Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals on a survival claim brought by the estate of Clark Davis against United Rentals North America, Inc., rendered a take nothing judgment on this claim, and remanded the case to the district court for a new trial on the remaining claims, holding that racial considerations impermissibly tainted the selection of the jury in the underlying trial.During jury selection, Plaintiffs' counsel stated that "the African-American female was the most favorable juror in this case," and this announced preference was consistent with Plaintiffs' peremptory strikes. The jury returned a verdict for Plaintiffs, and the district court awarded $5 million to Davis's estate. The court of appeals affirmed. The Supreme Court reversed, holding that a new trial was required because counsel stated a racial preference in jury selection, the peremptory strikes were consistent with that preference, and the district court did not remedy the issue. View "United Rentals North America, Inc. v. Evans" on Justia Law

The Washington State Criminal Justice Training Commission (“CJTC”), the City of Spokane, and others (collectively, the “CJTC Defendants”) moved for summary judgment in the district court on Plaintiff’s state law claims, asserting that they are entitled to statutory immunity under Wash. Rev. Code (“RCW”) 43.101.390(1). The district court denied summary judgment, and the CJTC Defendants appealed.   The Ninth Circuit certified to the Washington Supreme Court the following question: What is the scope of immunity provided by RCW 43.101.390? Specifically, does the provision grant immunity for intentional torts committed in the course of administering the Basic Law Enforcement Academy? View "JOHN CRUZ V. CITY OF SPOKANE, ET AL" on Justia Law

Plaintiff alleged that he was denied a bathroom break by his supervisor at a Dallas, Texas, warehouse until he was forced to defecate on himself at his workstation. Plaintiff sued his employer, UPS, for negligent supervision, invasion of privacy, and intentional infliction of emotional distress (IIED). The district court dismissed the first two claims under Fed. R. Civ. P. 12(b)(6) and granted UPS’s motion for summary judgment on the third. Plaintiff appealed.   The Fifth Circuit affirmed in part and reversed in part. The court explained that the district court correctly held that Plaintiff has not met the standard for IIED claims. However, it erred in concluding that Plaintiff’s negligent supervision claim was preempted by federal law. Further, the court wrote that based on its Erie guess, the court also disagreed with the district court’s conclusion that the alleged facts do not constitute an invasion of privacy. The court concluded that the invasion of privacy tort covers the alleged facts. In recent years, there have been troubling reports of industry practices that deny employees adequate bathroom breaks. It is important to clarify that such actions, or similar examples of public humiliation by an exhibition of intimate personal details or actions, are not immune from liability. View "Amin v. United Parcel Service" on Justia Law

Plaintiffs appealed from a judgment dismissing their lawsuit against Defendant following Defendant’s successful motion for judgment on the pleadings on the sole claim in the operative complaint, malicious prosecution. The operative complaint alleges that Defendant falsely reported to law enforcement that Plaintiffs had attacked her. It further alleges that Defendant’s false reports led to a law enforcement investigation, at the conclusion of which the district attorney declined to press charges. The trial court concluded that the operative complaint does not sufficiently allege a malicious prosecution claim because such a claim requires an adjudicative proceeding. The court further denied Plaintiffs’ leave to amend. On appeal, Plaintiffs challenge the court’s reliance on Van Audenhove v. Perry (2017) 11 Cal.App.5th 915 (Van Audenhove).   The Second Appellate District affirmed. The court concluded that Plaintiffs have standing to appeal. To the merits, the court agreed with Van Audenhove and agreed with the court below that, under Van Audenhove, the operative complaint is fatally defective. The proposed factual allegations Plaintiffs proffer they could allege if given leave to amend, would not address the deficiency in the only cause of action alleged in the complaint. Further, Plaintiffs are not entitled to amend their complaint to add causes of action they had voluntarily dismissed earlier in the litigation because Plaintiffs offered no explanation for their yearslong delay in seeking to do so. Nor are Plaintiffs entitled to add an abuse of process claim they had not previously alleged because this claim is time-barred and does not relate back to the sole cause of action in the operative complaint. View "Bidari v. Kelk" on Justia Law

This appeal arises from Plaintiff’s suit against the City of Harahan (“the City”) for its alleged deprivation of his Fourteenth Amendment right to due process. In October 2019, the Harahan Police Department (“HPD”) Chief of Police determined that Plaintiff was guilty of numerous offenses. Plaintiff was entitled to a fifteen-day appeal window of the Chief’s disciplinary determinations. Plaintiff exercised his right to appeal a week after the charges. However, the Chief emailed the Jefferson Parish District Attorney’s office (“JPDA”) to inform it of his disciplinary action against Plaintiff before he exercised his right. Plaintiff brought a civil rights suit against the City for violation of his procedural due process rights, stigma-plus-infringement, and defamation. He included Louisiana state law claims for defamation, invasion of privacy, and negligence. The City moved to dismiss his Section 1983 claims under Rule 12(c). The primary issue is whether the district court erroneously determined that Plaintiff had a liberty interest in his “future employment as a law enforcement officer.   The Fifth Circuit reversed the district court’s denial of the City’s Rule 12(c) motion and dismissed Plaintiff’s due process claim. The court explained that Plaintiff’s alleged liberty interest in his career in law enforcement has no basis in Supreme Court or Fifth Circuit precedent. Moreover, he does not provide a different constitutional anchor for this proposed liberty interest. Because he fails to state facts supporting the violation of a cognizable liberty interest, he fails to plead a due process violation. Furthermore, the court declined to address the adequacy of the process he received. View "Adams v. City of Harahan" on Justia Law

The Supreme Court held that certain statements made on air by a radio talk show host about a political figure could not serve as a basis for a defamation action given each statement's content, the overall context, and the protections afforded to core political speech by the First Amendment.Respondent Daniel McCarthy, a "Republican political hopeful," sued James Harris, a radio host on a local station owned by iHeartMedia, Inc. (collectively, Petitioners), alleging that statements made by Harris on his radio show were defamatory. Petitioners filed a motion to dismiss, arguing that the statements were rhetorical hyperbole incapable of being proved false and thus protected by the First Amendment. The trial court denied the motion to dismiss. The Supreme Court reversed, holding that none of the statements at issue were actionable because none of them could be reasonably interpreted as asserting or implying false statements of fact that defamed McCarthy. View "Harris v. Honorable Warner" on Justia Law

Plaintiff was struck by a truck driver on Interstate 20. A jury found the truck driver liable for the accident and, although Plaintiff cited millions of dollars in damages, the jury awarded him just $37,500. Plaintiff unsuccessfully moved for a new trial or remittitur on the basis of an alleged Batson violation and improper comments made by defense counsel during the closing argument.The Fifth Circuit affirmed, explaining that the “jury verdicts on damages may be overturned only upon a clear showing of excessiveness or upon a showing that they were influenced by passion or prejudice.” Here, defense counsel’s repeated comments implying Plaintiff’s counsel was trying to obtain as large a damages award as possible may have been improper, but they do not warrant a new trial.Additionally, the court rejected Plaintiff’s Batson claim, finding that defense counsel had a legitimate, nondiscriminatory reason for striking the jurors based on their belief that truck drivers should be held to a higher standard of care. View "Heckman v. Gonzalez-Caballero" on Justia Law

Moss Gropen brought suit against, among other defendants, Cyrus Shabrang and Michael Noud (together, Real Parties in Interest) arising out of Gropen’s treatment at a hospital. Gropen appeared at the noticed deposition with his wife Laura Gropen. Defense counsel objected to Laura’s presence at the deposition because she was a percipient witness in the action and could be deposed in the future. Gropen’s deposition did not proceed beyond the parties stating their objections on the record. Real Parties in Interest subsequently filed a motion for protective order and sanctions, asking the court to exclude Laura from Gropen’s deposition. At the hearing on the motion, for the first time, Gropen’s counsel explicitly requested under California Rules of Court, rule 1.100, that accommodations be provided to Gropen because he was suffering from Post-Traumatic Stress Disorder (PTSD), a recognized disability under the Americans with Disabilities Act of 1990 (ADA). The court acknowledged that PTSD fell under the ADA but found Gropen’s request for an accommodation untimely. It thus granted the protective order and sanctioned Gropen. Gropen petitioned for a writ of mandate, arguing that the superior court abused its discretion in granting the protective order and erred by not considering the evidence that Gropen was diagnosed with PTSD. Gropen also maintained that his request that Laura attend his deposition was a reasonable accommodation. The Court of Appeal concluded Gropen’s request for accommodation was timely, the district court abused its discretion by failing to remand the matter to the superior court with instructions to deny the motion for a protective order and sanctions, and to properly consider Gropen’s request under Rule 1.100. View "Gropen v. Super. Ct." on Justia Law

A trusted prison inmate was working unsupervised in a hog barn when the ceiling collapsed, striking him in the head. He told the prison agricultural specialist that he needed medical attention. But the specialist thought the inmate looked no worse for wear and ordered him back to work. A short while later, the inmate asked another prison staffer for medical attention. The staffer radioed a supervisor. Based on the staffer’s report, the supervisor, too, thought nothing serious had happened and did not immediately grant the inmate’s request. The inmate’s condition later worsened. He was sent to the hospital and diagnosed with a traumatic brain injury. Plaintiff sued under 42 U.S.C. Section 1983, alleging that prison staff violated his Eighth and Fourteenth Amendment rights by acting with deliberate indifference towards him. Under the Texas Tort Claims Act, Plaintiff alleged premises-liability claims. The district court granted summary judgment to Defendants based on qualified immunity.   The Fifth Circuit affirmed. The court explained that Plaintiff failed to raise a factual dispute over whether the prison officials acted with deliberate indifference. But even if he had, he’d still need to show that his rights were “clearly established at the time of the violation.” The court explained that involves showing that “the violative nature of particular conduct is clearly established.” It just isn’t enough to identify a right as “a broad general proposition.” The district court did not address qualified immunity’s second step. Further, the court agreed with Defendants that even assuming a violation, the law was not clearly established under this standard. View "Rogers v. Jarrett" on Justia Law

Plaintiff, a now-retired Special Agent with the United States Secret Service, filed a civil suit against two United States Park Police officers (“officers”) under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). Plaintiff asserted that the officers violated his rights under the Fourth Amendment by unlawfully seizing him during two traffic stops. A jury found the officers liable for Plaintiff’s emotional injuries resulting from the constitutional violations and awarded him a total of $205,000 in compensatory damages and $525,000 in punitive damages. The district court entered final judgment in accordance with the jury verdict and later denied the officers’ post-trial motions seeking judgment as a matter of law or a new trial.   The Fourth Circuit affirmed. The court concluded that Plaintiff presented a cognizable Bivens claim because his claim is not meaningfully different from the claim asserted in Bivens. Both cases involved allegations of unjustified, warrantless seizures in violation of the Fourth Amendment committed by federal “line” officers conducting routine police work. Also, the officers were not entitled to qualified immunity. They violated Plaintiff’s Fourth Amendment rights by significantly prolonging the initial stop without justification and by initiating a second, unjustified stop. This constitutional right to be free from such unlawful seizures was clearly established at the time the seizures occurred. Further, the court held that Plaintiff presented sufficient evidence of emotional injury to support the compensatory damage award, and the punitive damages award was not excessive. View "Nathaniel Hicks v. Gerald Ferreyra" on Justia Law