Justia Civil Rights Opinion Summaries

In this case brought by an alleged victim of child-sex abuse years after the alleged abuse occurred, the Supreme Court held that the Utah Legislature is constitutionally prohibited from retroactively reviving a time-barred claim in a manner depriving a defendant of a vested statute of limitations defense.Plaintiff, who alleged that Defendant sexually abused her in 1981, conceded that each of her claims had expired under the original statute of limitations. Plaintiff, however, argued that (1) her claims were revived when the legislature, in 2016, enacted Utah Code 78B-2-308(7), and (2) her claims against Defendant were timely filed under this statue. The federal court certified this case to the Supreme Court asking the Court to clarify whether the legislature had the authority to expressly revive time-barred claims through a statute. The Supreme Court held (1) the legislature lacks the power to retroactively vitiate a ripened statute of limitations defense under the Utah Constitution; and (2) therefore, section 78B-2-308(7) is an unconstitutional exercise of legislative power. View "Mitchell v. Roberts" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellant's federal and state civil rights claims and state wrongful death claims against the City of Lewiston, the Lewiston School Department (collectively, the City Defendants), and the Maine Department of Agriculture, Conservation and Forestry (DACF), holding that Defendant was not entitled to relief on his allegations of error.Appellant brought this suit after his seventh-grade son died while on a Lewiston school field trip to a state park. The complaint alleged due process violations and wrongful death claims. DACF filed a motion to dismiss. The district court granted the motion, holding that sovereign immunity insulated DACF from Appellant's claims in federal court. The court then granted the City Defendants' motion to dismiss after construing Appellant's due process violation claim as a substantive due process claim under 42 U.S.C. 1983 and the Maine Civil Rights Act, Me. Rev. Stat. Ann. tit. 5, 4682. The First Circuit affirmed, holding (1) Appellant waived any challenge to the dismissal of his claims against DACF; and (2) Appellant's allegations were insufficient to state a constitutional tort claim against the City Defendants. View "Abdisamad v. City of Lewiston" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiff's age discrimination and Older Workers Benefit Protection Act (OWBPA) claims, holding that Plaintiff's OWBPA-compliant waiver and release were knowing and voluntary under federal common law.Plaintiff, a former Winchendon police officer, decided to resign with a pension after the Defendants determined that he had made several threats against his former girlfriend. Plaintiff resigned instead of facing termination and the possibility of losing his pension and being criminally charged. Plaintiff signed a separation agreement agreeing to waive and release any claims he had against Defendants up and through signing the agreement. Plaintiff later brought a complaint alleging age discrimination, retaliation, and defamation, alleging that the waiver and release in his separation agreement violated the OWBPA and were thus invalid. The district court granted summary judgment on the age discrimination and OWBPA claims for Defendants, and a jury found for Defendants on the retaliation and defamation claims. The Supreme Court affirmed the district court's grant of summary judgment, holding (1) the waiver and release did not violate the OWBPA and were knowing and voluntary; and (2) Defendant's argument that the district court abused its discretion in withdrawing an exhibit at trial was meritless. View "Geoffroy v. Town of Winchendon" on Justia Law

Plaintiff-appellant Nancy Marks was serving a prison term in Colorado when she obtained entry into a community corrections program operated by Intervention Community Corrections Services (Intervention). To stay in the program, plaintiff needed to remain employed. But while participating in the program, she aggravated a previous disability and Intervention deemed her unable to work. So Intervention terminated plaintiff from the program and returned her to prison. Plaintiff sued, blaming her regression on two Colorado agencies,: the Colorado Department of Corrections (CDOC) and the Colorado Department of Criminal Justice (CDCJ). In the suit, plaintiff sought damages and prospective relief based on: (1) a violation of the Americans with Disabilities Act and the Rehabilitation Act; and (2) a denial of equal protection. The district court dismissed the claims for prospective relief and granted summary judgment to the CDOC and CDCJ on the remaining claims, holding: (1) the Rehabilitation Act did not apply because Intervention had not received federal funding; (2) neither the CDOC nor the CDCJ could incur liability under the Americans with Disabilities Act or Rehabilitation Act for Intervention’s decision to regress plaintiff; and (3) plaintiff did not show the regression decision lacked a rational basis. After review, the Tenth Circuit agreed that (1) claims for prospective relief were moot and (2) neither the CDOC nor CDCJ violated plaintiff's right to equal protection. However, the Court reversed on the award of summary judgment on claims involving the Rehabilitation Act and the Americans with Disabilities Act, finding the trial court mistakenly concluded the Rehabilitation Act did not apply because Intervention had not received federal funding, and mistakenly focused on whether the CDOC and CDCJ could incur liability under the Rehabilitation Act and Americans with Disabilities Act for a regression decision unilaterally made by Intervention, "This focus reflects a misunderstanding of Ms. Marks’s claim and the statutes." The matter was remanded for further proceedings. View "Marks v. Colorado Dept. of Corrections" on Justia Law

In 2010, plaintiff-appellant James Payne pled nolo contendere to stalking in Case No. CF-2010-27 in Pittsburg County, Oklahoma. He received a five-year deferment with special rules and conditions of probation. He was required to have no contact with the stalking victim. In addition, Payne pled guilty to violating a protective order in many other cases filed in Pittsburg County related to the same victim and was sentenced to six months in the county jail. The sentences were to run concurrently. He received extra credits and was released from custody on May 5, 2010. A month later, on June 10, 2010, the district attorney filed a motion to accelerate the deferred judgment for probation violations, alleging Payne had been contacting and harassing the victim. The district court issued a felony warrant and Payne was arrested and booked into jail by the Pittsburg County Sheriff's Office on June 11, 2010. Payne did not post bail and remained in the county jail. The district court ultimately executed a minute order finding Payne guilty of violating the terms of his deferred sentence, for which he received a five year sentence: four suspended and one year to serve in the Department of Corrections. Payne received credit for time served in the county jail since his June 10 arrest. The Judgment and Sentence ordered Payne into DOC custody and directed the Pittsburg Sheriff's office to transfer Payne to the Lexington Assessment and Reception Center to begin serving his time in DOC custody. The Sheriff's Office of Pittsburg County did not transfer Payne to the Lexington Assessment and Reception Center (LARC) until September 6, 2011, almost three months past the end of his sentence. Payne was released that same day without serving any of his time in DOC custody. Payne sue various Pittsburg county corrections and governmental officials, arguing his constitutional rights had been violated because he remained in custody beyond his sentence. The district court granted summary judgment in favor of the defendants. The Oklahoma Court of Civil Appeals affirmed. The Oklahoma Supreme Court granted certiorari on the remaining issue preserved for review, i.e., whether a private right of action under Article 2 Section 9 of the Oklahoma Constitution existed under the facts of this case. The Court held a private right of action existed at the time Payne was detained past his sentence, and remanded for further proceedings. View "Payne v. Kerns" on Justia Law

In these two cases arising from two instances of police misconduct the Court of Appeals held that the police officers were acting within the scope of their employment, and therefore, the City of Baltimore was responsible for compensating the plaintiffs.The officers in these cases were members of the Baltimore City Police Department's now-defunct Gun Trace Task Force. Members of the task force engaged in a wide-ranging racketeering conspiracy, resulting in the officers being convicted in federal court. These two cases arose out of instances in which the officers conducted stops and made arrests without reasonable articulable suspicion or probable cause. The plaintiffs and the officers agreed to a settlement of the lawsuits. As part of the settlements, the officers assigned to the plaintiffs the right to indemnification from the City. Thereafter, the plaintiffs sought payment of the settlements by the City. In both cases, the parties entered into a stipulated settlement of undisputed material facts. The Supreme Court held (1) the stipulations in both cases established that the officers' conduct satisfied the test for conduct within the scope of employment; and (2) therefore, the City was responsible for compensating the plaintiffs for the officers' actions by paying the settlements that the plaintiffs and the officers reached. View "Baltimore City Police Department v. Potts" on Justia Law

After Cody Franklin died in police custody, his father, as administrator of his estate, sued the police officers who struggled with Franklin the night he died, and against the municipalities who employed them. The elder Franklin asserted claims under 42 U.S.C. 1983 for excessive force, and claims under state law for battery and wrongful death. The district court entered summary judgment in favor of the municipalities and all but two of the officers. Those officers filed an interlocutory appeal, arguing they were entitled to qualified immunity on all claims. After review, the Eighth Circuit agreed with the officers with respect to the federal claims, and remanded. With respect to the state claims, the Court remanded for further proceedings, including a determination whether to exercise supplemental jurisdiction over those claims. View "Franklin v. Franklin County, Arkansas" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's decision determining that it had personal jurisdiction over Defendant and entering a judgment in favor of Plaintiff, holding that the factors weighed against the constitutional reasonableness of causing Defendant to defend this suit in Maryland.This case was filed by Defendant's stepson, who was a North Carolina resident, against Defendant, who was also a North Carolina resident. Plaintiff ultimately obtained a default judgment against Defendant in the amount of $99,856.84. The court of special appeals reversed the circuit court's decision with respect to the finding of personal jurisdiction. The Court of Appeals affirmed, holding that Defendant's act of filing a sole lawsuit through counsel did not rise to the level of a "persistent course of conduct" to justify the assertion of personal jurisdiction over her in this matter. View "Pinner v. Pinner" on Justia Law

The Supreme Court answered in the negative questions of law certified from the United States District Court for the Middle District of Tennessee regarding the constitutionality of Tennessee's statutory cap on noneconomic damages, Tenn. Code Ann. 29-30-102, holding that the statutory cap does not violate the right to trial by jury, the doctrine of separation of powers, or the equal protection provisions of the Tennessee Constitution.Specifically, the Supreme Court answered (1) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate a plaintiff’s right to a trial by jury, as guaranteed in Tenn. Const. art. I, 6; (2) the noneconomic damages cap in civil cases imposed by section 29-39-102 does violate Tennessee’s constitutional doctrine of separation of powers between the legislative branch and the judicial branch; and (3) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate the Tennessee Constitution by discriminating disproportionately against women. View "McClay v. Airport Management Services, LLC" on Justia Law

In the early morning hours of March 10, 2012, as hundreds of people emptied out of bars and concert venues in Wichita’s Old Town neighborhood at closing time, two Wichita Police Officers fatally shot Marquez Smart. Smart’s estate and heirs sued the City of Wichita, along with Officers Lee Froese and Aaron Chaffee, alleging the officers used excessive force. Smart. The district court granted summary judgment in favor of Officers Froese and Chaffee on the basis of qualified immunity, reasoning that although the jury could find that the officers had violated Smart’s right to be free from excessive force, the officers had not violated clearly established law under the facts presented. The district court also granted summary judgment in favor of the City. After review, the Tenth Circuit determined there was evidence from which the jury could conclude that the officers were mistaken in their belief that Smart was an active shooter. And there was also evidence from which the jury could conclude, with the benefit of hindsight, their mistake was not reasonable. The court affirmed summary judgment as to all defendants on the first two claims of violation of constitutional rights, and as to Officer Froese and the City with respect to the third claim. But the Court reversed judgment as to Officer Chaffee on Smart’s claim that Officer Chaffee fired the final shots after it would have been apparent to a reasonable officer that Smart was no longer a threat. The matter was remanded for further proceedings. View "Smart v. City of Wichita" on Justia Law