Justia Civil Rights Opinion Summaries

Two inmates at Smith State Prison in Georgia, Miguel Jackson and Kelvin Stevenson, were involved in a prison riot on December 31, 2010, after officers discovered contraband in Jackson’s cell. The officers alleged that Jackson and Stevenson assaulted them, leading to both inmates being handcuffed and escorted away. Jackson and Stevenson claimed that, after being restrained, they were severely beaten by correctional officers. They filed suit in the United States District Court for the Southern District of Georgia against thirty-nine officers, asserting claims of excessive force and failure to intervene under the Eighth Amendment.Over the course of more than a decade, the plaintiffs voluntarily dismissed many defendants, and the district court granted partial summary judgment, leaving nine officers as defendants by the time of trial. Just before jury selection, plaintiffs moved to dismiss seven more defendants under Federal Rule of Civil Procedure 41(a)(2), which the district court granted, entering judgment in favor of those defendants and reserving the issue of costs and sanctions. The case proceeded to trial against Officers Catanzariti and Harrison. The jury found for Catanzariti on Jackson’s excessive force claim but found he failed to intervene when other officers used excessive force, awarding Jackson $1.00 in damages. Stevenson’s claims against both officers were rejected.On appeal to the United States Court of Appeals for the Eleventh Circuit, the plaintiffs challenged the district court’s grant of their Rule 41 motion and several evidentiary rulings. The Eleventh Circuit held that the district court did not abuse its discretion in granting the partial dismissal and entering judgment for the seven defendants, nor in admitting the challenged evidence. The court affirmed the district court’s final judgments. View "Jackson v. Catanzariti" on Justia Law

Three men were prosecuted for their roles in the fatal shooting of Ahmaud Arbery, a Black man, in the Satilla Shores neighborhood of Glynn County, Georgia. On February 23, 2020, Arbery was running through the neighborhood and stopped at a house under construction, which he had visited before. Gregory and Travis McMichael, who lived nearby, saw Arbery and, suspecting him of recent burglaries, armed themselves and pursued him in a truck. William Bryan, a neighbor, joined the chase in his own vehicle. The men used their trucks to block and pursue Arbery through public streets, ultimately leading to a confrontation in which Travis McMichael shot and killed Arbery.After being convicted of murder and other charges in Georgia state court and sentenced to life imprisonment, the defendants were tried in the United States District Court for the Southern District of Georgia. There, they were convicted of interference with rights under 18 U.S.C. § 245(b)(2)(B), attempted kidnapping under 18 U.S.C. § 1201(a)(1), and, for the McMichaels, firearm offenses under 18 U.S.C. § 924(c)(1)(A)(iii). The district court denied their motions for acquittal, finding sufficient evidence that the defendants acted because of Arbery’s race and his use of public streets, that the streets were provided or administered by the county, and that the attempted kidnapping was for a benefit and involved an instrumentality of interstate commerce.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the sufficiency of the evidence de novo. The court held that substantial evidence supported the jury’s findings on all challenged elements, including racial motivation, use of public facilities, and use of an automobile as an instrumentality of interstate commerce. The Eleventh Circuit affirmed all convictions. View "USA v. Bryan" on Justia Law

In 2004, Clemente Javier Aguirre-Jarquin was arrested and later convicted for the murders of his neighbors, Cheryl Williams and Carol Bareis, in Altamonte Springs, Florida. The investigation by Seminole County Sheriff’s Office (SCSO) focused on Aguirre after bloody clothing and a knife were found near his residence, and forensic analysis by Donna Birks, a latent print examiner, identified Aguirre’s palm print on the murder weapon. Aguirre was tried and sentenced to death in 2006. Over the next decade, new evidence emerged: a 2007 investigation revealed misconduct in the SCSO Latent Print Unit, undermining the reliability of the fingerprint identification, and post-conviction DNA testing failed to link Aguirre to the crime scene but implicated Samantha Williams, the victims’ daughter and granddaughter, who later confessed to involvement in the murders.The Seminole Circuit Court denied Aguirre’s initial motion for a new trial, finding the evidence against him overwhelming. The Supreme Court of Florida affirmed this denial. However, after further post-conviction investigation and new DNA evidence, the Supreme Court of Florida vacated Aguirre’s convictions and ordered a new trial. In 2018, the State dropped all charges against Aguirre.Aguirre then filed suit in the United States District Court for the Middle District of Florida against Birks, lead investigator Robert Hemmert, crime scene analyst Jacqueline Grossi, and the Seminole County Sheriff, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and state law claims. The District Court denied qualified immunity to Birks, Hemmert, and Grossi on several counts and denied state-law immunity to Hemmert and Grossi.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of qualified immunity to Birks on the fabrication of evidence claim and affirmed the denial of state-law immunity to Hemmert and Grossi for intentional infliction of emotional distress. However, the court reversed the denial of qualified immunity to Birks and Hemmert on the malicious prosecution claim and to Hemmert and Grossi on the claim of inadequate investigation, finding no clearly established law requiring the investigation to eliminate all doubts. The case was remanded for further proceedings. View "Aguirre-Jarquin v. Hemmert" on Justia Law

In 2023, the Florida Legislature enacted Senate Bill 264, which, among other provisions, imposed restrictions on real property transactions involving persons domiciled in China who are not U.S. citizens or lawful permanent residents. The law included three key requirements: a purchase restriction barring certain Chinese domiciliaries from acquiring Florida real estate, a registration requirement mandating such individuals to register their existing property interests, and an affidavit requirement obligating all purchasers of Florida real estate to attest compliance with the law. Four Chinese citizens residing in Florida on various nonimmigrant visas and a real estate brokerage firm serving Chinese-speaking clients challenged these provisions, alleging violations of the Equal Protection Clause, the Fair Housing Act, the Due Process Clause, and federal preemption.The plaintiffs filed suit in the United States District Court for the Northern District of Florida against several state officials responsible for enforcing SB 264. They sought a preliminary injunction to halt enforcement of the purchase restriction, registration requirement, and affidavit requirement. The district court found that the plaintiffs had standing to challenge all three provisions but denied the preliminary injunction, concluding that the plaintiffs were not substantially likely to succeed on the merits of their claims.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision. The Eleventh Circuit held that the plaintiffs lacked standing to challenge the purchase restriction because none had shown an imminent injury from that provision. However, at least one plaintiff had standing to challenge the registration and affidavit requirements. The court affirmed the denial of the preliminary injunction as to the registration and affidavit requirements, finding no substantial likelihood of success on the merits of the constitutional, statutory, or preemption claims. The court reversed and remanded the denial of the preliminary injunction as to the purchase restriction, instructing the district court to deny it without prejudice for lack of standing. View "Shen v. Commissioner, Florida Department of Agriculture and Consumer Services" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law

A city commissioner in Coffee County, Georgia, who was active in assisting voters, became involved in a heated exchange with the county’s Elections Supervisor at a polling site during early voting for the 2020 general election. After the confrontation, the police were called, and the commissioner left. Later that day, she returned to the polling site to assist another voter, prompting another police response. A City of Douglas police sergeant then issued her a criminal trespass warning, banning her from all county polling places for the remainder of the election period. When she refused to leave, she was arrested.The commissioner filed a lawsuit in the United States District Court for the Southern District of Georgia against the Elections Supervisor and Coffee County, alleging that the trespass warning violated her First Amendment rights and that her arrest violated the Fourth Amendment. The district court granted summary judgment to the defendants, finding that the police sergeant, not the Elections Supervisor or the County, had issued the trespass warning and made the arrest. The court concluded that the plaintiff failed to show that the defendants caused her alleged injuries, as required under 42 U.S.C. § 1983.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that the Elections Supervisor, rather than the police sergeant, caused her injuries. The court explained that the sergeant acted as a deliberative and autonomous decision-maker, conducting his own investigation and independently deciding to issue the trespass warning and make the arrest. Because causation is a necessary element of a § 1983 claim, and the plaintiff failed to establish it, summary judgment for the defendants was affirmed. View "Coley-Pearson v. Martin" on Justia Law

A woman was working late at her place of employment, a business located in a commercial cul-de-sac, when she was approached at night by two individuals carrying flashlights. Fearing for her safety, as she did not know they were police officers and they did not identify themselves, she attempted to drive away. The officers, who were investigating a report of a possible break-in at a different address in the same cul-de-sac, fired their weapons at her vehicle as she drove up the driveway. The woman was not physically harmed, but her car was struck by bullets and later declared a total loss. She was detained in a police cruiser for several hours before being released without charges.The United States District Court for the Northern District of Georgia reviewed the woman’s claims under 42 U.S.C. § 1983, alleging unlawful seizure, excessive force, and unlawful property seizure in violation of the Fourth Amendment. The district court granted summary judgment to the officers on state-law claims but denied summary judgment on the federal claims, finding that a reasonable jury could conclude the officers lacked reasonable suspicion or probable cause, and that their actions violated clearly established law. The officers appealed, arguing they were entitled to qualified immunity.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of qualified immunity. The court held that the officers seized the plaintiff both by physical force (when they shot her car) and by a show of authority, that no reasonable officer could have believed there was reasonable suspicion or probable cause to seize or shoot at her, and that the warrantless seizure of her vehicle was not justified by exigent circumstances. The case was remanded for further proceedings. View "Watkins v. Davis" on Justia Law

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law