Justia Civil Rights Opinion Summaries

M.R., a high school student and basketball player, was sexually abused by Cody Butler, a women's basketball coach at Yakima Valley Community College (YVCC), starting when she was 17 years old. The abuse continued into her adulthood, including inappropriate touching, sexual comments, and physical advances. Butler's actions had a significant negative impact on M.R.'s life, leading to substance abuse, abusive relationships, and other personal issues. In 2018, M.R. connected her experiences of abuse to her injuries while in therapy.In 2019, M.R. sued the State of Washington, YVCC, and Butler for various claims, including negligence and assault. The trial court denied the State's motion for summary judgment, which argued that M.R.'s claims were time-barred by the three-year statute of limitations in RCW 4.16.080(2). The court found that the abuse was a continuous series of events that could not be segregated. The Court of Appeals reversed, concluding that RCW 4.16.340 only applies to claims based on acts of childhood sexual abuse occurring before the plaintiff turns 18 years old.The Supreme Court of the State of Washington reviewed the case and reversed the Court of Appeals. The court held that RCW 4.16.340 does not preclude complainants from bringing claims of sexual abuse that originate from childhood sexual abuse and extend into the victim’s adulthood. The court found that the statute's plain language and legislative intent support the inclusion of claims for continuing sexual abuse that are based on intentional acts of childhood sexual abuse. The court also noted that the statute accounts for the continuing tort doctrine, allowing for claims involving a common scheme of abuse by the same perpetrator. View "M.R. v. State" on Justia Law

Marcus Dixon, while on supervised release after a federal prison sentence, was arrested based on his suspected involvement in a hit-and-run accident and drug dealing. Probation officers conducted warrantless searches of his property, including a Pontiac, a cellphone, a home in Silvis, Illinois, an Audi, and a duffel bag, finding evidence of drug distribution and firearms. Dixon was convicted on multiple counts related to drug possession and firearms. He moved to suppress the evidence obtained from these searches, arguing they exceeded the scope authorized by his supervised release conditions. The district court denied his motion, leading to this appeal.The United States District Court for the Central District of Illinois denied Dixon's motion to suppress, concluding that he lacked a legitimate expectation of privacy in the searched items and places. The court also found that the searches were supported by reasonable suspicion. Dixon was subsequently convicted on all counts by a jury and sentenced to 260 months in prison. He appealed the denial of his motion to suppress, challenging the searches' legality and the denial of an evidentiary hearing.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Dixon failed to establish Fourth Amendment standing as he did not provide evidence of a legitimate expectation of privacy in the searched items and places. The court also found that the searches of the Pontiac and cellphone were reasonable and permissible under Dixon's supervised release conditions. The court concluded that the district court did not abuse its discretion in denying an evidentiary hearing, as Dixon did not identify any disputed material facts warranting such a hearing. View "United States v. Dixon" on Justia Law

A Turkish graduate student, Rümeysa Öztürk, was lawfully residing in Massachusetts on a student visa when she was arrested by plainclothes officers without warning on March 25, 2025. She was transported across state lines and eventually detained in Louisiana. Her counsel, unaware of her location, filed a habeas petition in the District of Massachusetts, alleging her arrest was based on an op-ed she co-authored. The petition was transferred to the District of Vermont after it was revealed she had been in Vermont during transit.The District of Vermont set a schedule for a bail hearing and to resolve the constitutional claims in the habeas petition. The court ordered the government to transfer Öztürk from Louisiana to Vermont to aid in these proceedings. The government appealed this order, seeking an emergency stay of the transfer.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the government failed to justify a stay. It determined that the District of Vermont was the proper venue for the habeas petition since Öztürk was in Vermont when the petition was filed. The court also found that the government was unlikely to succeed on its arguments that jurisdiction-stripping provisions of the Immigration and Nationality Act deprived the district court of jurisdiction over Öztürk’s detention challenge. Additionally, the court held that the government did not demonstrate irreparable injury absent a stay and that the balance of equities favored Öztürk.The Second Circuit denied the government’s motion for a stay, denied the request for a writ of mandamus, and vacated the administrative stay. The court ordered the government to comply with the district court’s transfer order within one week. View "Öztürk v. Hyde" on Justia Law

A former inmate at the Illinois River Correctional Center (IRCC) filed a lawsuit under 42 U.S.C. § 1983 against several prison officials, including Wardens Walter Nicholson and Gregory Gossett. The plaintiff alleged that the IRCC's failure to treat his chronic kidney disease, which progressed to acute renal failure, constituted deliberate indifference in violation of the Eighth and Fourteenth Amendments. The plaintiff claimed that the wardens were aware of the deficient medical practices that led to his injury.The United States District Court for the Central District of Illinois granted Warden Nicholson's motion to dismiss, concluding that the plaintiff's claim was time-barred and that he failed to state a claim. The court also granted Warden Gossett's motion for summary judgment, finding that the plaintiff did not provide sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. Additionally, the court excluded the plaintiff's expert witnesses, determining that their testimony would not assist the jury and might cause confusion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's dismissal of the claim against Warden Nicholson, agreeing that the plaintiff's complaint contained only general allegations and did not provide specific deficiencies in the IRCC's health care system. The court also upheld the summary judgment in favor of Warden Gossett, concluding that the plaintiff did not present sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. The court found that the district court did not abuse its discretion in excluding the expert testimony, as the experts lacked relevant expertise and their opinions would not assist the jury. View "Ollison v Gossett" on Justia Law

In May 2016, a jury convicted the appellant of two counts of capital murder for fatally shooting his son and his partner's son. The trial court sentenced him to death based on the jury's punishment phase verdicts. The appellant raised twenty-six points of error and five supplemental points of error on direct appeal.The trial court's judgment of conviction was affirmed, but the death sentences were reversed and remanded for a new punishment trial. The appellant's competency to stand trial was challenged, leading to a retrospective competency trial where a jury found him competent during his 2016 trial. The appellant's supplemental points of error regarding the retrospective competency proceedings were overruled, including the trial court's determination of feasibility, evidentiary rulings, denial of a mistrial, and cumulative error claims.The appellant's requests for substitute counsel and to represent himself were denied, with the court finding he did not clearly and unequivocally assert his right to self-representation and suffered from severe mental illness. His pro se motion for a speedy trial was disregarded as he was represented by counsel. The trial court's denial of his motion to suppress evidence from a hotel room and a Jeep was upheld, as he lacked a legitimate expectation of privacy in both.The appellant's absence from the courtroom during certain proceedings did not constitute constitutional error. The jury charge errors in the punishment phase, including the incorrect formulation of the verdict form and the erroneous burden of proof on the mitigation issue, resulted in egregious harm, leading to the reversal of the death sentences and a remand for a new punishment trial. Other punishment phase issues raised by the appellant were dismissed as moot. View "BLUNTSON v. STATE OF TEXAS" on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law

Mr. Jorge Martinez was fatally shot by Officer Cheyenne Lee while being served with an emergency protective order. The incident began when Officer Lee arrived at Mr. Martinez's home, and a family member informed him that Mr. Martinez was asleep. Upon being awakened, Mr. Martinez told Officer Lee to leave. Officer Lee attempted to arrest Mr. Martinez, managing to handcuff one hand before a struggle ensued, ending with Officer Lee shooting Mr. Martinez. The administratrix of Mr. Martinez's estate filed a lawsuit under 42 U.S.C. § 1983, alleging violations of the Fourth Amendment due to unlawful arrest and excessive force.The United States District Court for the Northern District of Oklahoma initially granted summary judgment in favor of Officer Lee. However, upon appeal, the Tenth Circuit reversed this decision, stating that the district court had failed to consider the plaintiff's version of events, which could constitute an unlawful arrest and excessive force. The case was remanded to the district court to determine if these findings would clearly establish a constitutional violation. The district court concluded that they would and denied summary judgment to Officer Lee, leading to the current appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court held that Officer Lee lacked qualified immunity on the claims of unlawful arrest and excessive force. The court determined that no reasonable officer could have perceived probable cause for the arrest based on the plaintiff's version of events, which included no threats or violent actions by Mr. Martinez. Additionally, the court found that the use of deadly force was clearly established as unconstitutional in situations where the suspect posed no immediate threat. Consequently, the Tenth Circuit affirmed the district court's denial of summary judgment for Officer Lee. View "Ibarra v. Lee" on Justia Law

David Walton, a Wisconsin prisoner, filed a lawsuit under 42 U.S.C. § 1983 against Ashley Nehls, a prison nurse, alleging that she violated his Eighth Amendment rights by engaging in a sexual relationship with him. Walton testified that the relationship was consensual. The district court granted summary judgment for Nehls, reasoning that a consensual sexual relationship does not constitute cruel or unusual punishment under the Eighth Amendment.The United States District Court for the Eastern District of Wisconsin reviewed the case and entered summary judgment in favor of Nehls. The court concluded that Walton's testimony about the consensual nature of the relationship meant that it could not be considered a violation of the Eighth Amendment. Walton appealed the decision, urging the appellate court to adopt a legal presumption that any sexual activity between a prisoner and a prison official is nonconsensual and violates the Constitution unless the prison official can show an absence of coercion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit acknowledged the power dynamics between prisoners and prison officials and the evolving standards of decency, noting that all 50 states have criminalized sexual conduct between prison officials and prisoners. However, the court found that even if it applied the presumption of nonconsent, the evidence in the record established that the relationship between Walton and Nehls lacked any coercive factors. Therefore, the court affirmed the district court's entry of summary judgment for Nehls, leaving the broader legal question of adopting a presumption of nonconsent for another day. View "Walton v Nehls" on Justia Law

A woman, Lila B., was detained at a psychiatric hospital for a mental health evaluation due to a severe head-lice infestation. The hospital staff sought to shave her head without her consent, arguing it was necessary to treat the lice and prevent their spread to other patients and staff. Lila objected, citing her religious beliefs and the psychological impact of head-shaving.The Superior Court of Alaska authorized the involuntary head-shaving, finding that the hospital had a compelling interest in preventing the spread of lice and that shaving her head was the least restrictive means of achieving this. The court relied on testimony from hospital staff that other treatments, such as permethrin shampoo, would be ineffective due to the severity of the infestation and that isolation was not feasible.The Supreme Court of Alaska reviewed the case and held that the State must demonstrate by clear and convincing evidence that head-shaving is the least restrictive means of advancing a compelling government interest. The court found that the State failed to meet this heightened standard. The evidence did not clearly and convincingly establish that less restrictive alternatives, such as using permethrin shampoo in conjunction with a head covering or some form of isolation, were inadequate. The court concluded that the State did not sufficiently explore these alternatives.As a result, the Supreme Court of Alaska vacated the order authorizing the involuntary head-shaving, emphasizing the need for the State to meet a substantial evidentiary burden before infringing on a patient's fundamental rights. View "In the Matter of the Necessity for the Hospitalization of Lila B." on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law