Justia Civil Rights Opinion Summaries

Alcoa Officers arrested an obviously inebriated Colson following a report that, while driving her SUV, she chased her 10-year-old son in a field and then crashed in a ditch, and transported her to a hospital. Colson then withdrew her consent. to a blood draw. Colson defied repeated orders to get back into the cruiser. During the struggle, an officer's knee touched Colson’s knee, followed by an audible “pop.” Colson started screaming “my fucking knee” but continued to resist. Once Colson was in the cruiser, officers called a supervisor, then took Colson to the jail where a nurse would perform the blood draw. Colson never asked for medical care. At the jail, Colson exited the vehicle and walked inside, with no indication that she was injured. As she was frisked, Colson fell to the ground and said “my fucking knee.” Jail nurse Russell asked Colson to perform various motions with the injured leg and compared Colson’s knees, commented “I don’t see no swelling,” and then left. A week later, Colson was diagnosed with a torn ACL, a strained LCL, and a small avulsion fracture of the fibular head. Colson pleaded guilty to resisting arrest, reckless endangerment, and DUI.Colson sued; only a claim for failure to provide medical care for her knee injury survived. The Sixth Circuit held that the officers were entitled to qualified immunity on that claim. View "Colson v. City of Alcoa" on Justia Law

Detroit police officers apprehended a fleeing suspect who had run across several yards, including White’s yard. Believing that the suspect had disposed of a weapon nearby, officers called in a canine unit to search. Bodycam and security camera footage captured the events that followed. Officer Cherry arrived with her trained canine, Roky. The White family had two dogs outside, White’s daughter, Mi-Chol, grabbed Chino, a pit bull, to put him inside but he escaped and ran to the front yard. Mi-Chol went inside to grab a leash. As Officer Cherry and Roky reached the corner of the adjoining yard, Chino lurched through the fence’s vertical spires and bit down on Roky’s snout. Roky yelped. Cherry turned and saw Roky trapped up against the fence with his nose in Chino’s mouth. Cherry tugged at Roky’s leash and yelled at Chino to “let go.” Chino began “thrashing.” Unable to free Roky and afraid for the dog’s life, Cherry shot Chino. Six seconds passed between Chino’s attack and Cherry’s shot. Chino died from the shot. The Whites sued. The Sixth Circuit affirmed summary judgment for the defendants, citing qualified immunity. Officer Cherry acted reasonably. View "White v. City of Detroit" on Justia Law

Harrington, the founder of a nonprofit corporation that engages in anti-abortion protests, sought to demonstrate at the Democratic Party’s presidential-primary debates in Detroit in 2019. In response to security concerns, the Detroit Police Department imposed and enforced several measures that impeded the group’s speech. A “restricted area” blocked access to the debate venue’s immediate vicinity. Protestors were divided into “right-leaning” and “left-leaning” camps and were barred from commingling. Harrington was briefly detained after a confrontation with police. Harrington and his group eventually abandoned the site. They filed suit, alleging violations of the First and Fourth Amendments and the Equal Protection Clause.The district court granted summary judgment to the defendants—the city and three individual officers. The Sixth Circuit affirmed. The restricted area satisfies intermediate scrutiny; to hold that law enforcement could not establish a restricted area around such an event without a known, specific threat would make it essentially impossible to guard against terroristic violence. The plaintiffs failed to establish a genuine dispute that the defendants’ asserted security rationale was somehow pretextual or non-existent. Noting that the protestors were not “similarly situated” to other groups, the court rejected equal protection claims. The court further noted that the property that the group was asked to leave was privately owned; when officers began to place Harrington in cuffs, they reasonably believed he was committing criminal trespass. View "Reform America v. City of Detroit" on Justia Law

In 2005, Adolphe was found murdered in front of his apartment building. Adolphe and Carr had been dating. Carr, age 16, was arrested and entered an Alford plea in 2008 to second-degree manslaughter, conspiracy to commit robbery, conspiracy to commit burglary, and tampering with physical evidence. She was paroled in 2009 and discharged in 2018. In 2019, Kentucky Governor Bevin granted Carr “the full and unconditional pardon she has requested.”A year later, Carr sued under 42 U.S.C. 1983, alleging that the defendants fabricated evidence, coerced false statements, and withheld exculpatory evidence. The district court dismissed Carr’s complaint, finding that her section 1983 claims were not cognizable under the Supreme Court’s “Heck” decision. The Sixth Circuit reversed. While a full pardon does not always indicate that the individual is innocent, Heck did not impose a prerequisite of innocence to seek relief under section 1983; a full pardon in Kentucky removes all legal consequences so that a plaintiff can proceed with her section 1983 claims. View "Carr v. Louisville-Jefferson County" on Justia Law

The Hopkinses kept cattle on their Marshall County, Tennessee farm. Detective Nichols received a complaint about the treatment of those cattle, drove by, and observed one dead cow and others that did not appear to be in good health. Nichols returned with Tennessee Department of Agriculture Veterinarian Johnson. Wearing his gun and badge, Nichols knocked and. according to Mrs. Hopkins, “demanded that [she] escort them to see the cattle,” refusing to wait until Mr. Hopkins returned or until she fed her children. Johnson completed a Livestock Welfare Examination, as required by law, noting that the cattle were not in reasonable health, that they lacked access to appropriate water, food, or shelter, and that major disease issues were present; she determined that probable cause for animal cruelty existed. Nichols returned to the Hopkins’s farm several times and discovered a sinkhole containing the remains of multiple cattle. Nichols and Sheriff Lamb eventually seized the cattle without a warrant and initiated criminal proceedings. The cattle were sold.The Sixth Circuit affirmed the denial of a motion for qualified immunity in a suit under 42 U.S.C. 1983. Forced compliance with orders is a Fourth Amendment seizure; words that compel compliance with orders to exit a house constitute a seizure. While the open fields doctrine allowed the officers to lawfully search the farm, it did not give them lawful access to seize the cattle; they lacked exigent circumstances when they seized the cattle. View "Hopkins v. Nichols" on Justia Law

Bell asked why Officer Korkis pulled him over. Korkis responded that Bell first needed to provide his driver’s license, registration, and car insurance and that more officers were on their way. Bell claims the officers forcefully removed him from his vehicle, despite Bell volunteering again to exit on his own. Dash-cam videos show Korkis and Bell arguing for three minutes. Korkis asked for Bell’s information about 20 times, then reached into the window to unlock the door. A physical struggle ensued, not fully visible in the videos. Officers eventually pried open the door and told Bell to get on the ground; he repeatedly refused. Officers wrestled him to the pavement, where he refused to comply. An officer warned Bell about the taser. Bell still did not put his hands behind his back. An officer tased him.Bell sued the officers (42 U.S.C. 1983), claiming they violated the Fourth Amendment’s bar against excessive force. The district court dismissed, citing qualified immunity. The Sixth Circuit affirmed in part after holding that the video footage could be considered at the motion-to-dismiss stage to determine whether allegations in the complaint were implausible. The court dismissed the appeal with respect to claims concerning the officers removing Bell from his car, noting that factual issues remain. With respect to claims concerning the tasing, Bell had not shown that the officers violated his clearly established rights. View "Bell v. City of Southfield" on Justia Law

Charlton-Perkins, a male research scientist, applied for a professorship at the University of Cincinnati (UC) in late 2017. He alleges that UC determined him the most qualified candidate for the position but refused to hire him on account of his gender, then canceled the job search itself, ensuring that Charlton-Perkins could never fill the position.The district court dismissed his complaint under Title IX, 20 U.S.C. 1681 and 42 U.S.C. 1983, for lack of subject-matter jurisdiction. Because nobody ever filled the canceled position, it reasoned, Charlton-Perkins’s claims never ripened into an adverse employment action, and thus he suffered no concrete injury cognizable in federal court. The Sixth Circuit reversed. Charlton-Perkins plausibly alleged a ripe employment discrimination claim, so his suit may proceed. No matter whether somebody else ever got the spot, it has always been the case that Charlton-Perkins was denied the spot. He has always had that de facto injury, no matter whether someone else got the position instead. Charlton-Perkins claims that the defendants not only failed to hire him because of his gender, but they then canceled the search itself as a pretext to conceal the discriminatory reason for the failure to hire. View "Charlton-Perkins v. University of Cincinnati" on Justia Law

Plaintiffs alleged they were sexually abused by Tyler, a Kentucky probation and parole officer, 2017-2019, while Plaintiffs served sentences for state convictions. In 2018, one victim filed a sexual harassment complaint but Tyler’s supervisor, Hall, concealed the complaint. The state terminated Hall and charged Tyler with rape in the first degree, sodomy in the first degree, sexual abuse in the first degree, tampering with physical evidence, official misconduct in the first degree, and harassment.Plaintiffs brought their claims under 42 U.S.C. 1983 and the Thirteenth Amendment, arguing that Defendants directly violated their rights. to be free from involuntary sexual servitude guaranteed by the Thirteenth Amendment and violated Plaintiffs’ Thirteenth Amendment rights to be free from “unwanted sexual physical contact,” “unwanted intrusion upon Plaintiffs’ person(s) for the sexual gratification of Defendants’ employee,” “sexual physical assault,” and “unwanted sexual contact.” Because the section 1983 limitations period had expired, Plaintiffs amended their complaint and claimed that their action arose out of the Thirteenth Amendment exclusively, disclaimed their arguments against Governor Beshear, and asserted that jurisdiction was proper under 28 U.S.C. 1331. The Sixth Circuit affirmed the dismissal of the suit; the Thirteenth Amendment neither provides a cause of action for damages nor abrogates state sovereign immunity against private damages actions. The court rejected Plaintiffs’ argument that no state or federal law prohibits them from filing suit directly against the Commonwealth. View "Smith v. Commonwealth of Kentucky" on Justia Law

Thomas called 911, stating that he believed he was overdosing from cocaine. Law enforcement officers customarily secure suspected drug overdose scenes before paramedics enter. Officer Pinkerman knocked on the door, which burst open. Thomas ran into the lawn, disobeying officers’ commands. When Thomas fell, Pinkerman fell on top of him. Thomas actively resisted. Four officers handcuffed Thomas and signaled to paramedics to approach. Thomas was kicking and dropping his weight, so the officers laid him down and called for a hobble strap to prevent him from kicking paramedics. Officer Shaffner applied his knee to Thomas’s lower back/hip area. Stephens had his knees against Thomas’s shoulder. Thomas was kept in this position for approximately 90 seconds while waiting for a hobble strap. Officers noticed that his breathing slowed and rolled Thomas onto his side. Paramedics administered Narcan to increase his respiratory rate and deemed Thomas to be in stable, non-life-threatening condition; minutes later he went into cardiac arrest. Thomas arrived at the hospital in critical condition. A drug screen detected marijuana, cocaine, and opiates. Thomas died of “anoxic encephalopathy” resulting from cardiac arrest.Thomas’s estate alleged that his cardiac arrest was caused by “forcible restraint that precluded adequate breathing.” The Sixth Circuit affirmed the summary judgment rejection of the estate’s 42 U.S.C. 1983 claims. The estate cannot establish that Thomas had a clearly established right against the type of force that was used; the officers are entitled to qualified immunity. View "Wiley v. City of Columbus" on Justia Law

Universal Life Church Monastery permits anyone who feels called to become ordained as a minister—over the Internet, free of charge, in a matter of minutes. Tennessee law permits only those “regular” ministers—ministers whose ordination occurred “by a considered, deliberate, and responsible act”—“to solemnize the rite of matrimony.” Tenn. Code 36-3-301(a)(1)–(2). Since 2019, the law has explicitly clarified that “[p]ersons receiving online ordinations may not solemnize the rite.”Asserting that those restrictions violate the federal and Tennessee constitutions, ULC and its members sued several Tennessee officials, seeking an injunction and declaratory judgment. The officials claimed sovereign immunity and that the plaintiffs lacked standing to sue. The district court entered a preliminary injunction against several defendants. The Sixth Circuit reversed in part. No plaintiff has standing to seek relief against Governor Lee, Attorney General Slatery, District Attorney General Helper, or County Clerks Crowell, Anderson, and Knowles. The plaintiffs have standing to sue District Attorneys General Dunaway, Pinkston, and Jones, and County Clerk Nabors. The court noted that county clerks have no discretion to inspect officiants’ credentials or to deny licenses on that basis; state law deems issuance of the licenses a ministerial duty. View "Universal Life Church Monastery Storehouse v. Nabors" on Justia Law