Justia Civil Rights Opinion Summaries

Plaintiff was arrested for an alleged sexual assault, which allegation turned out to be false. Plaintiff brought this lawsuit against Defendants, Polk County and a Polk County investigator, advancing claims under 42 U.S.C. 1983 for false arrest and false imprisonment, and state common law claims for false imprisonment, malicious prosecution, negligence, and defamation. The district court granted summary judgment in favor of Defendants, concluding that the investigator had arguable probable cause to effect Plaintiff’s arrest and was entitled to qualified immunity and that Polk County could not be held liable under Monell v. Dep’t of Soc. Servs. The court declined to assert supplemental jurisdiction over Plaintiff’s state law claims and dismissed them without prejudice. The Seventh Circuit affirmed, holding (1) the investigator was entitled to qualified immunity because she reasonably believed probable cause existed to arrest Plaintiff; (2) there was no dispute as to any material fact with regard to Plaintiff’s Monell claims; (3) the district court did not abuse its discretion in dismissing without prejudice Plaintiff’s state law claims; and (4) the district court did not abuse its discretion in denying Plaintiff’s motion to alter or amend the judgment. View "Burritt v. Ditlefsen" on Justia Law

Backpage.com provides an online forum for classified ads and includes an “adult section.” The Sheriff of Cook County initiated a campaign to extinguish Backpage’s adult section - and, by extension, all of Backpage - by demanding that credit card companies prohibit the use of their credit cards to purchase any ads on Backpage since the ads might be for illegal sex-related services or products. Backpage sought a preliminary injunction to stop the sheriff’s actions, arguing that the sheriff was violating the First Amendment by curtailing freedom of expression. The district judge denied the motion for a preliminary injunction. The Seventh Circuit reversed, holding that the sheriff, in his capacity as a public official, violated the First Amendment by issuing and publicizing threats against credit card companies that process payments made through Backpage’s website, including threats of prosecution, in an effort to shut down Backpage. View "Backpage.com, LLC v. Dart" on Justia Law

Plaintiff, an occasional employee of the Federal Emergency Management Agency, which is part of the Department of Homeland Security (DHS), filed an administrative claim of discrimination on the basis of her race, age, and sex. While the suit began as an administrative proceeding within the DHS, it molted into a judicial proceeding. Both the lawsuit and the administrative proceeding were based on Title VII of the Civil Rights Act of 1964. The federal district court granted DHS’s motion for judgment on the pleadings, concluding that Plaintiff had failed to exhaust her administrative remedies by failing to amend her original administrative complaint to add her retaliation claim. The Seventh Circuit reversed, holding that the district court erred in dismissing Plaintiff’s suit because it was the fault of the Equal Employment Opportunity Commission that the retaliation claim did not become part of the original case. Remanded. View "Moreland v. Johnson" on Justia Law

Mathew Neisler worked as a stockman in food service during his incarceration at the Waupun Correctional Institution. Three months after Neisler suffered work-related injury, he was fired for “medical” reasons. Neisler filed suit against defendant prison administrators, alleging that he had been fired because of a disability in violation of Title II of the Americans with Disabilities Act (ADA). Defendants filed motion for summary judgment, arguing, inter alia, that Neisler was not entitled to pursue an employment-discrimination claim under Title II. The district court granted summary judgment in favor of Defendants, concluding that Title II of the ADA covered Neisler’s claim but that no rational finder of fact could find disability discrimination. The Seventh Circuit affirmed but on different grounds, holding that Title II does not apply to a prisoner’s claim of employment discrimination in a prison job. View "Neisler v. Tuckwell" on Justia Law

An Illinois state trooper stopped a car that had been speeding. The subsequent search of the car revealed 1.5 kilograms of cocaine, which the police seized. Defendant, who was one of two passengers in the car, was prosecuted in federal court for possessing and intending to sell the cocaine found in the car. Defendant filed a motion to suppress the cocaine evidence. The district judge denied the motion, concluding (1) as a passenger in the car, Defendant had no standing to challenge the search; and (2) even if Defendant had standing, the delay did not make the search unlawful. Defendant subsequently entered a conditional plea of guilty to the charges. The Seventh Circuit affirmed in part, reversed in part, and remanded, holding (1) Defendant’s conviction was proper; but (2) the district court erred in imposing certain conditions of supervised release as part of Defendant’s sentence. View "United States v. Sanford" on Justia Law

After a jury trial in an Illinois state court, Appellant was found guilty of murdering his girlfriend’s one-year-old daughter. After exhausting his state appeals, Appellant filed a federal habeas petition, claiming, inter alia, that the forty-two-month delay in bringing his case to trial violated his Sixth Amendment right to a speedy trial. The district court denied the habeas petition. On direct appeal, the Illinois Appellate Court concluded that the pretrial delay was presumptively prejudicial but that the delay was attributable to continuances requested by Appellant’s counsel and did not impair the defense. The Seventh Circuit affirmed, holding that the Illinois court’s decision was not an unreasonable application of federal law, and therefore, habeas relief was unwarranted. View "O'Quinn v. Spiller" on Justia Law

Plaintiff, an employee of Costco Wholesale Corporation, made two requests for a medical leave under the FMLA. Costco granted both requests. During that time, Plaintiff was demoted from optical manager to cashier. Plaintiff filed this lawsuit against Costco and Gail Hinds, his supervisor, alleging retaliation and interference, both in violation of the FMLA, and discrimination based upon a disability and failure to accommodate, both in violation of the Americans with Disabilities Act. The district court granted summary judgment for Defendants on all of Plaintiff’s causes of action. The Seventh Circuit affirmed, holding that the district court (1) did not abuse its discretion in finding that Plaintiff failed to comply with the requirements of the Northern District of Illinois Local Rule 56.1; (2) properly granted summary judgment in favor of Defendants on Plaintiff’s FLMA retaliation and interference claims; and (3) properly granted summary judgment in favor of Defendants on Plaintiff’s reasonable accommodation claim. Lastly, Plaintiff waived any arguments with regard to disparate treatment. View "Curtis v. Costco Wholesale Corp." on Justia Law

Sixteen days after Defendant, a dentist, learned Plaintiff, an inmate of Illinois’s Stateville prison, was complaining of a tooth abscess, Defendant diagnosed an abscessed molar, prescribed penicillin to bring the infection under control, and extracted the molar. Plaintiff sued the dentist and a prison guard (together, Defendants), charging them with deliberate indifference to his abscess. The district judge granted summary judgment in favor of Defendants. The Seventh Circuit reversed, holding that the evidence of deliberate indifference by Defendants to Plaintiff’s serious medical need precluded granting summary judgment in their favor. Remanded. View "Dobbey v. Mitchell-Lawshea" on Justia Law

On July 5, 2013, the Governor of Wisconsin signed into a law a statute that the Wisconsin legislature had passed one month earlier prohibiting a doctor from performing an abortion unless he or she has admitting privileges at a hospital no more than thirty miles from the clinic in which the abortion is performed. Planned Parenthood of Wisconsin and Milwaukee Women’s Medical Services (which operate the only four abortion clinics in Wisconsin) joined by two doctors employed by Planned Parenthood, challenged the statute’s constitutionality under 42 U.S.C. 1983, first seeking and obtaining a preliminary injunction and ultimately seeking a permanent injunction against enforcement of the statute. After a trial, the trial judge granted a permanent injunction against enforcement of the statute. The Seventh Circuit affirmed, holding (1) Plaintiffs had standing to sue; and (2) the statute is unconstitutional because it imposes a burden excessive in relation to the aims of the statute and the benefits likely to be conferred by it. View "Planned Parenthood of Wisconsin, Inc. v. Schimel" on Justia Law

Plaintiff, who is black, filed a complaint against the Chicago Transit Authority (CTA) in federal court, alleging that the CTA fired him because of his race in violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The CTA responded that Plaintiff was fired because he violated CTA’s policy against sexual harassment. The district court granted the CTA’s motion for summary judgment, concluding that Plaintiff’s evidence was insufficient to create a triable issue under either the direct or indirect methods of proving unlawful discrimination. The Seventh Circuit affirmed, holding that Plaintiff’s case failed under both the direct and indirect methods of proof. View "Smith v. Chicago Transit Auth." on Justia Law