Justia Civil Rights Opinion Summaries

A man was convicted by a Michigan state jury for delivering oxycodone to a friend, resulting in her death from a drug overdose. The evidence showed that the man and the deceased had a longstanding relationship, and after her release from jail, he purchased 40 Percocet pills—containing oxycodone and acetaminophen—and spent time with her at a hotel where she died. Medical experts found oxycodone in her blood and acetaminophen in her urine, both components of Percocet, and testified that oxycodone was a substantial factor in causing her death.After his conviction, the defendant sought a new trial in the Michigan courts, arguing that his trial counsel was ineffective for two reasons: failing to investigate an “acetaminophen-based” defense (that the absence of acetaminophen in the blood meant the deceased had not consumed Percocet), and failing to call an expert witness to challenge the prosecution’s case on causation. The trial court held a hearing and ultimately rejected these claims. The Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied further review.The United States District Court for the Eastern District of Michigan then denied the defendant’s petition for habeas corpus, and the case was appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit held that, under the highly deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA), the state courts did not unreasonably apply clearly established Supreme Court law or make unreasonable determinations of fact in rejecting the ineffective assistance claims. The court further held that counsel’s strategic decisions were not objectively unreasonable and that the alleged failures did not prejudice the outcome of the trial. The Sixth Circuit affirmed the denial of habeas relief. View "DeBruyn v. Douglas" on Justia Law

A company sought to erect a digital billboard in a small Ohio municipality but was prevented from doing so by the local billboard ordinance, which included restrictions on size, location, and type of billboards permitted. The ordinance specifically banned “variable message” (digital) signs and implemented a “cap and replace” rule, allowing new billboards only if older ones were removed. The ordinance also contained several exemptions, including one for “public service” signs, which were allowed to display information like time or weather if not used for advertising.Previously, the United States District Court for the Southern District of Ohio granted summary judgment to the municipality, upholding the ordinance against the company’s First Amendment challenges. On appeal, the United States Court of Appeals for the Sixth Circuit determined that the exemption for public service signs was an unconstitutional, content-based restriction under the First Amendment, but remanded the case for the district court to determine whether the invalid exemption was severable from the rest of the ordinance.On remand, the district court found that the unconstitutional provision could be severed and that the remainder of the ordinance survived intermediate scrutiny, granting judgment again in favor of the municipality. The company appealed.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the public-service exemption was severable under Ohio law, applying the three-part test from Geiger v. Geiger. The court further held that the remaining provisions of the ordinance were content-neutral and survived intermediate scrutiny because they were narrowly tailored to significant governmental interests such as traffic safety and aesthetics. The court also held that the company was not entitled to damages or attorney fees, as it was not a prevailing party under 42 U.S.C. § 1988(b). View "Norton Outdoor Advertising, Inc. v. Village of St. Bernard" on Justia Law

A black-owned construction company was not invited to bid as general contractor on a major Boston public housing redevelopment project after participating in pre-construction work. Years earlier, the developer had called the company’s president to discuss possible involvement, but the parties disputed what promises, if any, were made during that conversation. The construction company performed pre-construction work and was later selected as general contractor for the first phase (Camden), but after performance and communication issues arose during that project, the developer chose a different, white-owned company for the second phase (Lenox). The construction company did not protest at the time but later sued, alleging breach of contract, quasi-contract, violation of Massachusetts consumer protection law, and racial discrimination under 42 U.S.C. § 1981.The matter was first brought in Massachusetts state court, then removed to the United States District Court for the District of Massachusetts based on federal question jurisdiction. After discovery, the developer moved for summary judgment. The District Court granted summary judgment for the developer, finding no enforceable contract or promise had been made regarding the Lenox phase, that the quasi-contract and Chapter 93A claims failed as derivative, and that there was insufficient evidence of racial discrimination.The United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The First Circuit held that the summary judgment record did not contain evidence from which a reasonable jury could find an enforceable implied-in-fact contract or a promise sufficient for promissory estoppel. It further held that the plaintiff failed to create a triable issue of fact regarding pretext or discriminatory intent under § 1981, given the legitimate business reasons cited for the company’s exclusion. Thus, summary judgment on all claims was proper. View "John B. Cruz Construction Co. v. Beacon Communities Corp." on Justia Law

While incarcerated in a Colorado state prison, the plaintiff, a practicing member of the Sac & Fox faith, brought suit seeking monetary and injunctive relief. He alleged that certain prison regulations and practices violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act. His claims focused on being denied possession of sacred items, spiritual cleansing of his cell, use of donated firewood for religious ceremonies, and access to faith grounds during and after the COVID-19 pandemic. The plaintiff named numerous officials and employees, including the Governor of Colorado, in both their official and individual capacities.The United States District Court for the District of Colorado denied the Governor’s motion to dismiss the official-capacity claims for injunctive relief, rejecting his assertion of Eleventh Amendment immunity. The Governor argued he lacked the required connection to the challenged regulations to qualify for the Ex Parte Young exception. During the appeal, the plaintiff was transferred to another facility within the Colorado Department of Corrections. The Governor raised the issue of mootness due to this transfer.The United States Court of Appeals for the Tenth Circuit considered whether the claims for injunctive relief against the Governor were moot because of the transfer and whether Eleventh Amendment immunity applied. The court held that the claims were neither constitutionally nor prudentially moot, as the plaintiff’s affidavit showed ongoing exposure to substantially similar conditions at the new facility. The court further held that, under Colorado law and the facts alleged, the Governor had sufficient authority and demonstrated involvement in the challenged practices to satisfy the Ex Parte Young exception. The court therefore affirmed the district court’s denial of Eleventh Amendment immunity and remanded for further proceedings. View "Eaves v. Polis" on Justia Law

An inmate at a correctional institution in Wisconsin, who practices Islam and prays five times daily at precise times, relied on a prayer schedule printed and distributed by prison chaplains. He discovered the schedule was inaccurate due to the chaplain entering the wrong location into an online tool, resulting in prayer times being off by several minutes. Although the chaplains corrected the schedule for meal deliveries during Ramadan, they declined to distribute revised prayer schedules to inmates, citing a policy prohibiting the use of government funds to purchase religious items for inmates. The inmate eventually received an accurate schedule by donation from a visiting imam, but complained he did not receive one from the prison.After exhausting internal grievance procedures, the inmate sued the corrections staff in the United States District Court for the Western District of Wisconsin, alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment, seeking relief under 42 U.S.C. § 1983. The district court granted summary judgment to the defendants on all claims. It found the initial error in the prayer schedule was a mistake, not an intentional constitutional violation, and determined neither RLUIPA nor the Free Exercise Clause required prison officials to purchase religious materials for prisoners using government funds. The court also concluded the defendants were entitled to qualified immunity because there was no clearly established law requiring the provision of religious materials as a courtesy.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The Seventh Circuit held that a de minimis cost for an inmate to purchase his own prayer schedule does not constitute a “substantial burden” under RLUIPA. Additionally, RLUIPA does not require states to purchase religious items for inmates. The court also affirmed that the neutral prison policy did not violate the Free Exercise Clause and that the negligence claim regarding the inaccurate schedule was waived. The judgment was affirmed. View "Childs v Webster" on Justia Law

A federal law enforcement officer was charged following two separate incidents that took place at a U.S. border crossing. In the first, the officer confronted an individual, Espinosa, who had been involved in a verbal disagreement with another officer. The officer intervened, physically redirected Espinosa, and both collided with a door, resulting in Espinosa experiencing physical injuries such as dizziness and confusion. Testimony from a supervisor and an expert witness indicated the force used was excessive and not justified by Espinosa’s behavior at the time. In the second incident, the officer engaged with Estrada, a returning traveler, following a verbal exchange. The officer brought Estrada into a secure area, used force to restrain him, and pressed his face into chairs, causing a nose injury. Witnesses and expert testimony again described the officer’s actions as excessive and unnecessary, and video evidence did not show Estrada acting aggressively or resisting.After these events, the officer filed a report about the Estrada incident, which contained statements that were contradicted by video evidence and expert analysis. The officer also made verbal statements to a supervisor that were later found to be false.The United States District Court for the Western District of Texas conducted a bench trial, found the officer guilty of two counts of deprivation of rights under color of law (18 U.S.C. § 242) and one count of falsifying a record in a federal investigation (18 U.S.C. § 1519), and imposed concurrent sentences below the guidelines. The officer appealed, challenging the sufficiency of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a highly deferential standard to the verdict. The court held that a rational factfinder could find all elements of the crimes proven beyond a reasonable doubt and affirmed the convictions. View "United States v. Delgado" on Justia Law

The plaintiff was mistakenly arrested in West Virginia due to an arrest warrant that had been issued for another person with a similar name. After being held in custody, the prosecutor determined at an initial hearing that the plaintiff was not the intended suspect and dismissed the charges. Subsequently, the plaintiff filed a lawsuit under 42 U.S.C. § 1983 against the city and the officers involved, alleging malicious prosecution and a violation of her Fourth Amendment rights due to an arrest without probable cause.Prior to review by the United States Court of Appeals for the Fourth Circuit, the United States District Court for the Northern District of West Virginia dismissed the claim. The district court applied West Virginia’s one-year statute of limitations for certain personal actions under West Virginia Code § 55-2-12(c), concluding that the claim accrued when the charges were dismissed and that the plaintiff’s suit, filed 23 months later, was time-barred. The district court also found that the complaint did not plausibly allege a basis for municipal liability against the city.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The Fourth Circuit held that the applicable statute of limitations for § 1983 claims in West Virginia is the two-year period for personal injuries under West Virginia Code § 55-2-12(b), not the one-year period applied by the district court. Because the plaintiff filed suit within two years after her claim accrued, her claim against the officers was timely. However, the court affirmed the dismissal of the claim against the city because the complaint did not allege a municipal policy or custom, as required by Monell v. Department of Social Services. The Fourth Circuit therefore affirmed in part, reversed in part, and remanded the case for further proceedings. View "Cooper v. City of Wheeling" on Justia Law

A sheriff’s deputy in Virginia arrested an individual for skateboarding on a public road and suspected public intoxication. During the arrest, the deputy punched the individual in the face multiple times, causing significant injuries, including facial fractures and a brain hemorrhage. The individual sued the deputy for excessive force under the Fourth Amendment and for common law battery. The deputy argued that the force he used was necessary because the individual resisted arrest and that, regardless, he was entitled to qualified immunity because he did not violate clearly established law.The United States District Court for the Western District of Virginia reviewed the case on the deputy’s motion for summary judgment. The district court examined the record, including body camera footage, and found that several key facts were disputed, such as whether the individual had surrendered and ceased resisting before the deputy continued to use force. The court held that if a jury found in favor of the individual on these disputed facts, it would be clearly established that the level of force used was excessive. Therefore, the district court denied the deputy’s motion for summary judgment, including his claim of qualified immunity.On appeal, the United States Court of Appeals for the Fourth Circuit addressed its jurisdiction to review the denial of qualified immunity at this interlocutory stage. The court explained that it could not review the district court’s factual determinations but could consider whether, taking the facts most favorably to the plaintiff, the deputy was entitled to qualified immunity as a matter of law. The Fourth Circuit held that, under the facts as viewed by the district court, prior precedent clearly established that the deputy’s actions would constitute excessive force. As a result, the appellate court affirmed the district court’s denial of qualified immunity. View "Barricks v. Wright" on Justia Law

The plaintiff, a former Federal Air Marshal, worked for over seven years within the Transportation Security Administration (TSA). She began her employment after disclosing several vision-related medical conditions, and over time developed additional health problems, including cardiac and nerve issues. As her conditions worsened, TSA placed her on temporary “light duty” and reassigned her to a ground-based Regional Coordinator role with limited flight requirements. Eventually, TSA determined she could not meet the essential medical standards of her position and advised her to seek reassignment. The plaintiff requested reassignment due to her inability to perform the essential duties of her current role and was ultimately transferred to a position at the Federal Law Enforcement Training Centers (FLETC), a separate division within the Department of Homeland Security.Following her reassignment, the plaintiff experienced difficulties in her new role and unsuccessfully sought reconsideration of her reassignment. She subsequently filed a complaint in the United States District Court for the Eastern District of Virginia, alleging that TSA failed to accommodate her disability under the Rehabilitation Act. The district court dismissed her claim, finding that she had not plausibly alleged that she was a “qualified individual” capable of performing the essential functions of her desired position. The court emphasized her own admission that she could not perform those duties and concluded that TSA had provided reasonable accommodations.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit affirmed the district court’s decision, holding that the plaintiff was not a “qualified individual” for her desired position because she conceded her inability to perform its essential functions, even with accommodations. The court further held that TSA met its obligation by providing reasonable accommodations, including reassignment, and was not required to offer a permanent “light duty” position. The judgment of the district court was affirmed. View "Redding v. Noem" on Justia Law

A fifth-grade student, J.S., attended a local Oklahoma elementary school where, in August 2022, the administration implemented a policy segregating fifth-grade students into all-boys and all-girls homerooms. J.S. was placed in the boys’ class, taught by Mr. McClain. During the initial weeks, Mr. McClain allegedly targeted J.S. with severe discipline, derogatory language, and inappropriate sexual comments. After J.S. and his parents complained about this treatment and the sex-segregated policy, J.S. was removed from his classroom and placed on a modified schedule, then ultimately withdrawn from the school by his parents, who cited ongoing retaliation and lack of safety. The parents also filed a Title IX complaint, but alleged that the school’s investigation was inadequate and retaliatory actions followed, including public shaming and further mistreatment of J.S.The United States District Court for the Eastern District of Oklahoma granted in part and denied in part various defendants’ motions to dismiss, finding some claims barred by qualified immunity but allowing others to proceed. The court found that school district officials and Mr. McClain could not claim qualified immunity on certain equal protection and retaliation claims, but dismissed some due process and conspiracy claims.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial of qualified immunity. The Tenth Circuit held that school officials were entitled to qualified immunity on the procedural due process claim but not on the equal protection claim related to sex-based class segregation. Principal Anderson and Mr. Blair were properly denied qualified immunity on retaliation claims, while others were dismissed. Mr. McClain was granted qualified immunity on the substantive due process claim but not on the equal protection claim for alleged sexual harassment. The court affirmed in part, reversed in part, dismissed in part for lack of jurisdiction, and remanded for further proceedings. View "Stepp v. Lockhart" on Justia Law