Justia Civil Rights Opinion Summaries

Eddie Bolden was arrested in 1994 for double murder and attempted murder, convicted by a jury in 1996, and sentenced to life in prison. After more than 22 years incarcerated, his conviction was vacated by Illinois courts in 2016 due to ineffective assistance of counsel, and the State dismissed all charges, leading to his immediate release. Bolden subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police officers, alleging constitutional and state law violations stemming from his wrongful conviction and imprisonment.The case was heard in the United States District Court for the Northern District of Illinois, Eastern Division. After delays, including judicial reassignment and the COVID-19 pandemic, the trial occurred in October 2021. The jury found in Bolden’s favor, awarding $25 million in compensatory damages for pain, suffering, and loss of normal life, plus punitive damages against two individual defendants. The district court later granted Bolden’s motion to amend the judgment to include $7.6 million in prejudgment interest, calculated from the date his conviction was vacated to the entry of final judgment.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether prejudgment interest could be awarded on noneconomic damages and whether the district court abused its discretion in granting the interest. The Seventh Circuit held that prejudgment interest is available as a matter of law for noneconomic damages in federal civil rights cases, reaffirming its precedent. However, the court found that interest should only be awarded on past damages, not future damages, and remanded for the district court to apportion the jury’s verdict accordingly. In all other respects, the district court’s judgment was affirmed. View "Bolden v. Pesavento" on Justia Law

A 69-year-old employee of the Cook County Sheriff’s Office, who previously had a long career with the Chicago Police Department, was terminated from his position as Assistant Chief of the Electronic Monitoring Unit. The termination followed an internal investigation into his work performance, which included allegations that he was absent from his post without authorization, failed to communicate with his team, and used work hours and resources for personal business. The investigation, initiated after a complaint by his supervisor, involved interviews with colleagues and a review of GPS and work records, ultimately concluding that he had neglected his duties on multiple occasions.After his termination, the employee filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against his supervisor in her individual capacity and the Sheriff in his official capacity, alleging age discrimination under the Fourteenth Amendment (via 42 U.S.C. § 1983), the Age Discrimination in Employment Act (ADEA), and the Illinois Human Rights Act (IHRA). He also brought an indemnification claim against Cook County. During discovery, he presented affidavits from other older officers alleging ageist comments and discriminatory treatment by the same supervisor. The district court granted summary judgment for all defendants, finding insufficient evidence of age-based disparate treatment or causation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, and that the evidence did not support a finding that any alleged discriminatory animus by the supervisor proximately caused the termination. The court also found that the internal investigation and the ultimate decisionmaker’s independent review provided legitimate, non-discriminatory reasons for the termination, precluding liability under the Fourteenth Amendment, ADEA, and IHRA. View "Gaines v Dart" on Justia Law

Bernard Mims spent a decade in prison after being convicted of murder, a conviction later vacated when the State’s Attorney’s Office lost confidence in the case for reasons unrelated to the claim at issue here. Mims then brought a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police detectives. He alleged, among other things, that two detectives violated his due process rights by failing to disclose an audio recording of a conversation between two individuals, one of whom had previously claimed involvement in the murder. Mims argued that this recording was exculpatory because it implicated someone else in the crime.The United States District Court for the Northern District of Illinois granted summary judgment to the defendants on all claims. As relevant to this appeal, the district court found that Mims had not produced evidence showing that the detectives concealed or withheld the recording from the prosecutor. The court also concluded that the recording was not material under Brady v. Maryland, and, alternatively, that the detectives were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court held that Mims failed to present evidence that the detectives intentionally or recklessly concealed the recording from the prosecution. The court emphasized that the prosecutor had knowledge of and access to the recordings through the court file and that the duty to disclose exculpatory evidence primarily rests with the prosecution. Because Mims could not show suppression by the detectives, the Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants. View "Mims v City of Chicago" on Justia Law

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law

An inmate at a Wisconsin correctional institution was attacked by another prisoner, resulting in serious injury. The inmate alleged that prison officials were aware of the risk of such an attack but failed to take preventive action. After the incident, medical staff did not arrange for the inmate to see a specialist within the recommended timeframe. The inmate claimed to have filed a formal complaint about both the lack of protection and inadequate medical care by placing a completed complaint form in his cell door for collection on January 2, 2017. He did not receive an acknowledgment of receipt and, after inquiring with a complaint examiner a month later, was told no complaint had been received. He then filed a new complaint, referencing his earlier attempt and supporting it with a journal entry and correspondence to other inmates.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the inmate failed to exhaust administrative remedies as required by the Prison Litigation Reform Act. The court relied on the Seventh Circuit’s decision in Lockett v. Bonson, finding that the inmate’s evidence was insufficient to show timely filing and that he should have followed up sooner when he did not receive an acknowledgment.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The appellate court found that, unlike in Lockett, the inmate provided more than a mere assertion of timely filing, including a sworn declaration, a journal entry, and references in subsequent complaints. The court held that this evidence created a genuine dispute of material fact regarding whether a timely complaint was filed. The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings, instructing the lower court to determine whether the exhaustion issue is intertwined with the merits, which could entitle the parties to a jury trial under Perttu v. Richards. View "Breyley v. Fuchs" on Justia Law

An Arab American faculty member began working at a university as an adjunct instructor and later held a term faculty position. In April 2017, he and another faculty member were informed that their contracts would not be renewed due to budget constraints. Around the same time, the university received a letter from an attorney alleging that the faculty member had engaged in repeated acts of sexual misconduct with a student. The university’s Title IX coordinator initiated an investigation, during which the faculty member admitted to a sexual relationship with the student but claimed it was consensual and began after she was no longer his student. The student did not participate in the investigation, and the coordinator found insufficient evidence of misconduct. The department chair and the faculty member discussed his possible reappointment as an adjunct, but after the student filed a lawsuit alleging sexual harassment and other misconduct, the university decided not to hire him as an adjunct, citing low course enrollment, his compensation request, and the lawsuit. A second investigation was launched, and this time the coordinator found, by a preponderance of the evidence, that the faculty member had sexually harassed the student. The university then deemed him ineligible for future employment.The faculty member sued the university and two former employees in the United States District Court for the Northern District of Illinois, alleging racial discrimination under 42 U.S.C. § 1981, among other claims. The district court dismissed his other claims and granted summary judgment to the university on the § 1981 claim, finding that the university had provided legitimate, nondiscriminatory reasons for its actions and that the faculty member had not shown these reasons were pretext for racial discrimination.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Seventh Circuit held that the faculty member failed to present evidence that the university’s stated reasons for its employment decisions were pretext for racial discrimination. View "Saud v DePaul University" on Justia Law

Amy Hadley’s home in South Bend, Indiana, was significantly damaged when law enforcement officers executed a search warrant in pursuit of a murder suspect they believed was inside her residence. The officers, acting on information that the suspect had accessed his Facebook account from Hadley’s IP address, obtained a warrant and forcefully entered the home, causing extensive property damage, including the use of tear gas and destruction of personal items. Hadley, who had no connection to the suspect, was denied compensation by both the City of South Bend and St. Joseph County for the $16,000 in damages.After her request for compensation was denied, Hadley filed suit in Indiana state court, seeking relief under 42 U.S.C. § 1983 for violations of her Fifth and Fourteenth Amendment rights, specifically invoking the Takings Clause. The case was removed to the United States District Court for the Northern District of Indiana, South Bend Division. The defendants moved to dismiss, arguing that Seventh Circuit precedent, particularly Johnson v. Manitowoc County, foreclosed her claim. The district court agreed and dismissed the complaint, finding that the Takings Clause did not entitle her to compensation for property damage resulting from the execution of a lawful search warrant.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that, under its precedent in Johnson v. Manitowoc County, the Fifth Amendment does not require the government to compensate property owners for damage caused by law enforcement executing a valid search warrant. The court declined to overrule Johnson and found that Hadley’s arguments did not warrant revisiting the established rule. View "Hadley v. City of South Bend" on Justia Law

Patrick Jones Jr. was hired as a probationary deputy sheriff by the Lake County Sheriff’s Office and sent to a police training academy. During his training, Jones obtained a document from his girlfriend, believing it to be a study guide, and offered to share it with classmates. The document was actually a cheat sheet for a prior version of the Illinois state law enforcement exam. After an investigation by the training institute, which concluded Jones likely did not understand the document’s true nature, the Sheriff’s Office nonetheless terminated his employment. The termination letter, authored by Undersheriff Lawrence Oliver, cited Jones’s conduct as violating the office’s code of conduct and was distributed internally and to the office’s Merit Commission. Jones later struggled to find new law enforcement employment, attributing this difficulty to the termination letter.Jones filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the termination letter was defamatory and that it deprived him of occupational liberty in violation of the Fourteenth Amendment. The district court granted summary judgment for the Sheriff’s Office and Undersheriff Oliver, finding that Jones failed to show it was virtually impossible for him to find new employment and that the statements in the letter were either true or opinion, and that Oliver was entitled to absolute immunity under Illinois law.The United States Court of Appeals for the Seventh Circuit affirmed. The court held that the Sheriff’s Office was not a proper defendant under 42 U.S.C. § 1983 because Jones did not allege a policy or custom as required for municipal liability. The court further held that Jones’s occupational liberty claim failed because there was no evidence that Undersheriff Oliver publicly disclosed the termination letter. Finally, the court held that Undersheriff Oliver was entitled to absolute immunity under Illinois law for statements made within the scope of his official duties. View "Jones v. Lake County Sheriff's Office" on Justia Law

Rodriquez D’Aundre Pam was shot and killed by Evansville police officers responding to a 911 call reporting that a man matching Pam’s description was in a backyard with a handgun, allegedly pointing it at a dog and at the caller. Officers arrived, encountered Pam on the property, and repeatedly ordered him to show his hands and get on the ground. Pam did not comply, appeared to reach for the doorknob, then moved along the house, put his hands in his pockets, and removed them when ordered. As officers continued to issue commands, Pam raised his left hand and kept his right hand at his side. Officers then fired multiple shots, killing him. A handgun was found near Pam’s body. Body camera footage captured the incident, but the video was unclear as to whether Pam was holding a gun at the moment he was shot.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the officers, finding it undisputed that Pam pointed a gun at them before they fired. Pam’s estate appealed, challenging the grant of summary judgment for Officers Offerman and McQuay.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering the evidence in the light most favorable to the estate. The court found that, while the video did not conclusively show Pam pointing a gun, the officers’ belief that Pam was threatening them with a firearm was objectively reasonable given the circumstances, including the 911 report, Pam’s actions, and the recovery of a gun. The Seventh Circuit held that the officers were entitled to qualified immunity because their perception and response did not violate clearly established law. The court affirmed the district court’s grant of summary judgment. View "Pam v. City of Evansville" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law