Justia Civil Rights Opinion Summaries

A 28-year-old man, Steven Mitchell Qualls, died in police custody from a methamphetamine overdose. Qualls had been taken to a hospital for chest pains and agitation but was arrested for public intoxication after refusing to leave. He was booked into the Jasper City Jail, where his condition worsened. Despite showing signs of severe distress, including vomiting black liquid and screaming in pain, officers did not seek medical help. Qualls died approximately 33 hours after being booked.Qualls’s mother, Frances E. Sims, sued the City of Jasper and several police officers under 42 U.S.C. § 1983, alleging deliberate indifference to Qualls’s serious medical needs in violation of the 14th Amendment. The district court dismissed claims against one officer and the city but denied summary judgment on qualified immunity grounds for the remaining officers. Sims then moved to bifurcate the trial into separate liability and damages phases, arguing that evidence of Qualls’s past behavior would unfairly prejudice the jury. The district court denied the motion, and the jury found for the defendants. Sims’s motion for a new trial was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in refusing to bifurcate the trial. The court reasoned that the evidence of Qualls’s past behavior was relevant to the officers’ defense, as it could show they did not recognize the severity of his condition. The court also found that standard trial practices, such as objections and limiting instructions, could mitigate any potential prejudice. The court affirmed the district court’s judgment and the denial of a new trial. View "Sims v. City of Jasper" on Justia Law

Curtis Terrell, after consuming a significant amount of alcohol, pain pills, and methamphetamine, began running erratically in a residential neighborhood. His wife, Angela Terrell, called 911, requesting an ambulance. Officer Jason Allgrunn arrived and arrested Mr. Terrell. When Mrs. Terrell began filming the incident, she was also arrested. The Terrells filed multiple federal and state claims against Allgrunn and other officers involved.The United States District Court for the Western District of Louisiana denied summary judgment to the defendants on all claims, rejecting their qualified immunity defense. The defendants appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of summary judgment for the defendants on the Terrells' false arrest claims, finding that Officer Allgrunn had probable cause to arrest both Mr. and Mrs. Terrell. The court also reversed the denial of summary judgment on Mrs. Terrell's excessive force claim, concluding that there was no clearly established law prohibiting the officer's conduct. However, the court dismissed the appeal regarding Mr. Terrell's excessive force claim for lack of jurisdiction, as there were genuine disputes of material fact about what occurred when Mr. Terrell was out of the video frame.Additionally, the court reversed the denial of summary judgment on the Terrells' malicious prosecution and First Amendment retaliation claims, citing the presence of probable cause. The court also reversed the denial of summary judgment for Officers Henderson and Banta on the failure-to-intervene claims, as there were no violations of clearly established constitutional law.Finally, the court vacated the district court's denial of summary judgment on the Louisiana state law claims and remanded for reconsideration in light of the appellate court's opinion. View "Terrell v. Allgrunn" on Justia Law

Tesla, Inc. and its affiliates challenged a Louisiana law that prohibits automobile manufacturers from selling directly to consumers and performing warranty services for cars they do not own. Tesla alleged that the law violated federal antitrust law, due process rights, and equal protection rights. The defendants included the Louisiana Motor Vehicle Commission, its commissioners, the Louisiana Automobile Dealers Association (LADA), and various dealerships.The United States District Court for the Eastern District of Louisiana dismissed Tesla's claims. The court found that the private defendants were immune from antitrust liability, Tesla had not plausibly pleaded a Sherman Act violation against the governmental defendants, there was insufficient probability of actual bias to support the due process claim, and the regulations passed rational-basis review for the equal protection claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the dismissal of Tesla's due process claim, finding that Tesla had plausibly alleged that the Commission's composition and actions created a possible bias against Tesla, violating due process. The court vacated and remanded the dismissal of the antitrust claim, noting that the due process ruling fundamentally altered the grounds for Tesla's alleged antitrust injury. The court affirmed the dismissal of the equal protection claim, holding that the regulations had a rational basis in preventing vertical integration and controlling the automobile retail market.In summary, the Fifth Circuit reversed the due process claim dismissal, vacated and remanded the antitrust claim dismissal, and affirmed the equal protection claim dismissal. The case was remanded for further proceedings consistent with the court's opinion. View "Tesla v. Louisiana Automobile Dealers" on Justia Law

The case involves a long-standing litigation concerning the Orleans Parish Sheriff’s Office and the conditions at Orleans Parish Prison. Plaintiffs, including detainees and the United States, argued that the jail provided constitutionally inadequate housing and medical care. In 2013, a district court approved a consent decree to address these issues, which included a plan to construct a mental health annex, known as Phase III. Despite years of delays, the district court ordered the construction to proceed. No party appealed these orders at the time.The United States District Court for the Eastern District of Louisiana oversaw the case initially. In 2016, the parties entered a stipulated order to develop a plan for appropriate housing for prisoners with mental health issues. The Compliance Director later proposed the construction of Phase III, which was agreed upon by the former Sheriff and the City. However, the City later sought to explore alternatives, leading to further court orders in 2019 to proceed with Phase III. The City’s subsequent motion to halt the project was denied, and this decision was affirmed by the United States Court of Appeals for the Fifth Circuit in Anderson v. City of New Orleans.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The new Sheriff, Susan Hutson, moved to terminate all orders concerning Phase III, arguing that the Prison Litigation Reform Act (PLRA) prohibits the construction of a new jail facility. The district court denied this motion, and the Fifth Circuit dismissed the appeal for lack of jurisdiction. The court held that it could review the denial of the motion but not the underlying orders, as the Sheriff’s motion was not a proper procedural mechanism under the PLRA to challenge the 2019 Orders and Stipulated Order. The appeal was dismissed, and the construction of Phase III continues. View "Anderson v. Hutson" on Justia Law

Bobby Stevenson, a prisoner at the Louisiana State Penitentiary, claims he was forced to labor in the prison’s agricultural fields despite severe ankle pain caused by two broken surgical screws. He alleges that two prison physicians, Dr. Randy Lavespere and Dr. Paul M. Tocé, refused to fix the screws or relieve him from field labor. Stevenson asserts that the broken screws caused him tremendous pain and secondary injuries, and that the physicians ignored his complaints and medical recommendations for surgery.The United States District Court for the Middle District of Louisiana reviewed the case. The magistrate judge allowed Stevenson to file an amended complaint and recommended denying the defendants' motion to dismiss, which argued for qualified immunity. The district court accepted this recommendation and denied the motion, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Stevenson sufficiently alleged that the defendants violated his Eighth Amendment rights by ignoring his severe medical needs and forcing him to work despite his condition. The court also determined that the defendants had fair warning from existing case law that their actions were unconstitutional. Consequently, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss, rejecting the defendants' claim of qualified immunity. View "Stevenson v. Toce" on Justia Law

Sha Kendrick Smith was convicted under 18 U.S.C. § 2422(b) for enticing a minor to engage in prostitution. The minor victim (MV) was a thirteen-year-old runaway who was a ward of the state. Smith provided MV with a cell phone and took her to various locations where she engaged in commercial sex with multiple men, with Smith keeping the money. MV initially told Smith she was eighteen, but he later learned she was underage. MV described Smith as always carrying a gun and being feared by those who knew him. Smith was eventually arrested after MV reported her situation to the police.The United States District Court for the Southern District of Texas sentenced Smith to 235 months of imprisonment and ten years of supervised release. The court applied two sentencing enhancements: one under U.S.S.G. § 2G1.3(b)(2)(B) for undue influence over the minor and another under U.S.S.G. § 3A1.1(b)(1) for MV’s status as a vulnerable victim. Smith objected to these enhancements, but the district court overruled his objections, adopting the presentence investigation report (PSR) and the government’s arguments.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s application of both sentencing enhancements. It found that the district court’s determination that Smith unduly influenced MV was plausible given the evidence of Smith’s control over MV, including his age, size, possession of a gun, and the fear he instilled in others. The court also upheld the vulnerable-victim enhancement, noting that MV’s age, status as a ward of the state, and economic desperation made her unusually vulnerable, and Smith knew or should have known of her vulnerabilities. The Fifth Circuit concluded that the district court did not commit clear error in its findings and affirmed Smith’s sentence. View "United States v. Smith" on Justia Law

Deputy James Killian responded to a domestic disturbance call at the home of Rubicela Ramirez and Francisco Gonzales. Upon arrival, Killian heard sounds suggesting a fight and entered the home without a warrant. Within the first minute, he pepper-sprayed Ramirez and Gonzales and shot their two dogs. Ramirez and Gonzales filed a lawsuit under 42 U.S.C. § 1983, claiming violations of their Fourth Amendment rights due to warrantless entry, excessive force, and unreasonable seizure of their dog.The United States District Court for the Northern District of Texas granted summary judgment in favor of Killian on the warrantless entry and excessive force claims, citing qualified immunity. However, the court allowed the unreasonable seizure claim regarding the shooting of one of the dogs to proceed to trial. The jury found Killian liable and awarded damages to Ramirez and Gonzales. Killian then moved for judgment as a matter of law, which the district court granted, overturning the jury's verdict.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's summary judgment on the warrantless entry claim, agreeing that exigent circumstances justified Killian's entry. However, the court reversed the summary judgment on the excessive force claims, finding that a reasonable jury could conclude that Killian's use of pepper spray and physical force was excessive and unreasonable. The court also reversed the district court's judgment as a matter of law on the unreasonable seizure claim, reinstating the jury's verdict. The case was remanded for further proceedings on the excessive force claims. View "Ramirez v. Killian" on Justia Law

Ryan Haygood, a dentist in Louisiana, faced an investigation by the Louisiana State Board of Dentistry, which led to the revocation of his dental license in 2010. Haygood alleged that competing dentists conspired with Board members to drive him out of business by fabricating complaints and manipulating the Board's proceedings. In 2012, a Louisiana appellate court vacated the Board's revocation of Haygood's license, citing due process violations. Haygood then entered a consent decree with the Board, allowing him to keep his license.Haygood filed a civil action in state court in 2011, alleging due process violations and unfair competition. In 2013, he filed a similar federal lawsuit, claiming violations under 42 U.S.C. § 1983 and the Louisiana Unfair Trade Practices Act (LUTPA). The federal district court dismissed the federal complaint, ruling that the § 1983 claim was time-barred and the LUTPA claim was not plausible. The court also awarded attorney’s fees to the defendants, deeming both claims frivolous.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to award attorney’s fees for the frivolous § 1983 claim, agreeing that it was clearly time-barred. However, the appellate court found that the district court erred in calculating the fee amount. The district court had properly calculated $98,666.50 for the defendants' private attorneys but improperly awarded $11,594.66 for the Louisiana Attorney General’s office without using the lodestar method. Consequently, the Fifth Circuit remitted the fee award to $98,666.50 while affirming the decision to award fees. View "Haygood v. Morrison" on Justia Law

Three individuals, Jamarr Smith, Thomas Iroko Ayodele, and Gilbert McThunel, were convicted of robbery and conspiracy to commit robbery. The convictions were based on evidence obtained through a geofence warrant, which collected location data from Google to identify suspects. The robbery involved the theft of $60,706 from a U.S. Postal Service route driver, Sylvester Cobbs, who was attacked with pepper spray and a handgun. Video footage and witness testimony linked the suspects to the crime scene, but no arrests were made immediately. Investigators later used a geofence warrant to gather location data from Google, which led to the identification of the suspects.The United States District Court for the Northern District of Mississippi denied the defendants' motion to suppress the evidence obtained through the geofence warrant. The defendants argued that the warrant violated their Fourth Amendment rights due to lack of probable cause and particularity, and that the government did not follow proper legal procedures in obtaining additional information from Google. The district court found that law enforcement acted in good faith and denied the motion to suppress. The defendants were subsequently convicted by a jury and sentenced to prison terms ranging from 121 to 136 months.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that geofence warrants, as used in this case, are unconstitutional under the Fourth Amendment because they resemble general warrants, which are prohibited. However, the court affirmed the district court's decision to deny the motion to suppress, citing the good-faith exception. The court concluded that law enforcement acted reasonably given the novelty of the geofence warrant and the lack of clear legal precedent. Therefore, the convictions were upheld. View "United States v. Smith" on Justia Law

In May 2020, following the death of George Floyd, several individuals participated in or were near protests in downtown Houston. They allege that they were falsely arrested by City of Houston police officers who used "kettle maneuvers" to confine and arrest protesters. The plaintiffs claim that then-Chief of Police Art Acevedo implemented a policy of "kettling" and arresting protesters. They sued the City and Acevedo under 42 U.S.C. § 1983, alleging violations of the First, Fourth, Fifth, and Fourteenth Amendments, based on the assertion that there was no probable cause for their arrests under section 42.03 of the Texas Penal Code, which prohibits obstructing passageways.The United States District Court for the Southern District of Texas found that there was probable cause to arrest the plaintiffs under section 42.03 and dismissed the claims against both the City and Acevedo. The plaintiffs appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that two previous panels had addressed similar issues with conflicting outcomes. In Utley v. City of Houston, the panel found probable cause for arrest and affirmed the dismissal of the plaintiff’s § 1983 lawsuit. Conversely, in Herrera v. Acevedo, the panel found that the plaintiffs had plausibly alleged false arrest and denied the defendants' motion to dismiss. The current panel agreed with the Utley decision, holding that there was probable cause to arrest the plaintiffs for obstructing a passageway under section 42.03. The court found that the size and location of the protests provided sufficient probable cause for the arrests, thus negating any First, Fourth, or Fourteenth Amendment violations. Consequently, the claims against the City and Acevedo were dismissed due to the lack of an underlying constitutional violation. The judgment of the district court was affirmed. View "Wade v. City of Houston" on Justia Law