Justia Civil Rights Opinion Summaries

In the spring of 2020, a woman with a history of severe mental illness was detained at the Bucks County Correctional Facility after an altercation with a neighbor. While in custody, she was allegedly subjected to repeated uses of force by corrections officers, including being pepper sprayed, handcuffed, and placed in a restraint chair on multiple occasions. The complaint asserts that these actions were taken as punishment for her inability to comply with directives due to her mental illness, and that she did not pose a threat to staff or other inmates. Her condition deteriorated significantly during her detention, leading to her eventual transfer to a mental hospital, by which time she was reportedly catatonic and unresponsive.Her parents, acting on her behalf, filed suit in the United States District Court for the Eastern District of Pennsylvania against Bucks County and various corrections officers, alleging violations of her constitutional rights under 42 U.S.C. § 1983. The District Court found that the complaint sufficiently alleged a violation of her Fourteenth Amendment right to be free from excessive force and denied the defendants’ motion to dismiss on qualified immunity grounds. The court reasoned that the complaint was not detailed enough to determine whether the right at issue was clearly established at the time of the alleged conduct, and that further factual development was necessary.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that when a complaint plausibly alleges a constitutional violation but lacks sufficient detail to assess whether the right was clearly established, qualified immunity cannot be granted at the motion-to-dismiss stage. The court concluded that the defendants’ entitlement to qualified immunity was not apparent from the face of the complaint and remanded the case for limited discovery to develop the facts necessary for a proper qualified immunity analysis. View "Stringer v. County of Bucks" on Justia Law

Alexander Smith, a Christian firefighter in Atlantic City, was prohibited from growing a beard due to the city's grooming policy, which he claimed violated his religious beliefs. Smith sued the city, alleging violations of the Free Exercise Clause, the Equal Protection Clause, and Title VII’s accommodation and anti-retaliation provisions. The District Court denied his motion for a preliminary injunction and later granted summary judgment for the city on all claims.The United States District Court for the District of New Jersey initially denied Smith's motion for a preliminary injunction, finding that his claims were unlikely to succeed on the merits. After discovery, the court granted summary judgment in favor of the city on all four claims, leading Smith to appeal the decision.The United States Court of Appeals for the Third Circuit reviewed the case. The court vacated the District Court’s judgment regarding Smith’s Title VII accommodation claim and his free exercise claim, finding that the city's grooming policy was not generally applicable and failed strict scrutiny. The court affirmed the District Court’s judgment on the equal protection claim and the Title VII retaliation claim, concluding that Smith did not establish a prima facie case of retaliation. Additionally, the court reversed the denial of Smith’s motion for a preliminary injunction, recognizing a likelihood of success on the merits and the irreparable harm caused by the loss of First Amendment freedoms. View "Smith v. City of Atlantic City" on Justia Law

A private fencing coach alleged that during a flight, a university’s assistant fencing coach sexually harassed and assaulted her. She reported the incident to the university’s head coach, who discouraged her from reporting it further and, along with the assistant coach, allegedly retaliated against her within the fencing community. The university later investigated and confirmed the harassment but found no policy violation. The coach sued the university, the two coaches, and the Title IX coordinator, claiming violations of Title IX and state-law torts.The United States District Court for the Middle District of North Carolina transferred the case to the Middle District of Pennsylvania due to improper venue and judicial efficiency. After the transfer, the plaintiff amended her complaint, and the defendants moved to dismiss. The transferee court dismissed the entire suit, holding that the plaintiff, as neither a student nor an employee, was outside the zone of interests protected by Title IX. It also dismissed the state-law tort claims as untimely or implausible.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the zone-of-interests test applies to Title IX claims and that the plaintiff’s claims related to her exclusion from university-hosted fencing events and retaliation manifesting on campus were within that zone. The court affirmed the dismissal of the state-law tort claims against the university and its employees, except for the claims against the assistant coach, which were not time-barred under North Carolina’s three-year statute of limitations. The case was vacated in part, affirmed in part, and remanded for further proceedings. View "Oldham v. Penn State University" on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

Richard Hightower, a pretrial detainee, was attacked by his cellmate, Anthony Tyler, in a Philadelphia jail, resulting in Hightower's paralysis. Hightower was classified as a low-security risk, while Tyler was classified as a high-security risk with a history of violent behavior. Due to a mistake by a prison health services company, Tyler was placed in Hightower's intake cell instead of being transferred to a permanent cell. Tyler's aggressive behavior escalated, culminating in a violent attack on Hightower.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the City of Philadelphia and the guards. Hightower did not appeal the judgment for the guard but did appeal the judgment for the city.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Hightower failed to prove that the city caused any constitutional violation. To succeed in his Monell claim, Hightower needed to show that the city had an unconstitutional policy or custom or was deliberately indifferent to inmates' rights. The court found that the city had no policy of not separating inmates by security-risk level during intake and that the lack of a policy is not a policy. Additionally, Hightower could not show a custom that violated his rights or that the city acted with deliberate indifference. The court concluded that the risk to Hightower was not so obvious that the city could be held liable without a pattern of similar violations.The Third Circuit affirmed the District Court's summary judgment in favor of the City of Philadelphia. View "Hightower v. City of Philadelphia" on Justia Law

Jorge Rivera-Guadalupe was living in a rooming house in Harrisburg, Pennsylvania, when he was mugged and robbed. His friend, Christopher Valkosak, came to stay with him for protection. The next evening, Valkosak was shot by a stranger in the hallway outside Rivera-Guadalupe’s room. Detective Jacob Pierce investigated the incident, interviewed a neighbor who described the shooter as a tall Black male, and obtained a search warrant for Rivera-Guadalupe’s room. The search yielded marijuana, a knife, and IDs but no gun. Rivera-Guadalupe was arrested and charged with multiple offenses, including attempted homicide and possession of marijuana. He was acquitted of all charges after being incarcerated for over eighteen months.The United States District Court for the Middle District of Pennsylvania dismissed claims against other defendants but allowed the malicious prosecution claim against Det. Pierce to proceed. Det. Pierce sought dismissal based on qualified immunity, arguing that probable cause for some charges precluded a malicious prosecution claim. The District Court, referencing Johnson v. Knorr, held that probable cause for one charge does not insulate officers from liability for malicious prosecution on other charges lacking probable cause. Det. Pierce’s motion for judgment on the pleadings was denied, and he appealed.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the right to be prosecuted only on charges supported by probable cause was not clearly established at the time of Rivera-Guadalupe’s prosecution due to conflicting precedents within the circuit and among other circuits. The court reversed the District Court’s denial of qualified immunity for Det. Pierce and remanded the case with instructions to dismiss on that basis. The court clarified that the any-crime rule applies to false arrest claims but not to malicious prosecution claims. View "Rivera-Guadalupe v. Pierce" on Justia Law

A Harrisburg, Pennsylvania ordinance prohibits persons to “knowingly congregate, patrol, picket or demonstrate in a zone extending 20 feet from any portion of an entrance to, exit from, or driveway of a health care facility.” Individuals purporting to provide “sidewalk counseling” to those entering abortion clinics claimed that the ordinance violated their First Amendment rights to speak, exercise their religion, and assemble, and their due process and equal protection rights. The court determined that the ordinance was content-neutral because it did not define or regulate speech by subject-matter or purpose, so that intermediate scrutiny applied, and reasoned that it must accept as true (on a motion to dismiss) claims that the city did not consider less restrictive alternatives. The claims proceeded to discovery. In denying preliminary injunctive relief, the court ruled that plaintiffs did not demonstrate a likelihood of success on the merits. The Third Circuit vacated. In deciding whether to issue a preliminary injunction, plaintiffs normally bear the burden of demonstrating likelihood of prevailing on the merits. In First Amendment cases where the government bears the burden of proof on the ultimate question of a statute’s constitutionality, plaintiffs must be deemed likely to prevail for purposes of considering a preliminary injunction unless the government has shown that plaintiffs’ proposed less restrictive alternatives are less effective than the statute. View "Reilly v. City of Harrisburg" on Justia Law

Roquet, is a psychologist at the Avenel Special Treatment Unit (STU), where Oliver, a sexually violent predator, has been civilly committed for treatment. At least annually, the Treatment Progress Review Committee (TPRC) interviews each detainee and considers a range of materials to formulate a recommendation about whether the patient should progress to the next step in the program. Roquet, a member of the TPRC, wrote a report that recommended that Oliver not advance in treatment. The Report recognized that this was “not consistent” with Oliver’s treatment team's recommendation, but concluded that Oliver “had not fully met the treatment goals,” provided a detailed overview of Oliver’s sexual and non-sexual offenses, diagnostic history, and clinical treatment, and summarized the results of Oliver's interview, including that “it appears that he denies, minimizes or justifies much of his documented offense history,” and that “[h]e did not demonstrate remorse for his crimes or empathy for his victims.” Oliver sued, alleging retaliation for his First Amendment-protected participation in legal activities on behalf of himself and other STU residents. The Third Circuit concluded that Roquet was entitled to qualified immunity, reasoning that Oliver pleaded facts reflecting that Roquet based her recommendation on the medically-relevant collateral consequences of his protected activity, but has not sufficiently pleaded that the recommendation was based on the protected activity itself. View "Oliver v. Roquet" on Justia Law

Court erred in dismissing civil rights claims as time-barred without considering whether inmate exhausted administrative remedies and whether limitations period should be tolled.Wisniewski, a Pennsylvania inmate, filed suit under 42 U.S.C. 1983. He worked as an aide in the prison’s law library. Believing that prison policies were harming inmates’ ability to access the courts, he registered complaints. Based on his possession of another inmate’s grievance forms, Wisniewski was found guilty of engaging in or encouraging unauthorized group activity, possession or circulation of a petition, possession of contraband, and lying to an employee. The charges were dismissed after Wisniewski spent 90 days in the Restricted Housing Unit. Wisniewski alleged additional retaliation: removal from his job, tampering with his television, denying him yard time, delaying his disciplinary confinement release, and interfering with his access to legal materials and the photocopier. The district court dismissed the claims arising out of events that occurred more than two years before the filing of the complaint and dismissed the remaining First Amendment retaliation claims for failure to state a claim. The Third Circuit reversed in part; the district court erred in dismissing the claims as time-barred without considering whether Wisniewski properly exhausted administrative remedies and to what extent the limitations period should be tolled. View "Wisniewski v. Fisher" on Justia Law