Justia Civil Rights Opinion Summaries

A sheriff’s deputy in Virginia arrested an individual for skateboarding on a public road and suspected public intoxication. During the arrest, the deputy punched the individual in the face multiple times, causing significant injuries, including facial fractures and a brain hemorrhage. The individual sued the deputy for excessive force under the Fourth Amendment and for common law battery. The deputy argued that the force he used was necessary because the individual resisted arrest and that, regardless, he was entitled to qualified immunity because he did not violate clearly established law.The United States District Court for the Western District of Virginia reviewed the case on the deputy’s motion for summary judgment. The district court examined the record, including body camera footage, and found that several key facts were disputed, such as whether the individual had surrendered and ceased resisting before the deputy continued to use force. The court held that if a jury found in favor of the individual on these disputed facts, it would be clearly established that the level of force used was excessive. Therefore, the district court denied the deputy’s motion for summary judgment, including his claim of qualified immunity.On appeal, the United States Court of Appeals for the Fourth Circuit addressed its jurisdiction to review the denial of qualified immunity at this interlocutory stage. The court explained that it could not review the district court’s factual determinations but could consider whether, taking the facts most favorably to the plaintiff, the deputy was entitled to qualified immunity as a matter of law. The Fourth Circuit held that, under the facts as viewed by the district court, prior precedent clearly established that the deputy’s actions would constitute excessive force. As a result, the appellate court affirmed the district court’s denial of qualified immunity. View "Barricks v. Wright" on Justia Law

Michael Hickson, who had become severely disabled following cardiac arrest and anoxic brain injury in 2017, was hospitalized multiple times for recurring infections but recovered from several serious episodes. In June 2020, while hospitalized for pneumonia, sepsis, and suspected COVID-19, his doctors at St. David’s Healthcare assessed him as having a 70% chance of survival. Despite this, he was placed on hospice care and a do-not-resuscitate order was issued, with medical staff indicating that his inability to walk or talk equated to a poor quality of life. Life-sustaining treatment, including food and fluids, was withdrawn, even as his condition temporarily improved. Michael’s family, led by his wife Melissa Hickson, sought answers and attempted to visit him, but were repeatedly denied access and information. Michael ultimately passed away, and subsequent public statements by the hospital disclosed protected health information and cast aspersions on Melissa’s fitness as a guardian.The United States District Court for the Western District of Texas dismissed or granted summary judgment in favor of the defendants on all claims, including disability discrimination under § 504 of the Rehabilitation Act and § 1557 of the ACA, § 1983 claims, state-law medical negligence, informed consent, wrongful death, and intentional infliction of emotional distress. The plaintiffs objected to the recommendations for dismissal of the disability discrimination and § 1983 claims; the district court overruled these objections and dismissed those claims with prejudice. The remaining state-law claims were later resolved on summary judgment.Upon de novo review, the United States Court of Appeals for the Fifth Circuit held that disability discrimination claims based on alleged denial of medical treatment solely due to disability are cognizable and may proceed. The court also vacated and remanded the dismissals of the informed consent and intentional infliction of emotional distress claims, but affirmed dismissal of the § 1983 claims and other state-law claims. View "Hickson v. St. David's Healthcare Partnership" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law

A serious car accident occurred when a teenager, driving at excessive speeds while racing another vehicle, lost control and crashed, leaving the plaintiff, a sixteen-year-old passenger, with catastrophic injuries resulting in paraplegia. The plaintiffs, the injured teen and her mother, filed suit against a wide array of parties, including the two teenage drivers, various family members, city officials, law enforcement, fire department personnel, paramedics, two cities, a railroad company, and county prosecutors. The claims included negligence, allegations of discrimination and violations of civil rights under 42 U.S.C. § 1983, and claims related to the handling of the accident’s aftermath and investigation.In the United States District Court for the Eastern District of Texas, the court adopted a magistrate judge’s recommendation and dismissed all claims with prejudice against all defendants except one, whose claims were dismissed without prejudice. The district court found the complaint to be vague, conclusory, and “riddled with pleading deficiencies.” It determined that claims against certain defendants were time-barred, that some defendants were not state actors for purposes of § 1983, that the plaintiffs failed to state claims upon which relief could be granted, and that certain claims were duplicative or failed as a matter of law. The plaintiffs sought the opportunity to replead, which the district court denied, finding amendment would be futile.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissals de novo. The appellate court affirmed the district court’s judgment, holding that all claims were properly dismissed with prejudice except for those against the county prosecutors, which were modified to be dismissed without prejudice due to Eleventh Amendment immunity and lack of standing. The Fifth Circuit found no error or abuse of discretion in the lower court’s rulings and declined to remand for further amendment. View "Quiroz v. Hernandez" on Justia Law

Several residents of Estherville, Iowa, sued a former police officer, the police chief, the City of Estherville, and its insurance company, alleging that the officer repeatedly accessed and disseminated their confidential criminal history and intelligence data for improper purposes between 2015 and his resignation on May 3, 2019. The officer used this data for personal gain, including assisting with vehicle repossessions and harassing certain plaintiffs. Complaints about his conduct were made to the police chief, who ultimately placed the officer on administrative leave and accepted his resignation. Criminal charges were later brought against the officer in 2022 for his actions.After learning of the wrongful data access between 2021 and 2022, the plaintiffs filed suit on July 7, 2023, in the Iowa District Court for Emmet County, asserting statutory and common law claims, including invasion of privacy and conspiracy, and seeking damages under Iowa Code section 692.6. The defendants moved to dismiss, arguing the two-year statute of limitations under the Iowa Municipal Tort Claims Act (IMTCA) barred the claims, since all alleged misconduct ended by May 3, 2019. The district court denied dismissal, holding that the statutory claim under section 692.6 was subject to a five-year limitation with a discovery rule, and that the remaining claims accrued when plaintiffs discovered the wrongdoing.On appeal, the Iowa Court of Appeals reversed the district court and ordered dismissal, concluding that all claims were governed by the IMTCA’s two-year statute of limitations and that the date of injury was when the data was accessed or disseminated, not when plaintiffs learned of it. The Iowa Supreme Court affirmed the appellate court, holding that the IMTCA’s statute of limitations applied to all claims and began at the time of the wrongful acts, regardless of later discovery or emotional harm. The case was remanded for dismissal. View "Abrahamson v. Scheevel" on Justia Law

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

C.B., a 34-year-old man with developmental and psychiatric disabilities, died while residing at the Valley Ridge Center for Intensive Treatment, a secure state-run facility operated by the New York State Office for People with Developmental Disabilities. Although C.B. was admitted voluntarily, the facility imposed substantial restrictions on his liberty, including limits on leaving the premises and accessing medical care. In the days leading up to his death from cardiomyopathy, C.B. exhibited clear symptoms of heart failure and repeatedly asked staff for help, but his pleas were allegedly ignored or inadequately addressed by his caretakers.J.M., C.B.’s mother and administrator of his estate, brought suit in the United States District Court for the Northern District of New York, alleging violations of C.B.’s substantive due process rights under 42 U.S.C. § 1983, as well as state law claims for negligence and medical malpractice. The district court granted summary judgment for the defendants on the federal claim, holding that C.B., as a voluntarily admitted resident, had no constitutional right to adequate medical care, and declined to exercise supplemental jurisdiction over the state law claims. The court also denied J.M.’s motion to amend her complaint to add a new defendant, finding lack of diligence.On appeal, the United States Court of Appeals for the Second Circuit held that C.B. was entitled to substantive due process protections regardless of his voluntary admission status. The court clarified that when the state exercises sufficient control over a resident’s life such that the individual cannot care for himself, due process guarantees apply, consistent with Youngberg v. Romeo, Society for Good Will to Retarded Children, Inc. v. Cuomo, and DeShaney v. Winnebago County Department of Social Services. The Second Circuit vacated the district court's judgment and remanded for further proceedings. View "J.M. v. Sessions" on Justia Law

A sixteen-year-old boy and his friend were waiting for transportation under a carport near the boy’s home when they were approached by an off-duty Baltimore City police officer who had just returned from firearms training. The officer, dressed in plain clothes and carrying a loaded handgun, questioned the boys about their presence in the neighborhood. After a brief exchange, the officer brandished his gun at “low ready,” causing the boys to fear for their lives. The incident had a lasting traumatic effect on the boy, resulting in emotional distress, behavioral changes, and ultimately leading him to attend a boarding school to distance himself from the event.The boy filed suit under 42 U.S.C. § 1983 and Maryland state law against the officer, the Baltimore Police Department, the Mayor and City Council of Baltimore, and the State of Maryland. All claims against the institutional defendants were dismissed by the United States District Court for the District of Maryland, and some claims against the officer were dismissed at summary judgment. At trial, the district court submitted to the jury both constitutional claims and state law gross negligence claims, including gross negligence in the officer’s capacity as a private person. The jury found for the officer on constitutional claims but found him grossly negligent as a private person, awarding $250,000 in compensatory damages for emotional harm. The officer moved to alter or amend the judgment or for a new trial, arguing lack of notice on the private person claim and excessiveness of damages, but the district court denied the motion.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that the complaint sufficiently alleged gross negligence as a private person and that the officer had notice of this claim. The court rejected the officer’s arguments regarding supplemental jurisdiction, plain error in jury instructions, and excessiveness of damages, finding no abuse of discretion or plain error by the district court. The judgment was affirmed. View "Nicholson v. Durant" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

Juan Mendez was approached by two Chicago police officers investigating a gunshot detected near his home early one morning. As the officers arrived and questioned Mendez and a juvenile on the porch, Mendez suddenly fled, jumping a fence and running down an alley. The officers pursued him, with one warning that Mendez had something in his waistband and then in his hand. During the chase, Mendez fell, got up, and turned toward the officers with an object in his hand. One officer, perceiving a threat, shot Mendez three times, resulting in paralysis from the waist down.Mendez filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the City of Chicago and the two officers, alleging excessive force in violation of the Fourth Amendment, battery under Illinois law, and seeking indemnification from the City. Both parties moved for summary judgment. The district court granted summary judgment to the defendants, finding that, based on body-camera footage and the circumstances, a reasonable officer would have had probable cause to believe Mendez posed a threat to the officers’ safety. The court also found that, without a Fourth Amendment violation, Mendez could not prevail on his state law claims. Mendez appealed.The United States Court of Appeals for the Seventh Circuit reviewed the record independently and affirmed the district court. The Seventh Circuit held that Officer Szczur had probable cause to believe that Mendez posed a threat of serious physical harm under the totality of the circumstances, making the use of deadly force reasonable under the Fourth Amendment. The court also held that the state law battery and indemnification claims failed for the same reasons. The judgment for the defendants was affirmed. View "Mendez v City of Chicago" on Justia Law