Justia Civil Rights Opinion Summaries

Stephens visited the Oaklawn Club for gambling. After winning, playing slot machines, Stephens cashed out and left the casino. He returned later that evening and purchased another ticket for use in the slot machines. He was approached by uniformed security personnel and Jessup, a uniformed Hot Springs police officer. They accused Stephens of stealing the cashed-out ticket and detained Stephens while employees reviewed surveillance footage. Stephens alleges that Jessup threatened to “take him to jail immediately” if he did not return the money. Jessup recited Miranda warnings, escorted Stephens to his vehicle, and retrieved the money. An Arkansas state court granted Oaklawn summary judgment. Neither Jessup nor Amtote was a party to that action. Stephens then filed a federal suit against Jessup and Amtote, alleging the same causes of action against these new defendants. The court dismissed, citing issue preclusion. The Eighth Circuit reversed in part, finding that Stephens did not perfect an appeal with respect to Amtote. The court expressed no view on the merits of the Jessup claims, stating that the record is not clear that Stephens is trying to relitigate an issue that was previously decided or that Jessup and Oaklawn represent the same legal right. View "Stephens v. Jessup" on Justia Law

After a jury trial, Defendant, the Hartford Roman Catholic Diocesan Corporation, was found guilty of negligently and recklessly assigning Father Ivan Ferguson to serve as the director of Saint Marty’s Elementary School, where he sexually abused Plaintiff from 1981 through 1983. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the jury’s verdict; (2) the trial court did not commit prejudicial error in its evidentiary rulings; (3) the trial court properly granted Plaintiff’s motion to strike Defendant’s laches defense; and (4) the retroactive application of certain amendments to the applicable statute of limitations to revive Plaintiff’s otherwise time barred claims did not violate Defendant’s substantive due process rights under the Connecticut Constitution. View "Doe v. Hartford Roman Catholic Diocesan Corp." on Justia Law

Plaintiffs were five women who were formerly incarcerated at the Hillside Community Corrections Center in Oklahoma City. They filed a 42 U.S.C. 1983 action against multiple defendants, alleging they were sexually abused and harassed in violation of the Eighth Amendment’s prohibition against cruel and unusual punishment. Plaintiffs’ complaint named fifteen defendants, including Defendant-Appellant Charlotte Day and Defendant-Appellant Mary Pavliska, both of whom were guards at Hillside during the relevant period. Plaintiffs alleged Day and Pavliska were aware of the abuse and did nothing to prevent it. The claims against several defendants were dismissed without prejudice. The remaining defendants (except the alleged perpetrator Anthony Bobelu) moved for summary judgment. The district court granted summary judgment to all movants except Day and Pavliska. The district ruled a jury could conclude from the evidence presented that Day and Pavliska were deliberately indifferent to a known substantial risk of serious harm to the Plaintiffs. In an interlocutory appeal, Day and Pavliska argued to the Tenth Circuit Court of Appeals that the district court erred by ruling they were not entitled to qualified immunity. Upon review, the Tenth Circuit dismissed Day’s appeal for lack of jurisdiction and affirmed the denial of qualified immunity as to Pavliska. View "Castillo v. Day" on Justia Law

Snyder was on parole after serving sentences for possession of a controlled substance and automobile theft. The Missouri Board of Probation and Parole determined that Snyder had absconded and issued a warrant for his arrest. Julian, an employee of the Board’s Fugitive Apprehension Unit, received a telephone call informing him that Snyder was at an apartment in Cape Girardeau. Julian drove to the address and positioned his car in a well-lighted parking lot in front of the apartment. Julian saw Snyder, got out of his car, and informed Snyder that he was a parole officer with a warrant for Snyder’s arrest. Snyder placed his hands on the back of Julian’s car. Julian approached, stood to Snyder’s left, and placed his left hand on Snyder’s left shoulder. Snyder then turned to his right and began to run. After Snyder took two steps, Julian fired one shot, killing him. In a suit by Snyder’s estate, the jury rejected claims under 42 U.S.C. 1983, but awarded $1 million for wrongful death. The Eighth Circuit affirmed, finding that there was sufficient evidence to defeat Julian’s motion for judgment as a matter of law, and that the damages award did not require a new trial. View "Estate of Snyder v. Julian" on Justia Law

At 4 a.m. one night, Plaintiff broke into his estranged wife’s apartment to talk about their relationship. The woman reported the break-in and provided a description of the car Plaintiff was driving. Defendant, a police officer, began to follow Plaintiff. The pursuit led to a tussle, which led to Defendant firing two shots in Plaintiff’s direction. Plaintiff later filed suit against Defendant, alleging that Defendant had violated his Fourth Amendment rights and committed common law assault. The district court awarded summary judgment to Defendant on the grounds of qualified immunity and discretion act immunity. The Supreme Court affirmed, holding that Defendant was entitled to qualified immunity. View "Mitchell v. Miller" on Justia Law

Wagner worked for Gallup for 12 years before his 2011 termination at age 50. Wagner co-authored two books for Gallup. The first became a New York Times bestseller. Gallup still sells both books. Wagner received positive verbal feedback from individuals in management. Gallup presented him with many awards during his employment. In 2011, Bogart became Wagner's supervisor. Bogart was 35, but had worked for Gallup longer than Wagner. Wagner stated that he and Bogart only interacted twice while Bogart was his supervisor. Bogart called Wagner and discussed the ongoing transitional situation of Wagner’s position and Bogart's difficulty finding a place for Wagner on a team given the perception that Wagner was too "self-referential." During a second call, Bogart terminated Wagner, informing Wagner that his position had been eliminated. Wagner sued, alleging age discrimination under the Minnesota Human Rights Act and invasion of privacy based on appropriation of his name or likeness. Wagner submitted declarations from two former Gallup employees who had worked with Wagner. Both stated that Gallup had initiated a "youthful movement" and targeted older employees for termination. The district court granted judgment in favor of Gallup. The Eighth Circuit affirmed. Wagner was unable to establish a question of fact as to Gallup's motives for his termination and did not establish intentionality with respect to his privacy clam. View "Wagner v. Gallup, Inc." on Justia Law

The Provincial Government of Marinduque (the Province), was a political subdivision of the Republic of the Philippines. Placer Dome Inc. (PDI), was incorporated under the laws of British Columbia, Canada. A predecessor of PDI formed Marcopper Mining Corp. to undertake mining activities in the Province. The predecessor and PDI controlled all aspects of Marcopper’s operations. During the course of the corporation’s operations, Marcopper caused significant environmental degradation and health hazards to the people living in the Province. The Province filed its complaint in a Nevada district court. Shortly thereafter, PDI and another business entity amalgamated under the laws of Ontario, Canada to form Barrick Gold Corporation. Barrick’s subsidiaries had substantial mining operations in Nevada. Barrick and PDI moved to dismiss for forum non conveniens. The district court found that dismissal for form non conveniens was warranted. The Supreme Court affirmed, holding that dismissal for forum non conveniens was proper because this case lacked any bona fide connection to the state, adequate alternative fora existed, and the burdens of litigating in Nevada outweighed any convenience to the Province. View "Provincial Gov't of Marinduque v. Placer Dome, Inc." on Justia Law

Albuquerque police sergeant Adam Casaus had ended his shift when he drove home in his squad car, lights flashing and going at a high rate of speed. He ran a red light, hitting Ashley Browder's car. Browder died, and her sister Lindsay suffered serious injuries. Casaus was ultimately charged with reckless vehicular homicide in state court. Lindsay and her parents filed a civil suit under 42 U.S.C. 1983 seeking damages. Casaus moved to dismiss on qualified immunity grounds. The district court denied relief, and Casaus appealed to the Tenth Circuit. Finding no reversible error, the Tenth Circuit affirmed the district court's decision. View "Browder v. City of Albuquerque" on Justia Law

In two separate murder trials in Puerto Rico’s courts, jurors convicted a group of individuals based in large part on the testimony of a single witness. When that witness later recanted her testimony, the Commonwealth courts vacated the convictions and dropped the charges against the convicted individuals. Thereafter, the wrongfully convicted individuals (and/or their heirs and family members) filed these consolidated civil damages actions against police officers and prosecutors involved in their prosecutions, asserting claims under 42 U.S.C. 1983 and various constitutional and tort claims under Puerto Rico law. Defendants moved for summary judgment based on absolute or qualified immunities. The district court rejected the defenses. The First Circuit (1) reversed in part the denial of summary judgment for the assistant district attorney, holding that absolute immunity shielded the assistant district attorney from having to stand trial for Plaintiffs’ malicious prosecution and conspiracy claims under section 1983; and (2) otherwise affirmed the district court’s denial of summary judgment, holding that, to the extent the appeal was predicated on Defendants’ qualified immunity defense under federal or state law, Defendants’ claims were waived for inadequate briefing. View "Diaz-Colon v. Solivan-Solivan" on Justia Law

Around midnight, 15-year old Tabitha had a severe asthma attack at her North Philadelphia home. Her mother, Vargas, called 911. Waiting for the paramedics to arrive, Vargas went outside and found Tabitha lying on the sidewalk, gasping for air. She quickly lapsed into unconsciousness. Tabitha’s cousin unsuccessfully performed CPRl. Neighbors lifted Tabitha into a car belonging to Diaz, so that Diaz could take her to the hospital. Meanwhile, Vargas and Diaz placed five frantic 911 calls between 12:08 a.m. and 12:14 a.m. In response to “a person screaming” in a call made at 12:10 a.m. officers were dispatched. Neither was aware that the call involved a medical emergency. The events following the arrival of the officers at 12:13 are disputed. The family claims the officers blocked Diaz’s car. Both officers assert that they did not. Contemporaneous dispatch records indicate that, from the time the officers noted their arrival, to the time the ambulance arrived, was just over one minute. Paramedics loaded Tabitha into the ambulance and provided CPR. She arrived at the hospital at 12:28, having suffered a severe anoxic brain injury, and died two weeks later. The district court dismissed claims against the city and officers. The Third Circuit affirmed. The undisputed facts show that the actions of the officers were reasonable in responding to a volatile situation. View "Vargas v. City of Philadelphia" on Justia Law