Justia Civil Rights Opinion Summaries

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Three Coast Guard servicemembers, Eric Jackson, Alaric Stone, and Michael Marcenelle, objected to a COVID-19 vaccination mandate issued by the Coast Guard, which operates under the Department of Homeland Security. Their requests for religious accommodations were denied, and they faced reprimands for refusing the vaccination. They filed a class action lawsuit against the Secretaries of Homeland Security and Defense, the Commandant of the Coast Guard, and the Assistant Commandant for Human Resources, alleging violations of the Religious Freedom Restoration Act, the First Amendment, and the Administrative Procedure Act. They sought declaratory and injunctive relief.The United States District Court for the Northern District of Texas dismissed the case as moot after the Department of Defense rescinded its vaccination mandate, and the Coast Guard followed suit. The Plaintiffs' motion for relief from final judgment was also denied, leading to their appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s Rule 12(b)(1) dismissal de novo. The appellate court found that the case was not moot because the Coast Guard had not issued policies protecting unvaccinated servicemembers from discrimination, unlike the Navy, which had implemented such protections. The court noted that the Plaintiffs could still face adverse actions based on their vaccination status and that a court order could provide effective relief. Consequently, the Fifth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Jackson v. Noem" on Justia Law

A citizen sought access to police use of force reports under the Iowa Open Records Act. The Des Moines Police Department requires officers to complete a report whenever force is used, detailing the incident's specifics. The reports are reviewed by supervisors and used for accountability, training, and identifying trends. In 2020, 387 use of force reports were filed, with only a few resulting in disciplinary action.The Iowa District Court for Polk County granted summary judgment in favor of the citizen, ordering the City of Des Moines to disclose the use of force reports. The court found that the reports were factual accounts of incidents and not evaluative or performance records, thus not exempt from disclosure under Iowa Code section 22.7(11). The court allowed redaction of information about officer injuries or medical treatment.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the use of force reports are not exempt from disclosure under section 22.7(11) as they are factual reports, not confidential personnel records. The court also rejected the City's argument that the reports were protected under Iowa Code section 80F.1(20), as this section pertains to statements and interviews in response to complaints, not routine use of force reports. The court noted that any specific redactions could be justified on other legal grounds if necessary. View "Harrison v. Mickey" on Justia Law

Plaintiff K.C. alleged that she was sexually abused while in foster care under the custody of the County of Merced. The abuse occurred in two separate foster homes between 1971 and 1977. K.C. claimed that she reported the abuse to her social worker, but no corrective action was taken, resulting in continued abuse. She filed a complaint citing negligent acts and omissions by the County and its employees, which she argued proximately caused her injuries.The Superior Court of Merced County sustained the County's demurrer without leave to amend, leading to the dismissal of K.C.'s complaint with prejudice. The court found that the County and its employees were protected by discretionary immunity under Government Code sections 815.2 and 820.2, which shield public employees and entities from liability for discretionary acts.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case and affirmed the lower court's judgment. The appellate court held that the social workers' decisions regarding the investigation of child abuse and the continuation of foster home placements were discretionary acts protected by immunity. The court emphasized that these decisions involved the exercise of judgment and policy considerations, which are shielded from liability to ensure that public employees can perform their duties without fear of civil suits. Consequently, the County was also immune from liability under the derivative immunity provided by Government Code section 815.2, subdivision (b). View "K.C. v. County of Merced" on Justia Law

Misty Coleman alleges that she fell and broke her ankle after slipping on a wet shower floor in a county jail. She pursued constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county, corrections officers, and medical personnel. Coleman claimed that the slippery shower violated the Due Process Clause and that a county policy or custom was behind her poor medical care. She also questioned whether the county could invoke state-law immunity from her negligence claim at the pleading stage.The United States District Court for the Southern District of Ohio dismissed all claims against all parties. The court found that Coleman failed to allege a plausible constitutional violation regarding the slippery shower and did not connect the inadequate medical care to a county policy or custom. The court also held that Ohio law granted immunity to Hamilton County on the negligence claim. The court allowed Coleman to conduct limited discovery to identify unnamed officers and nurses, but her subsequent amended complaint was dismissed as it was filed outside the statute of limitations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's dismissal, holding that Coleman’s claims accrued on the date of her accident and that her amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15. The court also found that Coleman did not meet the requirements for equitable tolling, as she did not allege facts showing that she was intentionally misled or tricked into missing the deadline. The Sixth Circuit affirmed the district court's dismissal of Coleman’s complaint. View "Coleman v. Hamilton County Bd. of County Commissioners" on Justia Law

Richard Hightower, a pretrial detainee, was attacked by his cellmate, Anthony Tyler, in a Philadelphia jail, resulting in Hightower's paralysis. Hightower was classified as a low-security risk, while Tyler was classified as a high-security risk with a history of violent behavior. Due to a mistake by a prison health services company, Tyler was placed in Hightower's intake cell instead of being transferred to a permanent cell. Tyler's aggressive behavior escalated, culminating in a violent attack on Hightower.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the City of Philadelphia and the guards. Hightower did not appeal the judgment for the guard but did appeal the judgment for the city.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Hightower failed to prove that the city caused any constitutional violation. To succeed in his Monell claim, Hightower needed to show that the city had an unconstitutional policy or custom or was deliberately indifferent to inmates' rights. The court found that the city had no policy of not separating inmates by security-risk level during intake and that the lack of a policy is not a policy. Additionally, Hightower could not show a custom that violated his rights or that the city acted with deliberate indifference. The court concluded that the risk to Hightower was not so obvious that the city could be held liable without a pattern of similar violations.The Third Circuit affirmed the District Court's summary judgment in favor of the City of Philadelphia. View "Hightower v. City of Philadelphia" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

The complainant, John Ward, filed a complaint with the Commission on Human Rights and Opportunities (CHRO) alleging that the City of Stamford discriminated against him based on his veteran status and disability. The CHRO found reasonable cause and certified the complaint to the Office of Public Hearings (OPH). During the public hearing, Ward moved to amend his complaint to include a claim for denial of reasonable accommodations. The human rights referee granted the motion over the city's objection.The city filed an interlocutory administrative appeal with the Superior Court, arguing that the CHRO lacked jurisdiction to hear the amended complaint without a reasonable cause finding. The CHRO and Ward moved to dismiss the appeal, contending that interlocutory rulings are not appealable under General Statutes § 46a-94a (a) and that the statutory requirements for an interlocutory appeal under § 4-183 (b) were not met. The trial court denied the motions to dismiss, finding that the referee's ruling was a final decision under § 4-183 (a).The Supreme Court of Connecticut reviewed the case and concluded that the referee's ruling was not a final decision under § 4-183 (a) because it did not terminate any aspect of the case or determine any rights or obligations. The court also determined that § 46a-94a (a) allows for interlocutory appeals under § 4-183 (b), but the city's appeal did not meet the criteria for such an appeal because postponement would not result in an inadequate remedy. The court reversed the trial court's decision and remanded with direction to grant the motions to dismiss the city's appeal. View "Stamford v. Commission on Human Rights& Opportunities" on Justia Law

Michael Chapman, an Alabama inmate, sued prison officials and staff for deliberate indifference to his medical needs, violating the Eighth Amendment. Chapman alleged that an untreated ear infection led to severe injuries, including mastoiditis, a ruptured eardrum, and a brain abscess. He also claimed that the prison's refusal to perform cataract surgery on his right eye constituted deliberate indifference. The district court granted summary judgment for all defendants except the prison’s medical contractor, which had filed for bankruptcy.The United States District Court for the Middle District of Alabama found Chapman’s claim against nurse Charlie Waugh time-barred and ruled against Chapman on other claims, including his request for injunctive relief against Commissioner John Hamm, citing sovereign immunity. The court also concluded that Chapman’s claims against other defendants failed on the merits and dismissed his state-law claims without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court reversed the district court’s determination that Chapman’s claim against Waugh was time-barred, finding that Chapman’s cause of action accrued within the limitations period. The court vacated the district court’s judgment for Waugh and remanded for reconsideration in light of the recent en banc decision in Wade, which clarified the standard for deliberate indifference claims. The court also vacated the judgment for Hamm on Chapman’s cataract-related claim for injunctive relief, as sovereign immunity does not bar such claims. Additionally, the court vacated the summary judgment for all other defendants due to procedural errors, including inadequate notice and time for Chapman to respond, and remanded for further consideration. View "Chapman v. Dunn" on Justia Law