Justia Civil Rights Opinion Summaries

Plaintiff brought suit under 42 U.S.C. 1983 against officials who seized numerous dogs from a kennel she ran on her property. The district court granted summary judgment in favor of defendants on plaintiff's claims and plaintiff appealed. The court concluded that the district court properly granted summary judgment on plaintiff's claims against the county under Heck v. Humphrey where plaintiff did not allege that her 163 convictions for animal cruelty had been overturned and plaintiff conceded that several of her allegations underlying such claims were past the statue of limitations. As for the 2006 claims, plaintiff failed to dispute the district court's holding that she failed to exhaust her remedy under Arkansas Rule of Criminal Procedure 15.2. Plaintiff also failed to show an unconstitutional policy or custom was the moving force behind the violation of her rights. The court further held that the district court properly granted summary judgment on plaintiff's claims against the Humane Society defendants because no evidence supported plaintiff's conspiracy allegations. Accordingly, the court affirmed the judgment.

Plaintiff, as the administratrix of Brenda Shelton's estate, appealed the district court's dismissal of her civil action against several public officials and health officials. The complaint alleged shortcomings in the way medical professionals at a state mental health facility responded after Brenda hanged herself while a patient at the facility. The district court dismissed all federal claims with prejudice and dismissed the state law claims without prejudice, electing not to exercise jurisdiction over the state law claims. The court held that the circumstances did not trigger duties related to involuntary commitment nor did they give rise to a constitutional-level of care. The court also held that a claim based upon an improper medical treatment decision could not be brought pursuant to either the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., or the Rehabilitation Act, 29 U.S.C. 701 et seq.

This appeal arose from an insurance coverage dispute where the City sought coverage from Genesis for 42 U.S.C. 1983 claims in the nature of malicious prosecution. Genesis filed suit against the City, seeking a declaratory judgment that its policies provided no coverage for the underlying actions. The district court granted summary judgment to Genesis and the City appealed, arguing that the district court erred in ruling as a matter of law that the policies did not provide the City insurance coverage for the claims. Because Genesis did not have an insurance contract with the City in 1977, when the underlying charges were filed, it did not have a duty to defendant and indemnify the city in the suits. Accordingly, the court affirmed the judgment.

Defendant appealed the district court's denial of qualified immunity on an excessive-force claim in plaintiff's 42 U.S.C. 1983 action. In this interlocutory appeal, at issue was whether the conduct that the district court found was sufficient to withstand a motion for summary judgment violated plaintiff's clearly established rights. The court concluded that the law regarding forced consent was clearly established in August 2009 such that a reasonable person in defendant's position would have known that his actions were unreasonable. Accordingly, the court affirmed the judgment.

Plaintiff appealed the district court's order granting summary judgment to defendants on various claims arising from plaintiff's unsuccessful application for appointment as director of the City's Department of Human Rights and Equal Economic Opportunity, as well as denial of his motion to compel various depositions. The court affirmed the district court's grant of summary judgment to defendants on plaintiff's due process claims because he had no protected property interest in the position; because plaintiff had not presented evidence that he was treated differently from similarly situated candidates or that he was the victim of intentional or purposeful discrimination, plaintiff's equal protection claim failed as a matter of law; the court affirmed the district court's grant of summary judgment to defendants on plaintiff's conspiracy claim because plaintiff's assertion did not demonstrate a class-based invidiously discriminatory animus; and the court affirmed the district court's remaining rulings.

Sinan Cingilli, a student at the University of Minnesota, and TCA, a non-profit corporation that provided information about the nation of Turkey and Turkish-Americans, appealed the district court's dismissal of their respective First Amendment claims and TCA's state-law defamation claim for failure to state a claim. Defendant Professor Chaouat directed the Center for Holocaust and Genocide Studies at the university. The Center's website displayed a list of "Unreliable Websites" which included websites that disputed the factuality of the Nazi genocide of Jews during World War II. The first "Unreliable Website" on the list was that of TCA. The court held that, because Cingilli failed to plead facts sufficient to demonstrate an objectively reasonable chilling effect, he had not established standing to pursue a First Amendment claim under these circumstances; TCA had pled a cognizable injury and had standing to pursue its First Amendment claim; in light of the absence of the allegations that the challenged actions posed obstacle to students' access to the materials on TCA's website or made materials substantially unavailable at the university, the Rule 12(b)(6) dismissal of TCA's First Amendment claim was affirmed; and because the challenged statements at issue either were true or could not reasonably be interpreted as stating facts, the Rule 12(b)(6) dismissal of TCA's defamation claim was also affirmed.

Plaintiff brought an action pursuant to 42 U.S.C. 1983 against a sheriff's deputy, individually and in his capacity as deputy, alleging that the deputy violated plaintiff's Fourth Amendment right to be free from excessive force by unnecessarily tasering plaintiff. The deputy subsequently appealed the district court's denial of his motion for summary judgment as to the section 1983 individual capacity claim, asserting that plaintiff's claim was barred by the doctrine of qualified immunity. The court held that a reasonable officer would not have concluded that an argument occurred between plaintiff and another; plaintiff was an unarmed suspected misdemeanant who did not resist arrest, did not threaten the officer, did not attempt to run from him, and did not behave aggressively towards him. Therefore, tasering plaintiff under the circumstances was excessive force in violation of clearly established law. Accordingly, the court affirmed the judgment.

Plaintiff brought this action under 42 U.S.C. 1983 against officers of the St. Charles County Sheriff's Department, claiming the officers unlawfully entered her home and detained her in violation of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officers, concluding the officers did not violate plaintiff's constitutional rights and were therefore entitled to qualified immunity. The court held that it was reasonable for the officers to conclude their warrantless entry into plaintiff's home was lawful under the emergency aid exception or the community caretaker exception. The court further held that the officer's brief two-minute detention of plaintiff was lawful. Accordingly, the court affirmed the judgment.

Plaintiff, an Arkansas inmate, sued officials of the Arkansas Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1 et seq., and 42 U.S.C. 1983, alleging violations of his statutory and constitutional rights. Defendant, whose religious practice incorporated elements of Christianity, Islam, and Buddhism, alleged that correctional officers seized a prayer cap, prayer rugs, thikr beads, and prayer oil from his cell, as well as religious texts and books. His amended complaint alleged that these actions violated his rights under RLUIPA and the First Amendment. The court held that section 1983 provided no cause of action against agents of the State acting in their official capacities and therefore, sovereign immunity barred plaintiff's claims for damages under RLUIPA. The court further held that plaintiff's claim for injunctive relief was moot because he was transferred out of that facility. Because plaintiff was no longer subject to the policies that he challenged, there was no live case or controversy.

Plaintiffs sued various defendants, including police officers Larsen and Brown, under 42 U.S.C. 1983 and 1985, as well as state law, claiming that defendants violated their rights under the Iowa state investigation and prosecution of defendants for murder. The officers moved for summary judgment, asserting that they were entitled to qualified immunity on plaintiffs' claims that they could be defeated if the officers had probable cause to arrest plaintiffs. The officers subsequently appealed the district court's denial of their motion. Assuming a Fourth Amendment right against malicious prosecution existed, such a right was not clearly established when plaintiffs were prosecuted in 1977 and 1978. Given this precedent, reasonable officers, in the officers' position here, could not have known in 1977 or 1978 that malicious prosecution violated plaintiffs' Fourth Amendment rights. Therefore, the court held that the officers were entitled to qualified immunity on any Fourth Amendment malicious prosecution or prosecution without probable cause claims. The district court erred in denying the officers' motion for summary judgment. Accordingly, the court reversed and remanded for further proceedings on plaintiffs' remaining claims.