Justia Civil Rights Opinion Summaries

Patterson's mother called police after an argument. Officers approached Patterson, who sat on the porch, and told him, repeatedly, to leave. Patterson became agitated when they suggested that he go to a homeless shelter. They stated that he was under arrest and would be physically removed. The officers attempted to lift him. Patterson resisted. Patterson and an officer fell against a barbeque grill "with considerable force." Officer Hasiak punched Patterson in the stomach. That failing, Officer Hiatt used her taser; its probes did not connect. Hasiak thrust his knee into Patterson's thigh. Hasiak attempted to kick Patterson's leg, missed, and contacted Patterson's torso. Patterson stopped resisting. The officers put Patterson in their police cruiser and took him to the hospital. Medical staff diagnosed fractured ribs but believed that they would heal without further treatment. Patterson pleaded guilty to failing to leave his mother's property and was released. He collapsed outside of the jail and was returned to the hospital. Doctors discovered a torn intestine. He underwent surgery and was released a week later. Patterson sued under 42 U.S.C. 1983. A jury found excessive force, yet only awarded $1. The district court and Eighth Circuit affirmed. A jury may reasonably conclude that compensatory damages are inappropriate despite finding that excessive force was used if it finds that both justifiable and unjustifiable force might have been used and the injury may have resulted from justifiable force. View "Patterson v. City of Omaha" on Justia Law

In 2011, after about two weeks of reporting symptoms and being treated for constipation and gas, Allard, a prisoner at the Clarinda Correctional Facility of the Iowa Department of Corrections , suffered a bowel obstruction and perforation. Allard had emergency surgery where a colostomy bag was installed and his bowel was repaired. Allard filed suit under 42 U.S.C. 1983. The district court granted summary judgment to the prison staff. The Eighth Circuit affirmed, rejecting a claim that material questions of fact existed regarding the appropriateness of the care Allard received. Although Allard demonstrated that CCF medical staff failed to properly diagnose his bowel obstruction, and demonstrated that failure to treat the bowel obstruction led to a bowel perforation, Allard failed to put forward evidence to support a finding of deliberate indifference. View "Allard v. Baldwin" on Justia Law

Two security guards employed by SSA Security, Inc. and four of their confederates carried out a conspiracy to set fire to several homes. The resulting fires destroyed ten homes and damaged twelve others. Appellants asserted various civil claims against SSA and the five convicted arsonists, contending that the Maryland Security Guards Act (“Act”) section 19-501 established a basis for SSA’s strict liability for its employees’ intentional torts and civil rights violations. A federal district judge granted summary judgment in SSA’s favor as to the negligence claims and the claims premised on strict liability under section 19-501, concluding (1) section 19-501 was merely a codification of the common law and did not expand the doctrine of respondeat superior; and (2) any intentional acts of SSA’s employees were outside the scope of employment. Appellants appealed, arguing that the Act extends the vicarious liability of security guard agencies beyond the state common law doctrine of respondent superior. The federal appellate court certified a question of law to the Court of Appeals regarding the meaning of section 19-501. The Court answered that section 19-501 has the same meaning as Maryland’s common law doctrine of respondent superior. View "Antonio v. SSA Sec., Inc." on Justia Law

Villanueva was the contact to the police department for her neighborhood watch group, communicating with Officer Moreno. She told Moreno that her ex-husband (Alvaro) had assaulted her. Moreno did not file a report or take official action, but spoke with Alvaro about the incident. Moreno began spending time alone with Villanueva, touching her, and sending sexually explicit messages. The relationship became sexual. Villanueva ended the relationship and began experiencing what she believed was harassment. She saw unknown cars parked outside her house and received anonymous threatening phone calls referencing private conversations between Villanueva and Moreno. Villanueva believed Moreno orchestrated the harassment. Villanueva reported to the Scottsbluff police. Officers were dispatched after many calls, but they generated only two reports and took no official action. Villanueva, diagnosed with PTSD, filed suit, citing the Equal Protection Clause and negligent infliction of emotional distress. The district court construed Villanueva’s complaint to allege substantive due process violations of her rights to bodily integrity and to be free from state-created danger, granted summary judgment in favor of defendants on the constitutional claims, and declined to exercise supplemental jurisdiction. The Eighth Circuit affirmed. The evidence did not suggest Moreno coerced Villanueva into sexual relations through an abuse of authority so egregious and outrageous that it shocked the conscience. View "Villanueva v. City of Scottsbluff" on Justia Law

Appellee Barto Mitcham filed a negligence action against appellants, the City of Atlanta (the “City”) and George Turner, in his official capacity as the Chief of Police for the City of Atlanta Police Department, alleging that Mitcham was seriously injured as a result of appellants’ failure to provide him necessary medical treatment while in their custody. Mitcham specifically alleged that after he was arrested by the City of Atlanta Police Department, he became ill because of low blood sugar associated with diabetes. He was taken to the hospital, and upon his discharge and release back into the custody of the City, Atlanta Police Department officers were informed of his diabetic condition and the need to monitor and regulate his insulin levels. He alleged they failed to do so, causing him further illness and serious and permanent injuries. The Supreme Court granted a petition for writ or certiorari in this case to determine whether the Court of Appeals used the proper analysis when it determined that the provision of medical care by the City of Atlanta to inmates in its custody was a ministerial function for which the City of Atlanta’s sovereign immunity had been waived. Because the Court found that the care of inmates in the custody of a municipal corporation is a governmental function for which sovereign immunity has not been waived, it reversed and remanded for further proceedings. View "City of Atlanta v. Mitcham" on Justia Law

Plaintiff, a town official for the town of Raymond, claimed that Michael Reynolds, a fellow town official, told the sheriff’s department that Plaintiff had driven while intoxicated, that the reports were false, and the false statements damaged his reputation. Plaintiff brought suit in state superior court, alleging state law claims for defamation and false light invasion of privacy, as well as federal claims under 42 U.S.C. 1983. The case was removed to federal court on the basis of the federal claims. The district court dismissed the federal claims and proceeded to resolve the state law claims. The First Circuit (1) affirmed the dismissal of the federal claim; and (2) vacated the dismissal of Plaintiff’s state law claims as to Reynolds and remanded the claims to state court, holding the state law claims involved resolution of a potential conflict between Maine’s Anti-SLAPP statute and Maine’s Constitution, a conflict that “is best resolved by the Maine courts.” View "Desjardins v. Willard" on Justia Law

Plaintiffs filed suit against Deputy Arnold and Sheriff Graves, alleging violations of federal and state law after Arnold fatally shot their father while responding to a 911 call that the father was threatening to commit suicide. Plaintiffs also filed suit against ReliaStar to recover $179,000 they allege ReliaStar owes them under the father's accidental death policy. The district court granted Arnold and Grave's motions for summary judgment and granted ReliaStar's motion for summary judgment. The court held that Arnold did not violate the father's Fourth Amendment rights when he entered the father's home without a warrant because he had an objectively reasonable belief that the father would imminently seriously injure himself, and the district court did not err in granting Arnold's motion for summary judgment on the warrantless entry claim because Arnold is entitled to qualified immunity; Arnold is entitled to qualified immunity because he did not violate the father's constitutional right to be free from excessive force; the district court did not err in granting summary judgment for Arnold on the assault and battery claims, the false imprisonment claims, and the intentional infliction of emotional distress claim; the district court correctly granted Graves's motion for summary judgment; and the district court did not err in granting summary judgment for ReliaStar where the record was replete with factual evidence that ReliaStar relied on in determining that the father's death was not accidental, demonstrating that ReliaStar could have reached its determination without resorting to the conflict of interest at issue. Accordingly, the court affirmed the judgment of the district court.View "Rice, et al. v. Reliastar Life Ins. Co." on Justia Law

After Plaintiff retired from his employment with the United States Immigration and Customs Enforcement (ICE) in the Department of Homeland Security (DHS) he filed an administrative claim for employment discrimination, alleging that he was constructively discharged on the basis of his age or national origin. Plaintiff’s claim was denied. Thereafter, Plaintiff filed this action claiming liability under the Age Discrimination in Employment Act, Title VII of the Civil Rights Act of 1964, 42 U.S.C. 1983, the Federal Tort Claims Act (FTCA), and Puerto Rico law. The district court granted summary judgment for Defendants, finding the action time-barred. The First Circuit affirmed, holding (1) to the extent Plaintiff’s complaint asserted an FTCA claim, it must be dismissed on the grounds that Plaintiff did not present an FTCA claim in his administrative complaint; and (2) Plaintiff’s remaining claims were time-barred.View "Acevedo-Perez v. United States" on Justia Law

Satkar owns Schaumburg, Illinois hotel and was mentioned in blog posts and a television news report as having made a large donation to a local politician and later won a property-tax appeal. In response, the Cook County Board of Review revoked Satkar’s property-tax reduction and opened an inquiry. Satkar sued the Board, its members and staff, the blog, the television station, and reporters, under 42 U.S.C. 1983, and for defamation and false light. The district court dismissed the 1983 claims against the Board and the officials. The Seventh Circuit affirmed. The court separately dismissed the state-law claims against the media defendants, applying the Illinois Anti-SLAPP statute. Because the section 1983 claims were still pending, the judge entered final judgment under FRCP 54(b) to permit appeal of the SLAPP issue. Later, the judge orally invited Satkar to ask for a Rule 54(b) judgment on the SLAPP dismissal, forgetting that he had already entered final judgment. Satkar did not correct the judge, did not seek clarification, and did not file a notice of appeal. After the deadline to appeal expired, Satkar sought an extension, claiming that the judge’s comment created confusion. The judge granted the extension, relying on the defunct “unique circumstances” doctrine. The Seventh Circuit dismissed an appeal, noting that the Supreme Court has disavowed the unique circumstances doctrine and Satkar has not otherwise demonstrated excusable neglect. View "Satkar Hospitality, Inc.v. Fox Television Stations, Inc." on Justia Law

This case was an interlocutory appeal from the district court’s denial of qualified immunity in an Eighth Amendment case brought by a Colorado state prisoner. Plaintiff Homaidan Al-Turki filed suit under 42 U.S.C. 1983 against several prison officials, including Defendant Mary Robinson (a prison nurse) based on these officials’ failure to provide him with any type of medical evaluation or treatment while he was suffering through several hours of severe abdominal pain from what turned out to be kidney stones. The district court granted qualified immunity to the other prison officials, none of whom were medical professionals, but denied Defendant Robinson’s summary judgment motion for qualified immunity. Defendant then filed this interlocutory appeal. On appeal, the issues this case presented to the Tenth Circuit were: (1) whether the hours of severe pain Plaintiff experienced constituted a sufficiently serious medical need to satisfy the objective prong of the Eighth Amendment deliberate indifference test; and (2) whether Defendant’s alleged actions violated clearly established law. Finding no reversible error, the Tenth Circuit affirmed the district court on both issues. View "Al-Turki v. Robinson, et al" on Justia Law