Justia Civil Rights Opinion Summaries

Plaintiff, formerly a pretrial detainee, filed suit against defendants under 42 U.S.C. 1983, alleging that defendants were deliberately indifferent to his serious medical needs. The district court granted summary judgment for defendants. The court concluded that, viewing the record in the light most favorable to plaintiff, there is evidence that defendant had a serious medical need for treatment after he fell, broke his left humerus, dislocated the hardware in his arm, and began to experience severe pain. The court affirmed the district court's grant of summary judgment for Dr. Fowler and Deputy Booth; reversed the grant of summary judgment for Nurse Ray, Dr. Sullivan, Sheriff Abston, Deputy Abston, Chief Deputy Carr, and Deputy Ellis; and held that Sheriff Abston and the deputy defendants are immune from suit in their official capacities as Alabama state officials. View "Melton v. Abston" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging unlawful seizure by Officers Allen and Crews, false imprisonment by Officer Allen, and municipal liability against the City for the officers' actions. The district court granted qualified immunity to Officer Allen with respect to plaintiff's federal and state claims. The district court also granted summary judgment to Officer Crews and the City. The court affirmed in part, reversed in part, and remanded. The court concluded that Officer Allen had arguable probable cause to seize plaintiff and found that the district court’s erroneous conclusion that the standard was not clearly established was harmless error. Accordingly, the court affirmed the district court's ultimate holding as to the propriety of Officer Allen’s initial decision to seize and transport plaintiff to the hospital. The court similarly concluded that Officer Allen is entitled to qualified immunity on plaintiff's 1983 false imprisonment claim. However, the court concluded that the district court erred in granting Officer Allen qualified immunity for his conduct during the seizure. Therefore, the court reversed and remanded on the question of whether Officer Allen’s conduct during the seizure was done in an extraordinary manner unusually harmful to plaintiff's privacy interests. View "May v. City of Nahunta, Georgia" on Justia Law

Plaintiff filed suit against Major Michael Skelton in his official capacity as a deputy sheriff of Cobb County, seeking declaratory relief, damages, fees, and costs for violations of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. 2000cc et seq. The court reversed the district court's denial of Major Skelton's motion for summary judgment against plaintiff's claims for damages, concluding that the sovereign immunity of Georgia extends to a deputy sheriff who denies a dietary request of an inmate in a county jail. Accordingly, the court remanded with an instruction to enter judgment for Major Skelton on those claims. View "Lake v. Skelton" on Justia Law

Plaintiff, convicted of murder and sentenced to death, filed suit under 42 U.S.C. 1983, challenging Alabama’s use of midazolam in its lethal injection protocol. The district court denied relief. The court concluded that substantial evidence supported the district court’s fact findings and, thus, plaintiff has shown no clear error in them. The court also concluded that plaintiff has shown no error in the district court’s conclusions of law, inter alia, that: (1) plaintiff failed to carry his burden to show compounded pentobarbital is a feasible, readily implemented, and available drug to the Alabama Department of Corrections for use in executions; (2) Alabama’s consciousness assessment protocol does not violate the Eighth Amendment or the Equal Protection Clause; and (3) plaintiff's belated firing-squad claim lacks merit. Accordingly, the court affirmed the judgment. View "Arthur v. Commissioner, AL DOC" on Justia Law

Plaintiff, the personal representative of James Clifton Barnes, filed suit against defendants after Barnes died from injuries he sustained while he was involved in a struggle with Deputy Sheriff Kubler. Barnes was tased five times, and at least two of those tases occurred after Barnes had ceased resisting arrest. The district court denied Kubler's motion for summary judgment, determining that Kubler's use of the Taser gun amounted to an unconstitutional use of excessive force in violation of the Fourth Amendment, that was clearly established at the time. The court concluded that the record evidence, construed in favor of plaintiff, demonstrates that Barnes was not a flight risk or a threat to the safety of the officers or the public prior to the conclusion of the tasings. In this case, Kubler's multiple tasings of Barnes, after an arrest had been fully secured and any potential danger or risk of flight eliminated, violated Barnes's clearly established constitutional right to be free from excessive force. Accordingly, the court affirmed the judgment. View "Wate v. Kubler" on Justia Law

Plaintiffs, former sonography students at Valenica College, a public college, filed suit alleging that employees of the college violated their rights under the First and Fourth Amendments, 42 U.S.C. 1983. The district court dismissed the students’ complaint for failure to state a claim. In this case, the employees encouraged students to submit voluntarily to invasive ultrasounds performed by peers as part of a training program in sonography. When some students objected, the employees allegedly retaliated against the objecting students. The court vacated the order dismissing the complaint because the district court erroneously classified the students’ speech as school-sponsored expression, rather than pure student expression under Tinker v. DesMoines, and the district court erroneously ruled that the transvaginal ultrasound was not a search under the Fourth Amendment where inserting a probe into a woman’s vagina is plainly a search when performed by the government. The court remanded for further proceedings. View "Jane Doe I v. Shaheen" on Justia Law

Plaintiff filed suit against defendants, including two deputies, after he was arrested for violating an injunction prohibiting his possession of firearms. The deputies were escorting plaintiff's former lover into plaintiff's residence in order to retrieve her personal belongings when they saw the firearms in plain view. The court affirmed the district court's grant of summary judgment on plaintiff's claim of unlawful entry where the law was not sufficiently clearly established at the time of the alleged violation to give Deputies Harrison and Loucks fair warning that their entry into plaintiff's sunroom under the circumstances of this case would violate his Fourth Amendment rights; Harrison and Loucks are also entitled to qualified immunity on plaintiff's claim for unlawful entry into his home from the sunroom where plaintiff consented to the deputies' entry; the district court correctly found that Harrison and Loucks did not violate plaintiff's constitutional rights when they seized firearms within his home, because the firearms were in plain view; and the district court correctly found that defendants had at least arguable probable cause to arrest plaintiff. Accordingly, the court affirmed the judgment. View "Fish v. Brown" on Justia Law

In 2010, Alabama made changes to its election law that impacted the ADC’s ability to raise and spend money in state elections. The ADC filed suit challenging Alabama Code 17-5-15(b) (the PAC-to-PAC transfer ban), which limited the ADC's fundraising abilities. On appeal, the ADC challenges the district court's final judgment in favor of the State, arguing that the PAC-to-PAC transfer ban is unconstitutional as applied because the ban violates the ADC’s First Amendment right to make independent expenditures. The court concluded that the State’s proffered interest in transparency ties into its interest in preventing corruption to justify regulating transfers between PACs. The court also concluded that the PAC-to-PAC transfer ban as applied to the ADC is sufficiently closely drawn to avoid unnecessary abridgment of associational freedoms. The ban had met the less rigorous "closely drawn" standard by being narrowly tailored to achieve Alabama's desired objective in preventing quid pro quo corruption (or its appearance) as applied to the ADC in this case. Accordingly, the court affirmed the district court's finding on the merits that the ban is constitutional as applied to ADC. View "The Alabama Democratic Conference v. Attorney General, State of Alabama" on Justia Law

In 2005, the County adopted the Lauren Book Child Safety Ordinance, Fla., Code of Ordinances ch. 21, art. XVII, which imposes a residency restriction on “sexual offenders” and “sexual predators.” The Ordinance prohibits a person who has been convicted of any one of several enumerated sexual offenses involving a victim under sixteen years of age from “resid[ing] within 2,500 feet of any school.” Plaintiffs filed suit challenging the constitutionality of the County’s residency restriction. The district court dismissed the ex post facto challenge. Plaintiffs argue that they pleaded sufficient facts to state a claim that the residency restriction is so punitive in effect as to violate the ex post facto clauses of the federal and Florida Constitutions. The court concluded that Doe #1 and Doe #3 have alleged plausible ex post facto challenges to the residency restriction where they alleged that they are homeless and that their homelessness resulted directly from the County’s residency restriction “severely restricting available, affordable housing options.” Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "John Doe #1 v. Miami-Dade County" on Justia Law

The EEOC filed suit against CMS, alleging that the company's conduct discriminated on the basis of a black job applicant's race in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2(a)(1) & 2000e-2(m). When the applicant said that she would not cut her dreadlocks, she was told by a CMS human resources manager that the company would not hire her. The district court dismissed because the complaint did not plausibly allege intentional racial discrimination by CMS against the applicant. The court concluded that the EEOC conflates the distinct Title VII theories of disparate treatment (the sole theory on which it is proceeding) and disparate impact (the theory it has expressly disclaimed); the court's precedent holds that Title VII prohibits discrimination based on immutable traits, and the proposed amended complaint does not assert that dreadlocks - though culturally associated with race - are an immutable characteristic of black persons; the court is not persuaded by the guidance in the EEOC’s Compliance Manual because it conflicts with the position taken by the EEOC in an earlier administrative appeal, and because the EEOC has not offered any explanation for its change in course; and no court has accepted the EEOC’s view of Title VII in a scenario like this one, and the allegations in the proposed amended complaint do not set out a plausible claim that CMS intentionally discriminated against the applicant on the basis of her race. Accordingly, the court affirmed the judgment. View "EEOC v. Catastrophe Mgmt. Solutions" on Justia Law