Justia Civil Rights Opinion Summaries

After Janet Hahn died of diabetic ketoacidosis when she was a pretrial detainee at a correctional center, her husband and the administrator of her estate filed suit alleging that various government officials and private contractors failed to provide her adequate medical treatment. The district court dismissed some of plaintiffs' claims and granted summary judgment in favor of defendants on the remaining claims. The court concluded that the district court correctly dismissed the wrongful death claim but erred in dismissing it with prejudice where plaintiffs produced insufficient evidence to permit their claims against Sheriff Walsh and the jail's medical contractor to survive summary judgment. Therefore, the court reversed the district court's judgment insofar as it dismissed the wrongful death claim with prejudice. The court affirmed in all other respects. View "Hahn, et al. v. Walsh, et al." on Justia Law

Chris Hogan lost his job with the Utah Telecommunications Open Infrastructure Agency("UTOPIA"). Claiming he was fired for revealing a conflict of interest in contract awards, he threatened to sue the agency for wrongful termination. Shortly after making this threat, he was subject to several unflattering media articles about his job performance and his termination dispute with the agency’s leaders. Several of the stories claimed his threats to sue the agency amounted to extortion or blackmail. One of the stories was written pseudonymously by Michael Winder, the mayor of West Valley City where UTOPIA did much of its business. Hogan sued UTOPIA, the mayor, the City, and a number of other people he believed were involved in the publication of the articles. He claimed the articles were defamatory, portrayed him in a false light, invaded his privacy, were an intentional infliction of emotional distress, a deprivation of his constitutional rights in violation of 42 U.S.C. 1983, and a civil conspiracy under 42 U.S.C. 1985. He also sued UTOPIA for First Amendment violations, breach of contract, wrongful termination, and other violations of state law in a separate lawsuit. The district court dismissed all of the claims, and finding no reversible error, the Tenth Circuit affirmed: "because the articles' critical statements are explained by their context, we agree with the district court's conclusion that the articles were neither defamatory nor otherwise tortiously offensive. And we further agree that Hogan's federal law claims cannot go forward because he has insufficiently pleaded that the defendants' actions were exercises of their power under state law and that the defendants conspired to punish Hogan for bringing his claims to court." View "Hogan v. Winder, et al" on Justia Law

Davis retained Fenton to represent her in a home foreclosure proceeding. Davis later sued Fenton for malpractice. Davis claimed that, although she paid Fenton several thousand dollars, he did virtually nothing to help her and that he targeted her for inferior service based on her race, in violation of the Fair Housing Act, 42 U.S.C. 3601. That case is stayed pending arbitration. Fenton brought his own lawsuit in state court, against Davis’s lawyers: Dudley and Sidea, alleging that they intentionally spread false information about him to clients and business associates. Fenton also alleged that Sidea, who had previously worked at Fenton’s law office, had improperly obtained confidential information about Fenton’s clients and shared it with Dudley. The complaint claimed conversion, tortious interference with a business relationship, and defamation. Dudley and Sidea filed a notice of removal in federal court, citing the general removal statute, 28 U.S.C. 1441, and the civil rights removal statute, 28 U.S.C. 1443. Days later, despite the ongoing removal proceedings, the Cook County Court entered an ex parte preliminary injunction against Dudley and Sidea. The district court found that the case did not meet the removal requirements under either 28 U.S.C. 1441 or 1443 and remanded, The Seventh Circuit affirmed. View "Fenton v. Dudley" on Justia Law

The Alaska Workers' Compensation Board denied a death benefit claim filed by the decedent's same-sex partner because the death benefit statute grants benefits only to a worker’s "widow or widower" as defined by statute. The Board construed these terms by applying the Marriage Amendment to the Alaska Constitution, which defined marriage as "only between one man and one woman," thus excluding a decedent's same-sex partner. Because this exclusion lacked a fair and substantial relationship to the purpose of the statute, the Supreme Court concluded that this restriction on the statutory definition of "widow" violated the surviving partner's right to equal protection under the law. View "Harris v. Millennium Hotel" on Justia Law

Plaintiff, the widow of the deceased, filed suit under 42 U.S.C. 1983, alleging claims that individual defendants used excessive force against her husband and that defendants acted with deliberate indifference to his medical needs. On appeal, plaintiff challenged the district court's grant of summary judgment as to all of plaintiff's claims. The court concluded that the record presented genuine issues of material fact from which a jury could conclude that excessive force was used against the husband. Therefore, the court reversed and remanded for the district court to consider in the first instance whether any or all of the individual defendants may proceed to trial on a theory of direct liability for use of force or, in the alternative, on a theory of bystander liability. The district court should also consider whether individual defendants are entitled to qualified immunity. The court affirmed the district court's grant of summary judgment in regards to the deliberate indifference claim and the municipal liability claim for failing to provide adequate training. View "Kitchen v. Dallas County Texas, et al." on Justia Law

On February 28, 2007, Barriera barricaded himself in his bedroom. He had been diagnosed with schizophrenia years earlier, but had not been taking his medicine regularly. His mother (Wilson) feared he might harm himself. When the family’s efforts to convince him to leave his room were unsuccessful, Wilson called 911. She explained that Barriera might be suicidal. A firefighter was able to open the bedroom door enough to observe Barriera holding a hunting knife and moving around the room and called for police assistance. Officers arrived and worked for several minutes to persuade Barriera to leave his room. Later, an officer deployed his taser through the partially open door, hitting Barriera, who removed the prongs from his chest. Seconds later, he lunged at the officers with the knife. One officer deployed the taser and another fired his weapon. Barriera was struck by the taser prongs and two bullets.. Barriera later died from his injuries. A jury rejected Wilson’s claims against the officers (under 42 U.S.C. 1983) for excessive force; for wrongful death against the officers under Illinois law; under the Illinois Survival Statute against the officers; and that the city was liable for the torts of the officers under the theory of respondeat superior. The Seventh Circuit affirmed, rejecting challenges to evidentiary rulings and to the manner in which the court instructed the jury. View "Wilson v. City of Chicago" on Justia Law

King was in police custody awaiting a probable cause determination in 2007. After being rapidly tapered off his psychotropic medication by jail medical staff, complaining of seizure-like symptoms, and being placed in an isolated cell for seven hours, he was found dead. His estate sued La Crosse County and individual employees. After a remand, six weeks before the trial date, after unsuccessful settlement discussions, King’s counsel asserted in a letter to the defendants that the correct standard for jury instructions in the upcoming trial was one of objective reasonableness, not the deliberate indifference standard that had been used by both parties in the pleadings, the summary judgment briefing, the subsequent appeal, and remand pretrial preparations. The assertion was correct as a matter of law, but shortly after receiving the letter, defendants moved that King be precluded from arguing the applicability of the objective reasonableness standard because of her tardiness in asserting the argument. The district court agreed and ordered that the case be tried as scheduled under the deliberate indifference standard. The Seventh Circuit reversed and remanded, acknowledging that King’s long, unexplained delay in asserting the correct standard was puzzling and problematic, but stating that the district court failed to provide a sufficient explanation of how the defendants would suffer prejudice as a result of the delay. View "King v. Kramer" on Justia Law

Plaintiff Lorraine Gormley was an attorney employed by the Department of the Public Advocate, Division of Mental Health Advocacy, providing legal representation to clients involuntarily committed in state psychiatric facilities, including Ancora Psychiatric Hospital. Each ward at Ancora contained a day room in which up to forty patients could congregate. Visiting attorneys and psychiatrists also were required to use the day rooms for professional interviews. Although frequent violence occurred in the day rooms, no security guards or cameras were posted there. While at Ancora, Gormley met for the first time with her client B.R., a 21-year-old woman committed sixteen days earlier for a “psychotic disorder” that induced hallucinations. At the start of the interview in the hospital’s crowded and chaotic day room, B.R. violently attacked Gormley in the presence of hospital staff. Gormley filed a civil action against Ancora’s CEO, LaTanya Wood-El, and other government officials, in their individual capacities, under both the Federal Civil Rights Act and the New Jersey Civil Rights Act, alleging that her constitutional right to be free from state-created danger was violated. On defendants’ motions for summary judgment, the trial court concluded that Gormley had presented sufficient evidence to proceed on the civil-rights claims under the state-created-danger doctrine. The court deferred deciding whether she was entitled to injunctive relief. The issue before the Supreme Court in this case was whether injuries Gomley suffered resulted from a state-created danger that violated her substantive-due-process rights under the Fourteenth Amendment of the United States Constitution and whether defendants were entitled to qualified immunity. Under the facts of this case, the Supreme Court concluded that the lawyer had a substantive-due-process right to be free from state-created dangers. Because that right was clearly established at the time the lawyer was attacked, the state official defendants were not entitled to qualified immunity. View "Gormley v. Wood-El" on Justia Law

Plaintiff filed suit against the City and the ECCC, alleging violations of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., and various California statutes. Plaintiff tripped and fell as he tried to walk around a car show vendor's display blocking a curb ramp. On appeal, defendant challenged the district court's grant of summary judgment to defendants. The court concluded that the district court erred by granting summary judgment in favor of the City because the district court relied on an inapplicable legal standard and because there was a genuine dispute of material fact as to whether the City denied plaintiff access to a public service or otherwise discriminated against him under Title II. Because the City was not entitled to summary judgment on the ADA claim, the district court erred by granting summary judgment for the City on plaintiff's claims under the California statutes. The court took no position on whether the City did in fact deny plaintiff access to a public service or discriminate against him by reason of disability under 42 U.S.C. 12132. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Cohen v. City of Culver City" on Justia Law

Plaintiff filed a complaint against Defendant asserting multiple intentional torts and alleging that Defendant sexually assaulted Plaintiff in the early 1970s when Plaintiff was a child and Defendant was a Roman Catholic pastor. On remand, the superior court entered summary judgment in favor of Defendant, concluding that Plaintiff’s complaint was time-barred. At issue on appeal was whether the statute of limitations was tolled due to Defendant’s move to Massachusetts during the applicable time frame. The Supreme Court affirmed, holding that Defendant established, without dispute of material facts, that he was amenable to service because Maine’s long-arm statute permitted service of the complaint in Massachusetts and that Plaintiff could have located him through reasonable effort and served him by any means other than publication. View "Angell v. Hallee" on Justia Law