Justia Civil Rights Opinion Summaries

Rodney Owen Skurdal, who is not a licensed attorney, attempted to represent Ronald Trow during Trow’s initial appearance in a criminal case in Yellowstone County Justice Court. Judge Jeanne Walker, presiding over the case, ordered Skurdal to vacate the defendant’s table and did not permit him to represent Trow, as Skurdal was not a member of the bar. Trow subsequently entered a plea of not guilty, and a public defender was appointed. Skurdal then filed a lawsuit in the Thirteenth Judicial District Court for Yellowstone County against Judge Walker, later joined by Yellowstone County as a defendant, alleging violations of his and Trow’s rights and advancing various arguments, including those associated with the “Sovereign Citizen” movement.The Thirteenth Judicial District Court dismissed Skurdal’s complaint with prejudice, holding that Judge Walker and Yellowstone County were protected by absolute judicial immunity for actions taken in the course of judicial duties. The court also found that Skurdal, as a non-lawyer, had no statutory or constitutional right to represent another individual in a criminal proceeding in Montana. The court denied leave to amend the complaint, finding that any amendment would be futile due to the immunity defense.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that Montana law does not permit non-lawyers to represent others in criminal cases, and that Judge Walker’s actions were judicial acts performed within her jurisdiction, entitling her and Yellowstone County to absolute immunity from suit. The Court also concluded that the District Court did not err in denying leave to amend, as further amendment could not overcome the immunity bar. View "Skurdal v. Walker" on Justia Law

A large group of current and former Illinois prisoners diagnosed with hepatitis C brought lawsuits against various medical officials of the Illinois Department of Corrections. The plaintiffs alleged that, over the past two decades, these officials were deliberately indifferent to their medical needs by adopting and enforcing hepatitis C treatment policies that denied them effective care. The complaints sought only monetary damages and did not specify whether the defendants were being sued in their individual or official capacities.In the United States District Court for the Central District of Illinois, the Orr plaintiffs’ efforts to obtain class certification and injunctive relief were denied, and subsequent attempts to amend their complaint were dismissed for lack of specificity. The Ternaprovich plaintiffs, represented by the same counsel and making similar claims, also had their complaints dismissed for failing to provide sufficient notice to the defendants. Ultimately, in January 2024, the district court dismissed both cases with prejudice, holding that the claims were barred by the Eleventh Amendment as official-capacity suits for damages, and, alternatively, that the complaints failed to state plausible claims for relief under Federal Rule of Civil Procedure 12(b)(6).On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissals de novo. The appellate court concluded that, despite some ambiguity, the complaints should be interpreted as asserting individual-capacity claims under 42 U.S.C. § 1983, given the explicit request for damages. However, the court affirmed the dismissals on the alternative ground that the complaints failed to state plausible claims for relief. The court held that the plaintiffs did not provide sufficient factual allegations to connect specific defendants to the alleged constitutional violations, and thus failed to give fair notice as required by Rule 8. The judgments of dismissal with prejudice were affirmed. View "Ternaprovich v Shicker" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

In 1994, Kenneth Hayes was murdered in Wayne County, Michigan. Larry Smith was convicted of first-degree murder and a firearm charge, largely based on the testimony of Edward Allen, a jailhouse informant who claimed Smith confessed to the crime. Smith’s conviction was affirmed on direct appeal, and his subsequent state and federal habeas petitions were unsuccessful. Years later, the Wayne County Prosecutor’s Conviction Integrity Unit investigated and found evidence suggesting Allen’s testimony may have been fabricated as part of a broader scheme involving police and prosecutors eliciting false testimony from informants. Smith’s conviction was vacated in 2021, and he was released from prison.After his release, Smith obtained compensation from the State of Michigan under the Wrongful Imprisonment Compensation Act (WICA), settling for $850,000 and signing a release of claims against the State. He then filed a federal lawsuit against Wayne County and prosecutor Robert Donaldson, alleging constitutional violations under 42 U.S.C. § 1983 and a Monell claim against the County for policies encouraging false testimony. The United States District Court for the Eastern District of Michigan granted summary judgment to both defendants, finding Donaldson was protected by absolute prosecutorial immunity and that Smith’s settlement under WICA released his claims against Wayne County.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that Donaldson was entitled to absolute prosecutorial immunity because his conduct—preparing a witness for trial—was within the scope of his advocacy role, not investigatory. The court also held that Smith’s acceptance of the WICA settlement released all claims against Wayne County, including federal claims, as a matter of law. The Sixth Circuit affirmed the district court’s grant of summary judgment to both defendants. View "Smith v. Wayne County" on Justia Law

A Christian humanitarian organization offered a remote customer service representative position to an applicant who was openly in a same-sex marriage. After the applicant disclosed her marital status while inquiring about parental leave, the organization rescinded the job offer, citing its policy that limits employment to those who comply with its religious standards, including a prohibition on sexual conduct outside of marriage between a man and a woman. The applicant, who identifies as Christian and is active in LGBTQ advocacy, sued the organization for discrimination based on sex, sexual orientation, and marital status under federal and state law.The United States District Court for the Western District of Washington initially granted summary judgment to the organization, finding that the church autonomy doctrine barred judicial inquiry into the religiously motivated employment decision. Upon reconsideration, the district court reversed itself, holding that the church autonomy doctrine did not apply because the organization’s hiring policy was facially discriminatory and could be evaluated using neutral legal principles. The district court also rejected the organization’s ministerial exception defense and other constitutional and statutory defenses, ultimately granting summary judgment to the applicant and entering judgment for stipulated damages.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The Ninth Circuit held that the ministerial exception applies because customer service representatives at the organization perform key religious functions central to its mission, such as communicating its ministries to donors, engaging in prayer with supporters, and inviting participation in its religious mission. The court concluded that these duties are vital to the organization’s religious purpose, and therefore, the ministerial exception bars the applicant’s employment discrimination claims. The Ninth Circuit remanded the case for entry of summary judgment in favor of the organization. View "MCMAHON V. WORLD VISION INC." on Justia Law

Michael Hurd, Jr. was sentenced in 2005 to 15 months in prison for a felony firearm charge and an additional 27 months for four misdemeanor firearm and drug possession charges. After serving his felony sentence in federal custody, Hurd was mistakenly released instead of being transferred to serve his misdemeanor sentence. He completed his supervised release and, years later, was reincarcerated by the District of Columbia Department of Corrections when the error was discovered during a subsequent, unrelated incarceration. Hurd was not given a hearing before being required to serve the remainder of his original sentence.After his reincarceration, Hurd filed a habeas petition in the Superior Court of the District of Columbia, which was denied. His appeal was dismissed as moot after he completed his sentence. Hurd then brought a civil action in the United States District Court for the District of Columbia under 42 U.S.C. § 1983, alleging violations of his substantive and procedural due process rights under the Fifth Amendment. The district court granted summary judgment to the District, finding no substantive due process violation and holding that his procedural due process claim was barred by the Supreme Court’s decision in Heck v. Humphrey.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court’s judgment. The court held that reincarcerating a person to serve the remainder of a lawfully imposed sentence after an erroneous release does not violate substantive due process, as such action does not “shock the conscience.” The court also held that Hurd’s procedural due process claim for damages was barred by Heck v. Humphrey because a judgment in his favor would necessarily imply the invalidity of his confinement, which had not been set aside. View "Hurd v. DC" on Justia Law

A female firefighter with a long and decorated career in the Salt Lake City Fire Department alleged that her supervisors discriminated against her based on her sex and subjected her to a hostile work environment. She claimed that her male supervisors made derogatory comments about women, held her to different standards than male colleagues, and retaliated against her for complaining about sexist behavior. Over several years, she was passed over for promotions, reassigned to less prestigious roles, and eventually demoted. She filed multiple complaints with the Equal Employment Opportunity Commission and appealed her demotion to the Salt Lake City Civil Services Commission, which ultimately reversed the demotion, finding that the reasons given for it were unsupported and appeared to be manufactured.The United States District Court for the District of Utah denied the defendants’ motion for summary judgment, which sought qualified immunity on the plaintiff’s claims under 42 U.S.C. § 1983 for sex discrimination and hostile work environment in violation of the Fourteenth Amendment. The defendants, who were her supervisors, appealed the denial of qualified immunity to the United States Court of Appeals for the Tenth Circuit. The City also sought pendent appellate jurisdiction over the denial of its own summary judgment motion, but the appellate court declined to exercise such jurisdiction.The United States Court of Appeals for the Tenth Circuit dismissed the appeal as to the sex discrimination claim for lack of jurisdiction, finding that the defendants had not properly raised qualified immunity on that claim in the district court. The court also dismissed most of the appeal regarding the hostile work environment claim, holding that it lacked jurisdiction to review factual disputes and evidentiary rulings at this interlocutory stage. However, the court vacated the district court’s denial of qualified immunity on the hostile work environment claim and remanded for further proceedings, instructing the district court to conduct a more thorough analysis of whether the law was clearly established as to each defendant’s specific conduct. View "Ellis v. Salt Lake City Corporation" on Justia Law

Texas enacted a law in 2021 requiring voters who wish to vote by mail to provide an identification number—such as a driver’s license or the last four digits of their Social Security number—on both their mail-in ballot applications and the ballots themselves. This number must match the one provided during voter registration. If the numbers do not match or are missing, the application or ballot is rejected. The law was challenged by the United States and several private plaintiffs, who argued that these requirements violate the materiality provision of the Civil Rights Act of 1964, which prohibits denying the right to vote due to errors or omissions on paperwork if those errors are not material to determining voter qualification.The United States District Court for the Western District of Texas consolidated the lawsuits and denied Texas’s motion to dismiss, finding that the plaintiffs had standing and that sovereign immunity did not bar the private plaintiffs’ claims. After discovery, the district court granted summary judgment for the plaintiffs, holding that the identification number requirement was not material to voter eligibility and enjoined Texas from enforcing the number-matching provisions.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the district court lacked jurisdiction over the private plaintiffs’ claims against the Secretary of State due to a pending appeal on sovereign immunity, but found no jurisdictional bar to reviewing the United States’ claims. The Fifth Circuit held that the identification number requirement is material to determining whether an individual is qualified to vote under Texas law, as it serves to confirm the voter’s identity and prevent fraud. The court concluded that the law complies with the materiality provision of the Civil Rights Act and reversed the district court’s judgment, rendering judgment for the defendants. View "USA v. Paxton" on Justia Law

In 2021, Ralph Marcus Hardy, an inmate at Adams County Detention Facility (ACDF) in Colorado, fell from his wheelchair and suffered serious injuries. Despite his repeated requests for medical attention, jail officials allegedly ignored his pleas. Hardy claims that Detention Specialist Daniel DeHerrera ignored emergency distress signals from his cell, and Deputy Dennis Rabie, who later found Hardy in pain, also failed to provide medical assistance.The United States District Court for the District of Colorado reviewed the case. Deputy Rabie and Detention Specialist DeHerrera moved to dismiss Hardy’s claims, asserting qualified immunity. The district court denied their motion, finding that Hardy plausibly alleged violations of his Fourteenth Amendment rights. The court held that the defendants were not entitled to qualified immunity, leading to this appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Hardy sufficiently alleged that both Deputy Rabie and Detention Specialist DeHerrera acted with deliberate indifference to his medical needs. The court found that Hardy’s constitutional rights were violated and that these rights were clearly established at the time of the incident. The court concluded that both defendants were aware of Hardy’s serious medical needs and failed to take reasonable measures to address them, thus denying them qualified immunity. View "Hardy v. Rabie" on Justia Law

Three registered Texas voters alleged that three local officials—a justice of the peace, a sheriff, and a constable—conspired to punish them for political reasons. The plaintiffs were arrested after reporting for jury duty, accused of falsely claiming residency in Loving County. The officials argued they were enforcing voter-eligibility rules, while the plaintiffs claimed it was retaliation to silence dissent. The plaintiffs sued under § 1983, alleging constitutional violations.The United States District Court for the Western District of Texas granted judicial and quasi-judicial immunity to the officials for some claims but denied judicial immunity for actions related to the jury proceeding. The officials appealed the denial of judicial immunity, and the plaintiffs cross-appealed the grant of immunity on other claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that presiding over the jury proceeding was a judicial act protected by absolute judicial immunity. Consequently, the court reversed the district court's denial of judicial immunity for the jury proceeding. Regarding the plaintiffs' cross-appeal, the court found it lacked jurisdiction to review those claims at this interlocutory stage and dismissed the cross-appeal.The court's main holding was that the actions of the justice of the peace in presiding over the jury proceeding were judicial in nature and thus protected by absolute judicial immunity. The court reversed the district court's decision in part and dismissed the cross-appeal for lack of jurisdiction. View "Jones v. King" on Justia Law