Justia Civil Rights Opinion Summaries

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

Two brothers with developmental disabilities, Gaven and Jared, live with their parents, who are certified to provide in-home care. Both brothers qualified for Maine’s “Single Member Services,” which would allow each to receive one-on-one care from a designated provider. The family requested that each parent be reimbursed for providing care to one brother. However, the Maine Department of Health and Human Services determined that, because the brothers lived together, they were only eligible for “Two Member Services,” meaning a single provider would be reimbursed to care for both, at half the total rate. The parents continued to provide one-on-one care to both brothers, but were only reimbursed for one provider, resulting in a significant financial shortfall.The family challenged this determination in Maine Superior Court, which ruled in their favor, finding that the Department’s interpretation of its rules was arbitrary and inconsistent with its policies. Following this decision, the Department began reimbursing both parents for providing one-on-one care. The family then filed a federal lawsuit seeking damages for the period before the state court’s ruling, alleging discrimination under Title II of the Americans with Disabilities Act (ADA). The United States District Court for the District of Maine dismissed the case, holding that the Department was protected by Eleventh Amendment sovereign immunity.On appeal, the United States Court of Appeals for the First Circuit reversed the district court’s dismissal. The First Circuit held that the Department was not entitled to sovereign immunity because Congress validly abrogated such immunity under Title II of the ADA in this context. The court found that the Department’s policy violated the brothers’ equal protection rights, as there was no rational basis for providing reduced services solely because the brothers lived together. The case was remanded for further proceedings. View "McKenna v. Maine Department of Health and Human Services" on Justia Law

A police officer with the Cambridge Police Department, who had served in both patrol and special investigations roles, posted a comment on his personal Facebook page criticizing the naming of a federal police reform bill after George Floyd. In his post, he referred to Floyd as a "career criminal, a thief and druggie," and expressed pessimism about the country's future. The post was made from home, visible only to his Facebook friends, but was quickly screenshotted and shared with community members, including the local NAACP. The police commissioner was alerted, and the department initiated an internal investigation. The officer was placed on administrative leave and, after the investigation concluded that his post violated department policies on courtesy and professionalism, he was suspended without pay for four days.The officer filed suit in the United States District Court for the District of Massachusetts, alleging that his suspension was unconstitutional retaliation for exercising his First Amendment rights. Both parties moved for summary judgment. The district court granted summary judgment in favor of the department, finding that the department’s interest in maintaining public trust and effective service outweighed the officer’s and the public’s interest in his speech, particularly given the context of heightened scrutiny and protest following George Floyd’s death.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The First Circuit held that, while the officer’s speech addressed a matter of public concern, its mocking and disparaging nature diminished its First Amendment value. The court further held that the department’s prediction that the post could undermine public trust was reasonable, especially in the context of ongoing public unrest and the department’s need to maintain community confidence. The court found no evidence of impermissible viewpoint discrimination. The First Circuit affirmed the district court’s grant of summary judgment for the department. View "Hussey v. City of Cambridge" on Justia Law

In this case, the plaintiff, Robert Arias, sued several federal Drug Enforcement Administration (DEA) agents for damages, alleging that they violated his Fourth Amendment rights during his arrest in a shopping center parking lot in September 2016. Arias claimed that some agents used excessive force against him, while others failed to intervene to prevent that force. He based his claims on the implied cause of action for damages under the Fourth Amendment recognized by the Supreme Court in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics.The United States District Court for the District of New Hampshire granted summary judgment to the defendants. The court reasoned that, due to the 1988 amendment to the Inspector General Act (IGA), which created an administrative mechanism for reporting federal law enforcement misconduct, Arias’s claims arose in a “new context” compared to Bivens. The District Court concluded that the existence of this alternative remedial scheme counseled against extending the Bivens remedy, thus precluding Arias’s excessive force and failure-to-intervene claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the District Court’s decision. The First Circuit held that the IGA’s administrative remedy, by itself, does not make the context of Arias’s excessive force claims meaningfully different from Bivens. The court found that Arias’s excessive force claims arise in the same context as Bivens, so the Bivens remedy remains available. However, the court affirmed summary judgment on Arias’s failure-to-intervene claims, as he did not show that those claims arise in the same context as Bivens or justify extending Bivens to that context. The First Circuit thus reversed the District Court’s judgment on the excessive force claims and remanded for further proceedings, while affirming the judgment on the failure-to-intervene claims. View "Arias v. Herzon" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

Amber Lavigne filed a lawsuit against the Great Salt Bay Community School Board and various school staff members, alleging that they infringed on her constitutional right to parent by providing her child, A.B., with a chest binder and referring to A.B. by a different name and pronouns without informing her. Lavigne claimed that these actions were part of a school-wide policy of withholding such information from parents.The United States District Court for the District of Maine dismissed the claims against the individual defendants and later granted the Board's motion to dismiss, concluding that Lavigne had not plausibly alleged that the Board had a custom or policy of withholding information. The court found that Lavigne's allegations were based on conclusions unsupported by factual allegations and that the Board's statements did not constitute active approval of the individual defendants' actions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Lavigne had not plausibly alleged the existence of an unwritten policy or custom of withholding information from parents. The court noted that the Board's written policies encouraged parental involvement and that the statements made by the Board and school officials did not support the inference of an unwritten policy of withholding. The court also found that the Board's decision to renew the contract of the social worker involved did not amount to ratification of the alleged conduct. Thus, the appellate court concluded that Lavigne had failed to show that the Board was responsible for any constitutional violation. View "Lavigne v. Great Salt Bay Community School Board" on Justia Law

A graduate student and resident advisor (RA) at the University of Massachusetts, John Doe, was found responsible for sexual misconduct by the University in 2023. The University sanctioned him based on complaints from four female RAs about his interactions with them. Doe filed a federal lawsuit against the University, its trustees, and the members of the hearing panel, alleging that the University violated his First Amendment rights by punishing him for protected speech and expressive conduct. He sought a preliminary injunction, which the district court considered on a "case stated" basis, consolidating the preliminary injunction hearing with the trial on the merits.The district court ruled against Doe, finding that his First Amendment rights had not been violated. The court applied the Tinker standard, determining that the University's actions were justified because Doe's conduct caused or would cause a substantial disruption and invaded the rights of others. The court also held that the Individual Defendants were entitled to qualified immunity for monetary damages. Doe appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the record lacked evidence of substantial disruption to the academic environment or the complainants' jobs. The court also concluded that Doe's conduct did not constitute a pervasive pattern of unwelcome conduct. Therefore, the court held that the University's actions were not justified under the Tinker standard. However, the court affirmed the district court's ruling that the Individual Defendants were entitled to qualified immunity, as the law was not clearly established that their actions violated Doe's First Amendment rights. The judgment was reversed in part and affirmed in part. View "Doe v. University of Massachusetts" on Justia Law

From 1990 to 1999, Patrick Rose, Sr., a Boston Police Department (BPD) officer, sexually abused two children, John and Jane Doe. Rose pled guilty to 21 counts of child rape and sexual assault in April 2022. The Does, now adults, sued Rose, the BPD, and other defendants involved in the investigation and response to their abuse allegations, claiming the defendants deprived them of their Fourteenth Amendment right to bodily integrity by enhancing the danger from Rose's abuse.The United States District Court for the District of Massachusetts dismissed the case before discovery, concluding that the defendants could not be held responsible under the state-created danger doctrine because the Does did not sufficiently allege that the defendants' actions enhanced Rose's abuse and caused them harm. The court also dismissed the Does' remaining claims.The United States Court of Appeals for the First Circuit vacated the district court's decision regarding the Does' Fourteenth Amendment claims. The appellate court concluded that the Does plausibly alleged that some of the defendants' actions enhanced the danger to them, meeting the first requirement of the state-created danger test. The court remanded the case for the district court to evaluate those actions under the test's remaining requirements. The appellate court also vacated the dismissal of the claims against the City of Boston and the DCF defendants, allowing the Does to address those claims. However, the appellate court affirmed the dismissal of the Does' § 1985 claims, agreeing with the district court that the Does failed to allege membership in a protected class or class-based discrimination. View "Doe v. City of Boston" on Justia Law

The case involves Dr. Lisa Menninger, who was the Executive Director for Laboratory Operations at PPD Development, L.P. (PPD). Menninger claimed that PPD discriminated and retaliated against her due to her social anxiety disorder, violating the Americans with Disabilities Act (ADA) and Massachusetts antidiscrimination law. A jury found in favor of Menninger, awarding her over $24 million in damages. PPD then moved for judgment as a matter of law, a new trial, and remittitur, but the district court denied these motions.The United States District Court for the District of Massachusetts initially granted partial summary judgment for PPD, rejecting Menninger's theory that PPD could be liable solely for failing to engage in an interactive process. It also limited Menninger's disparate-treatment claims to a single adverse action. However, the court denied PPD's motion for summary judgment on other claims, allowing the case to proceed to trial. The jury found in favor of Menninger on all counts, concluding that PPD failed to provide reasonable accommodation, discriminated against her, and retaliated against her. The jury awarded substantial damages, including punitive damages.The United States Court of Appeals for the First Circuit reviewed the case. PPD argued that the evidence was insufficient to support the jury's verdict, that the jury instructions were misleading, and that the punitive damages were unsupported. The Court of Appeals found that PPD failed to properly preserve its sufficiency-of-the-evidence arguments by not specifying the grounds for its Rule 50(a) motion. The court also found no plain error in the jury instructions and concluded that the evidence supported the punitive damages award. The court affirmed the district court's judgment and its denial of PPD's posttrial motions. View "Menninger v. PPD Development, L.P." on Justia Law