Justia Civil Rights Opinion Summaries

In July 2018, Brian Lawler, a pretrial detainee, committed suicide at a county jail in Hardeman County, Tennessee. Lawler's father, Jerry Lawler, brought a lawsuit under 42 U.S.C. § 1983, alleging that the officers had been deliberately indifferent to the risk that Brian would commit suicide. The United States Court of Appeals for the Sixth Circuit held that the officers were entitled to qualified immunity because the laws in place at the time of the suicide did not clearly establish that the officers’ actions violated the Constitution. The court noted that in 2018, to hold officers liable for failing to prevent a pretrial detainee’s suicide, it was necessary to prove that the officers subjectively believed there was a strong likelihood the inmate would commit suicide. The evidence showed that the officers did not subjectively believe that Lawler was likely to take his life. Therefore, the court reversed the district court’s denial of qualified immunity to the officers. View "Lawler v. Hardeman County" on Justia Law

In a case heard before the United States Court of Appeals for the Sixth Circuit, plaintiff Jeffrey Hughes, an inmate in a Tennessee state prison, sued the Tennessee Board of Parole, alleging that the Board's refusal to move up his parole hearing date resulted in his overincarceration. Hughes believed that a recent change in state law entitled him to an earlier parole hearing. The Board refused his request, and he was paroled about three months after the date he believed he became eligible for release. The district court dismissed the case on the ground that the defendants, members of the Board, were absolutely immune from suit for their acts. Hughes then appealed.The Court of Appeals affirmed the district court’s decision, holding that the members of the Tennessee Board of Parole were entitled to absolute immunity from damages suits challenging its decision on when to hold a parole hearing. The court found that the Board's decision to schedule (or not to reschedule) a parole hearing was a judicial act, akin to a judge scheduling a court hearing. As such, the defendants were acting in a quasi-judicial capacity and were entitled to absolute immunity. The court also rejected Hughes's arguments of judicial estoppel and res judicata, stating that the defendants could not have raised their immunity defense in the previous state suit and thus were not barred from raising it in the present federal suit. View "Hughes v. Duncan" on Justia Law

This case involved a dispute over the rights of retired law enforcement officers to carry concealed firearms in New Jersey. The plaintiffs, three retired officers and two organizations, sued New Jersey officials, arguing that a federal statute, the Law Enforcement Officers Safety Act (LEOSA), gives them a federal right to carry a concealed firearm anywhere in the United States, including within New Jersey, and that LEOSA preempts any more burdensome state requirements. The state countered that the federal statute does not provide such an enforceable right, and even if it did, it would only apply to officers who retired from federal or out-of-state law enforcement agencies. The United States Court of Appeals for the Third Circuit held that LEOSA does provide certain retired officers with an enforceable right to carry concealed firearms, and that this right extends equally to officers who retired from New Jersey agencies and those who retired from federal or out-of-state agencies. The court concluded that LEOSA also preempts contrary aspects of New Jersey law. Therefore, the court affirmed the District Court’s order granting declaratory and injunctive relief to the retired officers. View "Federal Law Enforcement Officers Association v. Attorney General New Jersey" on Justia Law

This case involves a dispute over the interpretation of the federal Law Enforcement Officers Safety Act of 2004 (LEOSA), which allows certain qualified retired law enforcement officers to carry concealed firearms, and its relation to New Jersey’s more restrictive retired police officer permitting law. The retired law enforcement officers from various agencies claimed that LEOSA provided them with a federal right to carry concealed firearms in New Jersey, superseding the state law. The State of New Jersey argued that LEOSA did not provide an enforceable right and, if it did, it would only apply to officers who retired from federal or out-of-state law enforcement agencies—not to officers who retired from New Jersey law enforcement agencies.The United States Court of Appeals for the Third Circuit held that LEOSA does provide certain retired officers who meet all the statutory requirements with an enforceable right, and that right extends equally to officers who retired from New Jersey agencies and those who retired from federal or out-of-state agencies. The court held that the federal statute also preempts contrary aspects of New Jersey law. Therefore, the court affirmed the District Court’s order granting declaratory and injunctive relief to the retired officers, allowing them to carry concealed firearms. View "Federal Law Enforcement Officers Association v. Attorney General New Jersey" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered an appeal by several Missouri public officials who were denied qualified immunity by a lower court regarding five claims arising from a murder prosecution. The murder case, involving Donald Nash who was eventually convicted for the murder of Judy Spencer, was reopened in 2007, 25 years after the crime occurred. The officials based their case on a theory that DNA evidence found under Spencer's fingernails belonged to Nash, which they asserted could not have remained present if Spencer had washed her hair after their last encounter.Nash was convicted and spent 11 years in prison until the Missouri Supreme Court set aside his conviction in 2020. The charges were dismissed after DNA testing on the shoelace used to strangle Spencer supported Nash’s noninvolvement. Nash and his wife filed a lawsuit against the officials, claiming violations of rights including unlawful arrest and detention, fabrication of evidence, failure to investigate, violations of rights of access to courts, and violation of the right to familial and marital associations.The Eighth Circuit affirmed in part, reversed in part, and dismissed in part the appeals on the denial of qualified immunity. The court held that the officials were not entitled to qualified immunity on the claim of unlawful arrest and detention, finding that the omission of certain exculpatory facts from the probable cause affidavit negated probable cause for Nash's arrest. However, the court reversed the denial of qualified immunity for the claim alleging violation of the right to familial and marital associations, as this was not a clearly established constitutional right in 2008. The court dismissed the officials' appeal on the remaining claims due to lack of jurisdiction, as these involved genuine disputes of material fact to be resolved by a jury. View "Estate of Nash v. Folsom" on Justia Law

In a case heard by the United States Court of Appeals for the Eleventh Circuit, plaintiffs Jennifer Dupree and Detrich Battle challenged the dismissal of their Title V claims under the Americans with Disabilities Act (ADA) on the basis of sovereign immunity. Dupree, who worked for the Georgia Department of Human Services, and Battle, an employee of the Georgia Department of Corrections, had requested accommodations at their respective workplaces due to their health conditions. After their requests were denied and their employment terminated, they filed claims under Title V, alleging retaliation.The court, however, found that sovereign immunity applies to Title V claims when brought in conjunction with Title I claims. This meant that the plaintiffs' claims could not proceed. Importantly, the court clarified that dismissals based on sovereign immunity, a jurisdictional issue, should be entered without prejudice. Not specifying this in the dismissal could lead to misunderstandings about the nature of the dismissal. Therefore, the court vacated and remanded the case for the limited purpose of allowing the district court to dismiss the case without prejudice. View "Dupree v. Owens" on Justia Law

This case before the Indiana Supreme Court involved the intersection of a successful Section 1983 federal action and Indiana’s public-employee indemnification statute. The plaintiff, Kailee Leonard, hit and killed a dog belonging to a state conservation officer, Scott Johnson. In response, Officer Johnson pursued misdemeanor charges against Leonard for leaving the scene of the accident. Leonard was subsequently charged but never arrested, and the charges were later dropped at Officer Johnson's request. Leonard then filed a federal lawsuit against Officer Johnson, claiming false arrest. The jury found in Leonard's favor, awarding her $10,000 in damages and $52,462 in attorney’s fees and costs. Unable to pay the full amount, Officer Johnson assigned his indemnification rights against the State to Leonard and her attorney. Leonard subsequently sued the State for a declaratory judgment that the State had a duty to indemnify Officer Johnson and pay the judgment. The trial court found in Leonard's favor, but the State appealed, arguing that Officer Johnson's actions constituted a criminal act.The Indiana Supreme Court held that Leonard had shown that Officer Johnson’s conduct was noncriminal, and the State did not rebut that showing. The Court clarified that a party seeking indemnification under the Indiana public-employee indemnification statute must initially show that the loss occurred because of a noncriminal act or omission. The burden then shifts to the State to rebut that showing by producing evidence establishing a prima facie case of criminal conduct. In this case, Leonard met her burden of producing evidence that Officer Johnson’s conduct was noncriminal, and the State failed to establish a prima facie case that he had committed the crime of false informing. Therefore, the court affirmed the trial court's decision ordering the State to indemnify Officer Johnson and pay the federal judgment. View "State v. Smith" on Justia Law

In the case before the United States Court of Appeals for the Tenth Circuit, the plaintiff, Donald Ray Logsdon, Jr., alleged that Deputy United States Marshals used excessive force when executing a state-court warrant for Logsdon's arrest. The plaintiff relied on a precedent, Bivens v. Six Unknown Agents, which established a cause of action against federal agents for violations of the Bill of Rights. However, the district court dismissed Logsdon's case, holding that the Bivens claim was not applicable, and the plaintiff appealed.The Appeals Court affirmed the district court's judgment, holding that Logsdon had no claim under Bivens. The court found that there were two "special factors" that distinguished this case from Bivens and thus justified not recognizing a Bivens claim.Firstly, the court stated that agents of the United States Marshal Service (USMS) were a new category of defendant not considered by the Supreme Court in Bivens. The USMS is required by statute to partner with state and local law-enforcement authorities to create Fugitive Apprehension Task Forces. The court found that the potential chilling effect on such partnerships of recognizing Bivens liability for USMS officers was a special factor that suggested that Congress, not the courts, should create a remedy.Secondly, the court found that the availability of alternative remedies for misconduct by Deputy U.S. Marshals, including the internal USMS grievance procedure and the Department of Justice’s Office of the Inspector General (OIG) investigation procedure, was a special factor suggesting that the courts should not create a remedy. The court stated that the judiciary should not assess the adequacy of such remedies, indicating that this was the role of Congress or the Executive.The Appeals Court also rejected Logsdon's argument that the district court abused its discretion by granting the defendants' motion to reconsider its initial ruling that Logsdon had a Bivens claim. The court held that the district court had the discretion to reconsider any order short of a final decree. View "Logsdon v. United States Marshal Service" on Justia Law

In a case involving the Department of Child and Family Services of the County of Los Angeles and individual social workers, the Ninth Circuit Court of Appeals issued a mixed ruling. The case arose from the removal of two minor children from their parents' custody following an anonymous report that the parents were using medical marijuana to treat one child's severe autism. The court affirmed in part and reversed in part the district court’s judgment.The Circuit Court reversed the district court's summary judgment for the defendants on the parents' claim of judicial deception. The court concluded that the application submitted by the defendants in support of the warrant for removal contained misrepresentations and omissions and a reasonable trier of fact could find these misrepresentations material.The Circuit Court also reversed the district court's summary judgment for defendants on the parents' intentional infliction of emotional distress claim and their Monell claim, which argued that the county had an unofficial policy of encouraging social workers to omit exculpatory information from warrant applications.However, the Circuit Court affirmed the district court’s judgment on the Fourth Amendment claim concerning the social worker's interview of one child at her school, finding that the social worker was entitled to qualified immunity. The court also found no error in the district court's handling of a jury question during trial.The court remanded the case for further proceedings on the claims of judicial deception, intentional infliction of emotional distress, and the Monell claim.The case was remanded for further proceedings on these issues. View "SCANLON V. COUNTY OF LOS ANGELES" on Justia Law

A group of current and former inmates, or their representatives, filed a class action lawsuit against Kate Brown, the Governor of Oregon, and Patrick Allen, the Director of the Oregon Health Authority, claiming that the state's COVID-19 vaccine rollout plan, which prioritized corrections officers over inmates, violated their Eighth Amendment rights. The defendants moved to dismiss the claim, asserting immunity under the Public Readiness and Emergency Preparedness (PREP) Act. The district court denied the motion, and the defendants appealed.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision, finding that the defendants were immune from liability for the vaccine prioritization claim under the PREP Act. The court held that the statutory requirements for PREP Act immunity were met because the "administration" of a covered countermeasure includes prioritization of that countermeasure when its supply is limited. The court further concluded that the PREP Act's provisions extend immunity to persons who make policy-level decisions regarding the administration or use of covered countermeasures. The court also held that the PREP Act provides immunity from suit and liability for constitutional claims brought under 42 U.S.C. § 1983, even if those claims are federal constitutional claims. View "MANEY V. BROWN" on Justia Law