Justia Civil Rights Opinion Summaries

A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case involves Potomac Comprehensive Diagnostic & Guidance Center, Inc. (Potomac), a residential behavioral health center in West Virginia, and two former residents, L.K. and D.S., who were represented by their guardian and conservator, Kelly Young. The plaintiffs alleged that they were abused and neglected by Potomac staff members while residing at the facility for approximately five months spanning the years 2013 and 2014. They asserted claims for negligence and unlawful discrimination in violation of the West Virginia Human Rights Act.The case was initially heard in the Circuit Court of Hardy County, where the jury found in favor of the plaintiffs. Potomac appealed the decision, arguing that the lower court erred in several ways, including denying its pre-trial motion for summary judgment on the issue of whether Potomac is a “place of public accommodations” under the Human Rights Act, and admitting evidence at trial pertaining to the abuse of other children who resided at Potomac and the results of a 2014 investigation of that abuse.The Supreme Court of Appeals of West Virginia found that Potomac is not a “place of public accommodations” under the Human Rights Act and that the lower court erred by not granting summary judgment to Potomac on this issue prior to trial. The court also found that the lower court committed reversible error by admitting the 2014 investigative reports in their entirety into evidence at trial. Consequently, the court reversed the lower court’s final order and remanded the case for a new trial. View "Potomac Comprehensive Diagnostic & Guidance Center, Inc.v. L.K., By Her Guardian and Conservator, Young" on Justia Law

The case involves a developmentally disabled woman, referred to as A.L., who was sexually assaulted by an employee of a transportation service. The transportation service was contracted by Harbor Developmental Disabilities Foundation, a regional center under the Lanterman Developmental Disabilities Services Act. The regional center's role is to assess the needs of developmentally disabled individuals and contract with service providers to meet those needs. A.L. sued the employee, the transportation service, and the regional center, arguing that the regional center had a duty to protect her from sexual assault by the transportation service's employees.The trial court granted summary judgment in favor of the regional center, concluding that the regional center did not have a duty to protect A.L. from sexual assault by the transportation service's employees unless the regional center had actual knowledge of the employee's propensity to engage in such conduct. The trial court's decision was based on the fact that the regional center had no such knowledge in this case.On appeal, the Court of Appeal of the State of California Second Appellate District affirmed the trial court's decision. The appellate court agreed that the regional center had a duty to protect A.L. from sexual assault by the transportation service's employees only if the regional center had actual knowledge of the employee's propensity to engage in such conduct. The court concluded that imposing a broader duty on the regional center would effectively convert regional centers into insurers of all harm to consumers, which could potentially shut down these centers and deny essential services to the entire population of developmentally disabled persons. View "A.L. v. Harbor Developmental Disabilities Foundation" on Justia Law

The case involves three plaintiffs, Xingjian Sun, Xing Zhao, and Ao Wang, who sued their professor, Gary Gang Xu, for various allegations. Sun and Zhao, former students at the University of Illinois at Urbana-Champaign, accused Xu of sexual and emotional abuse. Wang, a professor at Wesleyan University, posted online that Xu had a history of sexually assaulting students. In response, Xu allegedly posted negative comments about Wang and sent a letter to his employer. Xu counterclaimed, asserting a defamation claim against Sun and claims for intentional infliction of emotional distress against all three plaintiffs.The case was tried in the United States District Court for the Central District of Illinois, where a jury found in favor of Xu on all issues and awarded him damages against Sun and Wang. The plaintiffs appealed, arguing that the district court erred in denying their motion for judgment as a matter of law regarding Xu’s intentional infliction of emotional distress counterclaims. They also contended that the district court erred in denying their motion for a new trial, based on the court’s decision to admit evidence that Sun had a relationship with another professor.The United States Court of Appeals for the Seventh Circuit reversed the judgment in favor of Xu on his counterclaim against Wang, finding that no reasonable jury could find Wang's conduct extreme and outrageous under Illinois law. However, the court affirmed the judgment in favor of Xu on his counterclaim against Sun, concluding that a reasonable jury could find that Sun's conduct met the requirements for intentional infliction of emotional distress. The court also affirmed the district court's denial of the plaintiffs' motion for a new trial. View "Sun v. Xu" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The case involves Maria Acosta, who sued six Miami-Dade officers involved in the arrest of her son, Maykel Barrera, who died after the encounter. Acosta alleged federal excessive-force claims and state wrongful-death claims. The district court granted summary judgment to the officers, and Acosta appealed. The United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting summary judgment to five of the six officers on Acosta’s excessive-force claims and to all of the officers on Acosta’s wrongful-death claims.The Court of Appeals found that, viewing the facts in the light most favorable to Acosta, the officers used excessive force when they tased and kicked Barrera while he was subdued, on the ground, and no longer resisting arrest, violating clearly established Fourth Amendment rights.Furthermore, the court vacated the summary judgment on Acosta’s wrongful-death claim, concluding that there was enough evidence for the case to go to trial. The court ruled that the district court erred in emphasizing Acosta’s lack of expert evidence directed to the cause of Barrera’s death since she did not have to present expert testimony to show causation. View "Acosta v. Miami-Dade County" on Justia Law

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

This case revolves around the fatal shooting of Daniel Hernandez by Officer Toni McBride of the Los Angeles Police Department (LAPD). Hernandez's estate and family members filed a lawsuit against McBride, the LAPD, and the City of Los Angeles, alleging violations of Hernandez's Fourth Amendment rights, the family members' Fourteenth Amendment rights, and several state law claims.The United States Court of Appeals for the Ninth Circuit concluded that a reasonable jury could find that the force McBride used in her final two shots was excessive, but she was entitled to qualified immunity because she did not violate clearly established law. The court explained that while the Fourth Amendment excessive force claim could proceed to trial, McBride was protected by qualified immunity because no prior case law established that her conduct was unlawful.The court also dismissed the Fourteenth Amendment claim, stating that plaintiffs failed to show that McBride acted with a purpose to harm without regard to legitimate law enforcement objectives. The court further ruled that the Monell claim against the City of Los Angeles and the LAPD failed because even if there was an underlying constitutional violation, plaintiffs failed to provide any basis for holding the City and LAPD liable for McBride’s actions.However, the court reversed the dismissal of plaintiffs' state law claims for assault, wrongful death, and violation of the Bane Act, determining that the reasonableness of McBride's final shots presented a question for a trier of fact. The court thus sent these claims back to the district court for further proceedings. View "In re Estate of Hernandez v. City of Los Angeles" on Justia Law

In June 2020, a local newspaper in Polk County published an article criticizing a local assistant district attorney, Tommy Coleman. The article claimed that Coleman had "assisted with the prosecution of Michael Morton" while he was a prosecutor in Williamson County. Michael Morton was wrongfully convicted in 1987 due to prosecutorial misconduct, a conviction that occurred before Coleman began practicing law. Morton was exonerated in 2011 after spending nearly 25 years in prison. The article specifically highlighted an instance during a post-conviction hearing where Coleman mocked requests for DNA testing of evidence that would eventually exonerate Morton. Coleman sued the newspaper and its author for defamation, arguing that the claim that he assisted in Morton's prosecution was false and defamatory.The Supreme Court of Texas held that the article's statement that Coleman "assisted with the prosecution of Michael Morton" was substantially true given Coleman’s public involvement in his office’s efforts to resist DNA testing of the evidence that exonerated Morton. The Court ruled that even if the article was not precise in its characterization of Coleman's role, the "gist" of the article - that Coleman supported the efforts to keep Morton behind bars by resisting DNA testing - was substantially true and therefore not actionably defamatory. As such, Coleman's claims were dismissed. View "POLK COUNTY PUBLISHING COMPANY v. COLEMAN" on Justia Law