Justia Civil Rights Opinion Summaries

Larry Trent Roberts spent 13 years in prison for a murder that he did not commit. After being exonerated, he sued several state actors involved in obtaining his wrongful conviction, including Assistant District Attorney John C. Baer. The United States Court of Appeals for the Third Circuit held that Baer is not entitled to absolute immunity from liability under 42 U.S.C. § 1983 because his actions of seeking a new witness to establish a motive for the murder served an investigatory function, not a prosecutorial one. The court noted that prosecutors are not entitled to absolute immunity when they perform investigative functions normally performed by a detective or police officer. Baer argued that he was immune from liability as his conduct occurred post-charge and was designed to produce inculpatory evidence for trial. However, the court clarified that the timing of a prosecutor's actions as pre- or post-indictment and the presence or absence of a connection to a judicial proceeding are only "relevant considerations" in determining whether a prosecutor’s action served a prosecutorial function. They are not enough to establish that a prosecutor's post-charge effort to fabricate evidence for trial served a quasi-judicial function. The court affirmed the District Court's decision denying Baer's motion to dismiss. View "Roberts v. Lau" on Justia Law

Shiheem Amos appealed the denial of his motion to suppress a firearm, which was found after he was stopped by police officers who suspected him of being involved in a disturbance reported at a nearby location. Amos argued that he was seized without reasonable suspicion, and therefore the firearm should not have been admissible in court. The United States Court of Appeals for the Third Circuit held that Amos was not seized until after he attempted to flee from the police officers, and at that point, the officers had reasonable suspicion to seize him based on his attempt to flee. Thus, the firearm was admissible, and the motion to suppress was correctly denied.Amos also challenged his 62-month sentence, which included an enhancement for a previous state court conviction that was classified as a crime of violence under the United States Sentencing Guidelines. The court records did not specify which subsection of the Pennsylvania aggravated assault statute Amos had been convicted under, but the government argued that all possible subsections qualified as a crime of violence. However, the Third Circuit held that one of the subsections, which can be violated by a failure to act, does not meet the definition of a crime of violence because it does not require the use of violent force. Therefore, the court vacated Amos's sentence and remanded for resentencing without the crime of violence enhancement. View "USA v. Amos" on Justia Law

Sherelle Thomas, on behalf of the estate of Terelle Thomas, sued the City of Harrisburg, PrimeCare Medical, Inc., and several individual law enforcement officers (the Officers) alleging that they failed to provide medical care and to intervene in the prevention of a violation of Thomas's right to medical care. The Officers moved to dismiss the case on grounds of qualified immunity, but the United States District Court for the Middle District of Pennsylvania denied the motion. The Officers then appealed the decision.The United States Court of Appeals for the Third Circuit, reviewing the case de novo, affirmed the District Court's denial of qualified immunity regarding the failure to render medical care. The court found that the Officers, based on their observations and knowledge, should have recognized that Thomas had ingested a significant amount of cocaine, presenting a serious medical need. The Officers' decision not to take Thomas to the hospital amounted to deliberate indifference to that need, constituting a violation of Thomas' constitutional right to medical care.However, the Court of Appeals reversed the District Court's recognition of a claim of failure to intervene. The court explained that neither the Supreme Court nor the Third Circuit have recognized a right to intervene in the context of rendering medical care. As such, the Officers were entitled to qualified immunity on this claim.The case was remanded to the District Court with instructions to dismiss the claim regarding the Officers' failure to intervene. View "Thomas v. City of Harrisburg" on Justia Law

The United States Court of Appeals for the Third Circuit reviewed a case involving the estate of Terelle Thomas who died after ingesting a large amount of cocaine while in police custody. The plaintiffs, acting on behalf of the estate, brought a suit against the City of Harrisburg, PrimeCare Medical, and several individual law enforcement officers, alleging that they failed to render medical care and intervene to prevent a violation of the right to medical care. The officers moved to dismiss the case on the grounds of qualified immunity, but the District Court denied the motion.On appeal, the Third Circuit affirmed in part and reversed in part. The court held that the officers were not entitled to qualified immunity for the failure to render medical care claim as the plaintiffs successfully alleged a violation of the constitutional right to medical care. The court found that the officers had a clear indication that Thomas had ingested a significant amount of drugs and thus had a serious medical need, and their decision to book Thomas instead of taking him to a hospital demonstrated deliberate indifference to that need.However, the court reversed on the failure to intervene claim. The court noted that neither the Third Circuit nor the Supreme Court had recognized a right to intervene in the context of rendering medical care. Therefore, the officers were entitled to qualified immunity on the failure to intervene claim. The case was remanded to the District Court with instructions to dismiss the failure to intervene claim. View "Thomas v. City of Harrisburg" on Justia Law

In 2011, Lutter began working for Essex County, in a bargaining unit represented by JNESO. Under Supreme Court precedent (Abood), a public-sector union could charge fees from non-union members whom the union represented. New Jersey law permitted public-sector unions to deduct an "agency fee." Lutter joined JNESO and authorized payroll deductions of her union dues.In 2018, New Jersey enacted the Workplace Democracy Enhancement Act (WDEA): a union member could revoke authorization for payroll deductions only during the 10 days following the anniversary of his employment start date. Previously, union members could give notice of revocation at any time. A month later, the Supreme Court (Janus) held that the First Amendment prohibits public-sector unions from collecting agency fees from nonmembers without their clear and affirmative consent. Under WDEA Janus would have to wait nearly a year to revoke her payroll deduction authorization. In July 2018, she nonetheless requested that deductions of her union dues cease and resigned from JNESO. Essex County deducted Lutter's union dues for 10 months.Lutter filed suit, 42 U.S.C. 1983. JNESO sent her a check in the amount of the contested union dues plus interest. She did not cash or deposit that check. The district court dismissed the case. The Third Circuit affirmed in part. The check did not moot her damages claims against JNESO but Lutter, as a non-union member no longer subject to payroll deductions, lacks standing for her claims against the other parties and for her additional requests for relief against JNESO. View "Lutter v. Jneso" on Justia Law

Durham, a prisoner with lumbar stenosis, received epidural steroid injections for pain and was prescribed a walking cane. In 2020, Durham was sent to a quarantine unit without his cane. For 10 days, Durham repeatedly, unsuccessfully requested his cane because he was in severe pain. His requests to see a doctor and to use a shower chair were ignored. Durham fell in the shower. Durham filed suit, alleging violations of the Eighth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act (RA).The district court dismissed the complaint, finding that Durham’s claims for money damages against the defendants in their capacity as state officials barred by Eleventh Amendment sovereign immunity; Durham failed to state an Eighth Amendment claim, having failed to plausibly allege that the prison officials were “subjectively aware of a substantial risk of serious harm”; and Durham failed to state ADA and RA claims, having failed to show that he is a qualifying individual with a disability. The Third Circuit vacated. Durham is a “qualified individual” and the provision of showers in prison is an activity that must be made accessible to people with disabilities. Durham sufficiently pleaded that the defendants had knowledge that his federally protected ADA right was substantially likely to be violated. A state program that accepts federal funds waives its Eleventh Amendment immunity to RA claims. Durham adequately alleged deliberate indifference. View "Durham v. Kelley" on Justia Law

Three men joined in a shootout, but only Rogers was convicted of murdering a bystander caught in their crossfire. At his trial, Rogers’s attorney did not object while the trial judge admonished a trial witness (Singleton) about perjury after that witness gave testimony favorable to Rogers. The attorney offered no arguments when Singleton changed his testimony and did not cross-examine Singleton about the change. The Third Circuit reversed the denial of habeas relief. Counsel’s failure to object to the trial judge’s admonishment, conduct he “did not think” was problematic, fell below an objective standard of reasonableness under “Strickland” as did counsel’s later failure to cross-examine Singleton regarding his changed testimony. Counsel characterized Singleton as “a liar, trying to help his buddy out,” whose testimony would not be “determinative of the outcome of this case,” but Singleton was the only witness to ever claim Rogers shot first—the ultimate issue in the case. Had Rogers’s counsel objected to the trial judge’s admonishment of Singleton and cross-examined Singleton about his changed testimony, “a reasonable probability” exists that “the result of the proceeding would have been different.” Without Singleton’s testimony against Rogers, the prosecution’s remaining evidence was negligible. View "Rogers v. Superintendent Greene SCI" on Justia Law

Philadelphia Police obtained a search warrant for the house where Dennis resided, suspecting that it was being used for drug activity. Dennis was not home. Six officers performing surveillance were in plain clothes “to maintain an advantage.” They spotted Dennis driving near his house and decided to stop his car. The ensuing events were captured by a nearby surveillance camera. The plainclothes officers in unmarked police cars surrounded Dennis’s vehicle at an intersection. For 48 seconds, Dennis attempted to free his car, bumping into the police vehicles. When Dennis’s car appeared to have stopped, Officer Nicoletti shot Dennis, who was unarmed, three times through the driver’s window. Dennis died at the scene.In the ensuing lawsuit (42 U.S.C. 1983), the court found open questions of fact concerning excessive force claims against Philadelphia and Nicoletti, regarding whether Dennis posed a threat to the officers or public safety. The court denied Nicoletti qualified immunity, reasoning that his conduct: “sho[oting] at an unarmed driver attempting to escape at slow speed who had hit a car,” and/or “using deadly force against an individual driving a car” when “the driver did not pose a threat to the safety of the officer or others,” violated clearly established law. The Third Circuit affirmed, declining to consider Nicoletti’s factual arguments and rejecting any arguments that could be construed as a legal challenge to the holding that his conduct violated clearly established law. View "Rush v. City of Philadelphia" on Justia Law

Officers swarmed a New Jersey hotel room to execute an arrest warrant for Montalvo-Flores in connection with his suspected involvement in a robbery. They found car keys during a search incident to arrest. Although Montalvo-Flores exclaimed that those were his car keys, he did not have a valid driver’s license. Upon locating the car in the parking lot, officers discovered that its registered owner was the Enterprise. Officers called Enterprise’s regional risk manager to obtain permission to search the car, stating that Montalvo-Flores was operating the vehicle while involved in criminal activity. The manager, noting Montalvo-Flores was not listed on the rental agreement (his girlfriend, Pisciotta, was) gave officers consent to search the vehicle. In that search, officers found 304 grams of cocaine inside the trunk.Montalvo-Flores, charged with possession with intent to distribute cocaine 21 U.S.C. 841(a)(1), moved to suppress, arguing that he, with his girlfriend’s permission, lawfully possessed and controlled the car. The district court denied Montalvo-Flores’s motion, holding that he lacked standing because he failed to establish a reasonable expectation of privacy in the car. The Third Circuit reversed. Montalvo-Flores had dominion and control of the car with his girlfriend’s permission and had a reasonable expectation of privacy in the car. View "United States v. Montalvo-Flores" on Justia Law

In 2022, New Jersey passed a law, N.J. Stat. 2C:58-33(a), that empowers only the state’s Attorney General to sue gun-industry members whose “unlawful … or unreasonable” conduct “contribute[s] to a public nuisance in [New Jersey] through the sale, manufacturing, distribution, importing, or marketing of a gun-related product.” It requires industry members to “establish, implement, and enforce reasonable controls” on these activities. The Attorney General has not attempted to enforce the law. Four months after the law was passed, the Foundation, a trade group of gun makers, retailers, and other industry members, filed suit, claiming that the law is preempted by the federal Protection of Lawful Commerce in Arms Act, 15 U.S.C. 7901–7903, and violates due process, the First and Second Amendments, and the dormant Commerce Clause. The Foundation moved for a preliminary injunction, attaching declarations that gunmakers “will continually be at risk of litigation and potential liability unless [they] cease[] doing business.” They gave no factual detail.The Third Circuit held that the challenges must be dismissed. “Pre-enforcement challenges are unusual,” the plaintiff must show that the stakes are high and close at hand. This suit “falls far short of even the “normal” pre-enforcement challenge.” A brand-new civil tort statute, without more, does not justify a federal court’s intervention. View "National Shooting Sports Foundation v. Attorney General New Jersey" on Justia Law