Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law

Fox TV obtained permission from Superintendent Dixon to film scenes for the television series, Empire, at the Cook County Juvenile Temporary Detention Center. Fox used the Center’s outdoor yard, visitation room, medical office, and certain living spaces for five days and returned to film retakes on seven additional days. During filming, several housing pods housed more detainees than the Center’s policy suggested; some detainees exercised indoors instead of in the outdoor yard; some classes were moved; and the Center postponed or canceled some extra‐curricular activities and held visitation hours in a smaller room.Three detainees filed a proposed class action lawsuit under 42 U.S.C. 1983. The district court granted Dixon partial summary judgment on qualified immunity grounds because the plaintiffs had not shown “a clearly established right to be free of the arguably modest disruptions” but did not dismiss state law claims. The court reasoned that Dixon acted as the detainees’ guardian and had a fiduciary duty to “protect [them] from harm.” Under the holding, Dixon would only be entitled to sovereign immunity on the state law breach of fiduciary duty claim if he proved that he did not violate the detainees’ constitutional rights. On interlocutory appeal, the Seventh Circuit held that Dixon is immune from suit under the Illinois State Lawsuit Immunity Act. The alleged wrongful conduct arose from decisions Dixon made within the scope of his authority. View "T. S. v. County of Cook" on Justia Law

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