Justia Civil Rights Opinion Summaries

In 2007, Pittman, a pretrial detainee in the Madison County, Illinois, jail, hanged himself in his cell. He did not die, but he sustained brain damage that has left him in a vegetative state, cared for entirely by his mother with no government benefits. Pittman left a suicide note in which he said that he was killing himself because the guards were “fucking” with him by not letting him see crisis counselors. In a suit under the Eighth Amendment, the district court granted defendants summary judgment. The Seventh Circuit reversed as to two guards. A jury then returned a verdict in favor of both defendants. The Seventh Circuit vacated. Another inmate, Banovz, stated that in the five days preceding Pittman’s suicide attempt, the guards ignored Pittman’s requests to see the crisis staff. Three hours after the suicide attempt a county detective obtained a 25-minute interview with Banovz about the attempt, which was captured on video. The video was not admitted at trial, even though Banovz’s testimony was the lynchpin of the plaintiff’s case and the defendants had stipulated to the showing of the video. While Banovz testified at trial, the passage of seven years had dimmed his recollection and his demeanor at trial was notably different from his demeanor in the video. The court stated it had “no assurance that Pittman’s claim was fairly tried.” View "Pittman v. Madison County" on Justia Law

Simpson fell off an upper bunk while incarcerated in the Bartholomew County Jail for a drunken driving conviction. Simpson was intoxicated when he reported to the jail to serve his weekend stay. Officers placed him in a holding cell. After they thought he was sober, they assigned him to an upper bunk, although he was obese. While sleeping, Simpson went into convulsions and fell off the bunk on to the concrete floor. He died from his injuries. His estate sued, arguing that the conditions under which the jail kept Simpson and the care he received were inadequate under the Eighth Amendment. The district court found insufficient evidence to show the defendants were aware of, but disregarded, a risk to Simpson’s health and safety and granted them summary judgment. The Seventh Circuit affirmed. The defendants tailored their care for Simpson to account for his intoxication, even asking Simpson if he was experiencing any withdrawal symptoms. Simpson said no. The deputies believed he was sober when they moved him. Had they known about Simpson’s alcoholism and the risk posed by withdrawal, they might have taken additional steps to protect him. Without any indication that they knew of a serious risk, they cannot be held liable under section 1983 for either the conditions of confinement or the medical treatment they provided. View "Estate of Simpson v. Gorbett" on Justia Law

Proctor, an Illinois prisoner who was confined for seven years at Hill Correctional Center, suffers from chronic abdominal pain and spasms in his colon. He sued medical providers working at Hill for Wexford Health Sources, the contractor providing healthcare to Illinois prisoners, and corrections officials, claiming that they violated the Eighth Amendment by not ordering a colonoscopy and endoscopy to diagnose his persistent abdominal pain. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed. A jury could not reasonably find that the defendants were deliberately indifferent to Proctor’s medical condition. Proctor’s abdominal pain and colon spasms were investigated thoroughly, and that investigation substantiated only a diagnosis of IBS. Over the course of treating him, the medical professionals routinely performed physical exams and ordered X‐rays, an ultrasound, bloodwork, stool cultures, and other tests, but the results were consistently normal. The decision whether further diagnostic testing— like a colonoscopy—was necessary is “a classic example of a matter for medical judgment. View "Proctor v. Sood" on Justia Law

Awaiting trial on state charges for armed robbery and unlawful restraint, Hudson's public defender advised that he faced a sentence of six-60 years. He rejected a plea deal that offered 16 years. Hudson was convicted. At sentencing, it was discovered that his criminal history including convictions for murder, armed robbery, burglary, felony theft, and felony drug possession. Hudson received a mandatory natural life sentence without the possibility of parole. After exhausting state appeals, Hudson filed a federal habeas action, alleging ineffective assistance of counsel. The district court issued the writ, ordering the state to reoffer Hudson the original plea deal. Hudson accepted a plea deal for attempted armed robbery, to avoid a mandatory life sentence. The judge declined to rule, stating that she had no jurisdiction because “orders from the Appellate Court … suggested all issues addressed by this Court were correct, and … nothing from the Federal Court that suggests otherwise.” The original sentence had not been vacated; the new agreement was contrary to Illinois law, in suggesting that Hudson plead guilty to an offense that he was not convicted of. The judge stated that she would have rejected the plea deal even if she were considering it for the first time, considering Hudson’s criminal history. Hudson’s state court appeal remains pending. Hudson filed a federal “motion to enforce” that sought his immediate release. The district judge denied the motion. The Seventh Circuit dismissed an appeal for lack of jurisdiction. State prosecutors complied with the original writ, but a state judge refused to accept the deal. Hudson received all the relief he sought in his first habeas action. View "Hudson v. Lashbrook" on Justia Law

The Equal Employment Opportunity Commission found reasonable cause to believe that Chicago Police Department violated Title VII by harassing Officer Sommerfield based on his national origin, German, and religion, Jewish. Sommerfield alleged that his complaints led to retaliation. He filed another EEOC charge alleging retaliation. The agency again found reasonable cause. After years of litigation in his subsequent 42 U.S.C. 1981, 1983 suit, a jury awarded Sommerfield $30,000, rejecting his retaliation claim. Sommerfield’s lawyer requested $1.5 million in attorney’s fees, which the district court reduced to $430,000. The attorney claimed to have worked 3,742 hours at an hourly rate of $395; the judge reduced the hours to 2,878 and the rate to $300, which yielded a lodestar of $863,000. The judge took into account the modest degree of success Sommerfield had achieved and halved the lodestar. The Seventh Circuit affirmed, upholding the district court’s decisions to grant partial summary judgment for the city by confining the discrimination counts to the question whether a fellow officer’s statements had created a hostile work environment; eliminating two counts for lack of any evidence that would permit a finding that Sommerfield’s injury resulted from an express policy, a widespread practice, or a policymaker’s final action; and restricting the retaliation claim period. View "Sommerfield v. City of Chicago" on Justia Law

Vidmar, Manney, and Gomez were discharged from the Milwaukee Police Department, for cause, by Police Chief Flynn. Their benefits and pay stopped immediately. They appealed their terminations to the Board of Fire and Police Commissioners, which rejected their appeals. They were permanently discharged. The former officers claimed that their employment did not end when they were discharged by the chief because they were entitled to employment until the conclusion of their appeals. They alleged that they were denied constitutional due process and wages. The district court rejected their claims and granted judgment on the pleadings. The Seventh Circuit affirmed. Under Wisconsin law, the former officers had no property interest in employment once they were discharged for cause by Chief Flynn. They were provided a full and adequate appellate process, and their discharges were upheld in accordance with Wisconsin law. They were not entitled to wages for the period of time between their discharge and the conclusion of their appeal under Wisconsin law as they were not employed during that time. View "Milwaukee Police Association v. Flynn" on Justia Law

Wilson-Trattner dated Roeger, a Hancock County Sheriff’s Department deputy. The relationship became combative. On one occasion Roeger threw Wilson-Trattner against a wall and choked her; other incidents involved lewd and threatening text messages, statements that Wilson-Trattner had “fucked with the wrong person,” Roeger locking Wilson-Trattner out of her home, and Roeger punching a hole in her door. The Sheriff’s Office responses included statements that “we’re sick of getting these calls.” The McCordsville Department eventually arrested Roeger. He pled guilty and resigned from the Sheriff’s Department. Wilson-Trattner filed suit. The district court granted judgment for the defense on Wilson-Trattner’s 42 U.S.C. 1983 substantive due process claim (against individual officers and Roeger in their individual and official capacities), her failure to train claim (against Sheriff Shepherd in his official capacity) and intentional infliction of emotional distress claim (against Shepherd in his official capacity). It declined to grant judgment on battery and intentional infliction of emotional distress claims against Roeger. The Sixth Circuit affirmed. Roeger was not serving as a state actor in his interactions with Wilson-Trattner. None of the defendants’ conduct was sufficiently outrageous to give rise to a cognizable claim; there was no evidence that they created or increased a danger to Wilson-Trattner. Mere indifference or inaction in the face of private violence cannot support a substantive due process claim. View "Wilson-Trattner v. Campbell" on Justia Law

Chicago Police Officers pulled over 18-year-old Jackson for a missing front license plate. The officers claim that Jackson fired a weapon toward the squad car and ran away. The officers shot him three times in the back; he died the next day. Two eyewitnesses testified that they thought Jackson did not have a weapon. The defense offered testimony that gunshot residue was found on Jackson’s hand and that casings were found at the site from which Jackson shot. The gun found near Jackson was swabbed for DNA, but the samples were never tested by the Illinois State Police. Jackson’s mother brought a civil suit for excessive force and wrongful death. A jury returned a verdict in favor of the defendants. The Seventh Circuit affirmed, rejecting arguments that the trial court erred in excluding evidence or argument relating to the failure to test the DNA swabs. The only issue was whether the officers were justified in shooting Jackson. A lack of DNA evidence, without more, would not tend to prove or disprove justification. There was nothing tying the shooting officers to any missing DNA evidence. It would be unfair to assume that testing of the DNA swabs would have helped, or harmed, Mitchell’s case View "Mitchell v. City of Chicago" on Justia Law

Indiana’s alcohol regulatory scheme, like that of many states, divides the market into three tiers of the distribution chain (producers, wholesalers, and retailers) and three kinds of alcohol (beer, liquor, and wine). With limited exceptions, Indiana prohibits any person who holds a permit in one tier of the distribution chain from also holding an interest in a permit in another tier. For example, anyone who holds an interest in a retailing permit is generally prohibited from having any interest in a manufacturer’s or wholesaler’s permit of any type. Indiana also restricts the issuance of wholesaling permits by type of alcohol. The law allows some wholesaling permits to be combined: a beer wholesaler can get a permit to wholesale wine; a liquor wholesaler can get a permit to wholesale wine, but a beer wholesaler may not acquire an interest in a liquor-wholesaling permit and vice versa. Monarch holds permits to wholesale beer and wine and would like to wholesale liquor. Monarch sued, alleging that this aspect of the law facially discriminates against beer wholesalers in violation of the equal protection guarantee. The district court and Seventh Circuit upheld the law as surviving “rational basis” review. Monarch could not identify a similarly situated class that receives better treatment under the statute and reducing liquor consumption is a legitimate governmental interest. View "Monarch Beverage Co., Inc. v. Grubb" on Justia Law

Meadows worked for the Rockford Housing Authority (RHA), and leased, for $10 per month, an RHA apartment in a high-rise occupied by elderly and disabled tenants. RHA tenants complained that someone else was living in Meadows’s apartment. RHA’s manager saw an unidentified man leave the apartment and lock the door with a key and reported to RHA’s director, who contacted Metro, a private security company under contract with the RHA. Metro employee Novay, knocked on the door and spoke with a Sockwell, who stated that he was renting the apartment. Novay took Sockwell’s key and escorted him from the building. Meadows returned to the apartment, and, without notifying RHA or Metro, installed a new lock. That evening, RHA's director suggested changing the apartment's locks to protect the other tenants. The next morning, Meadows went to the police station to report that his apartment “had been ransacked.” Novay arrived to supervise the locksmith and found that Sockwell’s key no longer worked. The locksmith picked the locks. Meadows arrived, became enraged, tried to physically remove Novay, and called the police. Meadows was given a new key and allowed to remain in the apartment that day. Meadows sued Metro’s employees under 42 U.S.C. 1983. The Seventh Circuit affirmed summary judgment for the defendants; the employees of a private security company, who carried out the RHA’s order, are entitled to qualified immunity. View "Meadows v. Rockford Housing Authority" on Justia Law