Justia Civil Rights Opinion Summaries

Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

In 2018, Gary Washington was released from prison after serving 31 years for murder, following a writ of actual innocence. Washington filed a civil lawsuit against the police officers involved in his case, alleging they coerced a witness into providing false testimony, which was later recanted. The district court granted summary judgment in favor of the officers, dismissing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress. The court found Washington was collaterally estopped from relying on the witness's recantation because a prior state court had found it incredible. The district court also dismissed Washington's alternative due process Brady claim and his intentional infliction of emotional distress claim on independent grounds.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state court decision granting Washington a writ of actual innocence was inconsistent with the prior post-conviction ruling that the recantation was incredible, precluding the application of collateral estoppel. The court also found that applying collateral estoppel to prohibit Washington from litigating the alleged misconduct was incompatible with equitable principles. The court agreed with the district court's dismissal of Washington's alternative due process Brady claim but reversed the dismissal of his intentional infliction of emotional distress claim, finding that wrongful incarceration for 31 years could constitute severe emotional distress.The Fourth Circuit reversed the district court's grant of summary judgment in part and affirmed it in part, allowing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress to proceed. View "Washington v. Pelligrini" on Justia Law

Jose Villegas, a 39-year-old inmate at Lake Correctional Institution (LCI) in Florida, died following a physical confrontation with correctional officers. The incident began when officers found Villegas unconscious in his cell. Upon regaining consciousness, Villegas resisted the officers' attempts to restrain him. The officers eventually subdued Villegas and transported him to a medical unit, but he was pronounced dead upon arrival. The autopsy reported that Villegas died from restraint asphyxia, with excited delirium as a contributing factor, and noted the presence of synthetic cannabinoids in his system.Douglas B. Stalley, representing Villegas's estate and his minor children, filed a lawsuit against the officers, their supervisors, and the Florida Department of Corrections (FDOC) for negligence, wrongful death, excessive force, deliberate indifference, and supervisory liability. The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants on the constitutional claims and declined to exercise jurisdiction over the state-law wrongful death claim, remanding it to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Stalley appealed the district court's decision regarding the deliberate indifference and supervisory liability claims. The Eleventh Circuit affirmed the district court's ruling, holding that the officers were entitled to qualified immunity. The court found that the officers' decision to transport Villegas to a medical unit rather than provide on-scene care did not violate any clearly established constitutional right. Consequently, the supervisory liability claim also failed, as it was contingent on the underlying constitutional violation. View "Stalley v. Lake Correctional Institution Warden" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law

Officer Henry Volentine, a deputy of the Hardin County Office of Sheriff (HCOS), initiated a traffic stop of Maurice Green on October 14, 2014, after noticing Green's vehicle had an expired license plate belonging to a different vehicle. Green initially pulled over but then drove off, prompting Volentine to pursue him. During the pursuit, Volentine believed Green had committed assault and wanton endangerment by nearly hitting two pedestrians. The pursuit ended in a head-on collision with Susan Sheehy’s vehicle, leading to the present litigation.The Hardin Circuit Court denied Volentine’s and HCOS’ motion for summary judgment based on qualified and governmental immunity. The court found that Volentine did not have a reasonable basis to believe a violent felony had occurred to justify the pursuit and that his actions were not in good faith. The court also determined that Volentine violated ministerial duties by failing to terminate the pursuit when it posed an extreme safety hazard and by not obtaining approval from a supervisor to continue the pursuit.The Kentucky Court of Appeals reversed the trial court’s decision, holding that Volentine was entitled to qualified official immunity and that HCOS was entitled to governmental immunity. The Court of Appeals reasoned that Volentine’s belief that he witnessed a felony was reasonable and that his actions during the pursuit were discretionary.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals. The Supreme Court held that Volentine was not entitled to qualified official immunity because he failed to abide by ministerial duties and lacked good faith in exercising his discretion to initiate the pursuit. Consequently, HCOS’ governmental immunity was waived by operation of KRS 70.040. The case was remanded to the Hardin Circuit Court for further proceedings consistent with the Supreme Court’s opinion. View "SHEEHY V. VOLENTINE" on Justia Law

Henry Washington, a state prisoner, alleged that prison guard T.S. Oswald sexually assaulted him twice, once in 2013 and again in 2015. During the first incident, Washington claimed that Oswald and another guard handcuffed him, fondled him, and attempted to insert a nightstick into his rectum, causing him to bleed. In the second incident, Oswald allegedly fondled Washington and attempted to insert his finger into Washington's rectum while escorting him back to his cell.Washington sued Oswald under 42 U.S.C. § 1983 for cruel and unusual punishment. The jury found in favor of Washington, awarding him $20,000 in compensatory damages and $25,000 in punitive damages for the 2013 assault, and $20,000 in compensatory damages and $200,000 in punitive damages for the 2015 assault. Oswald moved for judgment as a matter of law or a new trial, arguing insufficient evidence and excessive punitive damages. The United States District Court for the Western District of Pennsylvania denied these motions.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that there was sufficient evidence for the jury to find Oswald liable for both assaults. The court also upheld the punitive damages, finding them not excessive under the Due Process Clause. The court noted that Oswald's actions were highly reprehensible, the punitive damages were proportionate to the harm caused, and the awards were consistent with those in comparable cases. The court affirmed the District Court's decision, maintaining the jury's awards. View "Washington v. Gilmore" on Justia Law

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law

Charles Leonhardt, a pretrial detainee at the Big Horn County Jail, suffered from back pain and was eventually diagnosed with two lower back infections after being transported to a hospital. He sued Big Horn County Sheriff Ken Blackburn, Jail Captain Debbie Cook, unnamed detention officers, the Big Horn County Sheriff’s Office, and the Jail, alleging negligence and deliberate indifference under the Fourteenth Amendment.The District Court of Big Horn County granted summary judgment to the defendants on both claims. The court found that Sheriff Blackburn had fulfilled his duty to arrange for medical care by contracting with Midway Medical Clinic, which provided medical services to inmates. The court also determined that the actions of Sheriff Blackburn, Captain Cook, and the detention officers were reasonable and did not proximately cause Mr. Leonhardt’s injuries. Additionally, the court found no evidence of deliberate indifference to Mr. Leonhardt’s medical needs, as the defendants ensured he received timely medical care.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that there was no genuine dispute of material fact regarding the negligence claim, as the defendants acted reasonably and provided Mr. Leonhardt with access to medical care. The court also found no evidence that the defendants were aware of and disregarded an excessive risk to Mr. Leonhardt’s health, thus failing to meet the subjective component of a deliberate indifference claim. Consequently, the court affirmed the summary judgment in favor of the defendants on both the negligence and Fourteenth Amendment deliberate indifference claims. View "Leonhardt v. Big Horn County Sheriff's Office" on Justia Law

Plaintiffs Antonio Juarez, Jose Hinojosa, Jose Espinosa, and Maria Morfin filed a lawsuit against the San Bernardino City Unified School District following an incident involving Officer Alejandro Brown, a District employee. In February 2018, Juarez found a cell phone and later, Officer Brown, tracking his phone, confronted the plaintiffs, identifying himself as a District police officer. Brown, armed and displaying his badge, demanded compliance, struck Juarez with his firearm, and threatened the others. Brown later pled guilty to assault and battery and threatening the plaintiffs under color of law.The Superior Court of Riverside County sustained the District’s demurrer to the plaintiffs’ second amended complaint without leave to amend, leading to the dismissal of the case. The court found the complaint insufficient to establish that Officer Brown was acting within the scope of his employment with the District and dismissed the claims of negligence, battery, assault, negligent hiring, supervision, and retention, false arrest and imprisonment, intentional and negligent infliction of emotional distress, and violation of the Bane Act.The Court of Appeal, Fourth Appellate District, Division One, State of California, reversed and remanded the case. The appellate court held that the scope of employment is a factual issue that cannot be resolved as a matter of law on demurrer. The court found that Officer Brown’s off-duty misconduct, while investigating a suspected theft and wielding his authority as a peace officer, could be regarded as an outgrowth of his employment. The court directed the trial court to vacate its order sustaining the demurrer, enter a new order overruling the demurrer, and conduct further proceedings. The appellate court also rejected the District’s arguments regarding the Bane Act and found the plaintiffs’ allegations sufficient to state a cause of action for negligent hiring, supervision, and retention. View "Juarez v. San Bernardino City Unified Sch. Dist." on Justia Law