Justia Civil Rights Opinion Summaries

In a case before the United States Court of Appeals for the Fifth Circuit, Ivan Cantu, who was convicted of capital murder and sentenced to death in 2001, sought to authorize the district court to consider a successive petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2244. He claimed a violation of the Due Process Clause of the Fourteenth Amendment and suppression of evidence by the state in violation of Brady v. Maryland. The Fifth Circuit denied his motion for authorization, holding that Cantu had failed to meet the requirements of 28 U.S.C. § 2244(b)(2)(B).The court found that Cantu failed to exercise due diligence to discover the evidence he was now relying on and that he failed to provide clear and convincing evidence that no reasonable factfinder would have found him guilty. The court also noted that Cantu's last-minute filing was an attempt at manipulation and did not serve the public interest or the interest of the victims in the timely enforcement of the sentence. Consequently, the court denied Cantu's motion for a stay of execution. View "In Re: Ivan Cantu" on Justia Law

In this case, the United States Court of Appeals for the Fifth Circuit ruled on a civil rights lawsuit filed by James Everard and Christopher Grisham against the City of Olmos Park and several police officers. Everard and Grisham, self-identified "Second Amendment protestors", claimed their arrests on March 27, 2018, violated their First, Fourth, and Fourteenth Amendment rights. They were arrested after 911 operators received several calls about a man "with an AK-47" around his neck, standing on a busy street corner in Olmos Park. The officers arrived and found Everard with a large gun in a holster in front of his chest, and Grisham with a handgun in a holster on his hip. Everard and Grisham were charged with disorderly conduct and interference with the duties of a public servant respectively, but all charges were dismissed for insufficient evidence.The district court granted summary judgment in favor of the City and the officers, a decision that Everard and Grisham appealed. The Court of Appeals, however, affirmed the district court's decision, agreeing that the officers had probable cause to believe that Plaintiffs were engaging in criminal activity and that the officers were not objectively unreasonable in believing such probable cause existed.The court also rejected the Plaintiffs’ First Amendment claims, stating that officers cannot execute their law enforcement duties while someone is engaging in speech, where probable cause exists. The court ruled that the officers had probable cause to make the arrests for disorderly conduct and resisting arrest, thus precluding the arrestees’ retaliatory arrest claims. The court further rejected the Plaintiffs’ Fourth Amendment claims, stating that the officers are protected by qualified immunity since both Everard and Grisham could not point to any clearly established law that such force was unreasonably excessive under the circumstances. Lastly, the court affirmed the dismissal of the Plaintiffs' municipal liability claims, as they failed to establish that there were constitutional violations. View "Grisham v. Valenciano" on Justia Law

The case was brought before the United States Court of Appeals for the Fifth Circuit. The plaintiff, Jarius Brown, alleged that officers from the DeSoto Parish Sheriff's Office attacked him without provocation, leaving him to languish in a jail cell with a broken nose and eye socket. Almost two years later, Brown sued Javarrea Pouncy and two unidentified officers in the U.S. District Court for the Western District of Louisiana, seeking relief under 42 U.S.C. § 1983 for the alleged use of unreasonable force in violation of the Fourth and Fourteenth Amendments, as well as under Louisiana state law for battery. However, the district court dismissed Brown's Section 1983 claim as untimely under Louisiana's one-year statute of limitations for personal injury claims. Brown appealed this decision, arguing that the one-year period should not apply to police brutality claims brought under Section 1983 as it discriminates against such claims and practically frustrates litigants' ability to bring them.The Court of Appeals affirmed the district court's decision, holding that precedent required them to do so. The Court reasoned that while Brown's arguments that a one-year limitations period is too restrictive to accommodate the federal interests at stake in a civil rights action, the Supreme Court has yet to clarify how lower courts should evaluate practical frustration without undermining the solution it has already provided for the absence of a federal limitations period for Section 1983 claims. This was based on the principle that the length of the limitations period and related questions of tolling and application are governed by state law. The Court also noted that states have the freedom to modify their statutes to avoid being outliers in this regard. View "Brown v. Pouncy" on Justia Law

In October 2018, Warren G. Treme, a member of AJSJS Development, LLC, leased minerals on a tract of land in St. John the Baptist Parish, Louisiana, from Dr. Christy Montegut and his siblings. AJSJS intended to join a joint venture formed in 2010 between Treme, AIMS Group, Inc., and Fred Kinsley. The joint venture aimed to extract and process clay material from the tract for a U.S. Army Corps of Engineers project. However, to conduct mining and excavation activities, the plaintiffs needed to change the zoning classification of the tract. Despite multiple applications for rezoning, the Parish Council denied the applications after hearing complaints from affected residents. The plaintiffs then sued the Parish and the Council, alleging that the denial of the rezoning application constituted a regulatory taking without compensation in violation of the United States and Louisiana Constitutions. The plaintiffs also alleged violations of procedural and substantive due process and equal protection rights under the Fourteenth Amendment.The United States Court of Appeals for the Fifth Circuit held that the plaintiffs lacked standing to bring a takings claim because their mineral lease was not yet in effect, meaning they had no vested property interest in the tract. The court interpreted the lease to have a suspensive condition that required the plaintiffs to obtain governmental approvals for the lease to become effective. As the plaintiffs had not obtained these approvals, the lease had not yet come into effect. Consequently, the court affirmed the district court’s decision but modified the judgment to be a dismissal without prejudice. View "Treme v. St. John the Baptist" on Justia Law

In this case, Larry Donnell Gibbs, a pro se plaintiff, filed a complaint under 42 U.S.C. § 1983 against five officers of the Texas Department of Criminal Justice. He alleged that two officers allowed him to bleed for 45 minutes after being stabbed by another inmate, and three other officers used excessive force against him in retaliation for filing a grievance about the incident. Gibbs attempted to proceed in forma pauperis, which would have allowed service to be made by a United States marshal, but the district court denied this on the basis that he had already paid the filing fee, had sufficient funds in his inmate trust account to serve the defendants, and had not provided the addresses of the defendants.The United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court found that the district court had abused its discretion by denying Gibbs's in forma pauperis status. It held that a person who is not a pauper at the commencement of a suit may become one during or prior to its prosecution. The court also found that the district court had arbitrarily determined that the funds in Gibbs's inmate trust account were sufficient for him to serve the defendants and that there's no requirement for an individual to be absolutely destitute to enjoy the benefit of in forma pauperis status. The court also held that a district court's determination of whether a party may proceed in forma pauperis must be based solely upon economic criteria and not on the lack of addresses for the defendants. The court concluded that the denial of Gibbs's in forma pauperis status had prejudiced his chances of effecting service. The case was remanded to the district court with instructions to permit Gibbs to proceed in forma pauperis. View "Gibbs v. Jackson" on Justia Law

In the case between Jennifer Harris and FedEx Corporate Services, Inc., Harris alleged race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964. The United States Court of Appeals for the Fifth Circuit found that Harris's § 1981 claims were time-barred under her employment contract, making them fail as a matter of law. However, the court found sufficient evidence to support the jury’s verdict for Harris on her Title VII retaliation claim. In view of Title VII’s $300,000 cap on damages and the evidence presented at trial, the court remitted Harris’s compensatory damages to $248,619.57 and concluded she was not entitled to punitive damages. FedEx was not entitled to a new trial because of the court’s evidentiary ruling. View "Harris v. FedEx Corporate Services" on Justia Law

In March 2019, the Waxahachie Police Department (WPD) SWAT Team mistakenly executed a search warrant on the wrong house, which was the home of Karen Jimerson, James Parks, and their two young children, instead of the intended target house. The error was due to Mike Lewis, the WPD SWAT Team Commander, incorrectly identifying the target house. The plaintiffs sued the officers under Section 1983 for violations of the Fourth Amendment and several state laws. The United States Court of Appeals for the Fifth Circuit reversed the district court's denial of summary judgment to Lewis on the issue of qualified immunity. The appellate court held that while Lewis's efforts to identify the correct residence were deficient, they did not violate clearly established law. The court found no genuine disputes of material fact, and it concluded that the disputed issue was one of law. The case was remanded for dismissal. View "Jimerson v. Lewis" on Justia Law

An inmate in Texas, Raul Gerardo Favela, Jr., alleged that prison officials had ignored warnings and failed to prevent him from being assaulted by another inmate. Favela sued several employees of the Texas Department of Criminal Justice (TDCJ) under 42 U.S.C. § 1983, claiming that their failure to protect him violated his constitutional rights. However, the district court granted summary judgment in favor of the defendants, stating that Favela had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA). The United States Court of Appeals for the Fifth Circuit reversed the decision of the district court, finding that the summary judgment was inappropriate. Favela's declaration that he had filed and timely submitted grievances relating to his claims was found to be sufficient to establish a genuine issue of material fact, thereby meeting his burden to counter the defendant's prima facie case. The court concluded that the matter of the credibility of Favela's statement was a matter for trial, and not for summary judgment. The case was remanded for further proceedings. View "Favela v. Collier" on Justia Law

In a case before the United States Court of Appeals for the Fifth Circuit, the parents of Ashtian Barnes, who was fatally shot by Officer Roberto Felix, Jr. during a lawful traffic stop, alleged violations under 42 U.S.C. § 1983 against Officer Felix and Harris County. The parents argued that Officer Felix's use of force was unreasonable because even if Barnes attempted to flee, he did not pose a threat justifying deadly force. The district court granted the defendants' motion for summary judgement, stating that Officer Felix did not violate Barnes's constitutional rights and was entitled to qualified immunity. The district court found that Barnes posed a threat of serious harm to Officer Felix in the moment the car began to move, thus making Officer Felix's use of deadly force reasonable and not excessive. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's judgment, concluding that under the Circuit's precedent on the "moment of threat" analysis, there was no violation of Barnes's constitutional rights. Consequently, the court also affirmed the grant of summary judgement to Harris County, as there was no finding of constitutional injury. View "Barnes v. Felix" on Justia Law

The United States Court of Appeals for the Fifth Circuit was presented with a case involving police officers who shot and killed Schaston Hodge after he refused to pull over his vehicle, led the officers on a chase, and exited his car with a gun in his hands. The officers' actions were captured on their bodycam footage. Hodge's mother, Shandra Hodge, filed a suit against the officers, Joshua Engleman and Robert Litvin, as well as the Texas Department of Public Safety (TDPS) and the City of Dallas, alleging excessive force and failure to train and supervise. The district court granted the officers' motion to dismiss based on qualified immunity (QI), treating the dismissal as an implicit conversion to summary judgment, even though the footage was not included in the pleadings.On appeal, the Fifth Circuit agreed with the lower court's decision. The court found that the bodycam footage showed a complete account of the incident, including Hodge raising a gun and pointing it at one of the officers. The court concluded that the officers' use of deadly force was reasonable given the circumstances they faced. As a result, the court held that the officers did not violate Hodge's Fourth Amendment rights and were entitled to QI. Therefore, the court affirmed the summary judgment in favor of the officers. View "Hodge v. Engleman" on Justia Law