Justia Civil Rights Opinion Summaries

Plaintiff began experiencing severe headaches and swelling in his left eye in 2007 while incarcerated. Shortly after his release, plaintiff was diagnosed with Ewing’s Sarcoma, a serious form of bone cancer. According to plaintiff, surgery would have been sufficient to treat the disease had prison staff detected it earlier. However, due to the late diagnosis, chemotherapy and radiation are now necessary. In his suit under 42 U.S.C. 1983, the district court held that plaintiff pled sufficient facts upon which one could draw the inference that defendants violated the Eighth Amendment and committed medical malpractice. The doctor and nurse filed an interlocutory appeal, arguing that their involvement with plaintiff was minimal and cannot form the basis for a finding of deliberate indifference or gross negligence. The Sixth Circuit reversed, finding the defendants entitled to qualified immunity. Neither negligent medical care, nor delay in providing medical care, can rise to the level of a constitutional violation absent specific allegations of sufficiently harmful acts or omissions reflecting deliberate indifference.

Siblings of decedent, a 22-year-old inmate who committed suicide while incarcerated, sued under 42 U.S.C. 1983 alleging that staff members acted with deliberate indifference to his serious medical condition involving a long history of suicide attempts, self-harm, and mental illness. The district court granted qualified immunity to the management level defendants, the Wisconsin Resource Center defendants, and the nurse who was called after the suicide, but denied qualified immunity to staff members. The Seventh Circuit affirmed, noting the different levels of knowledge available to the defendants and that there is a clearly established right to be free from deliberate indifference to suicide

After Employee suffered a work-related injury and was terminated by Employer due to Employer's inability to accommodate his physical restrictions, Employee filed a worker's compensation claim for permanent and total disability. The Labor and Industry Review Commission (LIRC) determined that Employee was permanently and totally disabled as a result of his work injury. LIRC made this determination after denying Employer's last-minute request to cross-examine or make further inquires of Dr. Jerome Ebert, an independent physician appointed by the Department of Workforce Development to examine Schaefer and report on the cause of his disability. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Employer did not have a statutory right to cross-examine Dr. Ebert, (2) LIRC did not violate Employer's due process rights when it declined to remand for cross-examination, and (3) LIRC did not erroneously exercise its discretion by declining to remand for a third time to allow Dr. Ebert to be questioned further.

Training, simulating an arrest, took place at a police facility in San Juan without certified trainers. A requirement that weapons be emptied was not enforced and the highest-ranked officer gave the order that bulletproof jackets not be worn during the exercise. Loaded guns were present and the officer playing the suspect was shot and died. His family filed suit under 42 U.S.C. 1983. The trial court dismissed. The First Circuit reversed in part, first affirming dismissal of Fourth and Eighth Amendment claims. With respect to Fourteenth Amendment claims, plaintiffs adequately claimed that actions and inactions of the police and the use of a loaded firearm under the circumstances shock the conscience, and that defendants with supervisory responsibility were callously and recklessly deficient in the lack of any care for the safety of the officer. The mayor is not amenable to suit merely because he is mayor, nor may the municipality be sued, as pled, on a respondeat superior theory. Although the complaint alleges that there were insufficient regulations in place to govern the training exercise, it also describes several safety procedures that were intended to prevent exactly this type of accident.

Appellant Marla Ward filed suit seeking damages for personal injuries she sustained as she was sorting horses on Appellee Paul Johnson's property. Johnson resided in Pondera County. Johnson filed a motion to change venue, arguing that Pondera County was the appropriate place for trial because it was the only county where a defendant resided. Ward opposed the motion, asserting that case law permitted Ward to file her claim in Yellowstone County, her place of residence. The district court ruled in favor of Johnson. The Supreme Court reversed, holding (1) Ward's decision to file her complaint in Yellowstone County was legally correct under Mont. Code Ann. 25-2-122(2)(b); and (2) the statute permitting Ward to file her action in the county of her residence did not deprive Johnson of the equal protection of the laws.

Plaintiff sued defendant, a bail bondsman, and others, alleging civil rights violations under 42 U.S.C. 1983, as well as various state law tort claims. The claims stemmed from defendant's efforts to apprehend a fugitive in and around plaintiff's home. A jury found in plaintiff's favor on her section 1983, trespass, and assault claims. Defendant appealed, challenging the jury's verdict and damages award. The court held that defendant was not entitled to qualified immunity where neither history nor policy supported extending the defense to bail bondsmen. The court also held that there was sufficient evidence to support the jury's conclusion that plaintiff's consent was involuntary and the court affirmed the verdict on the 1983 claim. The court further held that there was a sufficient basis to support the jury's conclusion that plaintiff was in reasonable fear of bodily harm. Finally, the court affirmed the district court's denial of defendant's motion regarding the actual damages award and found no abuse of discretion in the district court's decision to leave the punitive damages award undisturbed. Accordingly, the court affirmed the judgment.

Eilman, a college student, was arrested outside an airport after behaving so badly that agents had called police. Eilman had developed bipolar disorder following an auto accident the previous year. She had not taken her medication and did not tell the police about her mental-health condition. By phone, her mother and stepfather told officers about her disorder. They did not believe the stepfather and the officer who talked to her mother did not share the information. Officers thought that Eilman was being difficult or was on drugs. In custody, Eilman alternated between calm and manic. Officers released her into a neighborhood she did not know, near a public-housing project with an exceptionally high crime rate without returning her cell phone. She was raped and either jumped or was thrown out a seventh-story window. She suffered permanent, serious brain damage. In a suit by her guardian under 42 U.S.C. 1983, the district court denied some of defendants’ claims of qualified immunity. The Seventh Circuit reversed in part, noting that whether police should have understood Eilman’s need for medical care is a factual issue and that police may have made her situation worse by releasing her far from where she was arrested.Easterbrook

The question before the Supreme Court was whether, and to what extent, a state's attorney was entitled to official immunity from civil liability for allegedly tortuous conduct concerning a local police officer. The trial court concluded that liability for the acts complained of was precluded by either qualified or absolute immunity, or was otherwise barred. In February 2010 when Plaintiff was employed as a police officer with the South Burlington Police Department, filed a complaint against Defendant, the Chittenden County State's Attorney, stating claims for defamation, intentional infliction of emotional distress, and intentional interference with Plaintiff's employment. The complaint alleged that Defendant (formerly a private lawyer and a member of what Plaintiff characterized as the Vermont "Drug Bar") harbored an animus against Plaintiff due to his police work. Plaintiff claimed that as state's attorney Defendant had "maliciously pursued a course of action . . . to undermine Plaintiff's work and credibility in the law enforcement community." As alleged in the complaint and in Plaintiff's later responses to discovery, Defendant's tortious misconduct included meeting with Plaintiff's supervisors to criticize his job performance and falsely accuse him of dishonesty; declining to file charges or seek search warrants based on Plaintiff's affidavits; threatening not to work with Plaintiff and thereby end his career if Plaintiff attempted to bypass the State's Attorney's office and obtain warrants directly from the trial court; criticizing Plaintiff's work when he was being considered by the State Police to serve on its Drug Task Force; impugning Plaintiff's honesty to other prosecutors; encouraging the filing of a civil-rights lawsuit against Plaintiff and testifying falsely in that action; and "leaking" harmful information about Plaintiff to criminal defense attorneys. Upon review, the Supreme Court concluded "[t]he trial court's ruling was sound" and affirmed the trial court's ruling that the State's Attorney was entitled to absolute immunity.

Plaintiff appealed from the district court's order dismissing his complaint against Target and Virginia Winn. Plaintiff, a Hispanic male, alleged that Winn, a white Target cashier, refused to serve him based on his race and publicly humiliated him when she turned him away from her register. Plaintiff brought suit against Winn for intentional infliction of emotional distress (IIED); against Target for vicarious liability and for negligent training, supervision, and retention; and against both defendants for violating his right to make contracts under 42 U.S.C. 1981. The district court dismissed the case, explaining that plaintiff could not maintain a section 1981 claim because he was ultimately able to complete his purchase, and that Winn's alleged actions did not rise to the level of outrageousness required to state an IIED claim under controlling Florida law. After thorough review and having had the benefit of oral argument, the court agreed and affirmed the judgment of the district court.

Plaintiffs were involved in a physical altercation with employees of a nightclub. Plaintiffs sustained visible injuries. Club employees took them outside, handcuffed them and called the police. The officers were apparently unwilling to listen to plaintiffs' side of the story; they were taken to a squad car and placed in the rear seat, though they were never told they were under arrest. Both were charged with assault and battery. Although there were surveillance cameras, tapes were never requested and were destroyed before plaintiffs filed their suit under 42 U.S.C. 1983 against the city, officers, the club, and its owner. The district court granted summary judgment in favor of all defendants, holding that the club and owner were not functioning as state actors; that plaintiffs failed to show a conspiracy between the city and the club; that there was probable cause to arrest plaintiffs; and that probable cause defeats a claim of malicious prosecution. The Seventh Circuit affirmed.