Justia Civil Rights Opinion Summaries

Anthony Buntyn, an employee of a private company that transported detainees for law enforcement agencies, was charged with willfully violating the detainees' rights under the Fourteenth Amendment's due process clause due to inhumane conditions of confinement. The conditions developed while Buntyn transported the detainees in a van to various detention facilities. The government alleged that Buntyn had violated the Fourteenth Amendment's due process clause through deliberate indifference to intolerable conditions of confinement and that this indifference had resulted in bodily injury to three detainees. The jury found Buntyn guilty of depriving the detainees of humane conditions, acting willfully and with deliberate indifference, and causing bodily injury to one detainee.Buntyn appealed his conviction to the United States Court of Appeals for the Tenth Circuit, arguing that the evidence was insufficient for a finding of guilt, that the district court erred in preventing his attorney from using the term malice in closing argument, and that the court coerced the jury to reach a verdict. The Tenth Circuit rejected Buntyn's arguments and affirmed his conviction. The court found that the evidence was sufficient to support the jury's findings of inhumane conditions, deliberate indifference, and willfulness. The court also found that the district court did not err in prohibiting the use of the term malice in closing argument, and that Buntyn had waived his challenge to the district court's instruction for the jury to continue deliberating. View "United States v. Buntyn" on Justia Law

The plaintiff, Gary Avant, was a truck driver for Muskogee County. County officials believed that Avant was complaining to other citizens about the county’s road plan and the assignment of a county worker. Avant was subsequently fired by the county commissioner. Avant sued the commissioner under 42 U.S.C. § 1983, claiming retaliation in violation of the First Amendment. However, during the litigation, Avant denied making the statements that led to his firing. The commissioner moved for summary judgment, arguing that the perceived speech hadn’t involved a matter of public concern. The district court denied this part of the motion, and the case was remanded for the district court to develop the record.After remand, the district court again denied summary judgment, leading the commissioner to appeal again. On appeal, the commissioner argued that Avant hadn’t pleaded a claim for perceived speech and that qualified immunity applies given the lack of precedent on how to assess a public concern for perceived speech.The United States Court of Appeals for the Tenth Circuit found that it lacked jurisdiction to consider the adequacy of the pleadings. However, it did have jurisdiction over the commissioner’s argument for reversal based on the absence of a clearly established violation. The court concluded that Avant had not shown that the perceived speech involved a clearly established public concern. Therefore, the commissioner was entitled to qualified immunity, and the court reversed the denial of qualified immunity and remanded the case for the district court to grant summary judgment to the commissioner in his personal capacity on the First Amendment claim for retaliation based on perceived speech. View "Avant v. Doke" on Justia Law

The case involves Alonzo Cortez Johnson, a state prisoner who petitioned for federal habeas relief under 28 U.S.C. § 2254. Johnson, a Black man, claimed that his constitutional rights were violated because the state court failed to follow the appropriate procedural steps under Batson v. Kentucky, which prohibits racial discrimination in jury selection. Johnson alleged that the prosecutor had exercised peremptory strikes based on race. The Tenth Circuit Court of Appeals agreed that the state court had mishandled the Batson procedural framework and remanded the case to the district court to hold a Batson reconstruction hearing, unless doing so would be impossible or unsatisfactory.On remand, the district court granted Johnson conditional habeas relief, deciding that holding a Batson reconstruction hearing would be “both impossible and unsatisfactory.” The court reasoned that it could not sufficiently reconstruct all relevant circumstances to meaningfully apply Batson’s third step, which involves determining whether the prosecutor’s stated reasons for the strikes were actually a pretext for discrimination.The Tenth Circuit Court of Appeals disagreed with the district court's decision. The court found that the district court had enough evidence to hold a Batson reconstruction hearing at step two, which involves the prosecution providing a race-neutral reason for the objected-to strike(s). The court concluded that the district court had applied the “impossible or unsatisfactory” standard too harshly and remanded the case back to the district court to hold a Batson reconstruction hearing. View "Johnson v. Rankins" on Justia Law

The case involves a lawsuit filed by the parents of Shamikle Jackson against four police officers for using unconstitutionally excessive force. Jackson had called 911, claiming that two people were dead inside an apartment and that he was holding others hostage. When the police arrived, they encountered Jackson's sister who informed them that Jackson was alone, unarmed, and might have mental health problems. However, as the officers proceeded to search the apartment, Jackson emerged from a bedroom with a machete and was shot and killed by the officers.The United States District Court for the District of Colorado denied the officers' motion for summary judgment based on qualified immunity. The court concluded that a reasonable jury could find that the officers recklessly created the need to use deadly force, thereby unreasonably violating Jackson's constitutional rights under clearly established law.The United States Court of Appeals for the Tenth Circuit reversed the lower court's decision. The appellate court found that the officers had a split second to respond to a deadly threat posed by Jackson. Under these circumstances, it was not clearly established that the officers recklessly created a situation where the use of deadly force was necessary. Therefore, the officers were entitled to qualified immunity. The court also rejected the claim that the other officers failed to intervene to prevent the violation of Jackson's rights, as there was no underlying constitutional violation. View "Flores v. Henderson" on Justia Law

The case revolves around Mr. Lyndell Daniels, who was detained by law enforcement officers who linked him to a stolen Glock firearm based on his name. Daniels was charged with being a felon in possession of a firearm. Daniels moved to suppress his name as the fruit of an unlawful investigative detention, arguing that the officers had no reasonable suspicion to detain him. The district court agreed with Daniels and granted his motion. The government appealed this decision, arguing that the district court erred because there was reasonable suspicion to detain Daniels.The case originated from a near-anonymous call to the Aurora Police Department, expressing concern about three Black men, wearing dark hoodies and jeans, intermittently taking guns in and out of their pockets and getting in and out of a dark SUV. The caller believed they were “getting ready to do something,” but reported no illegality. The police arrived at the scene and detained Daniels, who was standing near the SUV. The officers did not observe any illegal activity or firearms when they arrived.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the totality of the circumstances known to the officer when he detained Daniels did not amount to reasonable suspicion. The court noted that the 911 call, the presence and actions of the SUV, the time of the encounter, and the location of the encounter were not sufficient to establish reasonable suspicion. The court concluded that Daniels' detention was unreasonable under the Fourth Amendment, and the district court's grant of Daniels' motion to suppress was proper. View "United States v. Daniels" on Justia Law

The case involves Dr. Adam Lowther and his wife, Jessica Lowther, who sued various state officials on behalf of themselves and their children, alleging constitutional claims under 42 U.S.C. § 1983 and state law claims under the New Mexico Tort Claims Act. The claims arose from the warrantless entry into their home, the arrest of Dr. Lowther, and the removal of their children by officials from New Mexico’s Children, Youth, and Family Department (CYFD) and the Bernalillo County Sheriff’s Department (BCSD). The actions of the officials were based on an anonymous report alleging that Dr. Lowther was sexually abusing his four-year-old daughter.The United States District Court for the District of New Mexico granted summary judgment in favor of the defendants, concluding that they were entitled to qualified immunity on the § 1983 claims and that the state law claims failed for similar reasons. The Lowthers appealed the decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the officials had reasonable suspicion that the children had been abused and were in imminent danger, which justified the warrantless entry into the Lowthers' home and the removal of the children. The court also held that the officials had probable cause to arrest Dr. Lowther. Therefore, the officials were entitled to qualified immunity, and the Lowthers' claims were dismissed. View "Lowther v. Children Youth and Family Department" on Justia Law

A prisoner, Khalfan Khamis Mohamed, alleged that officials from the Federal Bureau of Prisons (BOP) beat him while others watched. He brought claims under the Eighth Amendment for excessive force and failure to intervene, arguing that the BOP officials' actions gave him a cause of action under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The BOP officials moved to dismiss the claims, arguing that Bivens did not extend to Mohamed's claims. The district court denied their motion.The BOP officials appealed the district court's decision, seeking interlocutory review. However, the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction. The court found that the BOP officials had not shown that the district court's order extending Bivens to Mohamed's Eighth Amendment excessive force and failure to intervene claims qualified for interlocutory review under the collateral order doctrine. The court noted that the BOP officials bore the burden of establishing the court's appellate jurisdiction and had failed to convince the court to create an exception to the final judgment rule for all district court orders extending a Bivens remedy. The court also noted that the BOP officials had not shown that Bivens extension orders were effectively unreviewable after final judgment and therefore had not satisfied the third Cohen factor. View "Mohamed v. Jones" on Justia Law

The case revolves around an incident where Colorado Springs Police Officers Robert McCafferty and Christopher Pryor responded to a 911-call placed by Sasha Cronick reporting a drug overdose. During the incident, Officer Pryor questioned Cronick, which escalated into an argument, leading to her arrest for failure to desist and disperse in violation of Colorado Springs Code § 9.2.103. Cronick filed a claim under 42 U.S.C. § 1983, alleging the officers violated her constitutional rights. The officers asserted qualified immunity, but the district court denied their claim.The district court found several disputes of fact, including whether Officer Pryor issued an order for Cronick to leave the scene, whether Cronick was obstructing the scene, and whether Officer Pryor grabbed Cronick's arm to escort her away or after she had already turned to walk away. The court concluded that these disputes prevented it from finding that the officers had probable cause to arrest Cronick.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court concluded that a reasonable officer under these circumstances would not have arguable probable cause to arrest Cronick for failure to desist or disperse. The court also found that the officers did not have probable cause to conduct a search incident to arrest. The officers failed to articulate specific facts that led them to believe Cronick posed a threat and offered nothing beyond conclusory references to safety. Therefore, the officers were not entitled to qualified immunity because they violated Cronick's clearly established constitutional rights. View "Cronick v. Pryor" on Justia Law

A student, John Doe, through his mother, Jane Doe, filed a lawsuit against Rocky Mountain Classical Academy (RMCA), Nicole Blanc, and Cullen McDowell, alleging that the school's dress code, which prohibited boys from wearing earrings, violated his rights under the Fourteenth Amendment's Equal Protection Clause and Title IX. The plaintiff also claimed that the school retaliated against him for complaining about sex discrimination.The United States District Court for the District of Colorado dismissed the plaintiff's claims, applying the "comparable burdens" test from the Seventh Circuit's decision in Hayden ex rel. A.H. v. Greensburg Cmty. Sch. Corp. The district court found that the dress code imposed comparable burdens on both boys and girls, and therefore did not constitute sex discrimination.On appeal, the United States Court of Appeals for the Tenth Circuit disagreed with the district court's application of the "comparable burdens" test. The appellate court held that the district court should have applied the intermediate scrutiny standard, which requires a sex-based classification to serve important governmental objectives and be substantially related to achieving those objectives. The court found that the plaintiff had stated a claim upon which relief could be granted under both the Equal Protection Clause and Title IX, as the school had not provided an "exceedingly persuasive justification" for its sex-based classification. Therefore, the court reversed the district court's dismissal of the plaintiff's sex discrimination claims.However, the appellate court agreed with the district court's dismissal of the plaintiff's Title IX retaliation claim. The court found that the plaintiff had not stated a plausible claim for retaliation, as the complaint only permitted the inference that the school took disciplinary actions because of the plaintiff's dress code violations. View "Doe v. Rocky Mountain Classical Academy" on Justia Law

The case involves Brandon Pryor, an advocate for quality educational opportunities in Far Northeast Denver, who was stripped of his volunteer position and restricted from accessing Denver School District No. 1 facilities after he criticized the district and its officials. The district claimed that Pryor's conduct was abusive, bullying, threatening, and intimidating. Pryor sued the district, Superintendent Alex Marrero, and Deputy Superintendent Anthony Smith, alleging First Amendment retaliation.The United States District Court for the District of Colorado granted a preliminary injunction in part, enjoining the defendants from enforcing the restrictions and from taking any other retaliatory action against Pryor, his family, or the school he co-founded, the Robert W. Smith STEAM Academy. The defendants appealed the preliminary injunction.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that Pryor was substantially likely to succeed on the merits of his First Amendment retaliation claim. The court also found that Pryor would suffer irreparable injury if the injunction was denied, that the harm to Pryor without the injunction outweighed the harm to the defendants with the injunction, and that the injunction was not adverse to the public interest. The court concluded that the district court did not abuse its discretion in granting the preliminary injunction. View "Pryor v. School District No. 1" on Justia Law