Justia Civil Rights Opinion Summaries

The case involves Kimberly Marroquin, who sued Los Angeles Police Officer DiMaggio Rico and the City of Los Angeles under 42 U.S.C. § 1983, alleging excessive force and negligence after being injured by a less-lethal projectile during a crowd control situation following a Lakers game. Marroquin claimed that the injury caused her substantial physical and emotional harm. The jury found in favor of Marroquin on her excessive force and negligence claims but awarded inconsistent damages: $1.00 against Officer Rico and $1,500,000.00 against the City.The United States District Court for the Central District of California granted a new trial limited to damages under Fed. R. Civ. P. 59(a)(1)(A), citing a miscarriage of justice due to the jury's improper apportionment of damages. The court also denied the defendants' motion for relief from judgment under Fed. R. Civ. P. 60(b)(2), which was based on newly discovered surveillance footage. The court found that the defendants failed to show reasonable diligence in discovering this evidence.The United States Court of Appeals for the Ninth Circuit reviewed the district court's post-trial orders. The Ninth Circuit held that the district court did not abuse its discretion in granting a new trial limited to damages, rejecting the defendants' argument that the liability and damages issues were so interwoven that a damages-only trial violated their Seventh Amendment rights. The court found that the liability issues were distinct and separable from the damages issues and that the jury's confusion was likely due to an improper instruction on the verdict form.The Ninth Circuit also upheld the district court's denial of the Rule 60(b)(2) motion, agreeing that there is no exception to the requirement of reasonable diligence, even if the newly discovered evidence is conclusive. The court affirmed the district court's decisions, maintaining the new trial limited to damages and the denial of relief from judgment based on the newly discovered evidence. View "MARROQUIN V. CITY OF LOS ANGELES" on Justia Law

In February 2016, two Seattle police officers, Scott Miller and Michael Spaulding, fatally shot Che Andre Taylor during an attempted arrest. Kshama Sawant, a Seattle City Council member, publicly referred to the incident as a "blatant murder" and later reiterated that Taylor was "murdered by the police." Following an inquest, prosecutors declined to file charges against the officers due to insufficient evidence of malice. Miller and Spaulding subsequently filed a lawsuit alleging defamation and outrage under state law, as well as a federal defamation claim against Sawant.The United States District Court for the Western District of Washington dismissed the federal defamation claim but retained jurisdiction over the state law claims. The court later granted Sawant's motion for summary judgment on the state law claims and awarded her expert witness deposition expenses, including fees for preparation time. Miller and Spaulding appealed the decision, challenging the award of expert witness fees and the admissibility of the expert's opinions.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that Federal Rule of Civil Procedure 26 allows for the recovery of reasonable expenses for time an expert witness spends preparing for a deposition. The court joined other circuits in concluding that such preparation fees are recoverable under Rule 26. The court found that the expert witness deposition preparation fees awarded to Sawant were reasonable and did not result in manifest injustice. The Ninth Circuit also noted that objections to the admissibility of the expert's opinions did not negate the obligation to pay a reasonable fee under Rule 26. The court affirmed the district court's grant of summary judgment and the award of expert witness deposition expenses. View "Miller v. Sawant" on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

Patrick Neiss was convicted in Montana state court of deliberate homicide and evidence tampering, based on circumstantial evidence. He filed a pro se federal habeas petition under 28 U.S.C. § 2254, claiming ineffective assistance of trial and appellate counsel. Neiss argued that his trial counsel failed to challenge the particularity of a search warrant, which led to the discovery of silencer-related internet searches on his computer, and that his appellate counsel failed to raise this issue on appeal.The United States District Court for the District of Montana dismissed Neiss’s habeas petition under Rule 4 of the Rules Governing Section 2254 Cases, which allows for preliminary screening of habeas petitions. The district court adjudicated the petition on the merits, concluding that Neiss’s trial counsel was not deficient because they had made multiple attempts to suppress the evidence, albeit not on the particularity grounds. The court did not find the petition procedurally defective or frivolous.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that the district court misapplied the Rule 4 standard, which is intended to screen out only those petitions that are procedurally defective or frivolous. The court emphasized that Rule 4 does not permit summary dismissal on the merits. The Ninth Circuit found that Neiss’s petition alleged a cognizable, non-frivolous claim of ineffective assistance of counsel, which should not have been dismissed summarily. The case was remanded for further proceedings consistent with this opinion. View "NEISS V. BLUDWORTH" on Justia Law

Hasmik Chinaryan was driving home with her daughter and a friend when Los Angeles Police Department (LAPD) officers mistakenly suspected her vehicle was stolen due to a DMV error with the license plates. Despite driving normally, officers conducted a high-risk felony stop, ordering Chinaryan and her passengers out of the vehicle at gunpoint, handcuffing them, and making them lie on the street while they investigated.The plaintiffs sued the officers, the LAPD, and the City of Los Angeles under 42 U.S.C. § 1983 and California’s Bane Act, alleging illegal seizures, excessive force, and failure to properly train the officers. The United States District Court for the Central District of California granted partial summary judgment in favor of the officers, ruling they were entitled to qualified immunity on the § 1983 claims and that there was no evidence of specific intent to violate plaintiffs’ rights under the Bane Act. A jury later found in favor of the City and the LAPD on the Monell claims.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment in favor of the individual officers on the Fourth Amendment and Bane Act claims. The appellate court held that it was clearly established in Washington v. Lambert and Green v. City & County of San Francisco that officers cannot conduct a high-risk vehicle stop based solely on reasonable suspicion that a vehicle is stolen. The court found that the officers were not entitled to qualified immunity and that there was sufficient evidence for a jury to find that the officers acted with reckless disregard for plaintiffs’ rights. The court affirmed the judgment in favor of the City and the LAPD, ruling that the district court did not abuse its discretion in declining plaintiffs’ requested jury instructions. The case was remanded for a new trial on all claims against the individual officers. View "Chinaryan v. City of Los Angeles" on Justia Law

A Los Angeles County Sheriff’s Department deputy entered the curtilage of Harson Chong’s home without a warrant, leading to the discovery of drugs, guns, and money. Chong and Tac Tran, who was present at the home, were subsequently charged with federal drug and gun offenses. They claimed ineffective assistance of counsel because their attorneys did not object to the search on Fourth Amendment grounds.The United States District Court for the Central District of California initially denied their suppression motions, ruling the search justified by the parole-search exception. However, after the Ninth Circuit’s decision in United States v. Grandberry, the district court reversed, finding insufficient probable cause that Tran resided at Chong’s home. Despite this, the court upheld the search based on exigent circumstances. Chong and Tran were convicted, and their convictions were affirmed on direct appeal. They then filed post-conviction motions under 28 U.S.C. § 2255, which the district court denied, finding no ineffective assistance of counsel.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the deputy’s entry onto the curtilage without a warrant, consent, or exigency was unreasonable under the Fourth Amendment. The court found Chong’s counsel ineffective for not moving to suppress the evidence, as the search was clearly unlawful. However, Tran lacked standing to challenge the search, as he did not reside at Chong’s home and was merely a visitor. Consequently, the court reversed the district court’s denial of Chong’s § 2255 motion and remanded for relief, but affirmed the denial of Tran’s motion. View "Chong v. United States" on Justia Law

The case involves a non-fatal shooting of Joseph Williams by officers of the Sparks Police Department following a 42-minute car chase. Williams had stolen alcohol and vandalized a vehicle, leading to a police pursuit. During the chase, Williams ran red lights, drove through a fence, and briefly drove on the wrong side of the freeway. The chase ended when officers pinned Williams's truck, but he continued to attempt to flee, leading officers to fire multiple rounds, injuring him.The United States District Court for the District of Nevada denied summary judgment on Williams's claims of excessive force, municipal liability, and battery, except for the negligence claim. The court found genuine factual disputes about the threat Williams posed and whether he was attempting to flee when officers fired. The court also denied summary judgment on the Monell claims and the battery claim, citing unresolved factual issues.The United States Court of Appeals for the Ninth Circuit reversed the district court's denial of summary judgment. The appellate court found that video evidence clearly showed Williams attempting to accelerate, contradicting his claim. The court held that the officers' use of deadly force was objectively reasonable, given the threat Williams posed to public safety. The court also exercised pendent jurisdiction over the Monell and battery claims, finding no constitutional violation in the officers' use of force and ruling that the battery claim failed because the force used was not unreasonable. The court reversed and remanded the case for further proceedings consistent with its opinion. View "Williams v. City of Sparks" on Justia Law

Charles Clements was convicted by a California state jury of two counts of aggravated kidnapping, three counts of second-degree robbery, and related enhancements. His convictions were based in part on the testimony of a jailhouse informant, Donald Boeker, who claimed Clements had solicited him to murder a key witness. Boeker testified that he received no benefits for his cooperation and that his motives were altruistic. However, it was later revealed that Boeker did receive parole consideration for his testimony, which the prosecution knew or should have known.Clements appealed the denial of his federal habeas corpus petition, which was filed under 28 U.S.C. § 2254, to the United States Court of Appeals for the Ninth Circuit. The district court had denied his claims, including one under Napue v. Illinois, which asserts that the prosecution knowingly used false testimony. The district court reviewed the Napue claim de novo but ultimately denied it, finding no reasonable likelihood that Boeker’s false testimony affected the jury’s judgment.The Ninth Circuit reversed the district court’s denial of Clements’s Napue claim, holding that the prosecution violated Napue by allowing Boeker to falsely testify about not receiving any benefits for his cooperation. The court found that Boeker’s testimony was highly probative of Clements’s consciousness of guilt and identity on the aggravated kidnapping counts. The court concluded that there was a reasonable likelihood that the false testimony could have affected the jury’s judgment. Consequently, the Ninth Circuit remanded the case with instructions to grant Clements’s habeas petition with respect to the aggravated kidnapping charges. The court did not address Clements’s Brady claim or his request for an evidentiary hearing, as the relief sought was already granted under the Napue claim. The court also affirmed the denial of Clements’s Massiah and prosecutorial misconduct claims, finding that the state court’s determinations were not objectively unreasonable. View "Clements v. Madden" on Justia Law

La Dell Grizzell, acting on behalf of her minor children, sued San Elijo Elementary School and the San Marcos Unified School District, alleging that the school violated her children's federal and state civil rights. The complaint included claims of racial discrimination and other civil rights violations, such as racial epithets, physical assaults, and discriminatory disciplinary measures. Grizzell sought to proceed without legal representation.The United States District Court for the Southern District of California dismissed the case without prejudice, citing the "counsel mandate," which precludes nonlawyer parents from representing their children pro se. The court emphasized that regardless of the merits of the case, Grizzell could not represent her children without an attorney. The district court instructed that the minor plaintiffs could only proceed through a licensed attorney.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that it was bound by its precedent in Johns v. County of San Diego, which prohibits nonattorney parents from representing their children in court. Despite Grizzell's arguments that this rule impedes access to justice for children from low-income families, the panel concluded that it could not deviate from established precedent. The court acknowledged the serious implications of the counsel mandate but affirmed the dismissal without prejudice, indicating that only en banc review could potentially alter the rule. View "GRIZZELL V. SAN ELIJO ELEMENTARY SCHOOL" on Justia Law

Roy Scott, who was unarmed and in mental distress, called the police for help. Officers Kyle Smith and Theodore Huntsman from the Las Vegas Metropolitan Police Department responded. Despite Scott complying with their orders and not being suspected of a crime, the officers used force to restrain him. Scott lost consciousness shortly after and was later pronounced dead. Scott’s daughter Rochelle and a representative of Scott’s estate sued the Department and the two officers, alleging violations of Scott’s Fourth Amendment right to be free from excessive force and Rochelle’s Fourteenth Amendment right to familial association.The United States District Court for the District of Nevada denied the officers' motion for summary judgment on the basis of qualified immunity for both the Fourth and Fourteenth Amendment claims. The officers appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on the Fourth Amendment claim, holding that the officers violated Scott’s Fourth Amendment right to be free from excessive force. The court found that Scott was mentally ill, not suspected of a crime, and did not present a risk to officers or others, making the use of severe or deadly force constitutionally excessive. The court also held that Scott’s Fourth Amendment rights were clearly established at the time of the violation, referencing Drummond ex rel. Drummond v. City of Anaheim.However, the Ninth Circuit reversed the district court’s denial of qualified immunity on Rochelle’s Fourteenth Amendment claim. The court held that while the officers violated Rochelle’s right to familial association, that right was not clearly established at the time of the officers’ conduct, entitling the officers to qualified immunity on this claim. The case was remanded for further proceedings consistent with the opinion. View "SCOTT V. SMITH" on Justia Law