Justia Civil Rights Opinion Summaries

Fitzgerald had not eaten all day, had not slept in three day, and drank some wine. Feeling “down,” Fitzgerald attempted to call a hospital help line, but instead dialed a police non-emergency number. She proceeded to talk to the desk officer. Though Fitzgerald denied suicidal thought or intention, the desk officer described a “very depressed,” possibly suicidal, intoxicated female caller. As officers approached the building, Fitzgerald abruptly hung up on the desk officer. This information was relayed to the officers. Upon entering the apartment, officers and paramedics found Fitzgerald unsteady on her feet and slurring her words. For 30 minutes, they talked to her. She denied wanting to harm herself, but admitted being upset and told them that she had been taking anti-depressants. They, along with Fitzgerald, unsuccessfully attempted to contact Fitzgerald’s friends. The decision was made to take Fitzgerald to the hospital. Fitzgerald would not go voluntarily. She screamed and physically resisted. Eventually, the officers and paramedics lifted Fitzgerald onto the stretcher and handcuffed her right hand to the stretcher. She continued to resist, eventually breaking bones in her wrist. Surgical repair was necessary. The district court dismissed her 42 U.S.C. 1983 claims. The Seventh Circuit affirmed. View "Fitzgerald v. Santoro" on Justia Law

The City of Rapid City applied a deicer to the streets adjacent to property owned by the Ruperts. The Ruperts sued the City, claiming that the deicer ran onto their property and destroyed several pine trees. The trial court granted the Ruperts' motion for summary judgment on their inverse condemnation claim, and a jury awarded the Ruperts $126,530 to compensate them for the damage to their property. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court did not err in granting summary judgment in favor of the Ruperts on their inverse condemnation claim, but the measure of damages used at trial for purposes of calculating the just compensation award was erroneous; (2) the trial court properly denied the Ruperts' request for attorney fees; and (3) the trial court's grant of summary judgment in favor of the City on the Ruperts' claims of negligence and trespass did not constitute reversible error. Remanded for a new trial on damages. View "Rupert v. City of Rapid City" on Justia Law

Devbrow entered the Indiana prison system in 2000. During intake, he told the medical staff that he had prostate problems and would need to be tested for prostate cancer within two to four years. In 2004 a test revealed an elevated PSA, but the medical staff did not order a prostate biopsy for more than a year. In a biopsy six months later, Devbrow was diagnosed with prostate cancer that had spread to his spine; treatment options were severely limited. Devbrow sued prison doctors and a nurse practitioner under 42 U.S.C. 1983 for deliberate indifference to serious medical needs in violation of the Eighth Amendment. The district court entered judgment for the defendants based on the two-year statute of limitations, construing the claim as a constitutional violation that in April 2005 when the biopsy was ordered. The Seventh Circuit reversed. The statute of limitations for a section 1983 deliberate-indifference claim does not begin to run until the plaintiff knows of his injury and its cause. Devbrow did not know of his injury when the defendants ordered a biopsy; he discovered it six months later when he learned he had cancer that might have been diagnosed and treated earlier. View "Devbrow v. Kalu" on Justia Law

In 1989, Appellant was tried and convicted of murder in a Massachusetts state court. After serving fourteen years of his sentence, Appellant moved for a new trial on the ground that exculpatory evidence had been withheld by several Boston police officers involved in his prosecution, including Timothy Callahan, a police detective. Appellant's motion was granted and he was released from prison in 2003. After his release, Appellant filed a civil action in federal district court against Callahan, a Boston police commissioner, two police officers, and the City of Boston, alleging that his constitutional due process rights were violated by the withholding of material exculpatory evidence during his criminal trial. After a jury deadlocked on the issue of whether Callahan's failure to disclose evidence caused Appellant's conviction, a retrial was held. The retrial jury determined in 2009 that Callahan had withheld evidence and determined that his actions caused Appellant's conviction. Appellant was awarded damages of $14 million. The First Circuit Court of Appeals remanded the case to the district court for a new trial, holding that Callahan was entitled to a new trial because the district court judge erred in instructing the retrial jury on causation. View "Drumgold v. Callahan" on Justia Law

Stoudemire, then age 23, entered the Michigan Department of Corrections system in 2002, suffering from systemic lupus erythematosus, a chronic, painful autoimmune disease; hypercoagulapathy, a related disorder involving tendency to develop blood clots; and depression. Stoudemire bore a significant risk of experiencing kidney and liver damage, heart attacks, amputations, and chronic pain. Stoudemire’s health quickly deteriorated. She experienced a heart attack, liver failure, and life-threatening embolisms. She underwent three amputations, losing both legs below the knee. At her 2007 parole, she suffered from chronic depression, posttraumatic stress disorder, and conditions related to medications. In her suit under 42 U.S.C. 1983, the Americans with Disabilities Act, 42 U.S.C. 12132; and Michigan law, Stoudemire, alleged that she was placed in a segregation unit following her amputation that lacked accommodations for disabled persons, and was subjected to a strip search that served no legitimate purpose. The district court denied motions by the warden and an officer, seeking summary judgment on qualified immunity grounds. The Sixth Circuit vacated with respect to the warden, stating that the court did not adequately analyze deliberate indifference, but affirmed with respect to the officer, stating that the excessively invasive nature of the search outweighed any need to conduct it. View "Stoudemire v. MI Dep't of Corrs." on Justia Law

MCR, LLC filed an action for condemnation of a compressor station site on property owned by Appellees. Appellees counterclaimed against MCR for damage to their property and claimed punitive damages. Appellees sought restoration costs as the measure of damages for their contract, trespass, and nuisance claims. The parties stipulated to the substitution of MCR Transmission, LLC (MCR-T) for MCR on the condemnation claim. The district court dismissed MCR-T's condemnation claim and granted Appellees' summary judgment motion allowing Appellees to seek restoration costs. The jury awarded restoration costs and punitive damages to Appellees. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) erred in dismissing MCR-T's motion to condemn Appellees' property for a compressor station, as genuine issues of material fact existed as to whether Appellees' property was necessary for the compressor station; (2) properly determined that Appellees were entitled to seek restoration costs as the measure of their damages; and (3) properly admitted evidence at trial that MCR had jumped Appellees' bid on state trust land leases. View "McEwen v. MCR, LLC" on Justia Law

Plaintiff (ex-wife) and her parents sought damages for intentional infliction of emotional distress. Defendant is a psychiatrist who was court-appointed to make recommendations in connection with plaintiff’s custody dispute with her ex-husband, following the 1998 entry of a marriage dissolution judgment. Plaintiff initially requested the evaluation, but was unhappy with the results. Defendant reported that plaintiff and her parents were delusional and that the children should be removed from their mother’s custody and have no further contact with her. A change of custody was granted. The Department of Children and Family Services later made a finding of abuse and neglect against the plaintiff. Plaintiff accused defendant of making false statements and a false evaluation. The trial court dismissed on the basis of res judicata; the appellate court affirmed. The Illinois Supreme Court affirmed, based on a separate civil rights class action that plaintiff had filed earlier in federal court against defendant and others for their role in custody proceedings. That action was dismissed for the immunity of such evaluators, and that dismissal was affirmed on appeal.View "Cooney v. Rossiter" on Justia Law

School administrators approved a seventh grade field trip to Mauthe Lake. Students were not required to attend. The school district forbids swimming on field trips unless a lifeguard is present. The administrator, present at the lake, knew that there was no lifeguard and that there were places in the swimming area where water would be over the children’s heads. Several students entered the lake at the beach. The chaperone told the children not to go deeper than their chests, Kamonie, with others, walked until the water reached his chest, and was pulled down to water over his head. He drowned inside the designated swimming area. His parents sued (42 U.S.C. 1983), claiming that the defendants deprived Kamonie of his life in violation of the due process clause. The district judge dismissed. The Seventh Circuit affirmed. A state does not deprive a person of his life in violation of the Fourteenth Amendment by failing to prevent death, but only if the death was caused by the reckless act by a state employee acting within the scope of employment. Negligence enhanced the risk to Kamonie, but negligence is not enticement, or deliberate indifference, or blindness to obvious dangers. The parents may have state law claims, but damages would be capped at $150,000. View "Slade v. Bd. of Sch. Dirs.of the City of Milwaukee" on Justia Law

Mike Alexander was one of two former employees of Bozeman Motors who filed suit against Bozeman Motors and its president and managers, alleging negligence, battery, and negligent or intentional infliction of emotional distress. Plaintiffs claimed long-term physical and emotional injuries resulting from exposure to carbon monoxide and propane. Alexander died after filing suit. Bozeman Motors moved for summary judgment on the basis that the claims against it were barred by the exclusive remedy provision of Montana's Workers' Compensation Act. The district court granted Bozeman Motors' motion, holding that the conduct of Defendants did not rise to the level of deliberate intent to cause specific harm, and that Mont. Code Ann. 39-71-413, which provides an exception to the exclusive remedy provision of the Act, was constitutional. The Supreme Court reversed and remanded with respect to Alexander's claims. On remand, the jury returned a verdict for Defendants on all claims. The Supreme Court affirmed, holding (1) section 39-71-413(2) does not create an impermissible class of employees in violation of equal protection; (2) the district court did not err in instructing the jury; and (3) the court did not err in denying Plaintiffs' motion to exclude Alexander's cause of death. View "Alexander v. Bozeman Motors, Inc." on Justia Law

Plaintiff filed an action in district court under 42 U.S.C. 1983, alleging that her Fourth Amendment rights had been violated by an officer's warrantless entry into her front yard and sought damages for her injuries. Plaintiff sustained serious injuries as a result of the officer's act of kicking down the front gate of her yard while in pursuit of a suspect who had committed at most a misdemeanor offense. The district court found that the officer was entitled to qualified immunity and granted his motion for summary judgment. The court held, however, that the law at the time of the incident would have placed a reasonable officer on notice that his warrantless entry into the curtilage of a home constituted an unconstitutional search, which could not be excused under the exigency or emergency exception to the warrant requirement. Therefore, the officer was not entitled to qualified immunity and the court reversed the judgment of the district court. View "Sims v. Stanton" on Justia Law