Justia Civil Rights Opinion Summaries

This appeal arose from prison officials’ attempt to gain control over an agitated prisoner who refused to obey their orders, locked himself in the prison’s outdoor recreation yard, and threatened prison officials. Officials decided to drop tear gas into the recreation yard. An intake vent in the yard drew the gas in and filtered it into the prison. Numerous prisoners in their cells were exposed to the gas. Prison officials evacuated the prisoners housed in two sections of the prison after they secured the prisoner in the recreation yard. The officials did not, however, evacuate the prisoners in two other sections. On behalf of a class of about one-hundred prisoners, Timothy Redmond sued three of the prison officials for constitutional violations under 42 U.S.C. 1983, claiming the officials violated the Eighth Amendment and Utah’s Constitution by exposing the prisoners to gas, and then failing to provide adequate medical care. The district court granted the defendants’ summary judgment motion. After review of the claims, the Tenth Circuit affirmed: the prison officials’ conduct, at most, only accidently exposed the prisoners to CS gas, and qualified immunity shields government officials from liability for mistakes like this one. And the rest of Redmond’s claims failed either because Redmond forfeited them, failed to prove a constitutional violation occurred, or did not cite case law that clearly established the alleged rights. Furthermore, violating the Utah Constitution required more-than-negligent conduct, and the prison officials’ conduct was “textbook negligence.” View "Redmond v. Crowther" on Justia Law

Cheryl Brown and Matthew Denis were involved in a traffic accident, when Denis’s truck bumped into Brown’s car from behind. Denis claimed the accident happened when he inadvertently took his foot off the brake as he turned to roll the rear window down to provide fresh air to his dog, who was riding in the back seat. Denis’s truck, which was positioned behind Brown’s car, rolled forward five to six feet, striking her rear bumper. The collision took place in stop-and-go traffic. Denis, a sergeant with the Vermont State Police, estimated his speed at impact to be two miles per hour and did not believe there was any damage caused to Brown’s vehicle from the collision. Brown claimed the impact caused a scratch on her rear bumper. The truck Denis was driving did not have any markings indicating it was a police vehicle. Brown filed suit against the State of Vermont alleging it was responsible for injuries she sustained in the accident due to Denis’s negligence. Brown also raised constitutional claims, alleging: (1) due process and equality of treatment violations under the Vermont Constitution’s Common Benefits Clause, and (2) an equal protection, and possibly a due process, claim under the United States Constitution. Brown did not name Denis as a defendant in her suit. Brown’s constitutional claims were based on her assertion that Denis received favorable treatment because he was not prosecuted for causing the accident or leaving the scene without providing identifying information. Before trial, the court dismissed the due process and equal protection claims under the United States Constitution on the basis that Brown had only sued the State, and not Denis personally, and that the State was not a “person” for claims arising under 42 U.S.C. 1983. The court further ruled that Brown lacked standing to assert any claim based on the State’s failure to prosecute Denis. The court also dismissed the Common Benefits Clause claim because Brown lacked any cognizable interest in the prosecution or discipline of Denis. Lastly, the court held that, to the extent a due process claim had been raised, it was undisputed that Brown received the information required to be exchanged in the event of a car collision shortly after the accident, and her ability to file suit against the State as a result of the accident showed her due process rights were not impeded. On appeal, Brown alleged several errors in pre-trial and trial rulings, as well as in the failure to grant her a new trial. Finding no reversible error, the Vermont Supreme Court affirmed. View "Brown v. Vermont" on Justia Law

Arun Gopalratnam purchased an HP laptop computer that contained a DynaPack battery pack with Samsung lithium-ion battery cells. Months later, the Menomonee Falls Fire Department responded to a major fire in a basement bedroom of the Gopalratnam’s home. After the fire was extinguished, firefighters discovered Arun deceased on the floor of the room. Am autopsy classified smoke inhalation as the cause of death, with no evidence of pre-fire injury or disease, and no drugs or alcohol in Arun’s system. Special Agent Martinez concluded that the fire originated in the basement bedroom where Arun’s body was located. Martinez excluded multiple potential sources of the blaze (electrical and gas meters, electrical distribution panels, gas-fueled furnaces, electrical plugs, light switch, and ceiling light fixture) but could not ascertain the fire’s ultimate cause. He did not eliminate a possible mattress fire. The remains of Arun’s HP laptop, cell phone, and the laptop battery cells, were in the debris. In the Gopalratnams’ suit, alleging negligence, strict products liability, and breach of warranty, the plaintiffs claimed that a defective battery cell in Arun’s laptop caused the fire. The district court granted motions to exclude plaintiffs’ expert witnesses on causation. The Seventh Circuit affirmed. The district court applied the proper legal standard: The admissibility of expert testimony is governed by Federal Rule of Evidence 702 and Daubert. The experts failed to account for other possible explanations. View "Gopalratnam v. ABC Insurance Co." on Justia Law

The Supreme Court denied Garland DeCourcy’s petition for writ of prohibition seeking to prohibit the circuit court from proceeding in this action brought by William Williams to recover a computer, telephone system, and keys to a vehicle from DeCourcy. After a bench trial in magistrate court, DeCourcy was ordered to return certain property to Williams. DeCourcy appealed and filed a motion to dismiss the case on the grounds that Williams could not meet his burden of proof because the evidence should be limited to the evidence presented to the magistrate court. The circuit court ruled that a trial de novo authorized it to consider additional evidence, including witness testimony not presented in magistrate court. DeCourcy then filed this petition for writ of prohibition. The Supreme Court denied the writ, holding (1) an appeal of a civil action tried before a magistrate without a jury under W. Va. Code 50-5-12(b) shall be a trial de novo, meaning a new trial in which the parties may present new evidence including witness testimony not presented in magistrate court; and (2) the circuit court did not err in its determination that new evidence, including witness testimony, was proper in this appeal from magistrate court. View "State ex rel. DeCourcy v. Honorable Jennifer P. Dent" on Justia Law

In this case filed by a Massachusetts-based company (“LevelUp”) against a California-based company (“Punchh”), alleging defamation and related causes of action connected with Punchh’s allegedly false statements about LevelUp to LevelUp’s prospective clients, the superior court allowed Punchh’s motion to dismiss on the grounds that it would not comport with due process to hale Punchh into a Massachusetts court. The Supreme Judicial Court remanded this matter to the superior court for further proceedings, holding (1) prior to exercising personal jurisdiction over a nonresident defendant, a judge must determine that doing so comports with both the forum’s long-arm statute and the requirements of the United States Constitution; and (2) the requisite statutory analysis did not occur in this case. View "SCVNGR, Inc. v. Punchh, Inc." on Justia Law

The Supreme Court accepted two questions of law certified to it by the United States Court of Appeals, answering (1) a hyperlink to source material about a judicial proceeding may suffice as a report within the common law fair report privilege; and (2) Delucchi v. Singer, 396 P.3d 826, 830 (Nev. 2017), explains that application of Nevada’s anti-SLAPP statute, prior to the most recent amendments in 2013, is not limited to communication addressed to a government agency but includes speech “aimed at procuring any governmental or electoral action.”Plaintiff in this case filed a defamation action against Respondents, who posted an online petition to pressure presidential candidate Mitt Romney to reject Appellant’s campaign contributions, alleging that the petition was false and defamatory. The federal district court concluded that Nevada law governed the controversy and dismissed Appellant’s complaint, ruling that the state’s anti-SLAPP statutes applied. On appeal, the court of appeals certified two questions of law to the Supreme Court. The Supreme Court answered the questions and held (1) the fair report privilege immunizes Respondents from civil liability; and (2) communications with either the government or the public that are intended to influence an electoral result potentially fall under Nev. Rev. Stat. 41.637(1). View "Adelson v. Harris" on Justia Law

The First Circuit affirmed in part and vacated in part the summary judgment granted to Defendants as to all of Plaintiffs’ claims. Plaintiff, a Massachusetts property owner, brought this lawsuit against three police officers challenging the owner’s arrest for actions that he took in connection with his objection to the clearing of vegetation on his property by the work crew for an electrical utility that held an easement on the owner’s property. Specifically, the First Circuit (1) affirmed the entry of summary judgment as to the officers on Plaintiff’s intentional infliction of emotional distress claim and the claims brought under 42 U.S.C. 1983 and Mass. Gen. Laws ch. 12, 11I; (2) affirmed the entry of summary judgment as to one of the officers on the malicious prosecution and false arrest claims; and (3) vacated the entry of summary judgment as to two of the officers on the malicious prosecution and false arrest claims and as to all three officers on the false imprisonment claim and remanded with instructions that the district court remand those claims to state court, holding that contested state law issues prevented summary judgment. View "Wilber v. Curtis" on Justia Law

Adolf Gonzalez was shot and killed in an incident with two Anaheim police officers. Plaintiffs were the Decedent’s mother and minor daughter, who filed a complaint in federal court against the City of Anaheim (the City) and the two officers (collectively, Defendants). The Federal Complaint ("F.E.V. I") asserted four claims for violation of civil rights pursuant to title 42 United States Code section 1983 and state law claims for false arrest/false imprisonment, battery, negligence, and violation of the Bane Act, Civil Code section 52.1. The federal district court granted summary judgment in favor of defendants on the civil rights claims, and declined to exercise supplemental jurisdiction over the state law claims, dismissing them without prejudice. Following that dismissal, Plaintiffs filed a State Complaint, which overlapped the Federal Complaint, but provided more detail. After the Court of Appeal held oral argument in the prior appeal, the Ninth Circuit Court of Appeals issued its panel opinion in Gonzalez v. City of Anaheim, 2013 U.S.App. Lexis 9607, affirming F.E.V. I. On its own motion, the Court of Appeal took judicial notice of that opinion, which confirmed what would have been the outcome based on the status of the judgment at the time of oral argument. Based on Hernandez v. City of Pomona, 46 Cal.4th 501 (2009), the Court of Appeal held that the federal court judgment collaterally estopped Plaintiffs from pursuing their state law causes of action based on both the shooting and on theory the officers’ conduct before the shooting was negligent, and their battery and false arrest/false imprisonment causes of action. Nine months after we issued our opinion, the Ninth Circuit issued its en banc opinion reversing the federal court judgment as to claims of excessive force. In February 2015, Plaintiffs filed a new complaint (the Second State Complaint) asserting the same five causes of action as in the first State Complaint. Plaintiffs filed a motion to vacate the prior state court judgment. The trial court denied the motion. Plaintiffs brought a petition for writ of mandate to challenge the order denying their motion to vacate the judgment. A panel of the Court of Appeal summarily denied the writ petition. Defendants demurred to the Second State Complaint on the ground the claims were barred by collateral estoppel, jurisdiction, and the applicable statute of limitations. After oral argument, the trial court sustained the demurrer without leave to amend. The Court of Appeal found: (1) the Ninth Circuit en banc opinion did not nullify F.E.V. I; (2) plaintiffs could not collaterally attack the judgment affirmed by F.E.V. I; and (3) it would have been manifestly unjust to give claim preclusion effect to the judgement affirmed by F.E.V. I. As such, the case was remanded for further proceedings. View "F.E.V. v. City of Anaheim" on Justia Law

The Supreme Court affirmed the district court’s order dismissing with prejudice Plaintiff’s complaint for failure to state a claim upon which relief could be granted. Plaintiff, which operated commercial grain warehouses and elevators and owned trading businesses through Nebraska, filed a complaint alleging that several defendants engaged in a pattern of behavior with the intent to deprive it of information, an opportunity to be heard, and due process of law. The district court concluded that Defendants were entitled to immunity under Nebraska’s Consumer Protection Act and the Noerr-Pennington doctrine and that Plaintiff’s claims of conspiracy and aiding and abetting required an underlying tort to be actionable. The Supreme Court affirmed, holding (1) Plaintiff failed to state a claim upon which relief could be granted because Defendants were entitled to immunity under the Noerr-Pennington doctrine and Plaintiff alleged only underlying statutory violations; and (2) any amendment to Plaintiff’s petition would be futile. View "Salem Grain Co. v. Consolidated Grain & Barge Co." on Justia Law

Kelcey Patton, a social worker for the Denver Department of Human Services (“DDHS”), was one of those responsible for removing T.D., a minor at the time, from his mother’s home, placing him into DDHS’s custody, and recommending T.D. be placed and remain in the temporary custody of his father, Tiercel Duerson. T.D. eventually was removed from his father’s home after DDHS received reports that T.D. had sexual contact with his half-brother, also Mr. Duerson’s son. DDHS later determined that during T.D.’s placement with Mr. Duerson, T.D. had suffered severe physical and sexual abuse at the hands of his father. T.D. sued Patton under 42 U.S.C. 1983 for violating his right to substantive due process, relying on a “danger-creation theory,” which provided that “state officials can be liable for the acts of third parties where those officials created the danger that caused the harm.” Patton moved for summary judgment on the ground that she is entitled to qualified immunity. The district court denied the motion. Finding no reversible error in that decision, the Tenth Circuit affirmed. View "T.D. v. Patton" on Justia Law