Justia Civil Rights Opinion Summaries

In 2005 Smith was charged with impersonating a police officer and was detained in the Sangamon County Detention Facility pending trial. Because he had a parole hold and a history of problems during a prior detention, Smith was housed in a maximum-security cellblock. While there, he was severely beaten by another inmate who was awaiting trial on armed-robbery and aggravated-battery charges. Smith filed suit under 42 U.S.C. 1983 claiming that the Department’s approach to classifying inmates for cellblock placement ignores serious risks to inmate safety by failing to separate “nonviolent” from “violent” inmates with assaultive tendencies. A magistrate entered summary judgment for the Sheriff’s Department. The Seventh Circuit affirmed. To avoid summary judgment, Smith needed evidence that the jail’s security classification policy systematically fails to address obvious risks to inmate safety. He had no such evidence. View "Smith v. Sangamon Cnty. Sheriff's Dep't" on Justia Law

Collins fled police officers by car and then by foot after he was stopped for speeding. An officer kicked Collins repeatedly and dosed him with pepper spray, but Collins did not stop resisting until another officer deployed his Taser. Afterward, the officers discovered a bag containing crack and powder cocaine that Collins had discarded during the foot chase, and a wad of cash in his pocket. The district court denied a motion to suppress, reasoning that use of excessive force during an arrest is not a basis for suppressing evidence and that the drugs and money were not seized as a result of the alleged use of excessive force. The Seventh Circuit affirmed. View "United States v. Collins" on Justia Law

Stitts was convicted of murder in Indiana state court and sentenced to 60 years’ imprisonment. The district court denied his petition for habeas corpus under 28 U.S.C. 2254. Stitts claimed that his trial counsel was ineffective under Strickland v. Washington, because, before deciding not to present an alibi defense, he only interviewed one alibi witness, Stitts’s father, unreasonably failing to investigate whether there might be more. The state court found that such a limited investigation was sufficient under Strickland. The Seventh Circuit reversed and remanded to state court for a factual determination of the amount of investigation actually conducted. Stitts’s alibi was that he was at a nightclub, where there could be any number of potential alibi witnesses, so failure to explore that possibility would be unreasonable. The state court unreasonably applied Strickland when it found no prejudice, because the prosecution’s case rested entirely on the shaky testimony of two witnesses which could have been neutralized by alibi witness testimony. View "Stitts v. Wilson" on Justia Law

Cromwell was fired from his position as a Momence police lieutenant, after an incident of alleged misconduct involving alcohol that was followed by lying and insubordination during the investigation. Cromwell sued, arguing that his termination was procedurally inadequate and that that he had a constitutionally protected property interest in his continued public employment derived from the city’s Police Department Rules and Regulations, which provide that probationary employees may be terminated at any time for any reason but omit similar language with regard to nonprobationary employees. The district court rejected this argument and dismissed. The Seventh Circuit affirmed. The regulations on which Cromwell based his claim do not contain the clear language needed to overcome Illinois’s presumption of at-will employment. Something more than inference from silence is required. View "Cromwell v. City of Momence" on Justia Law

Cloe started working for the City of Indianapolis in 2007 as an Unsafe Buildings/Nuisance Abatement Project Manager. In 2008, she was diagnosed with multiple sclerosis, a chronic, incurable neurological disorder that rendered her disabled and significantly impaired her day-to-day life. In 2009, the city terminated her, ostensibly for poor performance. Cloe sued under the Americans with Disabilities Act, 42 U.S.C. 12101, alleging that the city discriminated against her because of her disability; failed to reasonably accommodate her disability; and retaliated against her for requesting accommodations. The district court granted summary judgment in favor of the city. The Seventh Circuit affirmed with respect to the reasonable accommodation claims, but reversed on the discrimination and retaliation claims, noting “suspicious timing, ambiguous statements oral or written, and other bits and pieces from which an inference of retaliatory intent might be drawn.” View "Cloe v. City of Indianapolis" on Justia Law

In 2007 Maniscalco hosted a party for a local politician at his Gurnee restaurant. Maniscalco capped the night with celebratory shots of tequila and a trip to McDonald’s, where he encountered Fidel Castro at the drive-through window. Minutes earlier, a police officer had handed Castro a note containing four numbers (2626) and told him to give it to his co-worker Guzman. Castro did so. The numbers partly corresponded to Maniscalco’ license-plate number: C112626. Maniscalco got into an argument with Guzman while paying for his order, grabbing Guzman and, according to Guzman, nearly pulling him through the window. Maniscalco released Guzman and drove to the pick-up window. As Castro was giving him his food, Guzman yelled to stop. Castro stopped; Maniscalco drove off. The manager called 911. A dispatch went out over the police radio. Maniscalco was arrested. A jury found him not guilty of drunk driving and battery. Maniscalco sued the officers and McDonald’s under 42 U.S.C. 1983, claiming conspiracy to induce him to breach the peace so the officers would have a pretext to arrest him. The Seventh Circuit affirmed summary judgment for the defendants. Notwithstanding Castro’s deposition testimony about the unexplained note, the evidence supported probable cause to arrest. McDonald’s cannot be liable because there is no vicarious liability under section 1983. View "Maniscalco v. Simon" on Justia Law

Lisa Williamson and her husband Lance were arrested on a charge that they had stolen someone else’s horse. The facts are disputed, but the horse had apparently been boarded at Lance’s stable, by an agent of its owner, but against the owner’s specific wishes. After being acquitted, Williamson filed suit against two Lake County, Illinois sheriff’s deputies under 42 U.S.C. 1983, alleging that they arrested her without probable cause and in violation of her right to equal protection by arresting her based on nothing more (she contends) than her status as Lance’s wife. The district court dismissed. The Seventh Circuit affirmed. So far as the deputies knew, Lance was in the wrong in maintaining possession of the horse, and the lien filed by Williamson Stables was a ruse to give cover to his conversion of the horse and, quite possibly, to extort money from the horse’s owner; they also had reason to believe, based in large part on Williamson’s own interaction with them, that she shared responsibility along with her husband and Williamson’s Stables for the possession of and refusal to surrender the horse. View "Williamson v. Curran" on Justia Law

In 1996, Stalker was fatally bludgeoned and stabbed following a drug sale. Witnesses led Chicago police to Monroe and three fellow members of the Black P-Stone Nation street gang: Thomas, Curry, and Jackson, who had been selling crack cocaine and Stalker, a member of another gang, who had recruited customers. Members of Stalker’s gang drove up to make a purchase but sped off without paying for the cocaine. Stalker was beaten by Monroe and Curry, then stabbed by Thomas. Monroe later acknowledged striking Stalker but denied any foreknowledge that Thomas would stab him. Monroe pleaded not guilty. Jackson, after himself being acquitted on a murder charge, was a key witness. Monroe was convicted of first-degree murder on an accountability theory and sentenced to 40 years. After exhausting state remedies, Monroe unsuccessfully petitioned for habeas corpus under 28 U.S.C. 2254. The Seventh Circuit affirmed, rejecting arguments: that Monroe was arrested without probable cause; that his trial counsel was ineffective in failing to call his brother and sister-in-law as witnesses at trial and in support of his motion to suppress his post-arrest statements; and that the state presented insufficient evidence to support his conviction on an accountability theory. View "Monroe v. Birkey" on Justia Law

Warren shot and killed a man in 2002, during a marijuana sale. Although Warren was originally charged in state court with first-degree intentional homicide, he eventually pled no contest to first-degree reckless homicide, a reduced charge. Soon after entering the plea, Warren began attempting to withdraw it. He unsuccessfully fought his 40-year sentence through the Wisconsin court system and was denied habeas corpus in federal district court. The Seventh Circuit affirmed, rejecting his argument that the state trial court’s refusal to allow him to withdraw his plea deprived him of due process and that he received unconstitutionally ineffective assistance of counsel throughout his state court proceedings. View "Warren v. Baenen" on Justia Law

Following his arrest in 2009, Budd spent 45 days in the Edgar County Jail. In newspaper articles, the sheriff described the jail as not “livable” and violating “acceptable standards.” During his detention, Budd was confined with eight inmates in a space intended for three; he had to sleep on the floor alongside broken windows and cracked toilets. After another arrest, Budd returned to the jail. Vents were blocked, the heating and air conditioning systems did not work, and inmates were denied any recreation. During a third stay at the facility, something scratched or bit Budd’s leg. After infection set in, the jail nurse gave Budd ice. Budd wrote to the sheriff asking to see a doctor. Over the course of several hospital visits, he received tests, medication, and an MRI. He developed a “hole in [his] leg,” which doctors attributed to unsanitary conditions at the jail. He became “hysterical” at the prospect of returning to the jail. A judge ordered that he be taken to another facility. After a video conference to screen Budd’s 42 U.S.C. 1983 complaint, the district court dismissed, but furnished no written statement of reasons and did not prepare a transcript. The Seventh Circuit vacated and remanded. View "Budd v. Motley" on Justia Law