Justia Civil Rights Opinion Summaries

Plaintiffs filed a 42 U.S.C. Section 1983 action shortly after her son’s death, alleging that officers violated her son’s constitutional rights by failing to provide him with medical treatment while he was dying in a jail cell. The officers moved for summary judgment based on qualified immunity. The district court denied the officers’ motion. It found genuine disputes of material fact surrounding Plaintiff’s claims that the officers were deliberately indifferent to the man’s serious medical needs. And it concluded that the law was clearly established at the time of the alleged violation.   The Fifth Circuit affirmed the district court’s ruling and found that (1) the fact disputes identified by the district court are material to Plaintiff’s deliberate indifference claims, and (2) the court’s decision in Easter clearly established the man’s rights before the officers allegedly violated them.The court explained that in reviewing qualified immunity it looks to: (1) whether the defendant violated the plaintiffs’ constitutional or statutory rights; and (2) whether those rights were clearly established at the time of the violation. The court reasoned those it lacks jurisdiction to review the genuineness argument because the officers’ arguments do not address why the fact disputes the district court did find cannot affect the outcome of Plaintiff’s lawsuit—the materiality inquiry. Further, in reviewing Easter v. Powell, 467 F.3d 459 (5th Cir. 2006), the court held that a reasonable jury could find that the officers each refused to treat the man, ignored his cries for help, and overall evinced a wanton disregard for his serious medical needs. View "Sims v. Griffin" on Justia Law

Plaintiff sued her employer under the Age Discrimination in Employment Act (“ADEA”), claiming that Defendant engaged in unlawful age discrimination and retaliation. Plaintiff filed a motion with the district court requesting additional time so that Defendant could respond to her requests for production. The court denied the motion and Plaintiff later filed a supplement to her Rule 56(d) motion, again asking the court to defer consideration of Defendant’s summary-judgment motion and allow Plaintiff to conduct discovery, or alternatively, deny Defendant’s motion. The district court granted Defendant’s motion and entered final judgment in their favor.   The Fifth Circuit reversed the district court’s order and held that a district court cannot deny discovery rights protected by the Federal Rules of Civil Procedure. The court explained that a Rule 56(d) movant first must demonstrate that additional discovery will create a genuine issue of material fact. Here, Plaintiff identified such evidence for (1) her age-discrimination claim, and (2) her retaliation claim. The court reasoned it was an abuse of discretion for the district court to deny Plaintiff the opportunity to conduct discovery on the relevant issues in question and then fault her for having “no evidence of a causal connection” between her protected activity and the adverse employment actions. Further, the fact that Plaintiffs requests for discovery were repeatedly denied does not reveal a lack of diligence on her part. View "Bailey v. KS Mgmt Services" on Justia Law

Officers of the Prentiss Police Department arrested Plaintiff for aggravated assault after he and others told the officers that Plaintiff had shot the victim. Plaintiff sued the officers and the City of Prentiss under 42 U.S.C. Section 1983 for arresting him without probable cause. He argued that the officers lacked probable cause because he told them that he shot the victim in self-defense. The district court granted summary judgment on all claims and awarded fees to the defendants.   On appeal, Plaintiff argued, first, that the Officer and Chief arrested him without probable cause and that they are not entitled to qualified immunity. Second, the Chief intentionally or recklessly omitted material statements in the warrant affidavit, resulting in a warrant lacking probable cause. Third, the City of Prentiss is liable under Monell. Fourth, he established a material fact issue on his state-law malicious-prosecution claim. Finally, Defendants are not entitled to attorneys’ fees.   The Fifth Circuit affirmed the district court’s summary judgment order and award of fees to Defendants. The court reasoned it is not enough to invoke the general principle that the Fourth Amendment prohibits a warrantless arrest without probable cause. Therefore, the Officer and Chief would be entitled to qualified immunity even if they lacked probable cause for the initial warrantless arrest. Further, the court concluded that Plaintiff cannot show want of probable cause therefore, his malicious-prosecution claim cannot succeed. Finally, Plainitff has not shown that the district court abused its discretion in granting attorneys’ fees. View "Loftin v. City of Prentiss, MS" on Justia Law

After the Supreme Court overturned Plaintiff’s Louisiana capital murder conviction, Plaintiff brought Section 1983 and 1988 suits against the state prosecutor and a sheriff’s detective, alleging that they fabricated evidence that deprived him of due process and a fair trial. Defendants, District Attorney and Livingston Parish Sheriff’s, each moved to dismiss for failure to state a claim under Rule 12(c) based on assertions of absolute prosecutorial immunity. The district court denied the motions, holding that neither defendant was entitled to absolute immunity for fabricating evidence by intimidating and coercing a juvenile to adopt a false narrative the defendants had concocted out of whole cloth.   The Fifth Circuit affirmed the district court’s rulings, holding that a police officer is not entitled to absolute immunity reserved for a prosecutor. The court held that neither the Detective nor the District attorney is owed absolute immunity under the facts alleged in Plaintiff’s complaint. The court reasoned that the Supreme Court has made clear that police officers, even when working in concert with prosecutors, are not entitled to absolute immunity. Nor are prosecutors when they step outside of their role as advocates and fabricate evidence. The facts and actions alleged by the complaint are fundamentally investigatory in nature, and therefore absolute immunity is not warranted. View "Wearry v. Foster" on Justia Law

In a consolidated appeal, Plaintiffs challenged the district court’s application of the independent intermediary doctrine to dismiss their Fourth Amendment false arrest claims. Plaintiffs are motorcyclists who had gathered at a meeting and were eventually arrested following a shootout for Engaging in Organized Criminal Activity (“EIOCA”). All were arrested pursuant to the same “form warrant affidavit” that was presented as the basis for the arrest warrants. Following their arrests, Plaintiffs filed multiple individual Sec. 1983 actions asserting similar false arrest claims, which were premised on alleged defects in the form affidavit used to secure the arrest warrants. The district court granted in full the motion to dismiss the false arrest claims, but it did not discuss the merits of the claims.   The Fifth Circuit reversed the district court’s ruling and found in favor of Plaintiffs in their challenge of the district court’s application of the independent intermediary doctrine to dismiss their Fourth Amendment false arrest claims. The court held that the district court erred in its application of the independent intermediary doctrine. The court reasoned that an adequately pled Malley or Franks claim will also suffice to functionally apply the taint exception to the magistrate’s decision, if a plaintiff adequately pleads that a second intermediary, such as a grand jury, has been misled in a similar fashion, then the taint exception will apply to that intermediary’s decision as well. The court declined to decide whether Plaintiffs have adequately pleaded a Franks violation with respect to any of the named defendants. View "Miller, et al v. Stroman, et al" on Justia Law

Student is an elementary school pupil at the School District (“SD”). The SD moved her from general education into an essential academics program after they determined that despite the accommodations it offered her, Student was not making appropriate progress. Student’s mother objected to the SD’s decision and sought a due process hearing under the IDEA. A hearing officer concluded that the SD’s proposal was: (1) Student’s least restrictive environment; and (2) appropriate in light of her circumstances. Student’s mother appealed to the district court which affirmed the hearing officer’s decision. The Fifth Circuit affirmed the decision.   The court held that It is Student’s burden to establish that the SD’s decision violates IDEA and she has not carried that burden. The court reasoned that the proposed blended placement IEP is Student’s least restrictive environment. The court found that the SD took steps to accommodate Student by reviewing her overall record and found that she was not making appropriate progress in light of her circumstances. Further, the court considered what effect Student had on the general education classroom.   Finally, the court reasoned that to comply with the IDEA, a student’s plan must provide for exposure to nonhandicapped students to the maximum extent appropriate. Here, although Student occasionally saw glimpses of progress, the bottom line was one of minimal improvement and even regression. The proposed blended placement IEP was the next logical step when the SD found that Student was still not improving. View "H.W. v. Comal Indep Sch Dist" on Justia Law

Plaintiff filed a claim under Title VII of the Civil Rights Act of 1964 (“Title VII”) against the Administrators of the Tulane Education Fund (“Administrators”), alleging gender discrimination, retaliation, and hostile work environment. The district court granted summary judgment in favor of Defendant and Plaintiff appealed arguing that the district court’s ruling was erroneous.   The Fifth Circuit affirmed the district court’s grant of summary judgment in favor of Administrators. Plaintiff argued that the district court improperly required her to demonstrate that her proffered comparators were strictly identical. The court found that Plaintiff failed to establish a prima facie case because she did not present evidence that any male physician shared characteristics that would render them similarly situated. Further, even if Plaintiff established a prima facie case, her claim would not succeed because she did not rebut Defendant’s non-discriminatory reasons for declining to renew her contract.   The court further affirmed summary judgment in favor of Defendant on Plaintiff’s retaliation claim. The court concluded that a reasonable jury could not establish that her protected conduct was the “but for” reason for the alleged adverse employment action.   Finally, the court affirmed summary judgment in favor of Defendant on Plaintiff’s hostile work environment claim. The court found that although Plaintiff endured severe treatment by her supervisor, she did not establish that the treatment was based on her gender. View "Saketkoo v. Admin Tulane Educ" on Justia Law

Appellee sued officers asserting various Section 1983 claims including excessive force, unreasonable seizure due to an arrest without probable cause, malicious prosecution, violation of her First Amendment rights for arresting her in retaliation for filming the officers, and violation of her Fourteenth Amendment rights. The district court held that disputed issues of material fact barred summary judgment on the excessive force claim and that, viewing the facts in Appellee’s favor, the officers violated a clearly established right.   The Fifth Circuit denied Appellee’s motion to dismiss, reversed the district court’s order denying Appellant’s motion for summary judgment, and remanded with instructions that Appellee’s claims be dismissed.                                                                                        The court analyzed the officers’ actions and found that their conduct was not so objectively unreasonable as to violate Appellee’s constitutional rights. First, Appellee’s minor injuries weigh in favor of finding qualified immunity. Second, qualified immunity can apply even when only one factor weighs against the plaintiff. Finally, it was reasonable of Appellants to believe that, in light of Appellee’s interjections, comments, resistance, and indignation, some degree of force would be necessary to subdue her. The court further held that even if the officers violated Appellee’s constitutional rights, the right was not clearly established at the time of the alleged violation. View "Solis v. Serrett" on Justia Law

A jury convicted Appellant for capital murder in the death of a police officer. The Fifth Circuit rejected Appellant's last-minute efforts to stop the imposition of his sentence.The Fifth Circuit held that Appellant is unlikely to prevail on his request for a certificate of appealability (“COA”), and he is unlikely to succeed on his Sec. 1983 claim. In addressing habeas, the court rejected Appellant's request for COA on his future-dangerousness claim, and his request for COA on his Lackey claim. The court affirmed the district court’s denial of a stay of execution and dismissal of the 1983 claim and denied the COA.Here, Appellant argued his death sentence violated the Eighth and Fourteenth Amendments because it was based in part on the jury’s finding of a “probability that Appellant would commit criminal acts of violence that would constitute a continuing threat to society.” The court explained that reasonable jurors would not find it debatable whether Sec. 2244(b)(1) barred this claim. Further, the court reasoned that it’s undebatable that this claim is procedurally defaulted. Additionally, the court held substantive meritlessness is an independent ground for refusing a COA on Plaintiff’s future-dangerousness claim. Finally, the court held that Plaintiff’s claim is not a method-of-execution challenge; it is a challenge to the validity of his death sentence. It is therefore not cognizable under Sec. 1983. View "Buntion v. Collier" on Justia Law

Plaintiffs' son was killed when he attempted to drive through a low water crossing in Camp Bullis, a military training base outside San Antonio, Texas. As Plaintiff's son navigated the crossing, water swept across the road, ultimately resulting in his death.Plaintiffs filed suit against the United States, claiming the government failed to inspect the low water crossing, failed to warn approaching motorists about the dangers of flooding, and failed to install guard rails that may have prevented water from accumulating on the road. The district court granted summary judgment to the United States, finding the discretionary exception to the Federal Tort Claims Act ("FTCA") applied.The Fifth Circuit reversed. Under the FTCA, the federal government waives sovereign immunity for actions based on the negligence of federal employees who are acting within the scope of their employment. However, immunity is not waived if the federal employee is carrying out a discretionary function or duty on the part of a federal agency. To be discretionary, an action must involve some element of judgment or choice.Here, the relevant regulation states that "[a]ll Range/Control Area/Impact Area gates will either be locked or guarded by the unit using the area." A natural reading of the regulation imposed an obligation on the officers who were on-site to lock the gate. Thus, the discretionary exception to the FTCA did not apply. View "Barron v. USA" on Justia Law