Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Sixth Circuit
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The case revolves around a plaintiff, Jorden Brown, who was tasered by Officer Samuel Giles while fleeing from police, resulting in injuries to Brown. Brown sued Officer Giles, the police chief, and the municipality he was arrested in under 42 U.S.C. § 1983, alleging excessive use of force and violation of his Fourth Amendment rights. He also claimed that department policies or customs enabled these violations. The defendants moved to dismiss the case, and the district court granted the dismissal on the grounds that Brown failed to allege a violation of clearly established law. Brown appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court ruled that Brown failed to show that it was clearly established that tasing him in this particular context was excessive. They referred to previous cases where it was deemed reasonable for officers to tase fleeing suspects. The court further dismissed Brown's claim that the taser hit his head, arguing that during a chase, it is unrealistic to expect an officer to aim precisely to avoid the head.The court also rejected Brown's claim that Officer Giles continued to tase him after he was incapacitated. Brown had provided video footage of the incident which, according to the court, showed that Officer Giles tased Brown only once. The court therefore ruled that Officer Giles was entitled to qualified immunity. As Brown's claims against Officer Giles failed, his claims against the police chief and the municipality were also dismissed. View "Brown v. Giles" on Justia Law

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In this case, DeShawn Anderson-Santos, a juvenile detainee at the Kent County Juvenile Detention Center, claimed he suffered a head injury after being pushed by corrections officer Derek Leshan. Anderson-Santos filed a lawsuit against Leshan under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Eighth Amendment, alleging the use of excessive force. Leshan sought summary judgment arguing qualified immunity. The district court denied Leshan’s motion, finding that there was a genuine dispute of material fact as to whether Leshan had used excessive force, thus violating the Eighth Amendment. The court also found that Leshan was not entitled to qualified immunity at the summary judgment stage. Leshan appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit dismissed the appeal for lack of jurisdiction. The court noted that while denials of summary judgment are not typically appealable on an interlocutory basis, an exception exists for denials of claims of qualified immunity if the appeal turns on a legal issue. However, the court found that Leshan's appeal ultimately turned on questions of fact rather than an issue of law, divesting the court of jurisdiction. The court explained that a defendant seeking to challenge a denial of qualified immunity based on a genuine dispute of material fact may invoke the court's jurisdiction by conceding the plaintiff's version of the facts. However, the court determined that Leshan did not truly concede Anderson-Santos' version of the facts, thus the court lacked jurisdiction to hear the appeal. View "Anderson-Santos v. Kent County" on Justia Law

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In this case before the United States Court of Appeals for the Sixth Circuit, the defendant, Charles O’Neill, appealed the judgment of the district court. O’Neill was charged with sexually exploiting a minor and receiving or distributing child pornography. He pleaded guilty to both charges but reserved the right to appeal the district court’s denial of his motion to suppress evidence obtained from his home and a barn he owned. The evidence included large numbers of photographs of nude and partially nude minor boys on O’Neill’s phone and iPad, and a computer, camcorder, camera, digital storage devices, miscellaneous clothing, and a vibrator found in the barn.The district court found that although the affidavits from the police officers used to obtain search warrants contained false statements and lacked probable cause, the officers had not knowingly or recklessly misled the issuing magistrate, and their reliance on the warrants was objectively reasonable under the good-faith exception in United States v. Leon.On appeal, the Sixth Circuit affirmed the district court's decision, agreeing that none of the exceptions to the good-faith exception applied. The court found that the officers' errors in the affidavits were negligent rather than reckless, the affidavits weren't "bare bones" as they contained more than conclusory claims and were far from devoid of factual support, and the warrants weren't facially deficient. The court noted that the officers' reliance on the search warrants was objectively reasonable, and therefore the fruits of their searches shouldn't be suppressed. The court also noted that even if it shared the dissenting judge's view on the officers' state of mind, it would likely conclude that the district court's denial of the suppression motion was proper because the remaining content of the affidavit would likely establish probable cause. View "United States v. O'Neill" on Justia Law

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In July 2018, Brian Lawler, a pretrial detainee, committed suicide at a county jail in Hardeman County, Tennessee. Lawler's father, Jerry Lawler, brought a lawsuit under 42 U.S.C. § 1983, alleging that the officers had been deliberately indifferent to the risk that Brian would commit suicide. The United States Court of Appeals for the Sixth Circuit held that the officers were entitled to qualified immunity because the laws in place at the time of the suicide did not clearly establish that the officers’ actions violated the Constitution. The court noted that in 2018, to hold officers liable for failing to prevent a pretrial detainee’s suicide, it was necessary to prove that the officers subjectively believed there was a strong likelihood the inmate would commit suicide. The evidence showed that the officers did not subjectively believe that Lawler was likely to take his life. Therefore, the court reversed the district court’s denial of qualified immunity to the officers. View "Lawler v. Hardeman County" on Justia Law

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In a case heard before the United States Court of Appeals for the Sixth Circuit, plaintiff Jeffrey Hughes, an inmate in a Tennessee state prison, sued the Tennessee Board of Parole, alleging that the Board's refusal to move up his parole hearing date resulted in his overincarceration. Hughes believed that a recent change in state law entitled him to an earlier parole hearing. The Board refused his request, and he was paroled about three months after the date he believed he became eligible for release. The district court dismissed the case on the ground that the defendants, members of the Board, were absolutely immune from suit for their acts. Hughes then appealed.The Court of Appeals affirmed the district court’s decision, holding that the members of the Tennessee Board of Parole were entitled to absolute immunity from damages suits challenging its decision on when to hold a parole hearing. The court found that the Board's decision to schedule (or not to reschedule) a parole hearing was a judicial act, akin to a judge scheduling a court hearing. As such, the defendants were acting in a quasi-judicial capacity and were entitled to absolute immunity. The court also rejected Hughes's arguments of judicial estoppel and res judicata, stating that the defendants could not have raised their immunity defense in the previous state suit and thus were not barred from raising it in the present federal suit. View "Hughes v. Duncan" on Justia Law

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In this case, the United States Court of Appeals for the Sixth Circuit was faced with the claims of Cameron Cooper, an employee with Tourette Syndrome, who sued his former employer, Coca-Cola Consolidated, Inc. (CCCI), under the Americans with Disabilities Act (ADA). Cooper's Tourette Syndrome caused him to involuntarily utter racist and profane words. He alleged that CCCI failed to provide him with reasonable accommodations and constructively discharged him by forcing him into an undesirable position.Cooper had been working as a delivery merchandiser for CCCI, a role which required excellent customer service. However, his condition led to complaints from customers due to his use of offensive language. CCCI attempted various accommodations, including having Cooper work alongside another employee and ultimately transferring him to a warehouse position with no customer contact. Cooper claimed that CCCI could have accommodated him by assigning him to a non-customer-facing delivery route.The court held that providing excellent customer service was an essential function of Cooper's job and, given his condition, he could not perform this function without an accommodation. The court further held that Cooper's proposed accommodation (assigning him to a non-customer-facing delivery route) was not objectively reasonable because the suggested delivery route did involve customer contact and there were no other non-customer-facing routes available at the time. Additionally, the court found that the warehouse position offered by CCCI was a reasonable accommodation under the ADA.As to the constructive discharge claim, the court held that Cooper failed to show that CCCI deliberately created intolerable working conditions with the intention of forcing him to quit. The court concluded that CCCI provided Cooper with reasonable accommodations each time he requested, thus, there was no evidence to support a constructive discharge claim.The court affirmed the lower court's decision to grant summary judgment in favor of CCCI. View "Cooper v. Dolgencorp, LLC" on Justia Law

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In a case heard by the United States Court of Appeals for the Sixth Circuit, plaintiffs Mark Bambach and his minor children sued defendants Gina Moegle and Susan Shaw, employees of Michigan's Children’s Protective Services, under 42 U.S.C. § 1983. The plaintiffs alleged that Moegle and Shaw violated their Fourth and Fourteenth Amendment rights by removing the children from Bambach's custody without a warrant and failing to return them after Bambach revoked his consent for the children to stay with their mother during an investigation into allegations of child abuse. The court found that no clearly established law put the state defendants on notice that they were violating the Bambach's Fourteenth and Fourth Amendment rights. The court determined that the key factual dispute underpinning the remaining claims was whether Bambach’s children were removed from his custody without his consent from December 29, 2015, to January 14, 2016. The court found that a reasonable jury could determine that Bambach had revoked his consent to his children’s placement with their mother by expressing to Moegle that he wanted to see his children and wanted to know when they would be back. But the court did not assess whether those constitutional rights were clearly established at the time of the violations. The court found that Moegle and Shaw were entitled to qualified immunity as they could not have been on notice that their actions were unconstitutional. The court reversed the district court’s denial of summary judgment and remanded for entry of an order dismissing the plaintiffs' claims against the defendants. View "Bambach v. Moegle" on Justia Law

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Chinyere Ogbonna-McGruder, an African American professor, alleged that her employer, Austin Peay State University (APSU), and her supervisors engaged in racial discrimination and created a hostile work environment, and retaliated against her when she opposed their unlawful conduct. She also claimed that her supervisors violated her constitutional rights under 42 U.S.C. § 1983. The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision to dismiss all counts for failure to state a claim. The court ruled that Ogbonna-McGruder failed to sufficiently allege that the harassment she experienced was severe or pervasive, a necessary element of a hostile work environment claim. The court also found that she did not sufficiently allege that any adverse employment actions were motivated by discriminatory animus, and that she did not adequately assert that the conduct forming the basis of her §1983 claim violated a specific constitutional provision. View "Ogbonna-McGruder v. Austin Peay State Univ." on Justia Law

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In the case before the United States Court of Appeals for the Sixth Circuit, Leslie Fisher sued officers Randall Jordan, Matthew Rice, and John Trefelet of the Michigan State Police for violating federal and state law by arresting her without probable cause. Fisher and her husband were arrested after the officers executed a search warrant and found marijuana growing in their garage. All charges against Fisher were eventually dismissed in state court. She then filed a federal lawsuit against the arresting officers.The officers moved for summary judgment, invoking qualified immunity in response to Fisher's federal claims of arrest and prosecution without probable cause under 42 U.S.C. § 1983, and governmental immunity for her state claims of false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment to the officers, concluding that they had probable cause to arrest Fisher.On appeal, the Sixth Circuit affirmed the district court's decision. The court found that the officers had probable cause to believe that Fisher had committed the crime of possession of at least 5,000 grams of marijuana with the intent to distribute, based on various pieces of evidence. This included the fact that Fisher lived at and owned the site of the marijuana cultivation operation, and that she admitted to using marijuana grown by her husband. The court also found that the large quantity of marijuana in the Fishers' garage supported probable cause to infer intent to distribute.The court further concluded that the officers were entitled to governmental immunity from Fisher's state law claims, as the probable cause analysis for federal Fourth Amendment claims is the same under Michigan law. Since the officers had probable cause to suspect that Fisher possessed an illegal quantity of marijuana with the intent to distribute, they were entitled to governmental immunity from Fisher's state law claims. View "Fisher v. Jordan" on Justia Law

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In this case, Timmy Mosier, a man arrested for public intoxication, brought federal civil rights and state tort claims against Officer Joseph Evans and Crockett County, Tennessee. Mosier alleged that Officer Evans used excessive force resulting in serious injury when he pulled Mosier to the ground causing him to hit his head. The United States Court of Appeals for the Sixth Circuit held that Officer Evans was entitled to qualified immunity on Mosier's federal excessive-force and inadequate-medical-care claims because Mosier failed to demonstrate that Evans violated a clearly established statutory or constitutional right. The court also affirmed the grant of summary judgment in favor of Crockett County on Mosier's federal municipal-liability claim, finding that Mosier failed to show that a municipal policy or custom caused the alleged violation of his rights. The court also affirmed the dismissal of Mosier's state-law negligence claims against Evans in his official capacity and against Crockett County under the Tennessee Governmental Tort Liability Act's civil-rights exception. However, the court reversed the dismissal of Mosier's negligence claim against Evans in his personal capacity. View "Mosier v. Evans" on Justia Law