Justia Civil Rights Opinion Summaries

A Hobby Lobby manager called law enforcement because Kristopher Birtcher appeared to be suffering from a mental health crisis at the store. Birtcher, who was unarmed and had committed no crime, tried to flee when sheriff’s deputies arrived. The deputies subdued him by double-cuffing his hands behind his back, securing his ankles, tying his ankles to a cord around his waist, and applying bodyweight pressure to his back while he was lying face down. Birtcher gasped that he couldn’t breathe and called for help. He stopped moving after several minutes, and the deputies kept him in a prone position for another 50 seconds before turning him on his side, then later returned him to a prone position. Birtcher died from asphyxiation and sudden cardiac arrest within 25 minutes of the deputies’ arrival.Birtcher’s minor daughter, A.B., brought state claims in state court after unsuccessfully litigating federal claims. She asserted claims for wrongful death, battery, negligence, and negligent training, and a survival action for violation of the Bane Act. The Superior Court of San Diego County granted summary judgment to the defendants, finding no triable issues of material fact on the excessive force claim and ruling that the restraint was “by the book.” The court also ruled that A.B. failed to identify a legal basis for her negligent training theory against Sheriff Gore.The California Court of Appeal, Fourth Appellate District, Division One, reversed the trial court’s decision. The appellate court concluded that there were triable issues of material fact on the excessive force claim, noting that the deputies’ use of forceful prone restraint with bodyweight compression could be seen as excessive. The court also found that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as A.B. had identified a statutory basis for the claim, and Sheriff Gore failed to demonstrate the absence of triable issues of material fact. The judgment was reversed and remanded for further proceedings. View "A.B. v. County of San Diego" on Justia Law

In 1998, Ruben Gutierrez was charged with capital murder in Texas for his involvement in the killing of Escolastica Harrison. The prosecution argued that Gutierrez used one of two screwdrivers to stab Harrison. The jury convicted him, and he was sentenced to death after the jury found that he either caused Harrison's death, intended to kill her, or anticipated that a human life would be taken. Gutierrez has sought DNA testing of evidence for nearly 15 years, claiming it would prove he was not present at the crime scene. Texas courts denied his requests, stating that even if his DNA was not found, it would not prove his innocence of the underlying crime.Gutierrez filed a federal lawsuit under 42 U.S.C. §1983 against the district attorney, arguing that Texas's DNA testing procedures violated his due process rights. The District Court agreed and granted declaratory relief. However, the Fifth Circuit vacated this judgment, holding that Gutierrez lacked standing because a declaratory judgment would not likely result in the prosecutor allowing DNA testing.The Supreme Court of the United States reviewed the case and held that Gutierrez has standing to bring his §1983 claim. The Court reasoned that a state-created right to postconviction procedures can create rights to other procedures essential to realizing that right. The Court found that a declaratory judgment in Gutierrez's favor would redress his injury by removing the prosecutor's reliance on Article 64 as a reason for denying DNA testing. The judgment of the Fifth Circuit was reversed, and the case was remanded for further proceedings. View "Gutierrez v. Saenz" on Justia Law

In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law prohibiting public funds for abortion. Planned Parenthood and patient Julie Edwards sued, claiming the exclusion violated the Medicaid any-qualified-provider provision, which allows Medicaid beneficiaries to obtain services from any qualified provider. Edwards preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They filed a class action under 42 U.S.C. §1983 to enforce rights under the federal Medicaid statutes.The district court granted summary judgment for the plaintiffs and enjoined the exclusion. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated, and remanded the case in light of Health and Hospital Corporation of Marion Cty. v. Talevski, which addressed whether another spending-power statute created §1983-enforceable rights. On remand, the Fourth Circuit reaffirmed its decision.The Supreme Court of the United States held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court emphasized that spending-power statutes rarely create enforceable rights and that the any-qualified-provider provision lacks the clear rights-creating language necessary to support a §1983 action. The Court reversed the Fourth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Medina v. Planned Parenthood South Atlantic" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

Josiah Galloway sued five current and former Nassau County detectives, alleging they violated his constitutional right to a fair trial by improperly inducing witnesses to identify him as the perpetrator of a 2008 crime, coercing a witness to sign a statement implicating him, and withholding evidence of these deficiencies in violation of Brady v. Maryland. Galloway also sued Nassau County for state-law malicious prosecution. Galloway was exonerated after serving nearly a decade in prison for a crime he did not commit.The United States District Court for the Eastern District of New York denied the detectives' motion for summary judgment, which included a claim of qualified immunity. The court adhered to this decision on reconsideration. The detectives and the county appealed, seeking to reverse the denial of their motion for summary judgment. However, the appellate court's jurisdiction was limited to the defense of qualified immunity and only as a matter of law.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that by 2008, it was clearly established that detectives could not rig witness identifications, coerce a witness to sign a false inculpatory statement, or ensure that the state withheld Brady evidence from the defense. Therefore, the district court did not commit legal error in rejecting the detectives' qualified immunity defenses. The court dismissed Nassau County's appeal and affirmed the district court's decision in all other respects. View "Galloway v. County of Nassau" on Justia Law

Cole Michael Jacob was charged with felony indecent exposure after exposing himself to a minor. Initially pleading not guilty, Jacob later executed a plea agreement to enter an Alford plea in exchange for a recommended 10-year sentence with 6 years suspended and the withdrawal of the State's intent to seek persistent felony offender (PFO) status. However, Jacob requested more time to discuss the agreement and eventually decided not to change his plea. On the day of his trial, Jacob entered an Alford plea under a new agreement, where the State agreed not to seek a sentence exceeding 20 years and to withdraw its PFO notice.The Twentieth Judicial District Court, Lake County, held a sentencing hearing where the State recommended a 20-year sentence and presented a victim impact statement from the victim’s father. Jacob objected to the statement being read, claiming he had not received a copy. The court allowed the statement, and Jacob was sentenced to 15 years at the Montana State Prison with a requirement to complete sex offender treatment before being eligible for parole.Jacob appealed to the Supreme Court of the State of Montana, arguing that his due process rights were violated by the reading of the victim impact statement and that he should have been sentenced under the initial plea agreement, claiming he was not mentally competent to reject it. The Supreme Court found that Jacob’s due process rights were not violated as he did not allege any false information in the victim impact statement. Additionally, the court determined that Jacob did not preserve his argument regarding the plea agreement for appeal, as he did not raise the issue of his mental competence to reject the agreement before the District Court. The Supreme Court affirmed the District Court’s judgment. View "State v. Jacob" on Justia Law

Santoasha Harris endured five years of sexual harassment at her job with the City of Milwaukee. When she reported the harassment in 2017, the City separated her from the harasser, conducted an investigation, compelled the harasser’s resignation, and restored Harris to her position within a month. Harris sued the City, alleging it knew about the harassment for years, failed to act, and retaliated against her for reporting it. Due to Harris’s bankruptcy filing, her estate was substituted as the plaintiff.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the City. The court concluded that Harris’s Estate had not shown the City unreasonably failed to prevent the harassment or that she suffered a tangible employment action as a consequence of reporting it. The court found no evidence supporting the Title VII and Section 1983 claims against the City.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the evidence did not support the claims of quid pro quo harassment, hostile work environment, or retaliation under Title VII. The court found that Harris did not suffer a tangible employment action and that the City acted promptly and reasonably once the harassment was reported. Additionally, the court found no basis for employer liability under Section 1983, as there was no evidence of intentional discrimination by the City. The court concluded that no reasonable jury could find for the Estate on its claims against the City. View "Bankruptcy Estate of Harris v City of Milwaukee" on Justia Law

Randy Wiertella died in the Lake County Adult Detention Facility on December 10, 2018. Dennis Wiertella, as the Administrator of Randy's estate, filed a lawsuit claiming that Randy's constitutional rights under the Eighth and Fourteenth Amendments were violated by Jail staff Diane Snow, RN, and Christina Watson, LPN. Randy had been booked into the Jail without his essential medications for heart disease, diabetes, high blood pressure, and a psychiatric disorder. Despite multiple requests, he did not receive all necessary medications, leading to his death from hypertensive cardiovascular disease.The United States District Court for the Northern District of Ohio denied Snow and Watson's motion for summary judgment, which sought dismissal based on qualified immunity. The court found that there were genuine disputes of material fact regarding whether Snow and Watson were aware of the substantial risk to Randy's health and whether they failed to respond reasonably.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Snow and Watson were not entitled to qualified immunity. The court found that both nurses were aware of Randy's serious medical conditions and the need for continuous medication. Despite this knowledge, they failed to ensure that Randy received his essential medications in a timely manner. The court concluded that their actions were unreasonable and violated Randy's constitutional rights. The court affirmed the district court's decision and remanded the case for further proceedings on the Estate's § 1983 claim. View "Wiertella v. Lake County" on Justia Law

An inmate at Rayburn Correctional Center in Louisiana, Torriana Clark, filed a lawsuit under 42 U.S.C. § 1983 against prison officials, alleging that Lt. Lance Wallace used excessive force against him, violating his constitutional rights. Clark claimed that after feeling sick and seeking medical help, he was forcibly restrained and assaulted by Wallace, resulting in injuries. The prison officials' reports contradicted Clark's account, stating that Clark was combative and resisted orders, necessitating the use of force to restrain him.The United States District Court for the Eastern District of Louisiana granted partial summary judgment in favor of the defendants, ruling that Clark's § 1983 claim was barred by Heck v. Humphrey, which prevents prisoners from seeking damages under § 1983 if a judgment in their favor would imply the invalidity of their conviction or sentence. The district court also denied Clark's motion to amend his petition and remanded his state-law claims to state court.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Clark's § 1983 claim was indeed barred by Heck because success on his claim would require proof of facts inconsistent with his disciplinary convictions, which resulted in the loss of good-time credits. The court also agreed with the district court's denial of Clark's motion to amend his petition, concluding that any amendment would be futile as it would not change the Heck analysis. The appellate court's decision upheld the partial summary judgment and the denial of the motion to amend. View "Clark v. Dept of Public Safety" on Justia Law

In the early hours of August 22, 1972, military officers at the Almirante Zar Naval Base in Trelew, Argentina, removed nineteen unarmed political prisoners from their cells and shot them, resulting in what became known as the Trelew Massacre. The plaintiffs in this case are the surviving family members of four of those prisoners. They filed a lawsuit against Roberto Guillermo Bravo, one of the officers involved in the massacre, seeking compensatory and punitive damages under the Torture Victim Protection Act (TVPA) for the extrajudicial killing and torture of their relatives.The United States District Court for the Southern District of Florida heard the case. A jury found Mr. Bravo liable for the deaths and awarded the plaintiffs over $24 million. Mr. Bravo appealed, arguing that the district court erred by equitably tolling the TVPA statute of limitations on the plaintiffs’ claims until October 15, 2012. The district court had concluded that extraordinary circumstances, including the plaintiffs’ fear of reprisal, inability to locate Mr. Bravo, and inability to discover crucial evidence, justified tolling the statute of limitations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court vacated the district court’s judgment, finding that the district court failed to make sufficient findings of fact to support its ruling on equitable tolling. The appellate court remanded the case for additional findings on whether the plaintiffs were entitled to equitable tolling beyond March 2008. The court also instructed the district court to reconsider whether the plaintiffs acted with due diligence in filing their claims, particularly in the case of Eduardo Cappello, who was found not to have acted diligently by the district court. The appellate court upheld the district court’s exclusion of evidence regarding the victims' alleged ties to communism and Cuba, finding no abuse of discretion. View "Camps v. Bravo" on Justia Law