Justia Civil Rights Opinion Summaries

Jason Waterhouse, high on methamphetamine, barricaded himself in his sister's basement and started a fire when Lakewood Police Department officers arrived. After an hour of failed negotiations, seven officers entered the basement to extract him and locate the fire. Sergeant Marc Direzza, providing lethal cover, was among the last two officers in the basement when Waterhouse burst out of a bedroom and rushed towards them. Another officer fired a beanbag shotgun, and Direzza fired his pistol, killing Waterhouse with a shot to the back.The Estate of Jason Waterhouse filed a Fourth Amendment excessive-force claim under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado. The district court granted summary judgment in favor of Sergeant Direzza, concluding he was entitled to qualified immunity. The court found that Direzza's use of lethal force was reasonable under the circumstances and did not violate clearly established law. The district court also dismissed a state-law wrongful-death claim without prejudice.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's summary judgment, holding that Sergeant Direzza was entitled to qualified immunity. The court determined that Direzza's use of lethal force was objectively reasonable given the dangerous circumstances, including the fire and smoke, and the perceived threat posed by Waterhouse. The court also affirmed the dismissal of the wrongful-death claim, as it was contingent on the outcome of the excessive-force claim. View "Estate of Jason Waterhouse v. Direzza" on Justia Law

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law

In June 2015, Dylann Roof shot and killed nine people at Mother Emanuel AME Church in Charleston, South Carolina, including M.P.'s father, Reverend Clementa Pinckney. M.P., a minor, filed a lawsuit against Meta Platforms, Inc. (formerly Facebook, Inc.) and its subsidiaries, alleging that Facebook's algorithm recommended harmful content that radicalized Roof, leading to the murders. M.P. asserted claims of strict products liability, negligence, and negligent infliction of emotional distress under South Carolina law, as well as a federal claim under 42 U.S.C. § 1985(3) for conspiracy to deprive her of her civil rights.The United States District Court for the District of South Carolina dismissed M.P.'s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Section 230 of the Communications Decency Act barred her state law tort claims. The court also found that M.P. failed to plausibly allege a claim under 42 U.S.C. § 1985(3).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that M.P.'s state law tort claims were barred by Section 230 because they sought to hold Facebook liable as a publisher of third-party content. The court also determined that M.P. failed to plausibly allege proximate causation under South Carolina law, as her complaint did not provide sufficient factual foundation linking Roof's Facebook use to his crimes. Additionally, the court found that M.P. forfeited her challenge to the dismissal of her Section 1985 claim by not adequately addressing it in her appellate brief. The court also concluded that any potential claim under 42 U.S.C. § 1986 was barred by the one-year statute of limitations. Thus, the Fourth Circuit affirmed the district court's judgment granting Facebook's motion to dismiss. View "M.P. v. Meta Platforms Inc." on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law

Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

In 2018, Gary Washington was released from prison after serving 31 years for murder, following a writ of actual innocence. Washington filed a civil lawsuit against the police officers involved in his case, alleging they coerced a witness into providing false testimony, which was later recanted. The district court granted summary judgment in favor of the officers, dismissing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress. The court found Washington was collaterally estopped from relying on the witness's recantation because a prior state court had found it incredible. The district court also dismissed Washington's alternative due process Brady claim and his intentional infliction of emotional distress claim on independent grounds.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state court decision granting Washington a writ of actual innocence was inconsistent with the prior post-conviction ruling that the recantation was incredible, precluding the application of collateral estoppel. The court also found that applying collateral estoppel to prohibit Washington from litigating the alleged misconduct was incompatible with equitable principles. The court agreed with the district court's dismissal of Washington's alternative due process Brady claim but reversed the dismissal of his intentional infliction of emotional distress claim, finding that wrongful incarceration for 31 years could constitute severe emotional distress.The Fourth Circuit reversed the district court's grant of summary judgment in part and affirmed it in part, allowing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress to proceed. View "Washington v. Pelligrini" on Justia Law

Jose Villegas, a 39-year-old inmate at Lake Correctional Institution (LCI) in Florida, died following a physical confrontation with correctional officers. The incident began when officers found Villegas unconscious in his cell. Upon regaining consciousness, Villegas resisted the officers' attempts to restrain him. The officers eventually subdued Villegas and transported him to a medical unit, but he was pronounced dead upon arrival. The autopsy reported that Villegas died from restraint asphyxia, with excited delirium as a contributing factor, and noted the presence of synthetic cannabinoids in his system.Douglas B. Stalley, representing Villegas's estate and his minor children, filed a lawsuit against the officers, their supervisors, and the Florida Department of Corrections (FDOC) for negligence, wrongful death, excessive force, deliberate indifference, and supervisory liability. The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants on the constitutional claims and declined to exercise jurisdiction over the state-law wrongful death claim, remanding it to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Stalley appealed the district court's decision regarding the deliberate indifference and supervisory liability claims. The Eleventh Circuit affirmed the district court's ruling, holding that the officers were entitled to qualified immunity. The court found that the officers' decision to transport Villegas to a medical unit rather than provide on-scene care did not violate any clearly established constitutional right. Consequently, the supervisory liability claim also failed, as it was contingent on the underlying constitutional violation. View "Stalley v. Lake Correctional Institution Warden" on Justia Law