Justia Civil Rights Opinion Summaries

The case involves Justin Michael Wolfe, who was convicted of hiring Owen Barber to murder Daniel Petrole in 2001. Barber, the key witness, initially testified against Wolfe, implicating him in the murder-for-hire scheme. Wolfe was sentenced to death, but Barber later recanted his testimony, claiming he was coerced by the Commonwealth of Virginia with threats of the death penalty. Wolfe's conviction was vacated by the district court due to Brady violations and other prosecutorial misconduct, and the Commonwealth was ordered to retry Wolfe or release him.The United States District Court for the Eastern District of Virginia granted Wolfe habeas relief, finding that the Commonwealth had withheld exculpatory evidence and engaged in misconduct. The Fourth Circuit Court of Appeals affirmed this decision, but the Commonwealth continued to pursue charges against Wolfe. In a subsequent interview, Commonwealth officials again coerced Barber, leading him to invoke his Fifth Amendment rights, making him unavailable as a witness for Wolfe's retrial. Wolfe ultimately pled guilty to avoid the death penalty, receiving a 41-year sentence.Wolfe filed a new habeas petition in the Eastern District of Virginia, asserting claims of vindictive prosecution and due process violations based on the Commonwealth's intimidation of Barber. The district court dismissed the petition as untimely and found that Wolfe failed to present new, reliable evidence of actual innocence under the Schlup standard. Wolfe appealed to the Fourth Circuit Court of Appeals.The Fourth Circuit held that Barber's new declaration, which exculpated Wolfe and explained his previous invocation of the Fifth Amendment due to Commonwealth threats, constituted new, reliable evidence. The court found that Barber's declaration was credible and that no reasonable juror would have convicted Wolfe if they had heard Barber's recantation. The court vacated the district court's judgment and remanded for adjudication of Wolfe's substantive claims. View "Wolfe v. Dotson" on Justia Law

Ruben Santoyo, proceeding without counsel, filed a lawsuit under 42 U.S.C. § 1983 against the City of Chicago and two police officers, challenging the constitutionality of his arrest. Over three years, Santoyo repeatedly filed frivolous motions, many of which attacked the competence and integrity of the district judge. Despite numerous warnings from the judge that further frivolous filings would result in sanctions, Santoyo continued his behavior.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants and denied Santoyo's motions to vacate the judgment. While Santoyo's appeal of the denial was pending, the defendants moved to recover their costs. Instead of addressing the merits of this motion, Santoyo accused the defendants of bad faith and requested disciplinary action against their counsel. The district judge, having lost patience, granted the defendants' motion for costs, imposed a $1,500 sanction on Santoyo, and referred him to the district's Executive Committee, which barred future filings until the sanction was paid.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santoyo argued that the district judge violated his due process rights by not notifying him of the sanction or giving him an opportunity to respond. The appellate court disagreed, noting that Santoyo had been warned multiple times about the consequences of further frivolous filings. The court held that the district judge provided sufficient notice and opportunity for Santoyo to respond, satisfying due process requirements. The Seventh Circuit affirmed the district court's imposition of sanctions. View "Santoyo v. City of Chicago" on Justia Law

On September 1, 2016, law enforcement officers conducted narcotics raids at a home and shop in Pulaski County, Arkansas. During the raid, officers found contraband in both locations, and an officer shot and injured Lloyd St. Clair, who was holding a shotgun. Lloyd and other occupants of the home and shop filed a lawsuit under § 1983, alleging violations of their Fourth Amendment rights by the officers and the City of Little Rock.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The plaintiffs appealed the decision, arguing that there were genuine disputes of material fact regarding the existence of two separate search warrants and the justification for no-knock entries.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the record included two valid search warrants signed by a state judge, and there was no genuine dispute of material fact regarding their existence. The court also determined that the officers had reasonable suspicion to justify the no-knock entries based on videos of Amy St. Clair shooting firearms, which were seen by Officer Kalmer before the raids.Regarding Lloyd's excessive force claim, the court held that the use of deadly force by Officer Thomas was reasonable, as Lloyd admitted to pointing a gun at Thomas. The court also affirmed the district court's grant of summary judgment on the municipal liability claim, as there was no underlying constitutional violation by the city employees.The Eighth Circuit affirmed the judgment of the district court, upholding the summary judgment in favor of the defendants. View "Davenport v. City of Little Rock" on Justia Law

Detective Genaro Hernandez, a Dallas Police Department detective, was involved in a shooting investigation outside The Green Elephant bar in August 2019. Hernandez, who also worked for the Stainback Organization, allegedly pursued false charges against the bar's owner, Shannon McKinnon, and a security guard, Guadalupe Frias, to benefit his private employer. Despite the Special Investigation Unit finding no criminal offense by the plaintiffs, Hernandez bypassed standard procedures and directly sought prosecution from the Dallas County District Attorney’s Office, leading to the plaintiffs' indictment for tampering with evidence. The charges were later dropped when Hernandez's conflict of interest was revealed during Frias's trial.The plaintiffs filed a lawsuit against Hernandez, alleging federal claims under 42 U.S.C. § 1983 for false arrest and malicious prosecution, and state-law claims for malicious prosecution, false imprisonment, and civil conspiracy. The United States District Court for the Northern District of Texas dismissed the federal malicious-prosecution claim but allowed the federal false-arrest claim and the state-law claims to proceed. Hernandez appealed, arguing he was entitled to governmental immunity under the Texas Tort Claims Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Hernandez's actions, despite being motivated by personal interests, fell within the scope of his employment as a detective. The court held that Texas law provides broad immunity to state actors for actions within their employment scope, regardless of intent. Consequently, the court reversed the district court's decision denying dismissal of the state-law claims and remanded the case for further proceedings on the remaining federal claim. View "Frias v. Hernandez" on Justia Law

John Labriola, a media aide for the Miami-Dade Board of County Commissioners, wrote an inflammatory opinion piece criticizing the Equality Act, using derogatory language towards the LGBT community. Following public backlash and internal complaints, the County suspended him without pay, mandated anti-discrimination training, and eventually terminated him for not completing the training.Labriola sued Miami-Dade County in the United States District Court for the Southern District of Florida, alleging retaliation for exercising his First Amendment rights, compelled speech, and that the County's anti-discrimination policy was unconstitutionally overbroad. The district court granted summary judgment in favor of the County on all counts, applying the Pickering-Connick test to Labriola's free speech and free exercise claims, and ruling that his free-press claim was invalid because he was not a journalist.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Labriola's free speech and free exercise claims failed the Pickering-Connick balancing test, as his speech impeded the County's ability to perform its duties efficiently and disrupted workplace harmony. The court also rejected Labriola's free-press claim, noting that even though the district court erred in stating he couldn't bring the claim as a non-journalist, his claim failed on the merits. Additionally, the court found no evidence to support Labriola's compelled speech claim, as the required training did not compel him to express views he disagreed with. Lastly, the court dismissed Labriola's overbreadth challenge to the County's anti-discrimination policy, as he failed to demonstrate that the policy was substantially overbroad.The Eleventh Circuit affirmed the district court's grant of summary judgment to Miami-Dade County on all counts. View "Labriola v. Miami-Dade County" on Justia Law

Jeffery Johnson, a Black employee at Accenture LLP, reported racial discrimination while working on a client project. Accenture's internal investigation found his complaint was made in good faith but lacked merit. Subsequently, Johnson had difficulty securing new projects and was eventually terminated. He sued Accenture, claiming illegal retaliation for reporting discrimination.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Accenture, dismissing Johnson's case. The court found that Johnson's difficulty in finding projects and his termination occurred after his complaint but concluded that the record did not support Johnson's argument that his complaint caused these issues. The court also determined that Johnson's filings violated local rules by presenting unsupported assertions and irrelevant facts, leading to the admission of many of Accenture's facts as uncontroverted.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Johnson failed to show a causal link between his complaint and the adverse employment actions he experienced. The court noted that Johnson's evidence was insufficient to demonstrate that his complaint was the "but for" cause of his difficulties and termination. The court also found that Johnson's arguments relied on speculation rather than concrete evidence. Consequently, the court upheld the summary judgment in favor of Accenture, concluding that Johnson's retaliation claims under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964 could not proceed. View "Johnson v Accenture LLP" on Justia Law

In 2021, the Federal Reserve Bank of New York implemented a policy requiring all employees to be vaccinated against Covid-19, with exemptions for religious or medical reasons. Lori Gardner-Alfred and Jeanette Diaz, employees of the Federal Reserve, applied for religious exemptions, claiming that the vaccine conflicted with their religious beliefs. The Federal Reserve denied their requests and subsequently terminated their employment for non-compliance with the vaccination policy. Gardner-Alfred and Diaz filed a lawsuit, alleging that the Federal Reserve's actions violated their religious liberties under the Free Exercise Clause of the First Amendment and various federal statutes.The United States District Court for the Southern District of New York granted summary judgment in favor of the Federal Reserve on all federal claims. The court found no genuine dispute of fact regarding the sincerity of Gardner-Alfred's religious objections and concluded that the vaccination policy did not conflict with Diaz's professed religious beliefs. Additionally, the district court imposed discovery sanctions on Gardner-Alfred and Diaz for repeatedly neglecting their discovery obligations, withholding relevant documents, and violating court orders.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's summary judgment on Gardner-Alfred's claims, agreeing that she failed to provide sufficient evidence of sincerely held religious beliefs. However, the court vacated the summary judgment on Diaz's claims, finding that there were disputed issues of material fact regarding the sincerity of her religious beliefs and whether the vaccination policy burdened those beliefs. The court also upheld the district court's imposition of discovery sanctions, finding no abuse of discretion. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gardner-Alfred v. Federal Reserve Bank of New York" on Justia Law

Melissa Myers, an instructional aide at an elementary school in the Sunman-Dearborn Community Schools, took FMLA leave at the end of the 2017-2018 school year due to grief from her husband's death. Upon returning for the 2018-2019 school year, she exceeded her paid leave days within the first two months. The school principal, Kelly Roth, warned her about her attendance, leading Myers to resign and subsequently sue the school district and Roth for violations of the FMLA, ADA, and the Fourteenth Amendment’s Equal Protection Clause.The United States District Court for the Southern District of Indiana granted summary judgment for the defendants. The court found that Myers was neither eligible for FMLA leave nor had a qualifying condition in the weeks before her resignation. Additionally, she did not notify the school district of her intent to take statutory leave. The court also rejected her "anticipatory retaliation" theory due to insufficient evidence. The ADA claim failed because Myers did not experience an adverse employment action, and her working conditions were not objectively intolerable to constitute constructive discharge. The equal-protection claim was dismissed for lack of proof of differential treatment.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Myers did not meet the eligibility requirements for FMLA leave, lacked evidence of a serious health condition, and failed to provide sufficient notice of intent to take FMLA leave. The court also found no evidence of constructive discharge under the ADA, as her working conditions were not intolerable, and there was no imminent threat of termination. Lastly, the equal-protection claim was dismissed due to the absence of evidence showing that similarly situated employees were treated more favorably. View "Myers v. Sunman-Dearborn Community Schools" on Justia Law

Demmerick Brown, an inmate at Red Onion State Prison in Virginia, violated the prison’s COVID-19 policy by removing his face mask to get a shave at the barber shop. As a result, the prison fined him fifteen dollars, which was deducted from his prison trust account. Brown claimed that he was not provided the necessary forms to present evidence and call witnesses at his disciplinary hearing, and his request to postpone the hearing was denied. He was found guilty and fined.Brown sued three prison officials under 42 U.S.C. § 1983, alleging a violation of his Fourteenth Amendment due process rights. The United States District Court for the Western District of Virginia dismissed his case, concluding that Brown lacked a property interest in the money in his prison trust account, and thus, the fine did not trigger due process protections.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal, holding that inmates do have a property interest in the money in their prison trust accounts, as established in Henderson v. Harmon. The court found that the fifteen-dollar fine deprived Brown of this property interest, and thus, the Due Process Clause was applicable. The court rejected the argument that the fine was de minimis, noting its significance within the prison context.The Fourth Circuit vacated the district court’s decision and remanded the case for further proceedings to determine what process was due and whether any errors in Brown’s disciplinary proceedings were harmless. View "Brown v. Stapleton" on Justia Law

Joel Aaron Burrell, a prisoner, filed a lawsuit against several correctional officers under 42 U.S.C. § 1983. Burrell sought to proceed in forma pauperis, which allows indigent prisoners to file lawsuits without prepaying filing fees. The district court denied his request, citing the three-strike rule under the Prison Litigation Reform Act, which prevents prisoners from proceeding in forma pauperis if they have had three prior lawsuits dismissed for being frivolous, malicious, or failing to state a claim. The district court identified three such dismissals in Burrell's case history and dismissed his current action when he did not pay the filing fee.Burrell appealed, arguing that two of the prior dismissals should not count as strikes. The first case was dismissed under the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state proceedings. The second case was dismissed after Burrell failed to amend his complaint following a court order that found his initial complaint failed to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that a dismissal under Younger abstention does not count as a strike because it does not assess the merits of the complaint. Regarding the second case, the court determined that while a failure to amend following a finding of failure to state a claim can count as a strike, it should not be counted if the dismissal occurred after the current lawsuit was filed.The Fourth Circuit held that the district court erred in applying the three-strike rule to Burrell's case. Since Burrell had only one valid strike at the time he filed the current lawsuit, the district court's dismissal was vacated and the case was remanded for further proceedings. View "Burrell v. Shirley" on Justia Law