Justia Civil Rights Opinion Summaries

The plaintiff, a police officer for the Town of Salem, was involved in an off-duty incident over ten years ago where he drove at 62 mph in a 30 mph zone, refused to pull over for another officer, and avoided spike strips before stopping and laughing off the incident as a joke. An internal investigation found he violated the department's code of conduct for "Conduct Unbecoming an Employee." He accepted responsibility, waived hearings, and took a one-day unpaid suspension in a negotiated agreement with the Salem Police Department (SPD).Years later, following an audit, the New Hampshire Department of Justice (DOJ) requested the internal investigation report and added the plaintiff's name to the Exculpatory Evidence Schedule (EES). The plaintiff requested removal, citing a court order that his personnel file did not contain Brady/Giglio material. The DOJ denied the request, and the plaintiff filed a complaint in superior court seeking declaratory judgment and injunctive relief. The Superior Court dismissed the complaint, ruling that the plaintiff's conduct was "potentially exculpatory evidence" under RSA 105:13-d, and that he had received adequate due process.The Supreme Court of New Hampshire reviewed the case and concluded that the plaintiff's conduct was not "potentially exculpatory evidence" as it was not relevant to his general credibility and was stale. The court noted that the conduct was over ten years old, the plaintiff had accepted responsibility, and his criminal charges were nolle prossed and annulled. The court reversed the trial court's order and remanded for further proceedings, holding that the plaintiff's removal from the EES was warranted. View "Doe v. Salem Police Department" on Justia Law

Steve Winder became suicidal after discovering Facebook messages between his wife and her ex-husband. His wife, Latrisha, who was out of state, called her mother, Lou Anne, and the Young County Sheriff’s Department for a welfare check after Steve sent pictures of himself holding a gun to his head. Deputy Joshua Gallardo arrived at the scene, and after hearing Steve shout from within, opened the front door. Lou Anne indicated that Steve was armed. Deputy Gallardo then fatally shot Steve after ordering him to put the gun down.The United States District Court for the Northern District of Texas dismissed the case at the 12(b)(6) stage. The court found that Steve’s suicidality and possession of a gun created exigent circumstances excusing the need for a warrant. It also ruled that an objectively reasonable officer in Deputy Gallardo’s position would not need to wait for Steve to point the gun at him before using deadly force, thus defeating the excessive force claim. Additionally, the court found no underlying constitutional violation to support claims for supervisory or Monell liability and ruled that Title II of the ADA does not support claims where police officers face exigent circumstances.The United States Court of Appeals for the Fifth Circuit affirmed the District Court’s dismissal. The appellate court held that the exigent circumstances justified the warrantless entry and that Deputy Gallardo’s use of deadly force was reasonable under the circumstances. The court also found no basis for supervisory or Monell liability due to the absence of an underlying constitutional violation. Lastly, the court ruled that the ADA claims were foreclosed by the exigent circumstances and that there was no evidence that Steve was discriminated against by reason of his disability. View "Winder v. Gallardo" on Justia Law

The Tuscaloosa City Council passed an ordinance limiting the maximum occupancy of certain restaurants, affecting a sports bar owned by CMB Holdings Group. The ordinance required establishments with restaurant liquor licenses to maintain occupancy limits based on their configuration as restaurants, not as bars or entertainment venues. This change reduced the sports bar's maximum occupancy from 519 to 287, negatively impacting its revenue. CMB Holdings Group sued the City of Tuscaloosa, the mayor, city council members, and the fire marshal, alleging racial discrimination and other claims.The Tuscaloosa Circuit Court dismissed most of CMB's claims, including those for money damages against the City and personal-capacity claims against the mayor and councilors due to legislative immunity. The court also dismissed claims for procedural and substantive due process, equal protection, and others, leaving only claims for declaratory and injunctive relief under the Alabama Constitution's Contracts Clause. CMB requested the court to alter or amend its judgment or certify it as final for appeal purposes. The court denied the request to alter or amend but granted the Rule 54(b) certification, allowing CMB to appeal the dismissed claims.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court found that the adjudicated and unadjudicated claims were closely intertwined, particularly regarding whether the ordinance affected vested rights or mere privileges and whether it served a legitimate public interest. The court concluded that separate adjudication could lead to inconsistent results and dismissed the appeal for lack of a final judgment. View "CMB Holdings Groupv. City of Tuscaloosa" on Justia Law

On the night of July 18, 2019, in Charlestown, Indiana, bystanders called 911 to report a fight between RJ Slaymaker and his wife, Amylyn Slaymaker. Two police officers responded, separated the couple, and learned from Amylyn that RJ was drunk, had hit her, had guns, and was threatening to kill her and himself. RJ denied the allegations. The officers called an ambulance for RJ to seek mental health help at a hospital but did not place him under a 24-hour mental health hold. RJ left the hospital shortly after arriving, returned home, and killed Amylyn before committing suicide.The administrator of Amylyn’s estate sued Officer Roederer and the estate of Officer Johnson, claiming they created a danger by misleading Amylyn into believing RJ would be held for 24 hours, thus making her believe it was safe to return home. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, concluding they were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s judgment regarding Officer Roederer, finding no evidence of his personal involvement in making assurances to Amylyn. However, the court reversed the judgment regarding Officer Johnson, finding that a jury could reasonably infer that he misled Amylyn about RJ’s detention, creating a danger she would not have otherwise faced. The court held that Officer Johnson’s actions could be seen as a violation of clearly established law under the state-created danger doctrine, as established in Monfils v. Taylor. The case against Officer Johnson’s estate was remanded for further proceedings. View "Rakes v. Roederer" on Justia Law

A senior trooper with the Louisiana State Police (LSP), August McKay, committed suicide at his home after learning he was being reassigned and that a search warrant was to be executed on his residence. His widow, Brandy McKay, sued several LSP officers under 42 U.S.C. § 1983 and Louisiana state law, alleging their actions contributed to his death. The district court denied qualified immunity to two officers, Sergeant Rohn Bordelon and Trooper David LaCroix, leading to this appeal.The United States District Court for the Eastern District of Louisiana initially dismissed Brandy’s Eighth Amendment claim but allowed her to amend her complaint. She then limited her claims to the Fourteenth Amendment and state laws. The district court found that Brandy had sufficiently stated § 1983 claims against Sgt. Bordelon and Trooper LaCroix, concluding they had subjective knowledge of August’s suicide risk and responded with deliberate indifference. The court dismissed the claims against other defendants and allowed the state law claims against Sgt. Bordelon and Trooper LaCroix to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the officers were entitled to qualified immunity because there was no constitutional duty to protect August from self-harm, as he was not in state custody or otherwise restrained. The court emphasized that the officers did not attempt to arrest or confine August, and Brandy’s complaint focused on their failure to restrain him. Without a constitutional duty, there could be no violation, and thus, the officers were entitled to qualified immunity. The court reversed the district court’s decision regarding qualified immunity and dismissed the appeal concerning the state law claims without prejudice, remanding the case for further proceedings. View "McKay v. LaCroix" on Justia Law

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law

Robert Turner, a property owner in Suwannee County, Florida, claimed that his homestead property was sold at an impermissibly low amount under Florida law, which deprived him of any surplus after back taxes and costs were deducted. Turner had a homestead exemption on his property, which was automatically renewed until 2015. After failing to pay property taxes, a tax certificate was issued, and a tax deed sale was conducted in 2015. Turner alleged that the sale was unlawful because it did not account for the homestead exemption, and he did not receive proper notice of the sale.Turner initially sought relief in state court, challenging the removal of his homestead exemption, but his complaint was dismissed as untimely. He then filed a federal lawsuit under 42 U.S.C. § 1983, claiming violations of his constitutional rights, including First Amendment retaliation, Fourth Amendment illegal seizure, and due process violations. The federal district court dismissed his complaint, finding that abstention was warranted under the comity doctrine, which prevents federal courts from interfering with state tax administration when state remedies are adequate.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The court affirmed the dismissal, holding that the relief Turner sought would disrupt Florida's administration of its ad valorem property tax scheme. The court found that Florida provided plain, adequate, and complete state remedies, including the ability to challenge tax deed sales and homestead exemption removals in state court. The court concluded that the district court did not abuse its discretion in abstaining from exercising jurisdiction under the comity doctrine. View "Turner v. Jordan" on Justia Law

Carl McDaniel, a Wisconsin prisoner with multiple serious medical conditions, sued the Wisconsin Department of Corrections under the ADA and the Rehabilitation Act, claiming the Department violated his rights by denying him a cell in a no-stairs unit, a single-occupancy cell, and a bed without a top bunk. He also brought an Eighth Amendment claim against Dr. Salam Syed, alleging deliberate indifference to his medical needs. The district court granted summary judgment for the Department on all claims and for Dr. Syed on the Eighth Amendment claim. McDaniel appealed.The United States District Court for the Eastern District of Wisconsin initially handled the case. McDaniel, representing himself, submitted evidence that he missed approximately 600 meals in one year due to the pain and difficulty of navigating stairs to access meals and medications. The district court, however, largely discounted McDaniel’s factual statements and granted summary judgment for the defendants, concluding that McDaniel’s cell assignment was reasonable and that his medical treatment did not violate the Eighth Amendment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the summary judgment for the Department on the claims for a single-occupancy cell and no top bunk, as well as the Eighth Amendment claim against Dr. Syed. However, it reversed the summary judgment on the refusal to assign McDaniel to a no-stairs unit. The court found that McDaniel presented sufficient evidence that the denial of a no-stairs unit effectively denied him access to meals and medications, which could be seen as an intentional violation of the ADA and the Rehabilitation Act. The court also held that McDaniel’s ADA and Rehabilitation Act claims for compensatory damages survived his release from prison and his death.The Seventh Circuit concluded that a reasonable jury could find that the denial of a no-stairs unit amounted to an intentional violation of McDaniel’s rights under the ADA and the Rehabilitation Act, and that the Department was not entitled to sovereign immunity. The case was remanded for further proceedings consistent with this opinion. View "McDaniel v. Syed" on Justia Law

Deari Cole was committed to a developmental center under California's Welfare and Institutions Code section 6500, which allows for the commitment of individuals with developmental disabilities who pose a danger to themselves or others. Near the end of his commitment period, a petition to extend his commitment was filed, but it was too late for a trial to occur before the original commitment expired. Cole was held pending trial and subsequently filed a petition for writ of mandate or habeas corpus, arguing that equal protection principles required his release pending trial.The Contra Costa County Superior Court initially found Cole incompetent to stand trial on charges including felony possession of a firearm and second-degree burglary. He was committed to the Porterville Developmental Center for one year. Two days before this commitment was set to expire, the People filed a petition to extend it, and the court ordered Cole held pending trial on the recommitment petition. Cole's petition for writ of mandate and/or habeas corpus was summarily denied by the Court of Appeal, but the California Supreme Court directed the appellate court to issue an order to show cause.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and rejected Cole's equal protection argument. The court held that the statutory scheme under section 6500, which allows for continued confinement pending a hearing on a recommitment petition, did not violate equal protection principles. The court reasoned that the differences between individuals with developmental disabilities and those with mental health disorders justified the disparate treatment. The court concluded that the legislative distinctions were reasonable and factually based, and thus, Cole's continued confinement pending trial was constitutionally permissible. The petition was ultimately dismissed as moot. View "Cole v. Super. Ct." on Justia Law