Justia Civil Rights Opinion Summaries

Police officers in Bella Vista, Arkansas, responded to a home shared by the Welters and Hutchins families after a suspected drug overdose, where they found pills, including fentanyl, in areas accessible to children. A week later, another overdose occurred at the same residence, resulting in a fatality while children were present. Months later, officers discovered traces of THC in the home’s trash, and a subsequent search revealed marijuana and drug paraphernalia throughout the house, including a still-smoking bong. During an interview, one parent admitted that adults regularly smoked marijuana in the home, though they tried to keep the children out of the room. Police notified the Arkansas Department of Human Services about possible child endangerment. Shortly after, Detective Wilson and other officers took the minor children for forensic interviews without a warrant, over the parents’ objections, and warned the parents they would be arrested if they interfered. The children were later returned to their parents.The United States District Court for the Western District of Arkansas granted summary judgment to Detective Wilson on the parents’ Fourth Amendment claims, finding she was entitled to qualified immunity. The court determined that the parents had not alleged a violation of their own Fourth Amendment rights and that the claims on behalf of the children did not overcome qualified immunity. The parents appealed, focusing solely on the Fourth Amendment claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that Detective Wilson was entitled to qualified immunity because, under the totality of the circumstances, a reasonable officer could have believed there was reasonable suspicion that the children were in danger. The court also declined to adopt a new standard requiring probable cause and exigent circumstances for such removals, noting that existing precedent did not clearly establish such a right. View "Welter v. Wilson" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law

A Black defendant was convicted of multiple felonies, including attempted premeditated murder, torture, and assault, after a series of violent incidents. The most serious event occurred at a hotel, where the defendant attacked a night manager with a boxcutter, stabbed him, and then continued to assault him with a pen and by biting and headbutting him. The defendant also assaulted correctional officers on two separate occasions while in jail. At trial, the defense did not dispute the violent conduct but argued that the defendant lacked the specific intent required for the most serious charges, emphasizing his impulsive behavior and likening his actions to those of an animal.The case was tried in the San Mateo County Superior Court, where the jury found the defendant guilty on all charges presented. The court imposed consecutive sentences for attempted murder and torture, finding that the crimes involved separate acts of violence and objectives. The court also described the defendant’s conduct as “animalistic” at sentencing. The defendant appealed, arguing that his counsel’s and the court’s animal comparisons violated the California Racial Justice Act of 2020 (RJA), that the court erred in evidentiary rulings and sentencing, and that cumulative error deprived him of a fair trial.The California Court of Appeal, First Appellate District, Division Two, held that the defendant was procedurally barred from raising RJA claims based on his counsel’s animal comparisons because those statements were part of a deliberate defense strategy, invoking the doctrine of invited error. The court also found that the RJA claim regarding the trial court’s comment was forfeited due to lack of objection. The court rejected the defendant’s other claims, finding no evidentiary or sentencing error, and affirmed the judgment. View "People v. Midell" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

Paul Schwartz, while incarcerated at a federal correctional facility in Tucson, alleged that prison officials were deliberately indifferent to his serious medical needs over an eighteen-month period. He experienced a range of severe symptoms, including tachycardia, blood in his urine, and significant thyroid dysfunction, but claimed he received inadequate and delayed medical care despite repeated attempts to seek help. Schwartz specifically alleged that a mid-level practitioner, Ms. Tatad, refused to provide treatment or access to a physician and instructed others to deny him care. He also claimed that the warden and associate warden ignored his efforts to alert them to his condition, resulting in irreversible kidney injury and other long-term health risks.The United States District Court for the District of Arizona initially dismissed several defendants and later granted summary judgment for the remaining defendants. On appeal, the United States Court of Appeals for the Ninth Circuit reversed in part, allowing Schwartz’s claim against Tatad to proceed. After remand, the district court denied Schwartz’s motion to amend his complaint, then later granted Tatad’s motion for judgment on the pleadings, concluding that the Prison Litigation Reform Act (PLRA) constituted a special factor that placed Schwartz’s claim in a new Bivens context, foreclosing a damages remedy.The United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The Ninth Circuit held that Schwartz’s claim was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, which recognized a Bivens remedy for Eighth Amendment claims of deliberate indifference to serious medical needs. The court found that neither the PLRA, the Bureau of Prisons’ Administrative Remedy Program, nor the factual specifics of Schwartz’s case created a new Bivens context. The court also held that the district court abused its discretion in denying Schwartz leave to amend his complaint. View "SCHWARTZ V. MILLER" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

A physician assistant employed by a Michigan hospital, later affiliated with the University of Michigan Health System, was terminated after she refused, on religious and medical grounds, to use gender identity-based pronouns or refer patients for gender reassignment procedures. The hospital had required her to complete training on serving LGBTQ+ patients, which she believed conflicted with her Christian faith and medical judgment. After seeking a religious accommodation and participating in meetings with hospital administrators, she was fired for her refusal to comply with the hospital’s requirements.She filed suit in the United States District Court for the Western District of Michigan against the hospital and several administrators, alleging violations of federal constitutional rights under 42 U.S.C. § 1983, Title VII, and Michigan law. The hospital and its administrators moved to dismiss all claims on the merits, and the district court granted the motion in part and denied it in part, allowing several of her claims to proceed. Only after this partial denial, and more than a year into the litigation, did the hospital invoke an arbitration clause from her employment agreement and move to compel arbitration. The district court granted this motion, found the arbitration clause enforceable, and dismissed the case in favor of arbitration.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the hospital had forfeited its right to arbitrate by substantially litigating the case before seeking arbitration. The Sixth Circuit held that the hospital’s conduct—seeking a complete judicial victory on the merits before invoking arbitration—was inconsistent with the right to arbitrate and constituted “default” under the Federal Arbitration Act. The court reversed the district court’s order compelling arbitration and remanded the case for further proceedings. View "Kloosterman v. Metropolitan Hospital" on Justia Law

In this case, the defendant was shot five times in his apartment parking lot and, in the chaos, dropped his black iPhone and a satchel. His girlfriend took the satchel but left the phone, which was later recovered by police near some shrubs. The police also seized a different (white) iPhone from the defendant at the hospital. The black iPhone remained in police evidence for over two years, until it became relevant in a separate federal drug investigation. The government ultimately used data from the black iPhone, along with other evidence, to charge the defendant with drug trafficking, firearm offenses, and money laundering.The United States District Court for the District of Oregon presided over the trial. Before trial, the defendant moved to suppress evidence from the black iPhone, arguing that he retained a privacy interest in the device and its data, and also sought recusal of the district judge due to her prior service as U.S. Attorney when he was prosecuted for unrelated charges over fifteen years earlier. The district court denied both motions, finding that the defendant had abandoned the black iPhone and thus lacked standing to challenge its search, and that recusal was not warranted.The United States Court of Appeals for the Ninth Circuit reviewed the case. The Ninth Circuit disagreed with the district court’s finding that the defendant had abandoned his privacy interest in the black iPhone, holding that the circumstances—dropping the phone while fleeing after being shot—did not show intent to abandon the device or its data. However, the Ninth Circuit affirmed the denial of the suppression motion because federal agents obtained a warrant and searched the phone within a reasonable period. The court also affirmed the denial of the recusal motion, concluding that a reasonable person would not question the judge’s impartiality under these facts. The conviction and sentence were affirmed. View "USA V. HUNT" on Justia Law

A New York State Police trooper stopped Daniel Delgado for erratic driving and discovered that his license was suspended. During an inventory search of his vehicle, the trooper found a loaded “ghost gun” and ammunition, which Delgado admitted belonged to him. Delgado had several prior convictions, including a felony conviction for attempted second-degree murder in Florida, where he had shot a man in the back. Delgado was indicted for possessing ammunition after a felony conviction, in violation of 18 U.S.C. § 922(g)(1), and pleaded guilty without a plea agreement.The United States District Court for the Southern District of New York denied Delgado’s motion to withdraw his guilty plea and to dismiss the indictment, finding that § 922(g)(1) did not violate the Second Amendment. At sentencing, the court determined that Delgado’s prior Florida conviction for attempted second-degree murder was a “crime of violence” under U.S.S.G. § 2K2.1(a), resulting in a higher base offense level. Delgado was sentenced to thirty months’ imprisonment and three years of supervised release. He timely appealed, challenging both the constitutionality of § 922(g)(1) and the classification of his prior conviction.The United States Court of Appeals for the Second Circuit reviewed the case. It held that Delgado’s constitutional challenge to § 922(g)(1) was foreclosed by its recent decision in Zherka v. Bondi, which reaffirmed the statute’s constitutionality after New York State Rifle & Pistol Ass’n v. Bruen. The court also held that Florida’s offense of attempted second-degree murder is categorically a crime of violence under the Sentencing Guidelines, as it requires an intentional act imminently dangerous to another and demonstrating a depraved mind. The Second Circuit affirmed the judgment of the district court. View "United States v. Delgado" on Justia Law