Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the district court's ruling in this eminent domain case between Tenants and City involving the requirement that a condemning authority provide certain relocation benefits and assistance to those displaced by the government's exercise of eminent domain, holding that the district court lacked subject matter jurisdiction over Tenants' petition to recover relocation expenses.Specifically, the Supreme Court held (1) the district court lacked subject matter jurisdiction over Tenants' petition because the Kansas Eminent Domain Procedure Act (EDPA), Kan. Stat. Ann. 26-501 et seq., neither provides a private right of action to recover relocation benefits nor authorizes judicial review of relocation-benefit determinations in eminent-domain appeals; (2) while the Kansas Relocation Assistance for Persons Displayed by Acquisition of Real Property Act (KRA), Kan. Stat. Ann. 58-3501 et seq., does provide an administrative remedy to vindicate the statutory right to relocation benefits, Tenants' failure to exhaust this administrative remedy deprived the district court of subject matter jurisdiction under the KRA; and (3) while Kan. Stat. Ann. 60-2101(d) authorizes appeals to the district court from certain final judgments and orders of a political subdivision, the statute did not apply in this case. View "Kan. Fire & Safety Equipment v. City of Topeka" on Justia Law

Jenkins purchased a 1987 Oldsmobile and a 2001 Chevrolet and transferred the titles to his mother, Buchanan, retaining exclusive use of both vehicles. The DEA, investigating Jenkins for drug conspiracy crimes, seized the vehicles, which were towed to an impound lot. The DEA obtained a search warrant, which was executed in October 2012. In April 2013, Jenkins pled guilty and was sentenced to 252 months of imprisonment. In October, the impound lot sent letters to the address on file for Buchanan notifying her that the vehicles could be reclaimed upon payment of towing and storage charges. Buchanan did not receive the letters, having moved. No letter was addressed to Jenkins. Jenkins acknowledged that he “was informed" to pick up the vehicles. In February 2014, the impound lot sent final notices to Buchanan, who was incarcerated, then sold the vehicles, retaining the proceeds.In 2017, Jenkins moved in his criminal case for the return of the cars (FRCP 41(g)). The government responded that the cars “are available for return.” The court dismissed the motion. In 2019, Jenkins unsuccessfully sought monetary compensation in excess of $10,000, then filed a civil action under the Little Tucker Act, 28 U.S.C. 1346(a)(2), alleging a physical taking of his vehicles. The Sixth Circuit vacated summary judgment. While the government’s police power may preclude liability for an initial seizure, there is no police power exception that precludes takings liability for the period after the property is not needed for criminal proceedings. The court noted a factual issue of abandonment and affirmed the dismissal of the due process clause for lack of jurisdiction, without prejudice. View "Jenkins v. United States" on Justia Law

This appeal arises from the tragic death of a man who died while in custody. Appellants appealed the district court’s orders dismissing their claims against the Sheriff and granting summary judgment to the Fulton County Sheriff’s Department Officers, NaphCare, and a NaphCare employee.   The Eleventh Circuit affirmed the district court’s dismissal of the claims against the Sheriff and its grant of summary judgment to both the Officers and the employee. However, the court vacated and remanded the district court’s summary judgment in favor of NaphCare. The court explained that in Appellants’ response to NaphCare’s motion for summary judgment, Appellants relied mainly on the medical report and deposition of Dr. Timothy Hughes but also referred to the report and deposition of two other witnesses, as required by O.C.G.A. Section 9-11-9.1. Dr. Hughes’s report concluded the failure of NaphCare medical staff to properly screen, examine, and treat the decedent was the proximate cause of his death. This testimony is supported by the other witnesses. The court agreed with Appellants that, based on Dr. Hughes’s testimony, there is enough of a genuine issue of material fact for NaphCare’s liability to reach a jury. Dr. Hughes did not solely rest his argument on NaphCare’s failure to sedate the decedent. It was the failure of the staff to follow through with the decedent at all that was the problem. While this included the need for sedation, it also included immediate classification to suicide watch and observation. View "April Myrick, et al v. Fulton County, Georgia, et al" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Matthew Haney's complaint, brought as the Trustee of the Gooseberry Island Trust, against the Town of Mashpee and its Zoning Board of Appeals, holding that Haney's arguments on appeal were either waived or meritless.Haney brought this action seeking a declaratory judgment that Defendants' actions constituted uncompensated taking of property in violation of the Fifth Amendment of the United States Constitution due to an unconstitutional taking and the Massachusetts Constitution due to inverse condemnation. The district court dismissed the complaint on the grounds that the claims were not ripe for review. The First Circuit affirmed, holding (1) Haney waived his argument relative to whether the government had reached a final decision on the Trust's request for variances; and (2) Haney's remaining arguments were meritless. View "Haney v. Town of Mashpee" on Justia Law

Tyler's Hennepin County, Minnesota condominium accumulated about $15,000 in unpaid real estate taxes plus interest and penalties. The County seized the condo and sold it for $40,000, keeping the $25,000 excess over Tyler’s tax debt for itself, Minn. Stat. 281.18, 282.07, 282.08. The Eighth Circuit affirmed the dismissal of Tyler’s suit.The Supreme Court reversed. Tyler plausibly alleges that Hennepin County’s retention of the excess value of her home above her debt violated the Takings Clause. Whether the remaining value from a tax sale is property protected under the Takings Clause depends on state law, “traditional property law principles,” historical practice, and Supreme Court precedents. Though state law is an important source of property rights, it cannot “sidestep the Takings Clause by disavowing traditional property interests” in assets it wishes to appropriate. The County's use of its power to sell Tyler’s home to recover the unpaid property taxes to confiscate more property than was due effected a “classic taking in which the government directly appropriates private property for its own use.” Supreme Court precedent recognizes that a taxpayer is entitled to any surplus in excess of the debt owed. Minnesota law itself recognizes in other contexts that a property owner is entitled to any surplus in excess of her debt. The Court rejected an argument that Tyler had no property interest in the surplus because she constructively abandoned her home by failing to pay her taxes. View "Tyler v. Hennepin County" on Justia Law

In this action brought by Utah Stream Access Coalition (USAC) after USAC members were cited for trespass for wading in the Provo River on property owned by VR Acquisitions the Supreme Court held that the district court correctly entered judgment against USAC.In its complaint, USAC claimed that the Public Waters Access Act (PWAA) violated Utah Const. art. XVII and XX and federal common law. The district court entered summary judgment against USAC on its article XVII and federal common law claims but, after a bench trial, determined that the PWAA violated article XX. On appeal, the Supreme Court determined that the district court made a threshold error in reaching its article XX determination and remanded with instruction that the court address the threshold question of whether the easement identified in Conaster v. Johnson, 194 P.3d 897 (Utah 2008), had a historical basis as a public easement at the time the Utah Constitution was framed. On remand, the district court granted summary judgment for VR Acquisitions and the State. The Supreme Court affirmed, holding that because USAC did not identify an affirmative, 19th-century legal basis for a Conaster easement, the district court correctly ruled that USAC did not make the threshold showing. View "Utah Stream Access Coalition v. VR Acquisitions, LLC" on Justia Law

Nashville passed a “sidewalk ordinance.” To obtain a building permit, an owner must grant an easement across their land and agree to build a sidewalk on the easement or pay an “in-lieu” fee that Nashville will use to build sidewalks elsewhere.In a challenge to the ordinance under the Fifth Amendment’s Takings Clause, the landowner plaintiffs asked the court to apply the “unconstitutional-conditions” test that the Supreme Court adopted in 1987 to assess conditions on building permits (Nollan v. California Coastal Commission). Nashville argued that the Court has applied Nollan’s test only to ad hoc administrative conditions that zoning officials impose on specific permit applicants—not generally applicable legislative conditions that city councils impose on all permit applicants. For legislative conditions, Nashville argued in favor of the application of the deferential “balancing” test that the Court adopted to assess zoning restrictions in “Penn Central” (1978). The district court granted Nashville summary judgment.The Sixth Circuit reversed, agreeing with the landowners. Nothing in the relevant constitutional text, history, or precedent supports Nashville’s distinction between administrative and legislative conditions. Nollan’s test should apply to both types, including those imposed by the sidewalk ordinance. View "Knight v. e Metropolitan Government of Nashville and Davidson County" on Justia Law

In 2017, the County initiated an administrative tax foreclosure against BSI. The County Board of Revision (BOR) issued its final adjudication of foreclosure in June 2019. Because the County had opted for the alternative right of redemption, BSI had 28 days to pay the taxes before the County took title to the property. Days later, BSI filed a Chapter 11 bankruptcy petition, which automatically stayed the BOR’s final judgment and 28-day redemption period. The bankruptcy court granted the County relief from the stay on January 17, 2020. The BOR determined that the statutory redemption period expired on January 21, 2020. On January 30, rather than sell the property, the County transferred it to its land bank (Ohio Rev. Code 323.78.1). When a county sells foreclosed property at auction, it may not keep proceeds beyond the taxes the former owner owed; if the county transfers the property to the land bank, “the land becomes ‘free and clear of all impositions and any other liens.’”BSI filed suit, 42 U.S.C. 1983, alleging that a significant difference between the appraised value of the property and the amount that the County alleged BSI owed meant that the County’s action violated the Takings Clause. The district court dismissed the case under the two-year statute of limitations. The Sixth Circuit reversed. The limitations period began to run when the redemption period ended on January 21, 2020. If BSI paid its delinquent taxes during that period, the County would have been prohibited from taking the property. View "Beaver Street Investments, LLC v. Summit County, Ohio" on Justia Law

An Ohio tax lien on real property is enforced through a foreclosure action, which may result in a sale of the property at auction. If such a sale occurs and the price exceeds the amount of the lien, the excess funds may go to junior lienholders or the owner. If the tax-delinquent property is abandoned, an auction may not be required; the property may be transferred directly to a land bank, free of liens. When that happens, the county gives up its right to collect the tax debt, and any junior lienholders and the owner get nothing. The properties at issue were transferred directly to county land banks. US Bank owned one foreclosed property and claims to have held mortgages on the other two. US Bank alleges that at the time of the transfers, the fair market value of each property was greater than the associated tax lien and that the transfers to the land banks constituted takings without just compensation.The Supreme Court of Ohio affirmed the dismissals of the suits. US Bank lacks standing in one case; it did not hold the mortgage at the time of the alleged taking. As to the other properties, US Bank had adequate remedies in the ordinary course of the law. It could have redeemed the properties by paying the taxes; it could have sought transfers of the foreclosure actions from the boards of revision to the common pleas courts; it could have appealed the foreclosure adjudications to those courts. View "US Bank Trust, National Association v. Cuyahoga County" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claim brought by the Back Beach Neighbors Committee alleging that the Town of Rockport, Massachusetts committed a class-of-one equal protection violation by failing adequately to enforce local rules against scuba divers at Back Beach, holding that the district court did not err.The Committee brought this complaint claiming that the Town's failure consistently to enforce various rules as to Back Beach led to the singling out of the beach as a place "to welcome divers." The district court granted the Town's motion to dismiss as to six of the complaint's eight counts and then granted summary judgment for the Town on the remaining counts. The First Circuit affirmed, holding that because the Committee did not plausibly allege the existence of similarly-situated comparators, its class-of-one equal protection claim failed. View "Back Beach Neighbors Committee v. Town of Rockport" on Justia Law