Justia Civil Rights Opinion Summaries

Dorothy Bivens worked as a territory sales representative for a company that manufactures and distributes cleaning products. During a visit to a client’s motel, the client locked the office door and propositioned her, making her uncomfortable. Bivens reported the incident to her supervisor, who reassigned the client so she would not have further contact. Around the same period, the company’s president decided to reduce staff due to cost concerns, targeting positions in low-revenue territories, including Bivens’s. She was subsequently terminated.After her termination, Bivens filed suit in the United States District Court for the Eastern District of Michigan, alleging a hostile work environment, retaliation for reporting harassment, and racial discrimination under both Title VII and Michigan’s Elliott-Larsen Civil Rights Act. The district court denied her motion to compel production of certain documents and granted summary judgment to the employer on all claims, finding insufficient evidence to support her allegations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment decision de novo. The appellate court held that, under Title VII, an employer can only be held liable for harassment by a non-employee (such as a client) if the employer itself intentionally caused or was substantially certain harassment would occur, rejecting the negligence standard adopted by most other circuits and the EEOC. The court found no evidence that the employer intended for Bivens to be harassed. The court also found that Bivens’s retaliation claim failed because the decisionmaker who terminated her was unaware of her complaint, and her racial discrimination claim failed due to lack of evidence that she was singled out because of her race. The court affirmed the district court’s judgment in all respects. View "Bivens v. Zep, Inc." on Justia Law

In 1994, Kenneth Hayes was murdered in Wayne County, Michigan. Larry Smith was convicted of first-degree murder and a firearm charge, largely based on the testimony of Edward Allen, a jailhouse informant who claimed Smith confessed to the crime. Smith’s conviction was affirmed on direct appeal, and his subsequent state and federal habeas petitions were unsuccessful. Years later, the Wayne County Prosecutor’s Conviction Integrity Unit investigated and found evidence suggesting Allen’s testimony may have been fabricated as part of a broader scheme involving police and prosecutors eliciting false testimony from informants. Smith’s conviction was vacated in 2021, and he was released from prison.After his release, Smith obtained compensation from the State of Michigan under the Wrongful Imprisonment Compensation Act (WICA), settling for $850,000 and signing a release of claims against the State. He then filed a federal lawsuit against Wayne County and prosecutor Robert Donaldson, alleging constitutional violations under 42 U.S.C. § 1983 and a Monell claim against the County for policies encouraging false testimony. The United States District Court for the Eastern District of Michigan granted summary judgment to both defendants, finding Donaldson was protected by absolute prosecutorial immunity and that Smith’s settlement under WICA released his claims against Wayne County.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that Donaldson was entitled to absolute prosecutorial immunity because his conduct—preparing a witness for trial—was within the scope of his advocacy role, not investigatory. The court also held that Smith’s acceptance of the WICA settlement released all claims against Wayne County, including federal claims, as a matter of law. The Sixth Circuit affirmed the district court’s grant of summary judgment to both defendants. View "Smith v. Wayne County" on Justia Law

Davariol Marquavis Taylor, an incarcerated individual, sued several members of the correctional staff at Marquette Branch Prison under 42 U.S.C. § 1983, alleging constitutional violations. Taylor claimed that a nurse administered incorrect medication, resulting in another inmate's overdose and death. He also alleged that a doctor sexually assaulted him and punched him when he resisted. Taylor sought to proceed in forma pauperis, which allows a litigant to avoid paying filing fees upfront due to financial constraints.The United States District Court for the Western District of Michigan denied Taylor's motion to proceed in forma pauperis, citing the Prison Litigation Reform Act’s (PLRA) “three-strikes” rule, which prevents incarcerated individuals from proceeding in forma pauperis if they have had three or more prior cases dismissed as frivolous, malicious, or failing to state a claim. The district court identified four previous cases as strikes against Taylor and dismissed his suit when he did not pay the filing fee. Taylor appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Taylor had only two valid PLRA strikes, not three. The court determined that the district court's original order incorrectly counted two cases, Adler and Stump, as strikes. The court clarified that dismissals based on Eleventh Amendment immunity or improper filing under § 1983 do not count as strikes unless all claims in the complaint are dismissed for being frivolous, malicious, or failing to state a claim. Consequently, the Sixth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Taylor v. Stevens" on Justia Law

Anthony McClendon, a Michigan prisoner, was recommended by prison officials to participate in a sex-offender program due to his past conviction for criminal sexual conduct. McClendon refused to participate in the program, leading to repeated denials of parole by the Michigan parole board. McClendon filed a lawsuit under 42 U.S.C. § 1983, claiming that the recommendation to complete the sex-offender program and the subsequent parole denials violated his due process rights under the Fourteenth Amendment.The United States District Court for the Eastern District of Michigan dismissed McClendon’s complaint. The court found that McClendon did not have a cognizable liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary parole system. The court also noted that McClendon’s past conviction for a sex offense negated any liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Sixth Circuit held that McClendon’s due process claim failed because he did not identify a cognizable liberty interest. The court determined that McClendon did not have a liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary system. Additionally, the court found that McClendon’s past conviction for a sex offense meant he did not have a liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole. The court concluded that McClendon’s due process rights were not violated and affirmed the district court’s judgment. View "McClendon v. Washington" on Justia Law

Matthew Warman, a former graduate student at Mount St. Joseph University (MSJU), objected to taking the COVID-19 vaccine on religious grounds. When MSJU required all students and employees to be vaccinated, Warman applied for a religious exemption. He was allegedly detained by two MSJU Police Department officers who attempted to convince him to get vaccinated and disparaged his religious beliefs. Warman later sued MSJU, MSJPD, and several individual employees.The United States District Court for the Southern District of Ohio dismissed Warman’s complaint. The court dismissed his free exercise, equal protection, and disability discrimination claims with prejudice and dismissed MSJPD from all counts with prejudice. Warman appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of Warman’s free exercise, equal protection, and disability discrimination claims. However, the court found that Warman plausibly pleaded that the two officers who detained him violated his Fourth Amendment rights. Consequently, the court reversed the district court’s dismissal of Warman’s wrongful detention claim and reinstated the claim against those defendants. The court also vacated the district court’s declination of supplemental jurisdiction over Warman’s state-law claims and remanded for reconsideration.In summary, the Sixth Circuit affirmed the dismissal of most of Warman’s claims but reinstated his Fourth Amendment wrongful detention claim against the two officers and remanded the state-law claims for further consideration. View "Warman v. Mount St. Joseph University" on Justia Law

Officer Jeff Smith, the oldest and longest-tenured police officer in the City of Union, Ohio, was terminated after allegedly violating several police department policies over a two-day period. An arbitrator later ordered his reinstatement, finding the termination to be an overreaction to minor and excusable mistakes. However, the City delayed his return for two months, requiring a fitness-for-duty examination and acting slowly once he passed it. During this delay, a younger officer was promoted, and raises were secured for all officers except Smith.Smith sued the City under the Age Discrimination in Employment Act (ADEA) and its Ohio counterpart, alleging age-based termination and retaliatory delay in his return for filing a charge with the Equal Employment Opportunity Commission (EEOC). The United States District Court for the Southern District of Ohio granted summary judgment to the City on both claims, leading Smith to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that a jury could view the facts and agree with Smith, particularly given the arbitrator's decision and a comment by the police chief about "younger officers." The court held that Smith presented enough circumstantial evidence to raise a triable question of whether the City terminated him due to his age. Additionally, the court found that the City's delay in reinstating Smith, which caused him to miss a promotion and a raise, could be seen as retaliatory.The Sixth Circuit reversed the district court's grant of summary judgment for the City and remanded the case for further proceedings, allowing Smith's claims of age discrimination and retaliation to proceed. View "Smith v. City of Union" on Justia Law

Louisville Metro Police Department officers conducted a search of Jennie and Saul Wright’s home, where they lived with their great-nephews, Jawand Lyle and Brendon Burnett. The Wrights claimed the search violated their constitutional rights and filed a lawsuit against Louisville Metro Government and unknown police officers under 42 U.S.C. § 1983. The district court dismissed the claims of both the Wrights and their great-nephews.The United States District Court for the Western District of Kentucky dismissed the Wrights' claims, and the Wrights appealed. The Sixth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction. The Wrights' counsel withdrew, and the Wrights, proceeding pro se, filed an amended complaint naming the previously unknown officers. The district court dismissed the claims against the individual officers as untimely and dismissed the Monell claim against Louisville Metro Government for failure to state a claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that it lacked appellate jurisdiction over the claims of Jawand and Brendon because they were not included in the notice of appeal. The court affirmed the district court’s dismissal of Jennie and Saul Wright’s claims against the individual officers as untimely, as the amended complaint did not relate back to the original complaint under Rule 15(c)(1). The court also affirmed the dismissal of the Monell claim against Louisville Metro Government, finding that the Wrights failed to provide sufficient factual allegations to support their claims of inadequate training and unconstitutional policies or customs. The court declined to take judicial notice of a 2023 Department of Justice report and denied the request to remand the case for consideration of the report. View "Wright v. Louisville Metro Government" on Justia Law

James King sued the United States under the Federal Tort Claims Act (FTCA) and individual government employees under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging physical abuse by U.S. officials. The district court granted summary judgment to the defendants on both claims. King appealed only the Bivens claim, making the FTCA judgment final. The individual defendants argued that the FTCA's "judgment bar" precluded the Bivens claim. The Supreme Court ultimately ruled in favor of the defendants, stating that the FTCA judgment barred the Bivens claim.King then filed a Rule 60(b) motion in the district court to reopen the FTCA judgment to withdraw his FTCA claim and avoid the judgment bar. The district court denied the motion, reasoning that attorney error or strategic miscalculation is not a valid basis for reopening under Rule 60. King appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The court held that the district court did not abuse its discretion, as attorney error or strategic miscalculation does not justify reopening a final judgment under Rule 60. The court emphasized the public policy favoring the finality of judgments and noted that Rule 60(b)(6) relief is only available in exceptional or extraordinary circumstances, which were not present in this case. View "King v. United States" on Justia Law

Plaintiff Karim Codrington was subjected to an unlawful traffic stop, search, and arrest by Louisville Metro Police Department officers. During the criminal proceedings, a Kentucky state court suppressed the evidence seized from his vehicle and dismissed the charges. Over three years later, Codrington filed a 42 U.S.C. § 1983 lawsuit, alleging that the officers planted drugs on him, provided those drugs to prosecutors, and stole thousands of dollars from him.The United States District Court for the Western District of Kentucky granted summary judgment in favor of the defendants on all claims, finding that Codrington’s claims were either barred by the statute of limitations or failed on their merits. Specifically, the court found that the unlawful search and seizure, selective enforcement, and false arrest/imprisonment claims were time-barred. The court also found that Codrington failed to provide sufficient evidence to support his fabrication-of-evidence and malicious-prosecution claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment on the unlawful search and seizure, selective enforcement, false arrest/imprisonment, malicious prosecution, and state-law conversion claims. However, the court reversed the district court’s grant of summary judgment on the fabrication-of-evidence claim, finding that there was a genuine dispute of material fact regarding whether the officers fabricated evidence. The court also vacated the district court’s judgment on Codrington’s Monell claims and remanded for further proceedings. View "Codrington v. Dolak" on Justia Law

Randy Wiertella died in the Lake County Adult Detention Facility on December 10, 2018. Dennis Wiertella, as the Administrator of Randy's estate, filed a lawsuit claiming that Randy's constitutional rights under the Eighth and Fourteenth Amendments were violated by Jail staff Diane Snow, RN, and Christina Watson, LPN. Randy had been booked into the Jail without his essential medications for heart disease, diabetes, high blood pressure, and a psychiatric disorder. Despite multiple requests, he did not receive all necessary medications, leading to his death from hypertensive cardiovascular disease.The United States District Court for the Northern District of Ohio denied Snow and Watson's motion for summary judgment, which sought dismissal based on qualified immunity. The court found that there were genuine disputes of material fact regarding whether Snow and Watson were aware of the substantial risk to Randy's health and whether they failed to respond reasonably.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Snow and Watson were not entitled to qualified immunity. The court found that both nurses were aware of Randy's serious medical conditions and the need for continuous medication. Despite this knowledge, they failed to ensure that Randy received his essential medications in a timely manner. The court concluded that their actions were unreasonable and violated Randy's constitutional rights. The court affirmed the district court's decision and remanded the case for further proceedings on the Estate's § 1983 claim. View "Wiertella v. Lake County" on Justia Law