Justia Civil Rights Opinion Summaries

Steve Eggleston sued Clark County and Georgina Stuart, a social worker, alleging violations of his due process rights under 42 U.S.C. § 1983 and intentional infliction of emotional distress (IIED). Eggleston claimed that Stuart coerced him into signing temporary guardianship papers for his children during an ongoing child abuse/neglect investigation by threatening that his children would be permanently removed from his care if he did not comply. Stuart and Clark County moved for summary judgment, arguing that their actions were protected by qualified immunity and discretionary-act immunity. The district court denied their motion.The Eighth Judicial District Court of Nevada denied the motion for summary judgment, leading Stuart and Clark County to file a petition for a writ of mandamus challenging the order. The district court found that there were genuine issues of material fact regarding whether Stuart's conduct violated clearly established law and whether her actions were protected by discretionary-act immunity.The Supreme Court of Nevada reviewed the case and granted the petition for a writ of mandamus. The court held that Stuart was entitled to qualified immunity on Eggleston's substantive and procedural due process claims because her conduct did not violate any clearly established constitutional rights. The court also held that Stuart was entitled to discretionary-act immunity on Eggleston's IIED claim, as her actions involved individual judgment and were based on considerations of social policy. The court directed the district court to vacate the order denying summary judgment and to enter an order granting summary judgment in favor of Stuart and Clark County. View "Clark County v. District Court" on Justia Law

Brandon Duane Wagstaff was convicted by a jury of felony false imprisonment and related offenses stemming from a domestic violence incident. The trial court sentenced him to 16 months in prison. Wagstaff, who is Black, claimed that the trial court violated the California Racial Justice Act of 2020 (RJA) during various stages of the proceedings. However, his trial counsel did not object to these statements under the RJA, leading to the forfeiture of these claims on appeal. Wagstaff also argued that his trial counsel was ineffective for not objecting to a specific statement made by the trial court at sentencing, but the appellate court found this claim to be without merit.In the lower court, the prosecution charged Wagstaff with five counts, including felony false imprisonment, attempted second-degree robbery, contempt of court, threatening to commit a crime, and battery upon a person in a dating relationship. The jury found him guilty on four counts but acquitted him of attempted robbery. Wagstaff admitted to a prior conviction, and the trial court imposed an aggregate sentence of nine years and four months, including a term from a separate case.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that Wagstaff's claims under the RJA were forfeited due to the lack of objections by his trial counsel. The court also concluded that the trial court's failure to instruct the jury on misdemeanor false imprisonment as a lesser included offense was not erroneous because there was no substantial evidence to support such an instruction. The appellate court affirmed the judgment, finding no merit in Wagstaff's claims. View "P. v. Wagstaff" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law

In 2015, Shirley Carter was found dead in her home from gunshot wounds. Jason Carter, her son, was later found civilly liable for her wrongful death. Following this, Iowa Division of Criminal Investigation Agent Mark Ludwick and Marion County Deputy Sheriff Reed Kious arrested Jason for first-degree murder. However, Jason was acquitted in a jury trial. Jason then filed a 42 U.S.C. § 1983 action against Ludwick and Kious, alleging violations of his constitutional and state-law rights during the investigation of his mother's murder.The United States District Court for the Southern District of Iowa dismissed Jason's complaint, granting Ludwick and Kious qualified immunity on all federal claims and ruling that Jason failed to state a claim for his state law claims. The court also dismissed Marion County from the suit, as Jason did not allege a pattern of unconstitutional conduct.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Ludwick and Kious were entitled to qualified immunity. The court found that Jason failed to plausibly allege a constitutional violation for false arrest, as the arrest was conducted pursuant to a facially valid warrant. The court also held that Jason's claim of evidence concealment did not constitute a clearly established constitutional violation. Additionally, the court ruled that Jason's failure-to-investigate claim did not meet the threshold for a substantive due process violation. The court also affirmed the dismissal of Jason's state law claims for malicious prosecution and abuse of process, noting the presence of probable cause and the lack of improper motive. View "Carter v. Ludwick" on Justia Law

Joe Feazell, an inmate at Pontiac Correctional Center, sued his doctor, Andrew Tilden, and the prison’s healthcare contractor, Wexford Health Sources, Inc., alleging deliberate indifference to his hemorrhoid condition and significant gastrointestinal bleeding, violating the Eighth Amendment. Feazell claimed that Dr. Tilden failed to respond promptly to his abnormal lab results and adequately treat his hemorrhoids, while Wexford's treatment protocol was ineffective and deliberately indifferent.The United States District Court for the Central District of Illinois initially denied the defendants' motion for summary judgment. The parties consented to proceed before a magistrate judge, who later granted summary judgment for Wexford and partial summary judgment for Dr. Tilden. Feazell went to trial on his remaining claim against Dr. Tilden but was barred from testifying about his medical diagnoses or their causes. The jury returned a verdict for the defense.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the magistrate judge's summary judgment decision, finding no evidence that Wexford's Collegial Review policy caused Feazell to receive deficient care or that Dr. Tilden was aware of Feazell's hemorrhoids before the colonoscopy. The court also upheld the magistrate judge's evidentiary rulings, barring Feazell from testifying about medical diagnoses or causation, as he was not qualified to provide such testimony.The Seventh Circuit concluded that Feazell failed to demonstrate a genuine issue of material fact regarding Wexford's policy causing a violation of his Eighth Amendment rights and that Dr. Tilden was not deliberately indifferent to Feazell's medical needs. The court affirmed the district court's judgment. View "Feazell v Wexford Health Sources, Inc." on Justia Law

On June 1, 2018, Officer Jonathan Guzman of the City of Miami Police Department identified a speeding driver in a black Jeep Compass. The driver crashed into another vehicle and fled on foot. During an inventory search of the Jeep, Guzman found a firearm, ammunition, and marijuana. Shortly after, a radio dispatch reported the vehicle as stolen. Officer Michael Bloom arrived at the scene of the reported theft, where Samuel Scott Jr. claimed his Jeep had been stolen. Guzman arrived and recognized Scott as the driver who fled the crash. Scott was arrested for multiple charges, including reckless driving and falsely reporting a crime. The charges were later dropped.Scott filed federal and state law claims in the Southern District of Florida against the officers and the City of Miami, alleging unreasonable search and seizure, false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment for the defendants, citing qualified and sovereign immunity, and found that the officers had probable cause to arrest Scott based on Guzman’s eyewitness identification.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Guzman’s eyewitness identification provided sufficient probable cause for Scott’s arrest. The court also found that the officers were entitled to qualified immunity on the federal claims and that the City of Miami was not liable under state law due to the presence of probable cause. Consequently, all of Scott’s claims were dismissed. View "Scott v. City of Miami" on Justia Law

The defendants in this case challenged the constitutionality of 8 U.S.C. § 1326, which criminalizes unlawfully reentering the United States after a prior removal. They argued that the statute violates the equal protection component of the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latin American immigrants. Their theory was that the statute’s predecessor, the Undesirable Aliens Act of 1929, was enacted with discriminatory intent, and that § 1326, first codified in 1952 and amended several times thereafter, perpetuates that taint.The United States District Court for the Middle District of Florida denied the defendants’ motions to dismiss their indictments. The court assumed without deciding that the Arlington Heights framework applied but concluded that the defendants had failed to establish a discriminatory purpose behind § 1326’s enactment. The court also concluded that the statute easily satisfied rational-basis review. The defendants then entered conditional guilty pleas or proceeded to a stipulated bench trial, reserving their rights to appeal the constitutional issue. The District Court sentenced the defendants to varying terms of imprisonment and supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the District Court’s decision. The court found no clear error in the District Court’s conclusion that the defendants had not shown that § 1326 was enacted or maintained for a discriminatory purpose. The court noted that the defendants’ evidence, including historical context, statements by public officials, and statistical disparities, was insufficient to establish that the 1952 Congress acted with discriminatory intent. The court also emphasized that laws do not carry forward “taint” through reenactment unless the later legislature acted with the same constitutionally impermissible purpose. The judgments of the District Court were affirmed. View "USA v. Ferretiz-Hernandez" on Justia Law

The case involves Plaintiff Craig Gabaldon, who was stopped by New Mexico State Police Officer Kevin Smith for multiple traffic violations, including improper merging, speeding, and failing to use a turn signal. During the stop, Officer Smith detected signs of intoxication and arrested Gabaldon after a struggle, during which a loaded gun was found on Gabaldon. Officer Kurtis Ward assisted in the arrest. Gabaldon filed a civil action alleging constitutional violations and state-law claims, asserting that the stop was motivated by his affiliation with the Bandidos Motorcycle Club.The United States District Court for the District of New Mexico granted Defendants' motion for sanctions for spoliation of evidence, as Gabaldon had returned his Bandidos gear to the club, which likely destroyed it. The court also granted summary judgment in favor of Defendants on Gabaldon's Fourth, Fifth, and Fourteenth Amendment claims, citing qualified immunity and finding reasonable suspicion for the traffic stop and probable cause for the arrest. Gabaldon's affidavit, which contradicted his deposition testimony, was struck down as a sham affidavit.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the district court did not abuse its discretion in granting the spoliation motion or in striking Gabaldon's affidavit. The appellate court agreed that the affidavit was an attempt to create a sham fact issue, as it contradicted Gabaldon's earlier deposition testimony without new evidence. The court also upheld the summary judgment, finding that Officer Smith had reasonable suspicion to stop Gabaldon based on observed traffic violations. The appellate court concluded that the district court's rulings were correct and affirmed the judgment. View "Gabaldon v. New Mexico State Police" on Justia Law

Aarin Clinkscale was indicted in 2014 for his involvement in an armed robbery that resulted in two deaths. He pled guilty to aggravated robbery with a firearm specification and two counts of involuntary manslaughter. In 2016, the trial court sentenced him to a total of 14 years in prison, including a mandatory three-year term for the firearm specification. Clinkscale received 762 days of jail-time credit for time served prior to sentencing.Clinkscale filed his first motion for judicial release in June 2020, which the trial court denied, stating he would be eligible for release in October 2022. He filed a second motion for judicial release in October 2022. The State objected, arguing that Clinkscale was not eligible until November 2024, as he needed to serve the mandatory term and then wait five years. The trial court granted Clinkscale’s motion, and the State appealed to the Tenth District Court of Appeals. The appellate court affirmed the trial court’s decision, concluding that Clinkscale’s jail-time credit shortened the waiting period for judicial release.The Supreme Court of Ohio reviewed the case and disagreed with the Tenth District’s conclusion. The court held that jail-time credit does not reduce the required five-year waiting period following the expiration of mandatory prison terms under R.C. 2929.20(C)(1)(d). The court emphasized that the five-year waiting period is fixed and begins only after the mandatory term is completed. Consequently, Clinkscale’s motion for judicial release was premature. The Supreme Court of Ohio reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of Clinkscale’s equal-protection argument. View "State v. Clinkscale" on Justia Law