Justia Civil Rights Opinion Summaries

Plaintiffs, the husband and uncle of decedent, filed suit against defendants alleging state law tort claims and violations of decedent's federal constitutional rights. The court held that the district court properly dismissed plaintiffs' malpractice claim for failure to comply with Minnesota Statutes section 145.682 and that the magistrate judge did not abuse her discretion in denying plaintiffs' motion to extend deadlines to serve expert affidavits. The court also held that the district court properly dismissed plaintiffs' Federal Tort Claims Act (FTCA), 28 U.S.C. 2401(b), claim for lack of jurisdiction and that plaintiffs have not alleged error in the district court's determinations in regards to the dismissal of their 42 U.S.C. 1983 cause of action. The court affirmed the district court's order dismissing the Bivens action against Federal defendants and affirmed the district court's dismissal of the equal protection claim. Finally, the court rejected challenges to discovery and pretrial rulings.

Plaintiffs brought this action against defendants, social service employees, alleging that they violated 42 U.S.C. 1983 and state law by recommending that custody of their son be granted to his grandparents. According to plaintiffs, this recommendation resulted in the untimely death of their son. The court affirmed the district court's grant of summary judgment to the state employees after concluding that they were entitled to qualified immunity on the federal claims and official immunity on the state claims.

This appeal arose from a circuit court's dismissal of Brandon Johnson's action against Gary Hetzel, warden of the Donaldson Correctional Facility; Sean Carlton, a correctional officer trainee at the facility; and correctional officers Dennis Johnson and Joe Binder. Johnson was serving a life sentence without the possibility of parole following a conviction for murder. He was seen fighting with another inmate and placed under "house arrest" pending a disciplinary hearing. Johnson argued that the defendants "deliberately plac[ed] him in 'house arrest' two cells from [another inmate with whom he had the fight], and [that] the defendants were responsible for the protection of both inmates, but instead opened the door to both cells at which time [Johnson] and [the other inmate] got into another fight," in which, Johnson argued, he was injured. Johnson filed an affidavit of substantial hardship, requesting that the initial docket fee for his case be waived. Defendants filed a motion to dismiss the complaint or, in the alternative, for a summary judgment. The circuit court granted the defendants' motion and dismissed Johnson's complaint. Johnson has appealed the circuit court's judgment of dismissal, arguing, in pertinent part, that the circuit court never had jurisdiction over his case because he did not pay the necessary filing fee and the circuit court never approved either of the affidavits of substantial hardship he had filed. Upon review, the Supreme Court concluded that the filing of a court-approved verified statement of substantial hardship was not met in this case. Therefore, the circuit court did not have jurisdiction to enter its judgment dismissing Johnson's complaint. The Court ruled the circuit court's judgment void. "[B]ecause a void judgment will not support an appeal," the Court vacated the trial court's judgment and dismissed the appeal.

VLiranzo was born in 1955 in the Dominican Republic. He entered the U.S. as a lawful permanent resident in 1965; in 1972 his mother became a naturalized citizen and he obtained derivative citizenship, 8 U.S.C. 1432(a)(3) Liranzo did not know he had become a citizen and continued to renew his "green card" through 2006.In 2006 Liranzo was released from incarceration in New York for possession of a controlled substance. Before his release, U.S. Immigration and Customs Enforcement erroneously identified him as a permanent resident alien, subject to removal. He was transported to a detention center in Louisiana pending removal. During removal proceedings, it was discovered that Liranzo is a U.S. citizen, and he was released. He filed suit under the Federal Tort Claims Act, alleging that federal immigration officials had falsely arrested and imprisoned him. Following two years of discovery, the district court dismissed for lack of subject matter jurisdiction because there was no private analogue to the immigration detention suffered by plaintiff. The Second Circuit affirmed dismissal of a Fourth Amendment claim, but held that the court had jurisdiction over the FTCA claim, because there is a private analogue: false imprisonment.

Guzman, seven-and-a-half months pregnant, home alone, in bed, heard the doorbell and knocking. She walked toward the door. Sergeant Bonnstetter of the Chicago Police Department burst through the door. Officers wearing body armor rushed in, many with guns drawn. Guzman, fearful and crying, was ordered to lie face down on the floor. When she tried to position herself more comfortably, Rojas forced her down, pressing her pregnant belly against the floor. The Joint Gang Task Force executed a warrant, searching the apartment for about an hour. Guzman sued. The district court entered summary judgment in her favor, finding Bonnstetter and Rojas liable. At a damages-only trial, Guzman proved medical expenses. The court allowed defendants to testify that the search was legal and reasonable and that others might have caused Guzman’s injuries. The court instructed the jury that Guzman had to prove that Bonnstetter and Rojas were “personally involved” and could not be held “liable” for the conduct of “other employees.” The court instructed the jury to award nominal damages if Guzman failed to prove that her damages were the direct result of defendants’ conduct. Guzman was awarded $1. The Seventh Circuit reversed. Defendants’ theory of the case and evidence and the instruction likely confused the jury.

A former inmate sued under the Rehabilitation Act, 29 U.S.C.794–94e, the Americans with Disabilities Act, 42 U.S.C. 12111–213, and the Eighth Amendment, claiming that prison officials ignored his need for placement in an ADA-compliant facility, and refused to consider him for a work-release program solely because he walks with a cane. Imprisoned for driving on a suspended license, the inmate had advanced osteoarthritis and vascular necrosis in his hip. The prison declined his request for installation of grab bars or for a transfer. The district court screened the complaint before service and dismissed. The Seventh Circuit vacated. While the court correctly dismissed the Eighth Amendment count, the inmate adequately alleged that refusal to accommodate his disability kept him from accessing meals and showers on the same basis as other inmates.

Appellant Timothy Daniels appealed a superior court's grant of summary judgment in favor of Defendants Narraguagus Bay Health Care Facility and North Country Associates, Inc. Appellant contended that the court erred in concluding that Narraguagus and North Country were entitled to judgment as a matter of law on his disability discrimination and retaliation claims made pursuant to Maine's Human Rights Act. Appellant suffered a work-related injury to his right shoulder in 2007 and thereafter was given work restrictions by his physician that prevented him from performing all of the work duties he had previously handled. In 2008, Appellant underwent surgery and then began a leave of absence. A few months later, Appellant notified his employer that he was applying for more leave at her insistence. In that letter, Appellant also reported that he had been cleared for light duty work, accused his supervisor of refusing to accommodate his disability, and asked for light duty work. No work was afforded to Appellant as a result of that letter. Appellant suffered another work-related injury to his right shoulder in 2009, and, although he did not lose any time from work as a result of that injury, he was restricted to modified duty for the next three months. During that period Appellant was disciplined for performance issues. Early in November 2009, when Daniels no longer had any work restrictions, a new Narraguagus administrator gave Appellant a performance improvement plan for failing to complete some tasks at all and failing to complete other tasks on time. In November, 2009, in response to the complaint that he filed in 2008, the Commission issued Appellant a right-to-sue letter pursuant to the Human Rights Act. When state regulators visited Narraguagus to conduct a licensing inspection, they uncovered issues that resulted in fines to the facility. Narraguagus blamed Appellant for the negative inspection and terminated his employment on January 29, 2010. After his termination, Appellant filed a two-count complaint against Narraguagus and North Country. On appeal, Appellant advanced two theories of liability against North Country: (1) that it can be liable because it is part of an integrated enterprise with Narraguagus, and (2) that it acted in Narraguagus’s interest in discriminating against him. Finding multiple issues of disputed facts regarding North Country's involvement in the actions that Appellant claimed constituted discrimination and retaliation, the Supreme Court vacated the grant of summary judgment in favor of Defendants, and remanded the case for further proceedings.

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit.

Petitioners Robert and Rickie Bansbach sought injunctive relief in connection with allegations that their neighbors, Respondents Daniel Harbin and Mary Fanok, were engaging in conduct which constituted both a nuisance and harassment. The trial court ruled that Petitioners had failed to demonstrate that Respondents' conduct constituted a private nuisance or that Respondents' speech, both verbal and written, was unlawful. The Supreme Court affirmed, holding that the trial court did not err in ruling (1) Respondents' storing of materials on the Fanok property did not create a nuisance that must be abated by the Court; (2) Respondents' posting of signs and shouting profanities at Petitioners did not amount to fighting words for First Amendment purposes; and (3) Respondents' behavior was not so outrageous that it required injunctive relief.

After Racheal Wilson, a new recruit for the Baltimore City Fire Department, tragically died during a "live burn" training exercise, her survivors and estate commenced this action under 42 U.S.C. 1983 against defendants, alleging that the fire department violated Wilson's substantive due process rights by staging the exercise with deliberate indifference to her safety, so as to shock the conscience. The court concluded that because the complaint did not purport to allege that the fire department staged the live burn training exercise with the purpose of causing harm to Wilson or to any other recruit, it fell short of alleging a substantive due process violation in the context of the facts alleged, even though it might well allege causes of action under state law, as the complaint purported to do in other counts.