Justia Civil Rights Opinion Summaries

Plaintiffs, four former inmates, filed suit under 42 U.S.C. 1983, seeking monetary and injunctive relief for detention beyond their release dates. The court affirmed the district court's grant of qualified immunity to the DOC Director on the individual capacity damage claims because, under the circumstances, the law did not fairly warn him that the amount of time spent recalculating thousands of release dates, including plaintiffs', recklessly disregarded their constitutional right to release. View "Scott v. Baldwin" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against St. Louis police officers for, inter alia, arresting her on false charges and conspiring to hide it. The court concluded that the record was sufficient for a reasonable factfinder to find that Defendants Harris and Isshawn-O'Quinn participated in a section 1983 conspiracy to violate plaintiff's clearly established constitutional rights by, inter alia, conspiring with other officers to prevent plaintiff from filing a section 1983 action following her false arrest. Accordingly, the district court did not err in denying qualified immunity to these defendants. The court dismissed the appeal by the municipal defendants for lack of jurisdiction where the issues raised by these defendants were not inextricably intertwined with the question of qualified immunity. View "S.L. v. Board of Police Commissioners, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that a detective submitted a false statement of probable cause to secure a warrant for his arrest and that an assistant county attorney approved the warrant application even though it lacked probable cause. The detective sought a warrant for plaintiff's arrest, alleging that he had knowingly violated the state registration requirements for predatory offenders or intentionally provided false information. In light of the facts known to the detective when he applied for the warrant and the ambiguity of the statutory language, the court could not say that no reasonably competent officer would have applied for an arrest warrant. Accordingly, the court concluded that the detective was entitled to qualified immunity where the belief that probable cause existed to arrest plaintiff for failing to register his Belize address as his primary address - even if that belief was mistaken - was objectively reasonable. Even if no probable cause existed to support the warrant for plaintiff's arrest, the attorney was nonetheless entitled to absolute immunity because his acts in reviewing and approving the complaint against plaintiff were taken to initiate the criminal prosecution. Accordingly, the court affirmed the judgment. View "Saterdalen v. Spencer, et al." on Justia Law

Voters filed suit against Officials challenging the process by which Officials confirmed the eligibility of voters who register on election day (election day registrants or EDRs). Voters also challenged a provision of the Minnesota Constitution denying the right of persons under guardianship to vote, as well as the sufficiency of notice afforded to such persons under certain Minnesota statutes. The court concluded that Voters could not prevail on their 42 U.S.C. 1983 claims based on Officials' failure to verify EDR's voting eligibility before allowing EDRs to cast their votes where Voters raised no allegations of the "aggravating factors" identified in Pettengill v. Putnam County R-1 School District; alleged no discriminatory or other intentional, unlawful misconduct by Officials sufficient to implicate section 1983; and alleged no defects causing Minnesota's voting system to be so "fundamentally unfair" that relief under section 1983 would be appropriate. Further, Voters lacked standing to raise their remaining claims where the amended complaint failed to allege that any plaintiff has been denied the right to vote by a constitutional provision barring persons under guardianship from voting. Accordingly, the court affirmed the district court's dismissal of Voters claims and denial of their motion for summary judgment as moot. View "Minnesota Voters Alliance, et al. v. Ritchie, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the County after a jail operated by the County failed to provide him with necessary anti-seizure medication while he was incarcerated. In this instance, plaintiff presented no evidence to suggest that the County's policymaking officials would have received notice of the denial of his medication in the morning at issue and made a deliberate choice to ignore or tacitly authorize the denial in the course of those few hours. Accordingly, the court affirmed the grant of summary judgment to the County because plaintiff failed to present evidence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity's employees. View "Johnson, Jr. v. County of Douglas, NE" on Justia Law

Plaintiff filed suit against defendants, the city and four officers, alleging, among other things, Fourth Amendment excessive force violations of 42 U.S.C. 1983; and violations of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12132; and Rehabilitation Act of 1973, 29 U.S.C. 794; and state tort law. The events at issue occurred when officers arrived at plaintiff's home after his mother called 911, reporting that he was having a psychotic episode and had attacked a member of the family. The court affirmed the denial of qualified immunity and denial of summary judgment to Officer Martinec on plaintiff's Fourth Amendment excessive force claim in securing plaintiff; reversed the denial of qualified immunity and denial of summary judgment for Officers Ricker, Jones, and Raders on plaintiff's Fourth Amendment excessive force claims as to these individual officers; reversed the denial of qualified immunity for all the officers and the denial of summary judgment as to the ADA and Rehabilitation Act claims; reversed the denial of the city's motion for summary judgment on plaintiff's ADA and Rehabilitation Act failure to train claims; and remanded for further proceedings. View "Roberts v. City of Omaha, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 alleging that the deputy sheriff used excessive force against him. The court concluded that precedent in place at the time of this incident suggested that the presence of only de minimus injuries could preclude a claim for excessive force. In this instance, the amount of force that the sheriff used did not cause more than de minimus injury. Therefore, the sheriff was entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights under the Fourth Amendment. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the sheriff. View "Bishop v. Deputy Dale Glazier, et al." on Justia Law

Plaintiffs ("Parents") filed suit against Educators seeking a declaratory judgment that the Arkansas Public School Choice Act of 1989, Ark. Code Ann. 6-18-206(f)(1), violated the Equal Protection Clause and an injunction transferring their children to another school district. The court concluded that Parents' claims for declaratory and injunctive relief were moot because the Arkansas General Assembly enacted the Public School Choice Act of 2013, Ark. Code Ann. 6-18-1901 et seq., which repealed the 1989 Act in its entirety. Accordingly, the court vacated and remanded with directions to dismiss. View "Teague, et al. v. Arkansas Board of Education, et al." on Justia Law

Plaintiffs filed suit against the District alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 706 and 794a. Plaintiffs' claims involved disputes with the District over the manner in which the District implemented individualized education programs. The court concluded that plaintiffs were required to exhaust their administrative remedies under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491, before filing their ADA and Rehabilitation Act claims in the district court. Further, the futility, inadequate remedy, and contrary to law exceptions were not applicable in this case. Accordingly, the court affirmed the district court's grant summary judgment in favor of the District. View "J.B., et al. v. Avilla R-XIII School District" on Justia Law

Plaintiff filed suit against the OHA after she was terminated. At issue on appeal was whether plaintiff's appeal must be dismissed for failure to order the necessary portions of a trial transcript. Plaintiff ordered the portion of the trial transcript that contained her testimony and the remaining portions of the transcript were not transcribed and were not available. The court could not properly review the issues in the case based on the record plaintiff provided and, therefore, the court did not address the merits of plaintiff's First Amendment retaliation claim. Accordingly, the court granted the OHA's motion to dismiss plaintiff's appeal based on Federal Rule of Appellate Procedure 10(b). View "Kelly v. Omaha Housing Authority, et al." on Justia Law