Justia Civil Rights Opinion Summaries

The Nimers own land, zoned for residential use, where they operate a business that produces meat snacks. They began constructing buildings to expand the business to include butchering. They did not get zoning certificates. A state court enjoined the Nimers from putting the buildings to any use other than keeping and feeding animals, without the necessary zoning certificates. Several days after appealing the state court decision, the Nimers sued Litchfield Township in federal court under 42 U.S.C. 1983. The district court decided to abstain and dismissed without prejudice. The Sixth Circuit remanded with instructions to stay the case. While Younger abstention applies to section 1983 damages claims, a district court lacks the power to decide whether to dismiss such a damages claim. Where plaintiffs seek only legal relief (in the form of damages), relief that does not involve the district court’s equitable or discretionary powers, then the district court may not exercise its discretion to decide whether to dismiss the case; instead, the district court must stay the damages claim pending the outcome of the state court proceedings. View "Nimer v. Litchfield Twp. Bd. of Trs" on Justia Law

Quigley was 23 years old, with no known life-threatening physical conditions when he was transferred from one Michigan Department of Corrections (MDOC) facility to an MDOC guidance center, where he was under the care of CMS, a service provider with which MDOC contracted. CMS employees Dr. Thai and physician’s assistant Garver treated Quigley for moderate depression and prescribed medications. After about a month, Quigley was found dead in his cell. The medication chart confirmed that Quigley had been administered both Amitriptyline and Trazodone the previous three days. The autopsy report concluded that Quigley died of an epileptic seizure disorder. Quigley’s estate obtained affidavits from a forensic pathologist, who concluded that Quigley likely died from a fatal drug interaction between the tricyclic Amitriptyline and tetracyclic Trazodone and from a psychiatrist, who similarly concluded that the fatal drug interaction likely killed Quigley. Thai provided three medical-expert affidavits, all concluding that the best explanation for Quigley’s death is epileptic seizure. Quigley’s estate sued Thai, Garver, and CMS under 42 U.S.C. 1983. The district court denied a motion asserting qualified immunity. The Sixth Circuit affirmed, finding that there were unresolved material questions of fact concerning the cause of death. View "Quigley v. Thai" on Justia Law

Coley was convicted in Ohio of aggravated murder, attempted murder, kidnapping, aggravated robbery and firearm specifications, based on events that occurred in 1996. He was sentenced to death on the aggravated murder charges. His petition for state post-conviction relief was rejected at all levels. The federal district court denied his petition for a writ of habeas corpus. The Sixth Circuit affirmed, rejecting claims of ineffective assistance of trial counsel for failure to object to the indictment; ineffective assistance of trial counsel for failure to request that the trial judge recuse herself; prosecutorial misconduct for using inconsistent theories to convict; ineffective assistance of counsel during mitigation; ineffective assistance of counsel during mitigation for failing to request that trial judge recuse herself; ineffective assistance of appellate counsel; failure to consider mitigating evidence; and of error in the trial court’s decisions to not provide Coley with grand jury transcripts and to not sever certain counts. View "Coley v. Bagley" on Justia Law

D.W., age 13, alleged (42 U.S.C. 1983) that state defendants violated his procedural due process rights by listing him on the Tennessee child abuse registry. After an interview with a case manager, D.W. requested review and submitted information regarding the alleged victim’s inconsistent statements, but never was told the evidence against him. Children’s Services upheld the classification. Children’s Services then denied administrative review because the classification did not affect his employment. D.W. claimed that being listed deprived affected his liberty interest in pursuing common occupations, because Tennessee law prohibits his employment with child-care agencies and programs and adult-daycare centers and that the listing prohibits contact with children during the course of state agency employment. The district court held that D.W. did not present a justiciable controversy because the alleged deprivation was the possibility of future harm. The Sixth Circuit reversed. D.W. has standing to seek additional procedures because those procedures, if granted, could result in relief that is sufficiently concrete and particularized. The classification is complete and will not be expunged from state records; this is not a generalized grievance or an injury to a third party. No further facts are needed to determine whether the boy was afforded adequate process. View "Wright v. O'Day" on Justia Law

USCA is a non-profit national civic league with approximately 27,000 members that devotes itself to conservative values and opposes efforts of the federal government to interfere with market processes. Some of USCA’s uninsured members object to the purchase of private health insurance because they do not believe in the effectiveness of traditional medicine, prefer alternative and integrative medicine, or prefer to focus on preventative care that is not covered by traditional health insurance policies. Two individual plaintiffs do not have, nor do they wish to acquire, health insurance, but they are not exempt from the Patient Protection and Affordable Care Act’s individual mandate, 26 U.S.C. 5000A. They challenged the mandate as violating the Commerce Clause, rights to freedom of expressive and intimate association, rights to liberty, and rights to privacy. The district court dismissed in part, without substantive analysis, holding that plaintiffs failed to satisfy the “plausibility standard” and entered summary judgment on the Commerce Clause challenge. The Sixth Circuit affirmed, stating that the Supreme Court’s opinion in National Federation of Independent Business v. Sebelius controls the outcome on the Commerce Clause count and the remaining constitutional claims were correctly dismissed for failure to state a claim. View "U.S. Citizens Ass'n v. Sebelius" on Justia Law

Stoudemire, then age 23, entered the Michigan Department of Corrections system in 2002, suffering from systemic lupus erythematosus, a chronic, painful autoimmune disease; hypercoagulapathy, a related disorder involving tendency to develop blood clots; and depression. Stoudemire bore a significant risk of experiencing kidney and liver damage, heart attacks, amputations, and chronic pain. Stoudemire’s health quickly deteriorated. She experienced a heart attack, liver failure, and life-threatening embolisms. She underwent three amputations, losing both legs below the knee. At her 2007 parole, she suffered from chronic depression, posttraumatic stress disorder, and conditions related to medications. In her suit under 42 U.S.C. 1983, the Americans with Disabilities Act, 42 U.S.C. 12132; and Michigan law, Stoudemire, alleged that she was placed in a segregation unit following her amputation that lacked accommodations for disabled persons, and was subjected to a strip search that served no legitimate purpose. The district court denied motions by the warden and an officer, seeking summary judgment on qualified immunity grounds. The Sixth Circuit vacated with respect to the warden, stating that the court did not adequately analyze deliberate indifference, but affirmed with respect to the officer, stating that the excessively invasive nature of the search outweighed any need to conduct it. View "Stoudemire v. MI Dep't of Corrs." on Justia Law

Luedtke, a pro se federal prisoner, sought a writ of habeas corpus under 28 U.S.C. 2241, alleging that prison officials violated his Thirteenth Amendment rights by refusing to pay him the wages he earned in his prison job, failed to require all inmates to work, discriminated against white inmates in favor of black inmates and “illegal aliens from Mexico,” and improperly placed him on refusal status for the Inmate Financial Responsibility Program. The district court dismissed under its screening authority, 28 U.S.C. 2243. The Seventh Circuit affirmed in part, stating that section 2241 is not the proper vehicle for a prisoner to challenge conditions of confinement. Luedtke’s fourth claim is cognizable under 2241 as a challenge to the execution of a portion of his sentence and the district court erred in dismissing it as unexhausted at the screening stage. Exhaustion is an affirmative defense, generally and in the context of prisoner lawsuits. Even under the Prison Litigation Reform Act, an inmate’s section 1983 claim “may not be dismissed at the screening stage for failure to plead or attach exhibits with proof of exhaustion.” The court denied Luedtke’s motion for appointment of counsel View "Luedtke v. Berkebile" on Justia Law

Susan called 911, seeking help for her 21-year-old son, Andrew, who had “overdosed on some kind of drugs.” EMS personnel waited outside for police per township policy. Sergeant Hunt informed dispatch that he had previously arrested heroin addicts who lived at the address. Hunt was admitted by Andrew’s father and observed Andrew looking very pale. Learning that Hunt was a police officer, Susan demanded that Hunt leave. Hunt explained that rescue personnel have a duty to check the victim, but will not enter a home without a police officer. Susan told Hunt that she was a nurse and that there was no longer any need for EMS. Hunt left and waited in the driveway with medical personnel. Other officers arrived and demanded that the door be opened or that Andrew be sent outside to be checked out. The Strickers continued to resist. A state police dispatcher recommended forced entry to help Andrew, considering Andrew’s history as a heroin user. Assistant Prosecutor Riley agreed that a forced entry was warranted. The officers entered and handcuffed the parents while they administered care to Andrew. The district court granted defendants summary judgment in the Stricklers’ suit under 42 U.S.C. 1983, finding that exigent circumstances justified all of the police’s actions. The Sixth Circuit affirmed. View "Stricker v. Twp. of Cambridge " on Justia Law

McClellan, then age 19, was convicted of first degree murder in connection with a barroom conflict between two groups. McClellan received a mandatory life sentence without parole and a consecutive two-year sentence for a firearm conviction. The district court granted a writ of habeas corpus on the ground that McClellan’s defense lawyer did not provide the effective assistance of counsel required by the Sixth Amendment because the lawyer did not interview numerous eyewitnesses who would have testified that McClellan acted in self-defense. The Sixth Circuit affirmed, rejecting the state’s assertions that the defense lawyer did not violate the ineffective assistance of counsel standard set out in Strickland v. Washington, 466 U.S. 668 (1984); that the district court should not have reached the merits because McClellan defaulted his claim by not raising it in a procedurally correct way; and that the Antiterrorism and Effective Death Penalty Act and recent Supreme Court cases so limit the federal courts’ authority to decide habeas cases on the merits that McClellan’s petition must be dismissed. View "McClellan v. Rapelje" on Justia Law

Columbus motorists reported a person driving erratically. One saw that the driver was a woman and that there was a child in the truck. Both witnessed the truck jump onto the median at least twice. One followed the truck, trying to help the police locate it. The truck crashed into a tree. At the scene, the police found Volpe, intoxicated and trapped behind the steering wheel. Volpe’s daughter, ejected from the truck, died days later from multiple injuries. Volpe was convicted on two counts of aggravated vehicular homicide (operating a vehicle while under the influence (OVI) and recklessly causing her daughter’s death), each with a specification that she had been convicted of three or more OVI or equivalent offenses within the last six years, and of OVI with a specification that she had been convicted of five or more equivalent offenses within the last 20 years. Volpe received a total prison term of 20 years and six months. She argued that convictions of both OVI, Ohio Rev. Code 4511.19(A)(1)(a), and aggravated vehicular homicide as a proximate result of OVI, 2903.06(A)(1)(a), violated the federal Double Jeopardy Clause. The Sixth Circuit affirmed the district court’s rejection of her habeas corpus petition. View "Volpe v. Trim" on Justia Law