Justia Civil Rights Opinion Summaries

The owner of an outdoor amphitheater in a rural area claimed that the sheriff forced him to hire off-duty deputies as a private security force for events and threatened to close the road leading to his property if he did not comply. After giving plaintiff's attorney three tries at producing a complaint that complied with Rules 8 and 10(b) of the Federal Rules of Civil Procedure, the district court dismissed the case with prejudice. The Seventh Circuit affirmed, noting that each iteration of the complaint was generally incomprehensible and riddled with errors, making it impossible for the defendants to know what wrongs they were accused of committing. The Seventh Circuit ordered plaintiff's attorney to show cause why he should not be suspended from the bar of the court or otherwise disciplined under Rule 46 of the Federal Rules of Appellate Procedure and directed that a copy be sent to the Illinois Attorney Registration and Disciplinary Commission.

The United States appealed an award of attorney's fees and costs under the Hyde Amendment, Pub. L. No. 105-119, section 617, 111 Stat. 2440, 2519, and two attorneys, Sean Cronin and Andrea Hoffman, appeal public reprimands entered against them based on their work as Assistant United States Attorneys in an underlying criminal action marked by hard adversarial tactics. The court held that the district court abused its discretion when it imposed sanctions against the United States for a prosecution that was objectively reasonable, and the district court violated the constitutional right to due process of the two lead prosecutors, when it denied them notice of any charges of misconduct and an opportunity to be heard. Therefore, the court vacated the award of attorney's fees and costs against the United States and the public reprimand of Cronin and Hoffman, but the court denied the request of Cronin and Hoffman that the court reassign the case to a different district judge at this stage.

Appellant appealed the denial of her application for Social Security Administration (SSA) disability benefits where the ALJ concluded that she retained the ability to perform her past relevant work and was therefore not disabled. The court held that the ALJ was not required to give controlling weight to the opinions of appellant's treating physician. The court also held that because there was substantial evidence in the record to support the ALJ's findings, the court declined to disturb the ALJ's decision on the ground that the ALJ failed to comply with the SSA Commissioner's policies in evaluating the severity of appellant's fibromyalgia and that the ALJ failed to give adequate weight to appellant's statements and the statements of her family and friends. The court further held that the ALJ's hypothetical to the vocational expert was proper and there was no evidence in this case to support a finding that bias impacted the ALJ's decision. Accordingly, the Commissioner's final decision to deny appellant's application for benefits was affirmed.

After an injury trial, plaintiff's attorney called jurors to ask about the award of damages and assignment of fault between the parties, apparently believing that there had been a clerical error on the verdict form. After a juror informed the magistrate judge, the judge concluded that the attorney had violated ABA Model Rule of Professional Conduct Rule 3.5 by initiating post-verdict contact with a juror. The Third Circuit vacated, first holding that the attorney had standing to appeal. The judge abused his discretion and denied the attorney's due process rights by not following the disciplinary procedures outlined in Local Rule 83.2(b) of the District Court of the Virgin Islands and by failing to give sufficient notice and an opportunity to be heard prior to finding misconduct and imposing sanctions.

This case arose when Pauline Thomas brought her daughter, Jane Doe and four of her grandchildren, including John Doe and R.N.T. to the Emergency Room at the Hennepin County Medical Center and reported her concerns that Jane Doe might have been sexually abused by R.N.T. Appellants brought suit against appellees claiming that the 72-hour hold placed on John Doe, the internal examination of Jane Doe, and the examination of John Doe violated the children's rights under the Fourth Amendment and that the seizure and search of both children violated the Fourteenth Amendment rights of all appellants. At issue was whether the district court properly granted summary judgment in favor of appellees and denied appellants' motion for partial summary judgment on their claims under 42 U.S.C. 1983. The court rejected appellants' contention that appellees failed to move for summary judgment on all of appellants' claims; that the district court ignored questions of material fact; and that the district court at times used the wrong legal standards when analyzing the facts. The court also held that because it affirmed the district court's adverse grant of summary judgment against appellants, the court did not reach the denial of appellants' partial motion for summary judgment.

Plaintiff sued defendants, the Bureau of Land Management (BLM), the Alaska Department of Transportation (Alaska), and the Alyeska Pipeline Service Company (Alyeska), in federal court, alleging causes of action for inverse condemnation, injunctive relief, nuisance, breach of fiduciary duties, and civil rights violations. At issue was whether the district court properly dismissed the action against the BLM and Alaska on the basis of sovereign immunity. The court held that federal sovereign immunity barred plaintiff's inverse condemnation, injunctive relief, and civil rights violations claims against the United States, but that the Federal Tort Claims Act, 25 U.S.C. 345, could provide a waiver of the government sovereign immunity for plaintiff's nuisance and breach of fiduciary duties claims. Additionally, the court held that the Eleventh Amendment barred plaintiff's action against Alaska in its entirety. Accordingly, the judgment was affirmed in part and reversed in part and remanded.