Justia Civil Rights Opinion Summaries

The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment to Defendants on all claims in this employment case, holding (1) Plaintiff's direct civil action under Iowa Code 70A.28(5), the whistleblower statute, is not precluded by the availability of an administrative remedy; and (2) the district court correctly granted summary judgment on Plaintiff's claims of age discrimination and intentional infliction of emotional distress.Specifically, the Court held (1) section 70A.28(5) expressly creates an independent cause of action in the alternative to administrative remedies under Iowa Code chapter 17A, and therefore, the district court erred when it determined that judicial review following the administrative process was the exclusive means to seek redress for alleged retaliation against a whistleblower; (2) the district court did not err in determining that Plaintiff failed to present sufficient evidence from which a reasonable jury could infer age discrimination was the real reason for Plaintiff's termination; and (3) the district court did not err in granting summary judgment on Plaintiff's intentional infliction of emotional distress claim because none of Defendants' conduct was sufficiently egregious to satisfy the "outrageousness" prong. View "Hedlund v. State" on Justia Law

The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care."Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

Cesar Beltran-Serrano, mentally ill and homeless, was shot multiple times by a Tacoma, Washington Police Officer, Michel Volk. Beltran-Serrano survived the shooting, and through a guardian ad liter, filed suit for negligence and assault and battery against the City of Tacoma. The superior court dismissed the negligence claims on summary judgment, agreeing with the City that Beltran-Serrano’s legal redress would have been as an intentional tort claim for assault and battery. The Washington Supreme Court reversed: “the fact that Officer Volk’s conduct may constitute assault and battery does not preclude a negligence claim premised on her alleged failure to use ordinary care to avoid unreasonably escalating the encounter to the use of deadly force.” The Court concluded Beltran-Serrano presented evidence to allow a jury to find that the City failed to follow accepted practices in Officer Volk’s interactions with him leading up to the shooting, and that his negligence resulted in his injuries. View "Beltran-Serrano v. City of Tacoma" on Justia Law

The Supreme Court affirmed the circuit court's grant of summary judgment to Appellees on Appellant's negligence and civil rights claims, holding that summary judgment was properly granted.Appellant, as special administrator of the estate of his deceased son, filed a wrongful death action against the City of Little Rock and others over the City's alleged mishandling of a 911 call seeking rescue services for his son. The circuit court granted summary judgment in favor of the City. The Supreme Court affirmed, holding (1) the City proved entitlement to municipal immunity under Ark. Code Ann. 21-9-301; and (2) the circuit court did not err in granting summary judgment on Appellant's civil rights claims brought under 42 U.S.C. 1983. View "Yang v. City of Little Rock, Arkansas" on Justia Law

In an intersection, Patterson’s SUV rammed the door of Green’s sedan. According to Green, she was briefly unconscious and, after coming to, was dazed and in intense pain. Southfield Officer Maya arrived and spoke with Patterson, who did not look injured. Maya then went to Green, still on her back on the median. Because Green “didn’t respond too many times,” Maya refrained from asking many questions. Traffic Specialist Birberick arrived while paramedics were looking after Green. Patterson told him that he had entered the intersection with a green light when his car “was struck” by Green’s car. Birberick did not think that the accident was not severe enough to warrant significant investigation. Birberick determined that the physical evidence corroborated Patterson’s account. Birberick did not complete a police incident report but only completed the crash report that Michigan requires for highway-safety planning purposes. In the “Hazardous Action” box, Birberick wrote “none” for Patterson and “disregarded traffic [signal]” for Green. Crash reports cannot be used in court. Green was hospitalized for several days. When she saw the report, she insisted that Patterson ran the light and that she had a witness. Officers followed up but decided against amending the report. Green sued Patterson, then filed a 42 U.S.C. 1983; 1985 action against officers and the city, alleging that the investigation violated her equal protection rights (Green is a black woman, Patterson a white man) and her right of access to the courts. The Sixth Circuit affirmed that the officers were protected by qualified immunity, characterizing the officers’ actions as “mere laxity.” View "Green v. Southfield" on Justia Law

In this personal injury case, the Court of Appeals affirmed the order of the Appellate Division reversing Supreme Court's denial of Defendant's motion for summary judgment, holding that the requisite showing of minimum contacts with New York was lacking.Plaintiffs commenced this personal injury action against several defendants, including the defendant at issue in this appeal, an Ohio firearm merchant who sold a gun to an Ohio resident in Ohio that was subsequently resold on the black market and used in a shooting in New York. Defendant moved for summary judgment, asserting a defense of lack of personal jurisdiction. Supreme Court denied the motion. The Appellate Division reversed and dismissed the complaint as against Defendant. The Court of Appeals affirmed, holding that, in the absence of minimum contacts, New York courts may not exercise personal jurisdiction over Defendant. View "Williams v. Beemiller, Inc." on Justia Law

The Alaska Workers’ Compensation Board denied a Bryce Warnke-Green's request that his employer pay for a van modified to accommodate his work-related disability. On appeal, the Alaska Workers’ Compensation Appeals Commission decided that a modifiable van was a compensable medical benefit. Warnke-Green moved for attorney’s fees. The Commission reduced the attorney’s hourly rate, deducted a few time entries, and awarded him less than half of what was requested. Warnke-Green asked the Commission to reconsider its award, but the Commission declined to do so because of its view that the Alaska Workers’ Compensation Act (the Act) allowed it to reconsider only the final decision on the merits of an appeal. The Alaska Supreme Court granted Warnke-Green's petition for review, and held that the Commission had the necessarily incidental authority to reconsider its non-final decisions. The Court also reversed the Commission’s award of attorney’s fees and remanded for an award that was fully compensable and reasonable. View "Warnke-Green v. Pro-West Contractors, LLC" on Justia Law

In this excessive force action brought under 42 U.S.C. 1983, the Supreme Court affirmed the decision of the circuit court denying summary judgment in favor of Petitioners, correctional officers and the warden at Mount Olive Correction Center (MOCC), on grounds of qualified immunity, holding that genuine issues of material fact precluded summary judgment in this matter.Respondent, an inmate at MOCC, brought this action asserting violations of his federal constitutional rights. The circuit court concluded that Petitioners were not entitled to summary judgment because genuine issues of material fact existed concerning the excessive force, deliberate indifference, and supervisory liability claims brought against them. The Supreme Court affirmed, holding (1) given the genuine issues of material fact in this matter, Petitioners were not entitled to summary judgment based on qualified immunity; and (2) the circuit court's order sufficiently addressed the parties' disparate factual allegations and the legal standards upon which the court's decision was based. View "McCourt v. Delgado" on Justia Law

In 2013, Philadelphia police found drugs and a gun in an apartment that they thought was Randall’s. They arrested Randall. The Philadelphia District Attorney’s Office charged him but dropped all the charges in August 2015. When he was arrested in Philadelphia, he was already on probation in New Jersey and Delaware County, Pennsylvania. Hearing about his arrest, both jurisdictions issued detainers for him. After dropping the charges, Pennsylvania released Randall into New Jersey’s custody. He remained in custody, first in New Jersey and then in Delaware County, until December 24, 2015. On December 26, 2017, Randall sued the Philadelphia Law Department and the police officers who had arrested him under 42 U.S.C. 1983. The district court dismissed Randall’s claims as time-barred. The Third Circuit affirmed, rejecting Randall’s “continuing-violation” argument. Section 1983 borrows the underlying state’s statute of limitations for personal-injury torts. In Pennsylvania, that period is two years. When a Section 1983 claim accrues is a matter of federal law, under which a malicious-prosecution claim accrues when criminal proceedings end in the plaintiff’s favor. For Randall, that happened in August 2015, so he had until August 2017 to file his suit unless something tolled the statute of limitations. The continuing-violation doctrine focuses on continuing acts, not continuing injury. No Philadelphia defendant detained Randall beyond August 2015. View "Randall v. Philadelphia Law Department" on Justia Law

The Supreme Court affirmed the district court’s order dismissing Plaintiff-inmate’s complaint to the extent Plaintiff asserted state tort claims under Nev. Rev. Stat. 41.031 and 41.0337 but reversed the district court’s dismissal as to Plaintiff’s claims made pursuant to 42 U.S.C. 1983, holding that, while a plaintiff must name the State as a party to any state tort claims to comply with sections 41.031 and 41.0337, this statutory requirement does not apply to section 1983 claims.At issue in this case was how sections 41.031 and 41.0337’s requirement that the State be named by a plaintiff as a party to invoke a waiver of Nevada’s sovereign immunity operates when a plaintiff brings an action against state employee pursuant to both those state statutes and 42 U.S.C. 1983. Plaintiff asserted both state tort claims and section 1983 claims against state employees but did not name the State as party to any claims. The district court dismissed the complaint. The Supreme Court reversed in part, holding that Nev. Rev. Stat. Chapter 41’s requirement that a plaintiff name the State as a party to any state tort claims does not apply to section 1983 claims, even when brought in the same complaint as a plaintiff’s state tort claims. View "Craig v. Donnelly" on Justia Law