improvements by the Maverick County Commissioners Court. She collected signatures on a petition to force an election on the issue. Despite her petition, the commissioners decided to issue the certificates without holding an election. During the meeting, Diaz heckled the commissioners, leading County Judge English Cantu to hold her in contempt and order her removal. Diaz was detained outside in the rain for several hours and later sentenced to 24 hours in jail, though she was released without being confined.Diaz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Texas, seeking damages for false imprisonment and bystander liability against County Judge English Cantu and three county commissioners. The district court denied the defendants' motion to dismiss, rejecting their claims of state sovereign immunity, judicial immunity, and qualified immunity. The defendants appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that constitutional county judges in Texas are not entitled to state sovereign immunity as they are considered local rather than state officers. The court also determined that English Cantu was not entitled to judicial immunity because he was acting in an administrative capacity, not a judicial one, during the commissioners court meeting. Additionally, the court found that English Cantu was not entitled to qualified immunity because he acted without discretionary authority in holding Diaz in contempt. However, the court reversed the district court's denial of qualified immunity for the commissioners on the bystander liability claims, as the law was not clearly established that they had a duty to intervene. The case was remanded for further proceedings. View "Diaz v. Cantu" on Justia Law

Lloyd Gerald Napouk was fatally shot by two Las Vegas Metropolitan Police Department officers after they responded to reports of a man behaving suspiciously in a residential neighborhood with what appeared to be a long, bladed weapon. The officers attempted to engage Napouk, who refused to follow their commands and advanced towards them multiple times. When Napouk came within nine feet of one of the officers, both officers fired their weapons, killing him. The weapon turned out to be a plastic toy fashioned to look like a blade.Napouk’s parents and estate sued the officers and the Las Vegas Metropolitan Police Department, alleging excessive force in violation of the Fourth Amendment, deprivation of familial relations in violation of the Fourteenth Amendment, municipal liability based on Monell v. Department of Social Services, and Nevada state law claims. The United States District Court for the District of Nevada granted summary judgment for the defendants, determining that the officers’ use of force was reasonable as a matter of law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court held that the officers were entitled to qualified immunity from the Fourth Amendment excessive force claim because Napouk posed an immediate threat to the officers, and no rational jury could find the officers’ mistake of fact regarding the weapon unreasonable. The court also held that the plaintiffs’ Fourteenth Amendment claim failed because there was no evidence that the officers acted with anything other than legitimate law enforcement objectives. Additionally, the plaintiffs’ Monell claims failed due to the absence of a constitutional violation, and the state law claims failed because the officers were entitled to discretionary-function immunity under Nevada law. View "Napouk v. Las Vegas Metropolitan Police Department" on Justia Law

A newspaper, Copley Ohio Newspapers, Inc., doing business as Akron Beacon Journal, made several public-records requests to the City of Akron and the Akron Police Department in 2022. The requests sought records identifying police officers involved in three lethal use-of-force incidents. The city provided some records but redacted the officers' names, citing safety concerns and legal exceptions. The newspaper filed a mandamus action under the Ohio Public Records Act, R.C. 149.43, to compel the city to produce unredacted records.The lower court, the Supreme Court of Ohio, reviewed the case. The city argued that the requests for personnel files, discipline records, and internal investigations of unidentified officers were improper public-records requests and that the officers' names were protected under the confidential law-enforcement investigatory records (CLEIR) exception and the Kallstrom/Keller exception, which protects records that could endanger officers' lives.The Supreme Court of Ohio held that the requests for personnel files, discipline records, and internal investigations of unidentified officers were improper public-records requests. However, the court found that the requests for administrative leave or reinstatement notices and incident reports were proper. The court ruled that the names of the officers involved in the Walker shooting were exempt from disclosure under the CLEIR exception for uncharged suspects. The court ordered the city to provide copies of the Walker incident reports with only the names of the eight officers who are uncharged suspects redacted and to provide unredacted copies of the administrative leave and reinstatement notices. The court denied the newspaper's requests for statutory damages and attorney fees but granted court costs. View "State ex rel. Copley Ohio Newspapers, Inc. v. Akron" on Justia Law

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law

Plaintiffs Tati Abu King and Toni Heath Johnson were unable to register to vote in Virginia due to felony convictions. King was convicted of felony drug possession in 2018, and Johnson was convicted of multiple felonies, including drug possession, in 2021. Virginia's constitution disenfranchises individuals convicted of felonies unless their civil rights are restored by the Governor or other appropriate authority. King and Johnson argued that this disenfranchisement violated the Virginia Readmission Act, a federal statute from 1870, which they claimed restricted Virginia from amending its constitution to disenfranchise individuals for crimes that were not felonies at common law in 1870.The United States District Court for the Eastern District of Virginia dismissed three of the four counts in the plaintiffs' complaint for failure to state a claim but allowed one count based on the Virginia Readmission Act to proceed. The defendants, including various state election officials and the Governor of Virginia, moved to dismiss the complaint on sovereign immunity grounds, which the district court rejected.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiffs' claim met the requirements of the Ex parte Young doctrine, which allows suits for prospective relief against state officials to prevent ongoing violations of federal law. The court affirmed the district court's decision to allow the claim to proceed against most defendants but reversed the decision regarding the Governor of Virginia and the Secretary of the Commonwealth, finding that they lacked enforcement responsibility for the challenged state action. The court concluded that the Governor and Secretary must be dismissed from the case on sovereign immunity grounds. The district court's order was thus affirmed in part and reversed in part. View "King v. Youngkin" on Justia Law

Ashleigh Gelin died by suicide in November 2013 while incarcerated at the Baltimore County Detention Center. Her parents, Edward and Deborah Gelin, sued Baltimore County and several correctional officers, alleging violations of 42 U.S.C. § 1983, the Maryland Declaration of Rights, and Maryland common law. They claimed the officers showed deliberate indifference to Ashleigh's safety and were grossly negligent.The United States District Court for the District of Maryland partially granted and partially denied the County's motion for judgment on the pleadings. The court found that the complaint did not properly allege deliberate indifference to Ashleigh's mental health needs but did plausibly allege indifference to her physical safety. The court held that the officers could not claim qualified immunity or Maryland common-law public official immunity and denied Baltimore County's claim of governmental immunity. The County's subsequent motion for reconsideration was partially addressed, but the court did not rule on whether the officers could assert public official immunity against the negligence claims.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the County's appeal was premature because the district court had not yet ruled on all issues raised in the County's motion for reconsideration. Specifically, the district court had not decided whether the officers could assert public official immunity against the negligence claims. As a result, the Fourth Circuit held the appeal in abeyance, pending the district court's resolution of the remaining issue. The court directed the parties to inform it once the district court had made a final ruling on the pending issue. View "Gelin v. Baltimore County" on Justia Law

Ohio House, LLC operates a sober-living facility in Costa Mesa, California, within a multiple-family residential (MFR) zone. The City of Costa Mesa notified Ohio House that it was subject to Ordinance 15-11, which mandates that group homes with over six residents in MFR zones obtain a conditional-use permit and meet a separation requirement. Ohio House's application for a permit was denied due to non-compliance with the separation requirement, and its request for a reasonable accommodation was also denied.The United States District Court for the Central District of California granted partial summary judgment to the City on Ohio House's disparate-impact claim and denied Ohio House's post-verdict motions. The jury found in favor of the City on Ohio House's remaining claims, including disparate treatment, discriminatory statements, interference with fair housing rights, and reasonable accommodation. The district court also ruled that Ohio House's claim under California Government Code § 65008 was time-barred.The United States Court of Appeals for the Ninth Circuit affirmed the district court's rulings. The court held that Ohio House failed to establish facial disparate treatment as a matter of law because the City's group-living regulations facially benefit disabled individuals. The court also affirmed the summary judgment for the City on the disparate-impact claim, agreeing that Ohio House did not prove a significant, adverse, and disproportionate effect on a protected group. The court upheld the jury's verdict on the discriminatory statements claim, finding no unlawful discriminatory statements by the City. The court also affirmed the denial of judgment as a matter of law on the interference claim, concluding that Ohio House failed to prove a causal link between its protected activity and the City's actions. Finally, the court affirmed the denial of judgment as a matter of law on the reasonable accommodation claim, agreeing that the requested accommodation was unreasonable as it would fundamentally alter the City's zoning scheme. The court also upheld the district court's ruling that Ohio House's § 65008 claim was time-barred. View "THE OHIO HOUSE, LLC V. CITY OF COSTA MESA" on Justia Law

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State" on Justia Law

A federal inmate, Dustin Rowland, developed a hernia after a pretrial detention fight. A physician deemed the hernia "reducible and stable," recommending non-surgical treatments. Rowland, desiring surgery, utilized the Bureau of Prisons' (BOP) Administrative Remedial Program, which involves a four-step grievance process. His initial requests were denied, but a later appeal led to approval for a surgical consultation. However, Rowland's final appeal was denied for procedural reasons, and he did not correct the deficiency. He eventually received surgery but filed a lawsuit claiming deliberate indifference to his medical needs, seeking damages under Bivens, injunctive relief for post-operative care, and a negligence claim under the Federal Tort Claims Act (FTCA).The United States District Court for the District of Colorado dismissed Rowland's Bivens claim, granted summary judgment against his injunctive relief claim for failure to exhaust administrative remedies, and dismissed the FTCA claim for lack of subject matter jurisdiction due to non-exhaustion. Rowland's motion for reconsideration was also denied.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, noting that Rowland's case presented a new context not covered by previous Bivens cases and that the BOP's Administrative Remedial Program provided an adequate alternative remedy. The court also upheld the summary judgment on the injunctive relief claim, as Rowland failed to exhaust administrative remedies specifically for post-operative care. Lastly, the court affirmed the dismissal of the FTCA claim, emphasizing the jurisdictional requirement of exhausting administrative remedies before filing suit. The court found no abuse of discretion in the district court's denial of Rowland's Rule 60(b) motion for reconsideration. View "Rowland v. Matevousian" on Justia Law