Justia Civil Rights Opinion Summaries

Stapleton lured women into prostitution and exploited them using threats, force, and other forms of coercion. An anonymous tip led to his arrest. Indicted for sex-trafficking crimes, Stapleton claimed that the police had fabricated the anonymous tip and tampered with his cellphone. The court appointed a succession of defense attorneys, but Stapleton constantly disagreed with them regarding his police-misconduct claims. The judge denied his motion to suppress the evidence derived from the anonymous tip. Stapleton then insisted on representing himself. After making the inquiries required by Supreme Court precedent, the judge granted Stapleton’s motion and appointed a standby attorney. Before trial, Stapleton unsuccessfully moved for a court-funded expert to investigate his phone-tampering claim. Before opening statements, Stapleton announced that he would conditionally plead guilty, reserving the right to challenge the suppression ruling. The judge conducted a colloquy and accepted Stapleton’s pleas. Before sentencing, Stapleton unsuccessfully moved to withdraw his pleas. The judge sentenced him to life in prison.Stapleton did not appeal the suppression ruling but argued that his guilty pleas were invalid because he did not have counsel and was confused about his appellate rights and challenged the denial of his motion for a court-funded expert. The Seventh Circuit affirmed. Stapleton validly waived his right to counsel after two thorough colloquies; his guilty pleas were also knowing and voluntary. The judge did not abuse his discretion in denying Stapleton’s request for a court-funded cellphone expert. View "United States v. Stapleton" on Justia Law

The plaintiffs, firefighters and their union, alleged retaliation for protected First Amendment activity. Mayor Copeland, a former firefighter of 26 years, had implemented cost-cutting measures, including freezing the firefighters' salaries and benefits. During Copeland’s reelection campaign, the firefighter’s political action committee endorsed Copeland’s opponent and other candidates who opposed Copeland’s policies. Copeland was reelected. Several firefighters protested at Copeland’s inauguration. Copeland vetoed an ordinance to restore some of the benefits and directed Fire Chief Serna to develop a new schedule. An 8/24 schedule, whereby a firefighter would work eight hours and then be off 24 hours was proposed. No other fire department in the country has adopted that schedule, which assigns firefighters to different shifts every day. In a secretly-recorded conversation, Serna said: “You can call it retaliation.” The defendants proposed to give up the schedule in exchange for the Union giving up its right to lobby the Common Council. The Union rejected the proposal; the city implemented the 8/24 schedule. The Council later returned the firefighters’ to a 24/48 schedule. Copeland sued the Council, alleging that the ordinance violated his executive power. The state court agreed with Copeland and struck the ordinance—leaving the 8/24 schedule in effect.The Seventh Circuit affirmed a preliminary injunction, ordering the city to immediately begin reinstating the old work schedule. There was no evidence that the 8/24 schedule would result in cost savings; the firefighters would suffer irreparable harm without an injunction. View "International Association of Fire Fighters, Local 365 v. City of East Chicago, Indiana" on Justia Law

In 2017, Ramos settled his lawsuits against Cook County Jail correctional officers under 42 U.S.C. 1983 that alleged a failure to protect Ramos from another inmate and the use of excessive force. The settlement agreements contained an identical 262-word sentence—labeled a general release—that released Cook County and its employees from all claims. Months later, Ramos filed another section 1983 lawsuit against two Cook County police officers based on a 2016 arrest that occurred after the events that lead to the first two lawsuits but prior to the execution of the settlement agreements.The Seventh Circuit affirmed the district court’s grant of summary judgment to the defendants. “While the rambling, 262- word sentence is no model of clarity,” it unambiguously released Ramos’s claims arising out of the 2016 arrest. Three phrases signal that Ramos released all foreseeable claims against Cook County “and its agents, employees and former employees,” including those stemming from his 2016 arrest when he signed the settlement agreements in 2017. View "Ramos v. Piech" on Justia Law

Five days after Carter was booked into the Macon County Jail, he died of diabetic ketoacidosis. In the hours preceding his death, Carter exhibited symptoms commonly associated with diabetic ketoacidosis: confusion, lethargy, and labored breathing. He was denied timely medical care because the jail nurse thought he was faking his condition. She assured the corrections officers tasked with transferring Carter out of the medical unit that his vitals were within a normal range. Relying on the nurse’s medical judgment, the officers declined to intervene and proceeded to relocate Carter, believing that his failure to follow orders stemmed from deliberate refusal, not medically induced incapacity.In a suit under 42 U.S.C. 1983, including claims against five corrections officers, the district court denied the officers’ summary judgment based on qualified immunity, finding there to be a material factual dispute over whether they had reason to know that Carter was receiving inadequate medical care, creating a duty to intervene. The Seventh Circuit reversed. Established circuit precedent entitles a corrections officer to defer to the judgment of medical professionals. That is what the officers did here; they are entitled to qualified immunity. View "McGee v. Parsano" on Justia Law

Dorsey, an Illinois state prisoner, was emptying a bucket in the prison laundry when he felt a pop in his lower back and felt pain shoot down his leg. He asked to see a nurse and was told to “go lay down.” Dorsey took ibuprofen and lay down for two hours, but his pain worsened. He again, unsuccessfully, requested permission to seek medical care. The next morning, Dorsey could barely move. Six days later, a nurse concluded that he was exaggerating his symptoms. Dorsey alleges that instead of being treated for back pain, he was prescribed psychiatric medications without his knowledge or consent and was disciplined for refusing to take those medications.Dorsey sued. The district court screened his complaint under 28 U.S.C. 1915A and determined that Dorsey had improperly joined unrelated claims. His complaint asserted three claims under 42 U.S.C. 1983 against 12 defendants. Two claims alleged Eighth Amendment violations based on the poorly maintained washing machines and deliberate indifference to a serious medical condition, his back injury. The third alleged a due process violation, that Dorsey was prescribed medications without his consent. After deeming three amended complaints unsatisfactory, the district court dismissed the case. The Seventh Circuit reversed in part. Dorsey’s claims met both requirements of Rule 20(a)(2), so joinder was legally permissible and the dismissal was an abuse of discretion. The court rejected his other claims. View "Dorsey v. Varga" on Justia Law

Wallace and Santos, inmates at Menard Correctional Center in Illinois filed suit under 42 U.S.C. 1983, alleging that Menard’s “double-ceiling” policy of housing two inmates in single-person cells violated their Eighth Amendment rights. The district court dismissed for failure to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e.The Seventh Circuit reversed in part. Where a plaintiff is able to point to some evidence that administrative remedies were not “available” to him under the PLRA, as described by the Supreme Court in its 2016 Ross v. Blake decision, the district court must decide whether remedies were “available” before granting summary judgment on exhaustion. The plaintiffs claimed to have submitted grievances, offered some evidence that other inmates complained of the same issue with no response, and cited a mechanism by which prison officials can allegedly use state law to reject their grievances without any consideration of their merits. The court remanded for consideration of the exhaustion question as it applies to double-celling at Menard. If the district court finds that double-celling remedies were “available,” then the PLRA’s exhaustion requirement applies. The court affirmed a factual determination that Santos did not file a grievance regarding Menard’s double-celling policy. View "Wallace v. Baldwin" on Justia Law

During a traffic stop, a detective and a police officer worked in tandem to search Colbert’s vehicle and frisk him, uncovering on his person a brick-shaped package later confirmed to contain a controlled substance. Colbert moved to suppress this evidence, arguing that the frisk violated his constitutional rights. The district court denied the motion. Colbert entered a conditional guilty plea to possession with intent to distribute 40 grams or more of a mixture containing a detectable amount of fentanyl, 21 U.S.C. 841(a).The Seventh Circuit affirmed. The officers had reasonable suspicion to frisk him based on two officers observing the smell of marijuana coming from the vehicle, Colbert’s erratic driving, evasive and nervous behavior, a bulge in his pocket, and unwillingness to follow directions. Colbert had read and signed a form, giving the officer permission to search his vehicle. View "United States v. Colbert" on Justia Law

Indiana requires abortion providers to dispose of fetal remains by either burial or cremation. Women may choose to take custody of the remains and dispose of them as they please. The Supreme Court sustained this regimen against Equal Protection challenges in 2019.This suit was filed by two women who had abortions and object to the cremation or burial of the fetal remains, which they contend implies the personhood of a pre-viability fetus, and two physicians do not want to tell patients about their statutory options. The Seventh Circuit reversed a “needlessly broad injunction” that treats the statute as invalid on its face and “effectively countermands the Supreme Court’s decision for the entire population of Indiana." The state does not require any woman who has obtained an abortion to violate any belief, religious or secular. The cremate-or-bury directive applies only to hospitals and clinics. Indiana’s statute need not imply anything about the appropriate characterization of a fetus. Nor does Indiana require any woman to speak or engage in expressive conduct. A state may require medical professionals to provide information that facilitates patients’ choices directly linked to procedures that have been or may be performed. View "Doe v. Rokita, Attorney General of Indiana" on Justia Law

Moran was convicted of attempted murder and aggravated battery with a firearm for a 2006 Calumet City, Illinois shooting. After the trial, the prosecution learned that exculpatory evidence, including a ballistics report linking the gun used in the Calumet City shooting to a different shooting, had not been turned over to the defense as required by Brady v. Maryland. Moran sought postconviction relief. A state court vacated his conviction. Moran was retried and acquitted in 2017.Moran then filed a federal suit (42 U.S.C. 1983) against the city, two detectives who investigated the shooting, and a crime scene technician who mishandled the ballistics report, seeking redress for the decade he spent incarcerated. The district court granted the defendants summary judgment, noting that Moran’s allegation that an Assistant States Attorney knew about the report was a judicial admission that negated an essential element of the claim; prosecutorial knowledge of exculpatory evidence blocks civil liability for police officers. The court stated that even without that judicial admission, the record could not allow a reasonable jury to find that the evidence had been suppressed. Moran moved for leave to amend his complaint. The Seventh Circuit affirmed the denial of that motion. Moran unduly delayed seeking to amend his complaint; he should have known that his complaint contained factual errors at the outset. View "Moran v. Calumet City, Illinois" on Justia Law

Illinois State Police Officer Myers supervised 10 controlled drug purchases by a confidential source (CS) at a Cairo residence. Each purchase was recorded on video. The CS initially said that “Cornelius Dean” was selling crack cocaine at the house. Eventually, the CS found out the dealer’s name was Ed. Ed later told the CS that his surname was “Johnson.” Myers searched for an image of an “Ed or Edward Johnson” in the Illinois Secretary of State database but found no match. Alexander County Sheriff Brown suggested Ed’s last name might be Osborne. Myers again checked the state database and discovered that “Phillip Edward Osborne” resided in Cairo. Myers obtained Osborne’s driver’s license photo and concluded that it matched the dealer in the drug buy videos. Myers reported that the CS, upon seeing the photo, unequivocally, identified Osborne. Myers obtained an arrest warrant. Osborne was arrested and remained incarcerated for seven days before being released on bond. The state eventually dismissed the charges.Osborne sued under 42 U.S.C. 1983. The district court dismissed the claims against the county and granted Myers summary judgment on the false arrest claim, finding no evidence to undermine probable cause to arrest Osborne and that Myers was entitled to qualified immunity. The Seventh Circuit affirmed. The plaintiff failed to overcome the presumption of validity accorded to the warrant and the underlying information, with little more than bare allegations that Myers lied in his warrant application. View "Johnson v. Myers" on Justia Law