Justia Civil Rights Opinion Summaries

On Thanksgiving night in 2018, Officer David Alexander, a policeman with the City of Hoover, was on foot patrol at the Galleria Mall in Birmingham, Alabama. During a suspected active shooting situation, Officer Alexander saw Emantic "E.J." Fitzgerald Bradford moving towards two men with a gun in his hand. Without issuing a verbal warning, Officer Alexander shot and killed Mr. Bradford, who was legally authorized to carry his gun and was attempting to provide assistance.April Pipkins, Mr. Bradford's mother and representative of his estate, filed a lawsuit against Officer Alexander, the City of Hoover, and other defendants, asserting Fourth Amendment claims under 42 U.S.C. § 1983 and state law claims for negligence and wantonness. The United States District Court for the Northern District of Alabama dismissed the state law claims and granted summary judgment on the § 1983 claims, ruling that Officer Alexander's use of deadly force was reasonable under the Fourth Amendment and that a verbal warning was not feasible under the circumstances.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decisions. The court held that Officer Alexander acted reasonably under the Fourth Amendment given the circumstances, which included a crowded mall, the sound of gunshots, and Mr. Bradford running with a gun towards two men. The court also found that a verbal warning was not feasible due to the immediate threat perceived by Officer Alexander. Additionally, the court upheld the dismissal of the state law claims, concluding that the Mall defendants did not owe a duty to protect Mr. Bradford from the criminal acts of a third party and that the complaint did not plausibly allege foreseeability or incompetency in hiring, training, and supervising Officer Alexander. View "Pipkins v. City of Hoover, Alabama" on Justia Law

Dennis Christopher Howard sued Spotsylvania County Sheriff Roger L. Harris and Deputy David Setlock for injuries from a self-inflicted gunshot wound while detained in a law enforcement vehicle. Howard claimed Harris was responsible for Setlock’s actions, which he argued constituted gross negligence. The incident began when Howard, a convicted felon, was found with a suicide note and missing shotgun. After being detained and searched, Howard maneuvered his handcuffs, accessed a handgun left in the vehicle, and shot himself.The Circuit Court of Spotsylvania County granted summary judgment for the defendants, ruling that Howard’s gross negligence claim failed as a matter of law and that the defense of illegality barred his claims. The court found that Setlock’s actions did not amount to gross negligence and that Howard’s injuries resulted from his illegal act of possessing a firearm as a convicted felon.The Court of Appeals of Virginia reversed the circuit court’s decision, holding that Howard had stated a viable gross negligence claim and that his claim was not barred by the illegality defense. The appellate court found that there was a genuine dispute of material fact regarding Howard’s mental state and whether it negated the mens rea required for the illegal possession of a firearm.The Supreme Court of Virginia reviewed the case and concluded that Howard’s claim was barred by the defense of illegality. The court held that Howard’s violation of Code § 18.2-308.2, which prohibits convicted felons from possessing firearms, was a proximate cause of his injuries. The court reversed the judgment of the Court of Appeals and entered final judgment for the defendants, finding that Howard’s allegation of an “unsound mind” did not negate the strict liability offense of possessing a firearm as a convicted felon. View "Harris v. Howard" on Justia Law

Raymond Tackett, an inmate with the Indiana Department of Corrections (IDOC), suffered from Hepatitis C (HCV) and did not receive direct-acting antivirals (DAAs), a treatment that cures HCV. He died on November 29, 2019, from complications related to HCV. His daughter, Skyler Tackett, as the personal representative of his estate, filed an Eighth Amendment deliberate indifference claim and a state law medical malpractice claim against the medical professionals who treated him, Wexford Health Services, and Dr. Kristen Dauss, the Chief Medical Officer of the IDOC. She later dismissed all claims except the deliberate indifference claim against Dr. Dauss.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Dr. Dauss, finding that she took reasonable steps to expand access to DAAs and was not responsible for the treatment decisions that led to Mr. Tackett’s death. Ms. Tackett appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court found that Ms. Tackett presented insufficient evidence for a reasonable jury to find Dr. Dauss liable in her individual capacity. The court noted that Mr. Tackett was in a treatment priority group and that Nurse Myers had requested DAAs for him, but there was no evidence that Dr. Dauss’s actions or the IDOC policy prevented him from receiving the treatment. The court concluded that while Mr. Tackett’s death was tragic, there was no evidence that Dr. Dauss’s actions amounted to deliberate indifference under the Eighth Amendment. View "Tackett v Dauss" on Justia Law

Jeremy James Allen, while incarcerated at the Minnesota Correctional Facility in Faribault, filed a complaint against several officials alleging deliberate indifference and medical malpractice related to a hand injury from December 2017. He did not file any grievances with prison officials regarding his injury or medical treatment during his incarceration. Allen's complaint was initially filed in state court and later removed to federal court. After his release from custody, Allen amended his complaint, substituting Charles Brooks and Cheryl Piepho for previously unidentified defendants.The United States District Court for the District of Minnesota granted Allen's unopposed motion to amend his complaint after his release. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim, but did not initially raise the issue of exhaustion of administrative remedies. The district court denied the motion to dismiss on qualified immunity grounds, finding that Allen plausibly alleged a violation of his Eighth Amendment right to adequate medical care.Brooks and Piepho later raised the failure to exhaust defense in a summary judgment motion, arguing that Allen's original complaint, filed while he was incarcerated, was subject to the Prison Litigation Reform Act (PLRA) exhaustion requirement. The district court denied their motion, ruling that the amended complaint, filed after Allen's release, was not subject to the PLRA's exhaustion requirement and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c).The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that Allen's amended complaint, filed after his release, was the operative complaint and not subject to the PLRA's exhaustion requirement. Additionally, the court found that the amended complaint did not relate back to the original complaint because naming John and Jane Doe defendants did not qualify as a "mistake" under Rule 15(c). View "Allen v. Brooks" on Justia Law

Sandra Jones, representing the estate of her deceased son Antonio Jones, filed a lawsuit under 42 U.S.C. § 1983 and Arkansas state law against Faulkner County, Arkansas, and jail officials Garry Stewart, Karen Grant, and Leanne Dixon. She claimed that the officials exhibited deliberate indifference to Antonio’s serious medical needs, violating his Fourteenth Amendment rights, and that Stewart committed medical malpractice. Jones also alleged that Faulkner County’s policies contributed to Antonio’s death.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The court found that the jail officials were not deliberately indifferent to Antonio’s medical needs and that Jones could not establish a medical malpractice claim against Stewart due to the absence of a doctor-patient relationship. The court also dismissed the municipal liability claim against Faulkner County, concluding that no jail policy caused Antonio’s death.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the actions taken by Grant and Dixon did not constitute deliberate indifference. Grant responded to Antonio’s symptoms by placing him on a medical watch and took appropriate actions based on the information available to her at the time. Dixon, who was not a medical professional, followed her superior’s instructions and did not disregard any substantial risk of harm. The court also affirmed the dismissal of the municipal liability claim, as there was no constitutional violation by the county employees. Lastly, the court found no abuse of discretion in the district court’s exercise of supplemental jurisdiction over the state law claim against Stewart. View "Jones v. Faulkner County, Arkansas" on Justia Law

Edward Burrell, an inmate at Clarke County Jail, suffered a heart attack while serving a sentence. Chief Deputy Sheriff and Jail Administrator Tyler Norris drove Burrell to the hospital instead of calling an ambulance and released him from jail to avoid medical costs. Burrell died shortly after arriving at the hospital. Barbara Donald, administratrix of Burrell's estate, claimed that Norris's actions delayed medical care and caused Burrell's death, bringing a federal constitutional claim and an Alabama wrongful-death claim.The United States District Court for the Southern District of Alabama denied Norris's motion for summary judgment on both claims. The court held that Norris was not entitled to qualified immunity because he acted outside his discretionary authority by releasing Burrell early. The court also found that a reasonable jury could determine Norris's actions violated Burrell's constitutional rights. The court did not address whether Norris's actions violated clearly established law. For the wrongful-death claim, the court denied summary judgment under Alabama’s jailer immunity statute, concluding Norris was not acting within the scope of his duties.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Norris acted within his discretionary authority when he decided to drive Burrell to the hospital. The court emphasized that the discretionary-authority inquiry focuses on the general nature of the action, not whether the officer made the correct decision. The court found that Norris's actions did not violate any clearly established constitutional right and concluded that Norris was entitled to qualified immunity for the federal claim, reversing the district court's denial of summary judgment.Regarding the state wrongful-death claim, the court noted that the district court conflated state immunity with statutory jailer immunity. The court vacated the district court's denial of summary judgment on the state claim and remanded for the district court to determine whether to exercise supplemental jurisdiction and, if so, to decide the issue of state immunity. View "Donald v. Norris" on Justia Law

Plaintiff K.C. alleged that she was sexually abused while in foster care under the custody of the County of Merced. The abuse occurred in two separate foster homes between 1971 and 1977. K.C. claimed that she reported the abuse to her social worker, but no corrective action was taken, resulting in continued abuse. She filed a complaint citing negligent acts and omissions by the County and its employees, which she argued proximately caused her injuries.The Superior Court of Merced County sustained the County's demurrer without leave to amend, leading to the dismissal of K.C.'s complaint with prejudice. The court found that the County and its employees were protected by discretionary immunity under Government Code sections 815.2 and 820.2, which shield public employees and entities from liability for discretionary acts.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case and affirmed the lower court's judgment. The appellate court held that the social workers' decisions regarding the investigation of child abuse and the continuation of foster home placements were discretionary acts protected by immunity. The court emphasized that these decisions involved the exercise of judgment and policy considerations, which are shielded from liability to ensure that public employees can perform their duties without fear of civil suits. Consequently, the County was also immune from liability under the derivative immunity provided by Government Code section 815.2, subdivision (b). View "K.C. v. County of Merced" on Justia Law

Misty Coleman alleges that she fell and broke her ankle after slipping on a wet shower floor in a county jail. She pursued constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county, corrections officers, and medical personnel. Coleman claimed that the slippery shower violated the Due Process Clause and that a county policy or custom was behind her poor medical care. She also questioned whether the county could invoke state-law immunity from her negligence claim at the pleading stage.The United States District Court for the Southern District of Ohio dismissed all claims against all parties. The court found that Coleman failed to allege a plausible constitutional violation regarding the slippery shower and did not connect the inadequate medical care to a county policy or custom. The court also held that Ohio law granted immunity to Hamilton County on the negligence claim. The court allowed Coleman to conduct limited discovery to identify unnamed officers and nurses, but her subsequent amended complaint was dismissed as it was filed outside the statute of limitations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's dismissal, holding that Coleman’s claims accrued on the date of her accident and that her amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15. The court also found that Coleman did not meet the requirements for equitable tolling, as she did not allege facts showing that she was intentionally misled or tricked into missing the deadline. The Sixth Circuit affirmed the district court's dismissal of Coleman’s complaint. View "Coleman v. Hamilton County Bd. of County Commissioners" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

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