Justia Civil Rights Opinion Summaries

The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case involves a dispute between Christopher Sullivan, the respondent, and several police officers and cities, the petitioners. Sullivan filed a complaint against the petitioners following a confrontation with the police officers that led to his arrest on various charges. Sullivan asserted twenty-three state law causes of action against the petitioners. In response, the petitioners filed motions to dismiss Sullivan's complaint, alleging varying theories of immunity. The Circuit Court of Jefferson County partially granted the petitioners' motions to dismiss. The court determined that the police officers were not entitled to "qualified immunity" and that the cities and their respective police departments and police chiefs were entitled to "qualified immunity" from Sullivan's negligence claims. The court also determined that Sullivan was entitled to allege claims of negligence and intentional torts from the same facts.The petitioners appealed the Circuit Court's decision to the Supreme Court of Appeals of West Virginia. The Supreme Court found that the Circuit Court erred by basing its immunity decisions on common law qualified immunity principles, which are only applicable to the State, its agencies, officials, and employees, rather than applying the provisions of the West Virginia Governmental Tort Claims and Insurance Reform Act, which govern immunity for the claims asserted against the petitioners as they are undisputedly political subdivisions and employees of political subdivisions. The Supreme Court reversed the Circuit Court's decision and remanded the case for further proceedings. View "Kent v. Sullivan" on Justia Law

The case involves Dr. Adam Lowther and his wife, Jessica Lowther, who sued various state officials on behalf of themselves and their children, alleging constitutional claims under 42 U.S.C. § 1983 and state law claims under the New Mexico Tort Claims Act. The claims arose from the warrantless entry into their home, the arrest of Dr. Lowther, and the removal of their children by officials from New Mexico’s Children, Youth, and Family Department (CYFD) and the Bernalillo County Sheriff’s Department (BCSD). The actions of the officials were based on an anonymous report alleging that Dr. Lowther was sexually abusing his four-year-old daughter.The United States District Court for the District of New Mexico granted summary judgment in favor of the defendants, concluding that they were entitled to qualified immunity on the § 1983 claims and that the state law claims failed for similar reasons. The Lowthers appealed the decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the officials had reasonable suspicion that the children had been abused and were in imminent danger, which justified the warrantless entry into the Lowthers' home and the removal of the children. The court also held that the officials had probable cause to arrest Dr. Lowther. Therefore, the officials were entitled to qualified immunity, and the Lowthers' claims were dismissed. View "Lowther v. Children Youth and Family Department" on Justia Law

Dr. Jennifer Seed, a former employee of the Environmental Protection Agency (EPA), filed a lawsuit against the EPA and the United States, alleging age discrimination. Seed claimed that she was involuntarily demoted to a junior position as older managers were replaced with younger employees. The district court granted summary judgment in favor of the EPA, concluding that Seed had not provided sufficient evidence to support her claim of age discrimination.The district court's decision was based on its finding that Seed had not provided direct evidence of discriminatory intent that would entitle her to a trial, nor had she provided indirect evidence that would give rise to an inference of discrimination. The court also found that Seed had not shown that she was treated less favorably than younger employees after her reassignment or that her treatment was based on her age.On appeal, the United States Court of Appeals for the District of Columbia Circuit dismissed Seed's appeal, ruling that the court lacked jurisdiction to address the merits of her reassignment claims because she lacked standing under Article III of the United States Constitution. The court found that Seed had not demonstrated that a favorable court decision would likely redress her claimed injuries. The court therefore remanded the case to the district court with instructions to vacate the grant of summary judgment and to dismiss the reassignment claim for lack of standing. View "Seed v. EPA" on Justia Law

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

Paul Montemuro was elected as the President of the Jim Thorpe Area School Board. However, a week later, the Board elected someone else without giving Montemuro any prior notice. Montemuro sued the Board members who voted against him and the Jim Thorpe Area School District, alleging that they had deprived him of his property without due process, in violation of 42 U.S.C. § 1983 and the Fourteenth Amendment. The defendants claimed qualified immunity.The District Court held that Montemuro had a clearly established property right in his employment and had been deprived of that right without due process. The defendants appealed this decision, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court found that Pennsylvania law clearly established that Montemuro had a property interest in his job as the Board President. The Court also accepted Montemuro's allegation that he was removed from office without notice. Therefore, the Court concluded that the defendants were not entitled to qualified immunity because they had violated Montemuro's clearly established right to due process. View "Montemuro v. Jim Thorpe Area School District" on Justia Law

The case revolves around John Sabo, who was sentenced to a probation term that exceeded the maximum limit set by Wisconsin law. After his probation should have ended, he was imprisoned for violating its conditions. Sabo sued two groups of defendants under 42 U.S.C. § 1983: Sheri Hicks and Debra Haley, officials from the Wisconsin Department of Corrections who failed to correct his unlawful probation term, and Megan Erickson and Barb Hanson, the probation officers who enforced it. Sabo alleged that all four defendants violated his right of due process and showed deliberate indifference to his unjustified imprisonment.The district court dismissed all claims against Hicks and Haley, and most against Erickson and Hanson, before entering summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. Sabo appealed the dismissal of his claims against Hicks and Haley.The United States Court of Appeals for the Seventh Circuit found that Sabo's complaint stated claims of deliberate indifference against Hicks and Haley. The court held that assuming all facts and inferences in Sabo’s favor, the record did not compel a finding of qualified immunity for Hicks and Haley. Therefore, the court vacated the district court’s dismissal of those claims. However, the court affirmed the district court's decision in all other respects, including the summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. View "Sabo v. Erickson" on Justia Law

The case revolves around an incident where Colorado Springs Police Officers Robert McCafferty and Christopher Pryor responded to a 911-call placed by Sasha Cronick reporting a drug overdose. During the incident, Officer Pryor questioned Cronick, which escalated into an argument, leading to her arrest for failure to desist and disperse in violation of Colorado Springs Code § 9.2.103. Cronick filed a claim under 42 U.S.C. § 1983, alleging the officers violated her constitutional rights. The officers asserted qualified immunity, but the district court denied their claim.The district court found several disputes of fact, including whether Officer Pryor issued an order for Cronick to leave the scene, whether Cronick was obstructing the scene, and whether Officer Pryor grabbed Cronick's arm to escort her away or after she had already turned to walk away. The court concluded that these disputes prevented it from finding that the officers had probable cause to arrest Cronick.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court concluded that a reasonable officer under these circumstances would not have arguable probable cause to arrest Cronick for failure to desist or disperse. The court also found that the officers did not have probable cause to conduct a search incident to arrest. The officers failed to articulate specific facts that led them to believe Cronick posed a threat and offered nothing beyond conclusory references to safety. Therefore, the officers were not entitled to qualified immunity because they violated Cronick's clearly established constitutional rights. View "Cronick v. Pryor" on Justia Law