Justia Civil Rights Opinion Summaries

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law

In 2016, the DOJ sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act, alleging unconstitutional conditions in the county's detention facilities. A consent decree was established to address these issues, but disputes over compliance led to ongoing litigation. The DOJ claimed the county failed to comply, citing worsening conditions, while the county sought to terminate the decree. The district court found partial compliance, held the county in contempt, and issued a new injunction focusing on the Raymond Detention Center (RDC). As a sanction, the court appointed a receiver to oversee compliance.The district court's decision was based on findings of ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, and poor conditions. The court noted that despite some improvements, many issues persisted, such as severe understaffing and inadequate supervision, contributing to violence and unsafe conditions. The court also found deficiencies in use-of-force training, incident reporting, and investigations, which exacerbated the problems.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to retain the new injunction, finding that ongoing constitutional violations justified continued prospective relief. However, the appeals court found the new injunction overly broad in some respects and held that the district court did not abuse its discretion in appointing a receiver. The court also noted that the district court failed to make sufficient need-narrowness-intrusiveness findings for each of the receiver's duties as required under the Prison Litigation Reform Act. Consequently, the appeals court affirmed the district court's decision in part, reversed in part, and remanded for further proceedings to address these issues. View "United States v. Hinds County Board of Supervisors" on Justia Law

Following public outcry over "Pride Month" displays in St. Tammany Parish's public libraries, the Parish Council passed a resolution that vacated the terms of the Library Board of Control members, staggered those terms in accordance with Louisiana law, and appointed new Board members. Three ousted Board members—Anthony Parr, Rebecca Taylor, and William McHugh, III—sued under 42 U.S.C. § 1983, asserting viewpoint-discrimination, free-speech, retaliation, and substantive-due-process claims against the Council and Councilman David Cougle. They sought declaratory and injunctive relief to prevent the resolution from taking effect.The United States District Court for the Eastern District of Louisiana ruled that the legislative privilege was inapplicable because the resolution was not "legislative" in nature. Defendants brought an interlocutory appeal challenging this ruling. Before addressing the legislative privilege issue, the United States Court of Appeals for the Fifth Circuit examined whether the plaintiffs had standing to bring their claims.The Fifth Circuit concluded that the plaintiffs lacked standing. The court found that the plaintiffs' alleged speech-related injuries were not particularized, as they were tied to their positions as Board members and affected all members equally. Additionally, the court determined that the plaintiffs' alleged reputational injuries were neither fairly traceable to the defendants' conduct nor redressable by a favorable decision. Consequently, the court vacated the district court's order and remanded with instructions to dismiss the plaintiffs' claims for lack of subject matter jurisdiction. View "Parr v. Cougle" on Justia Law

George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law

The case involves a challenge to the constitutionality of 18 U.S.C. §§ 922(b)(1) and (c)(1), which prohibit Federal Firearms Licensees (FFLs) from selling handguns to individuals aged eighteen to twenty. The plaintiffs, including individuals in this age group and several nonprofit organizations, argue that these provisions infringe on their Second Amendment rights and deny them equal protection under the Fifth Amendment.The United States District Court for the Western District of Louisiana found that the plaintiffs had standing but dismissed the case under Rule 12(b)(6). The district court assumed that the Second Amendment's plain text covered the purchase of firearms by eighteen-to-twenty-year-olds but concluded that the prohibition was consistent with the nation's historical tradition of firearm regulation, relying on the framework established by the Supreme Court in New York Rifle & Pistol Ass’n, Inc. v. Bruen.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the Second Amendment does cover the right of eighteen-to-twenty-year-olds to purchase firearms. The court found that the historical evidence presented by the government, including 19th-century laws, was insufficient to establish a tradition of restricting firearm rights for this age group in a manner similar to the contemporary federal handgun purchase ban. The court emphasized that the Second Amendment's protections extend to all law-abiding, adult citizens, including those aged eighteen to twenty.The Fifth Circuit held that 18 U.S.C. §§ 922(b)(1) and (c)(1) and their attendant regulations are unconstitutional as they are inconsistent with the nation's historical tradition of firearm regulation. The court reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives" on Justia Law

Ignacia Carmona, representing herself and the estate of Veronica Carmona, filed a lawsuit against the City of Brownsville and several officers, claiming that the officers failed to provide necessary medical care to Veronica Carmona, who died while in pretrial detention. Veronica had been involved in multiple car accidents on the same night and exhibited visible injuries. Despite this, the officers did not seek medical attention for her, and she was later found dead in her cell due to internal bleeding from liver lacerations.The United States District Court for the Southern District of Texas dismissed the claims against the officers, granting them qualified immunity. The court concluded that the complaint did not plausibly allege that the officers had subjective knowledge of a substantial risk of serious harm to Veronica Carmona. The court found that the officers' failure to seek medical care did not amount to deliberate indifference because the injuries were not visibly apparent, and there were no complaints from Carmona that revealed the full extent of her injuries.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the plaintiff failed to plausibly allege that the officers were subjectively aware of the risk of internal bleeding. The court emphasized that actual knowledge of the risk is required for liability, and mere negligence or the fact that the officers should have known about the risk is insufficient. As a result, the officers were entitled to qualified immunity, and the dismissal of the deliberate-indifference claims was upheld. View "Carmona v. Olvera" on Justia Law

In 2012, three people were shot and killed outside a nightclub in Houston, Texas. Feanyichi E. Uvukansi was identified by an eyewitness, Jeresano, who picked him out of a photo array. Uvukansi was convicted of capital murder and sentenced to life without parole. At trial, Jeresano testified that he had no agreement with prosecutors regarding his testimony, but it was later revealed that he did have an agreement that could reduce his federal drug sentence in exchange for his testimony.Uvukansi did not raise the issue of false testimony on direct appeal but did so in state habeas proceedings. The state district court found that Jeresano's testimony was false but deemed it immaterial because the jury was aware of parts of the agreement through other testimony. The Texas Court of Criminal Appeals denied Uvukansi’s application without a written order. Uvukansi then filed a Section 2254 application in federal district court, which was dismissed on the grounds that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the state district court applied the correct "reasonable likelihood" standard for materiality and did not impose a higher burden of proof on Uvukansi. The court also found that the state district court did not err in considering the false testimony's impact on Jeresano's credibility rather than the identification itself. The Fifth Circuit concluded that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent and affirmed the dismissal of Uvukansi's Section 2254 application. View "Uvukansi v. Guerrero" on Justia Law

Joshua Stapleton was arrested for public intoxication by Officer Ernesto Lozano after failing a field sobriety test. During the booking process, Stapleton informed Officer Lozano that he was not feeling well and exhibited signs of intoxication. Despite this, he did not receive medical attention and was placed in a holding cell. Over the next few hours, Stapleton's condition deteriorated, and he eventually died from "combined drug toxicity." His family sued the officers and the police chief under 42 U.S.C. § 1983, alleging deliberate indifference to Stapleton's serious medical needs.The United States District Court for the Southern District of Texas denied the officers' and police chief's motion to dismiss the lawsuit based on qualified immunity. The defendants argued that the plaintiffs had not sufficiently alleged that the officers and chief were deliberately indifferent to a substantial risk of serious harm or that their conduct violated clearly established law. The district court's denial of the motion led to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that the plaintiffs did not sufficiently allege a deliberate-indifference claim against the officers. The court found that the symptoms exhibited by Stapleton were initially ambiguous and did not suggest a need for immediate medical attention. The court also determined that the plaintiffs failed to show that the officers acted with deliberate indifference, as required to overcome qualified immunity. Additionally, the court concluded that the plaintiffs did not establish that the constitutional right at issue was clearly established at the time of the alleged violation. Consequently, the appellate court reversed the district court's denial of the motion to dismiss based on qualified immunity. View "Stapleton v. Lozano" on Justia Law

Plaintiff and his family challenged the City's ordinance restricting where certain individuals convicted of sex offenses may live within the city. The Fifth Circuit affirmed the district court's grant of summary judgment for the city, holding that even assuming the ordinance deprived plaintiff of a liberty interest, due process does not entitle him to a hearing to establish a fact that is not material under the statute. In this case, the fact that defendant seeks to prove his current dangerousness is of no consequence under the ordinance. The court also held that the ordinance did not violate the Equal Protection Clause because its challenged classification rationally furthers a legitimate state interest. View "Duarte v. City of Lewisville, Texas" on Justia Law