Justia Civil Rights Opinion Summaries

Plaintiffs sued the City of Columbus after raw sewage that Plaintiffs claimed was the result of a malfunction of the City-run sanitary sewage system flooded into Plaintiffs' home. The district court found in favor of the City on all theories of recovery, including inverse condemnation, negligence, nuisance, and trespass. Plaintiffs appealed the district court's rulings with respect to negligence and inverse condemnation. The court of appeals affirmed the district court with respect to negligence but reversed the court's finding in the City's favor with regard to inverse condemnation. The Supreme Court granted review of inverse condemnation issues and reversed, holding that Plaintiffs did not establish an inverse condemnation claim because Plaintiffs failed to show the City exercised its right of eminent domain. Remanded. View "Henderson v. City of Columbus" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Alexander Gardner sued the City of Jackson, alleging that he had suffered a broken leg when one of the City's police officers forced him to sit down while in handcuffs. The City filed for summary judgment, which was denied by the trial court. On review of the City's interlocutory appeal, the Supreme Court reversed the trial court's denial of summary judgment, finding that the officer's conduct did not rise to the level of reckless disregard for Gardner's safety and well-being. View "City of Jackson v. Gardner" on Justia Law

Appellants were defrauded by an individual on parole from a Utah prison. Appellants filed a complaint alleging causes of action against the State for negligent supervision, gross negligence, failure to warn, and negligent misrepresentation. Under the Governmental Immunity Act, the State is immune from a suit where the injury arises out of deceit. The district court dismissed the case based on the State's governmental immunity, finding that Appellants' injury was the result of a third-party's deceit. The Supreme Court affirmed, holding (1) the State was immune under the Utah Governmental Immunity Act's deceit exception; and (2) the dismissal of Appellants' complaint on the basis of governmental immunity was timely. View "Van De Grift v. State" on Justia Law

In 1994, Plaintiff granted a drainage easement to Pennington County on land he owned. In 1996, silt began to accumulate near the bottom of the canyon on part of Plaintiff's land due to the County's repair of a section of road abutting Plaintiff's land. In 2010, Plaintiff filed suit against the County for nuisance, constructive taking, trespass, and unlawful taking. The trial court granted summary judgment for the County, determining that there was no continuing tort and that the statute of limitations had run. The Supreme Court affirmed, holding that the trial court did not err in granting summary judgment for the County, as the County's actions did not constitute a continuing tort, and thus, Plaintiff's action was untimely filed. View "Brandt v. County of Pennington" on Justia Law

Plaintiff-Appellant David Becker was pulled over by Defendant-Appellee Officer Jason Bateman in a parking lot in Heber City, Utah. A confrontation ensued which ended in Plaintiff being thrown to the ground and suffering a severe traumatic brain injury. Plaintiff brought suit against Officer Bateman, the Heber City Chief of Police in his official capacity, and Heber City under 42 U.S.C. 1983, alleging Officer Bateman used excessive force in violation of the Fourth Amendment. He also asserted a claim for loss of consortium. The district court granted the defendants' motion for summary judgment, concluding Officer Bateman did not violate Plaintiff's constitutional rights. Because the violation of constitutional rights Plaintiff asserted was not clearly established at the time of the violation, the Tenth Circuit affirmed the district court’s grant of summary judgment to Officer Bateman. However, the district court erred in concluding there were no genuine issues of material fact as to whether a constitutional violation occurred. The grant of summary judgment in favor of the City was therefore reversed. On remand, the district court must determine whether Plaintiff can withstand summary judgment as to the second element of his municipal liability claim. Similarly, the district court must determine whether Mrs. Becker could maintain a cause of action for loss of consortium against the City in light of the Court's ruling that a reasonable jury could conclude Plaintiff's constitutional rights were violated. View "Becker v. Bateman" on Justia Law

Quigley was 23 years old, with no known life-threatening physical conditions when he was transferred from one Michigan Department of Corrections (MDOC) facility to an MDOC guidance center, where he was under the care of CMS, a service provider with which MDOC contracted. CMS employees Dr. Thai and physician’s assistant Garver treated Quigley for moderate depression and prescribed medications. After about a month, Quigley was found dead in his cell. The medication chart confirmed that Quigley had been administered both Amitriptyline and Trazodone the previous three days. The autopsy report concluded that Quigley died of an epileptic seizure disorder. Quigley’s estate obtained affidavits from a forensic pathologist, who concluded that Quigley likely died from a fatal drug interaction between the tricyclic Amitriptyline and tetracyclic Trazodone and from a psychiatrist, who similarly concluded that the fatal drug interaction likely killed Quigley. Thai provided three medical-expert affidavits, all concluding that the best explanation for Quigley’s death is epileptic seizure. Quigley’s estate sued Thai, Garver, and CMS under 42 U.S.C. 1983. The district court denied a motion asserting qualified immunity. The Sixth Circuit affirmed, finding that there were unresolved material questions of fact concerning the cause of death. View "Quigley v. Thai" on Justia Law

The United States District Court for the Eastern District of Oklahoma certified questions of Oklahoma Law to the Supreme Court: (1) does the Okla. Const. art. 2, section 30 provide a private cause of action for excessive force, notwithstanding the limitations of the Oklahoma Governmental Tort Claims Act?; (2) if such a right exists, is the cause of action recognized retrospectively? and (3) are the standards of municipal liability coterminous with a Federal section 1983 action or does the common law theory of respondeat superior apply to such action? The questions in this case arose from an altercation at the Cherokee County Detention Center (a facility operated by the Cherokee County Governmental Building Authority) whereby plaintiff Daniel Bosh was attacked while he was standing at the booking desk of the Detention Center with his hands secured in restraints behind his back. Video surveillance of the events captured images of one of the jailers, defendant Gordon Chronister, Jr., approaching the plaintiff and grabbing him behind his back. Plaintiff was seriously injured as a result of the altercation. Plaintiff filed a lawsuit in state court against the Authority, the assistant jail administrator and the jailers who initiated the attack. He asserted federal Civil Rights claims against the individuals and state law claims against the Authority. The Authority removed the case to the United States District Court then filed a motion to dismiss the state tort claims based on exemptions from liability provided by Oklahoma Governmental Tort Claims Act (the OGTCA). Upon review, the Supreme Court answered the questions: (1) the Okla. Const. art 2, section 30 provides a private cause of action for excessive force, notwithstanding the limitations of the Oklahoma Governmental Tort Claims Act; (2) the action is recognized retrospectively; and (3) the common law theory of respondeat superior applies to municipal liability under such an action. View "Bosh v. Cherokee County Bldg. Authority." on Justia Law

Since 2006 Ray has experienced pain in his shoulder. He contends that the pain stems from an injury and that an MRI scan would point the way toward successful treatment; Shah, Ray’s treating physician at the correctional center, believes that the pain stems from arthritis and that a scan would not help in diagnosis and treatment. The district court rejected Ray’s suit under 42 U.S.C.1983. The Seventh Circuit affirmed, noting that Ray has been examined often, x-rays have been taken, and physicians have prescribed painkillers; staff also has arranged for Ray to be assigned a lower bunk. Because Ray’s claim fails the objective component of cruel-and-unusual-punishments analysis, his contention that Dr. Shah displayed subjective antipathy is irrelevant. View "Ray v. Wexford Health Sources, Inc." on Justia Law