Justia Civil Rights Opinion Summaries

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

A high school student in the District of Columbia was sexually assaulted by a classmate in a school bathroom. The student’s mother reported the incident to school officials, prompting an investigation by the District. The District ultimately found the assault claim credible and took steps to support the student, including offering counseling and a school transfer. However, the school principal, before any investigation, expressed disbelief in the student’s claim, made derogatory remarks about her, and attempted to undermine the investigation, even after video evidence corroborated the student’s account. The principal’s conduct included misleading superiors and withholding information. The student and her mother later learned of these actions, which caused them significant distress.The United States District Court for the District of Columbia dismissed the student’s claim for negligent infliction of emotional distress (NIED) for failure to state a claim, finding that the school-student relationship alone did not create a special duty under D.C. law. After discovery, the court granted summary judgment to the defendants on the intentional infliction of emotional distress (IIED) and Title IX claims, holding that the District’s response was not deliberately indifferent and that the principal’s conduct did not meet the standard for IIED because the remarks were made outside the student’s presence.The United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of the NIED claim and the grant of summary judgment to the District on the Title IX claims, finding the District’s overall response was not clearly unreasonable and that the principal’s actions could not be attributed to the District for Title IX retaliation. However, the appellate court reversed the grant of summary judgment on the IIED claim against the principal, holding that a reasonable jury could find her conduct was extreme and outrageous, intended or recklessly caused severe emotional distress, and remanded for further proceedings on that claim. View "Doe v. DC" on Justia Law

While incarcerated at a North Carolina state prison in February 2016, Manuel Moreno developed flu-like symptoms and sought medical attention. A nurse examined him and recorded slightly elevated respiration, but otherwise normal vital signs. Dr. Carol Bosholm, the on-duty physician, did not personally examine Moreno but reviewed the nurse’s notes, diagnosed sinus congestion and pharyngitis, and prescribed antibiotics. That same day, several inmates from Moreno’s housing area also reported similar symptoms, and some tested positive for influenza. Dr. Bosholm ordered Moreno and others to be quarantined for seventy-two hours, leaving general instructions for monitoring but no specific orders to check oxygen saturation or respiratory rates. Over the weekend, medical staff made routine rounds, but there is no record that Moreno’s oxygen or respiration were measured, nor that he reported worsening symptoms. By Monday, Moreno’s condition had deteriorated significantly, leading to hospitalization, a seizure, and long-term complications.Moreno filed suit in the United States District Court for the Middle District of North Carolina, alleging state law medical malpractice and gross negligence, as well as a federal claim for deliberate indifference to his serious medical needs under 42 U.S.C. § 1983. The district court excluded his expert’s testimony on the standard of care for the malpractice claim, finding the expert did not meet North Carolina’s requirements for such testimony. At trial, the court granted Dr. Bosholm’s motion for judgment as a matter of law on all claims, concluding Moreno failed to present sufficient evidence of causation, breach of the standard of care, or the heightened culpability required for gross negligence and deliberate indifference.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that Federal Rule of Evidence 601 required application of North Carolina’s expert competency rule for medical malpractice claims, and that Moreno’s expert was properly excluded. The court also found insufficient evidence to support the gross negligence and deliberate indifference claims, upholding judgment for Dr. Bosholm. View "Moreno v. Bosholm" on Justia Law

A man named Donald Prater, Jr. was found partially nude and behaving erratically after leaving a hospital, having previously told a deputy he had used methamphetamine and was hallucinating. Law enforcement officers from the City of Paintsville and Johnson County, along with emergency medical personnel, responded to reports of his behavior. When officers attempted to arrest Prater on a public street, he resisted and force was used, including a taser, pepper spray, and baton strikes. After being handcuffed, Prater stopped breathing and, despite immediate lifesaving efforts, died. The medical examiner found no lethal trauma and attributed the death to excited delirium syndrome, with other health factors possibly contributing.The personal representative of Prater’s estate filed a wrongful death suit in Johnson Circuit Court against various city and county entities and their employees, alleging excessive force, negligence, and wrongful death. The circuit court granted summary judgment to all defendants, finding the officers and emergency personnel were entitled to qualified official immunity, that the force used was reasonable, and that there was no evidence their actions caused Prater’s death. The court also dismissed claims against the city and county entities, including those for negligent hiring and supervision, on the basis that no underlying tort had been established.On appeal, the Kentucky Court of Appeals affirmed in part and reversed in part, holding that some claims against the city and police department for negligent hiring and supervision could proceed, and that the officers’ entitlement to qualified immunity required further factual findings. The Supreme Court of Kentucky reviewed the case and held that all defendants were properly dismissed. The Court concluded that the officers’ actions were discretionary, performed in good faith, and within the scope of their authority, entitling them to qualified official immunity. The Court reversed the Court of Appeals in part, affirmed in part, and remanded for any necessary proceedings. View "CITY OF PAINTSVILLE V. HANEY" on Justia Law

Plaintiffs, thirty survivors of childhood sexual abuse, sought damages for negligence from the Holy See under a vicarious liability theory. They alleged that the Holy See promulgated a mandatory policy of secrecy that governed how its dioceses and bishops handled reports of sexual abuse by clerics. Plaintiffs claimed that bishops in New York failed to warn children and parents of the dangers posed by the accused clerics and failed to report suspected abuse to law enforcement, thus emboldening abusers and exposing children to harm.The District Court granted the Holy See’s motion to dismiss for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The court concluded that the discretionary function exclusion from the FSIA’s tortious activity exception barred Plaintiffs’ claims. The court found that the bishops’ conduct was discretionary and susceptible to policy analysis, thus falling within the discretionary function exclusion.The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the District Court’s judgment. The appellate court agreed that the discretionary function exclusion applied, precluding federal courts from exercising jurisdiction over the claims against the Holy See. The court held that the bishops’ challenged conduct involved discretionary acts and that Plaintiffs failed to allege that the bishops’ conduct violated a mandatory policy. Additionally, the court found that the bishops’ conduct was susceptible to policy analysis, satisfying the second prong of the Berkovitz/Gaubert test. Therefore, the discretionary function exclusion barred the exercise of jurisdiction over Plaintiffs’ claims against the Holy See. View "Blecher v. Holy See" on Justia Law

William Carter, a paraplegic confined to a wheelchair, was arrested for unauthorized use of 911 and spent eight days in the Shreveport City Jail. During his incarceration, Carter, who had pre-existing bedsores, did not receive adequate medical care for his wounds, which allegedly led to their infection and his subsequent hospitalization. Carter's mother, suing on his behalf, filed claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act (RA), 42 U.S.C. § 1983, and Louisiana state negligence law.The United States District Court for the Western District of Louisiana excluded the expert testimony of Dr. Joel Nitzkin before trial. After a jury trial, the court granted the defendants' Rule 50 motion for judgment as a matter of law on the ADA/RA claim, concluding that the claim was about medical treatment rather than an actionable disability claim. The jury returned a verdict for the defendants on the § 1983 and state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, holding that the ADA/RA claim amounted to a complaint about medical negligence, which is not actionable under the ADA. The court found that the failure to change Carter's bandages was a medical treatment issue, not a failure to accommodate under the ADA. Additionally, the court held that Carter's placement in a segregated cell for his safety did not constitute intentional discrimination under the ADA. The court also did not address the exclusion of Dr. Nitzkin's testimony, as it was only relevant to the ADA claims, which failed as a matter of law. The judgment of the district court was affirmed. View "Carter v. City of Shreveport" on Justia Law

Kristopher Birtcher, experiencing a mental health crisis, was reported to law enforcement by a Hobby Lobby manager. Birtcher, unarmed and not threatening anyone, was detained by sheriff’s deputies. During the detention, Birtcher attempted to flee but was subdued by multiple deputies who restrained him in a prone position, applying bodyweight pressure to his back. Despite Birtcher’s pleas that he could not breathe, the deputies maintained the restraint, and Birtcher eventually stopped moving and died from asphyxiation and sudden cardiac arrest.In the Superior Court of San Diego County, the trial court granted summary judgment in favor of the defendants, finding no triable issues of material fact regarding the excessive force claim. The court concluded that the deputies’ actions were in accordance with their training and that Birtcher’s restraint was proper. The court also ruled that plaintiff failed to establish a legal basis for the negligent training claim against Sheriff William D. Gore.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court reversed the trial court’s decision, holding that there were indeed triable issues of material fact regarding the excessive force used by the deputies. The appellate court found that the evidence, including expert testimony, suggested that the deputies’ use of bodyweight pressure on Birtcher while he was restrained in a prone position could be considered excessive force. The court also held that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as there was a statutory basis for the claim and evidence suggesting his involvement in the training policies.The appellate court reversed the judgment in favor of all defendants and remanded the matter for further proceedings. View "A.B. v. County of San Diego" on Justia Law

In February 2022, a Minneapolis SWAT team executed a no-knock search warrant at an apartment in search of a murder suspect. Inside, they found Amir Locke, the suspect’s cousin, asleep on a couch. Upon entry, officers kicked the couch and commanded Locke to get on the ground. Locke, wrapped in a blanket, fell to the ground and reached for a nearby handgun. Officer Hanneman ordered Locke to show his hands. Locke began to comply by lowering the gun's barrel and raising his left hand, but before he could fully comply, Hanneman shot Locke three times, resulting in Locke's death.Karen Wells and Andre Locke, co-trustees for Locke’s next of kin, filed a lawsuit against Officer Hanneman and the City of Minneapolis under 42 U.S.C. § 1983 and Minnesota’s wrongful death statute. They claimed Hanneman violated Locke’s Fourth Amendment rights and that the City failed to properly train its officers and address unconstitutional practices. Hanneman moved for judgment on the pleadings, asserting qualified immunity, arguing that body camera footage showed Locke posed a threat. The District Court for the District of Minnesota denied the motion, finding the footage did not clearly contradict the complaint’s allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined it lacked jurisdiction to decide the appeal. The court found that the body camera footage did not blatantly contradict the district court’s assumed facts that Locke did not raise the gun in a threatening manner. Consequently, the court dismissed the appeal, stating it could not address Hanneman’s qualified immunity claim or the City’s municipal liability and state-law claims. View "Wells v. Hanneman" on Justia Law

In this case, the families of Michael Jackson, Carl Wiley, Jr., and Rashad Henderson, who were killed during high-speed police chases in Houston, Texas, sued the City of Houston. They alleged that the Houston Police Department (HPD) has a policy of racial profiling that leads to more high-speed chases in predominantly black neighborhoods, resulting in the deaths of their loved ones. The plaintiffs brought several federal municipal liability claims, including violations of equal protection, Title VI, 42 U.S.C. § 1982, and substantive due process, as well as state tort claims.The United States District Court for the Southern District of Texas granted in part and denied in part Houston's motions to dismiss for lack of subject matter jurisdiction and for judgment on the pleadings. The court dismissed all claims except the equal protection claims and Jackson’s state law claims. Houston then filed an interlocutory appeal, raising issues regarding standing, failure to state federal claims, capacity to sue, and governmental immunity for Jackson’s state law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it lacked jurisdiction to review non-final district court orders except under 28 U.S.C. § 1292(b). The court found that it could only review whether the plaintiffs had standing to assert their equal protection claims. The court held that the plaintiffs lacked standing because their injuries did not stem from unequal treatment based on race. Consequently, the court reversed the district court’s order regarding standing for the equal protection claims and vacated the district court’s decision on governmental immunity for Jackson’s negligence claim, remanding the case for further proceedings. View "Jackson v. City of Houston" on Justia Law