Justia Civil Rights Opinion Summaries

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law

Randy Erickson, an inmate at Gogebic County Jail, Michigan, was involved in an incident with Deputy Sheriff Scott Voit. Erickson, who was serving a sentence for operating a vehicle while intoxicated, had an altercation with Voit after making a disrespectful comment. Voit responded by canceling Erickson's family visit, which led Erickson to act out by hitting and kicking the cell door. Voit then handcuffed Erickson and took him to a holding cell, where he threw Erickson to the ground and kneed him in the back. Erickson later sought medical attention for injuries including a fractured rib and back contusions.The United States District Court for the Western District of Michigan denied Voit's motion for summary judgment on qualified-immunity grounds, finding that a reasonable jury could conclude that Voit used excessive force maliciously and sadistically to cause harm. However, the court also found that there was no evidence to suggest that Voit deliberately disregarded Erickson's medical needs, as there was no indication that Voit knew of Erickson's injuries.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court that a reasonable jury could find that Voit used excessive force in violation of the Eighth Amendment, as the force used was disproportionate to the threat posed by Erickson, who was handcuffed and compliant. The court held that Voit was not entitled to qualified immunity on the excessive force claim because the law clearly established that malicious and sadistic use of force violated the Eighth Amendment.However, the Sixth Circuit disagreed with the district court regarding the claim of deliberate indifference to medical needs. The court found no evidence that Voit knew of Erickson's injuries or that Erickson requested medical care from Voit. Therefore, the court held that Voit did not act with deliberate indifference to Erickson's medical needs.The Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Erickson v. Gogebic County" on Justia Law

Sara Watts, an African American woman, sued her former homeowners’ association, Joggers Run Property Owners Association (HOA), alleging racial discrimination under the Fair Housing Act (FHA) and the Civil Rights Act. Watts claimed the HOA interfered with her property enjoyment through unwarranted citations, restricted access to amenities, and discriminatory treatment as a former HOA board member. She cited provisions from the FHA (42 U.S.C. §§ 3604(b), 3617) and the Civil Rights Act (42 U.S.C. §§ 1981, 1982).The United States District Court for the Southern District of Florida dismissed Watts' claims, ruling that the FHA did not cover discriminatory conduct occurring after the purchase of her home and that Watts failed to specify the contractual terms the HOA allegedly violated. The court found her allegations insufficient to support claims under the FHA and the Civil Rights Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Watts presented plausible claims under the FHA and the Civil Rights Act. It found that the FHA's language is broad and inclusive, prohibiting a wide range of discriminatory conduct related to housing. The court concluded that the HOA's actions, including restricted access to amenities and selective enforcement of rules, fell within the scope of the FHA. The court also determined that Watts sufficiently alleged intentional racial discrimination causing contractual injury under Section 1981 and that the HOA's actions violated her right to use property on an equal basis with White citizens under Section 1982.The Eleventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watts v. Joggers Run Property Owners Association, Inc." on Justia Law

A Texas state jury convicted Jesus Jaime Jimenez of organized crime involving violent robbery, and he was sentenced to 50 years in prison. Jimenez filed a federal habeas corpus petition, claiming his conviction was tainted by judicial bias due to the trial judge's relationship with the district attorney, who had misappropriated funds to pay for the judge's travel expenses.Jimenez first appealed his conviction through the Texas court system, where the Fourth Court of Appeals affirmed the jury's verdict, and the Texas Court of Criminal Appeals (TCCA) refused his petition for discretionary review. He then filed a state habeas corpus application, which was remanded by the TCCA to the trial court for findings on his claims of ineffective assistance of counsel, Brady violations, and judicial bias. The trial court rejected his claims, and the TCCA denied relief without a written order. Jimenez subsequently filed a federal habeas petition, which was initially denied as time-barred. However, the Fifth Circuit granted a certificate of appealability (COA), vacated the district court's decision, and remanded for further consideration. On remand, the district court again denied the petition as time-barred, but the Fifth Circuit found Jimenez entitled to equitable tolling and remanded for consideration on the merits. The district court ultimately denied relief on the merits, and Jimenez appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and denied Jimenez's habeas relief. The court held that the state court's adjudication of Jimenez's judicial-bias claim was not contrary to, nor an unreasonable application of, clearly established federal law. The court found that the trial judge's actions, while inappropriate, did not demonstrate actual or presumptive bias against Jimenez. The Fifth Circuit also denied Jimenez's motion to expand the COA to include his ineffective assistance of counsel and Brady claims, concluding that the district court's resolution of these claims was not debatable among jurists of reason. The court affirmed the district court's judgment and denied habeas relief. View "Jimenez v. Guerrero" on Justia Law

A Texas county judge, Brian Umphress, challenged the State Commission on Judicial Conduct's application of Canon 4A(1) of the Texas Code of Judicial Conduct, which requires judges to conduct their extra-judicial activities in a manner that does not call into question their impartiality. Umphress, who refuses to perform same-sex marriages for religious reasons while continuing to perform opposite-sex marriages, argued that applying the Canon to his refusal is unconstitutional. This challenge arose after a similar situation involving Justice of the Peace Dianne Hensley, who was publicly warned by the Commission for her refusal to perform same-sex weddings.The United States District Court for the Northern District of Texas dismissed Umphress's case for lack of subject matter jurisdiction, holding that he lacked standing and that his claims were not ripe. The court also noted that even if it had jurisdiction, it would have abstained under the Pullman doctrine, which allows federal courts to defer to state courts on issues of unclear state law.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that Umphress had standing and that his claims were ripe for review. The court held that Umphress had demonstrated an imminent injury in fact, as his intended conduct was arguably proscribed by Canon 4A(1) and there was a substantial threat of future enforcement by the Commission. The court also determined that the case was not moot despite the Commission's rescission of its warning against Hensley, as the Commission had not disavowed future enforcement against Umphress.The Fifth Circuit reversed the district court's dismissal and declined to abstain under Pullman, noting that state court litigation was unlikely to resolve the crucial threshold question of Texas law. Instead, the court certified the question to the Supreme Court of Texas, asking whether Canon 4A(1) prohibits judges from publicly refusing to perform same-sex weddings for moral or religious reasons while continuing to perform opposite-sex weddings. View "Umphress v. Hall" on Justia Law

Gustavo Santander and his wife visited a sports bar in Fort Worth, Texas, where Jose Salazar, an off-duty police officer working as a security guard, allegedly pushed Santander without provocation, causing him to fall. When Santander confronted Salazar, Salazar allegedly punched him multiple times, leading to his arrest for public intoxication. The charge was later dismissed, and an internal review by the Fort Worth Police Department concluded that Salazar had violated departmental rules, resulting in his termination. Santander then filed a lawsuit under 42 U.S.C. § 1983, claiming excessive force, false arrest, and malicious prosecution.The United States District Court for the Northern District of Texas dismissed Santander’s claims with prejudice, stating that he failed to cite relevant legal authority to support his claims and did not show that Salazar violated any clearly established rights. Santander appealed the decision, arguing that the district court erred in its judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that the district court applied an incorrect pleading standard by requiring Santander to substantiate his claims with legal authority in his complaint. The appellate court held that Santander’s excessive force claim was plausible and could defeat Salazar’s qualified immunity at the pleading stage. However, the court affirmed the dismissal of Santander’s false arrest and malicious prosecution claims, as he could not show that Salazar violated clearly established law regarding these claims.The Fifth Circuit affirmed the district court’s dismissal of the false arrest and malicious prosecution claims but reversed the dismissal of the excessive force claim, remanding it for further proceedings. View "Santander v. Salazar" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

A retired teacher, Patsy Talley, received overpayments in her retirement benefits from the North Carolina Teachers’ and State Employees’ Retirement System (TSERS) for over eight years, totaling $86,173.93. When the overpayment was discovered, TSERS began reducing her monthly benefits to recoup the overpaid amount. Talley did not dispute the overpayment but argued that the recoupment process violated her due process rights because she was not provided a hearing before the reductions began.The United States District Court for the Eastern District of North Carolina dismissed all of Talley’s claims. The court held that her official capacity claims were barred by the Eleventh Amendment, her substantive due process claim failed because she received adequate post-deprivation process, and her equal protection claim did not allege a fundamental right or suspect class. The court also dismissed her individual capacity procedural due process claim, finding the defendants were entitled to qualified immunity. Additionally, the court denied Talley’s motion to amend her complaint to add new plaintiffs, citing procedural deficiencies and lack of good cause.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that the Eleventh Amendment barred the official capacity claims and that the individual capacity claims were barred by qualified immunity. The court found that Talley failed to state a substantive due process claim because she received adequate post-deprivation process and that her equal protection claim did not meet the rational basis review. The court also upheld the denial of her motion to amend the complaint, finding no abuse of discretion by the district court. View "Talley v. Folwell" on Justia Law

William Maxwell, a federal prisoner, filed a 28 U.S.C. § 2241 petition for writ of habeas corpus, seeking transfer to a halfway house or home confinement under the First Step Act of 2018. He argued that the district court erred in determining that he failed to exhaust administrative remedies.The United States District Court for the Eastern District of Texas dismissed Maxwell's petition, concluding that he had not exhausted his administrative remedies. Maxwell appealed this decision, contending that the district court's determination was incorrect.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Maxwell's request for transfer to a halfway house or home confinement did not entitle him to accelerated release. According to the court's precedent in Melot v. Bergami, such relief should be sought through a civil rights suit rather than a habeas petition. Consequently, the court did not address whether Maxwell had exhausted his administrative remedies, as the proper vehicle for his claim was a civil rights suit, not a habeas petition. The court affirmed the district court's dismissal of Maxwell's petition. View "Maxwell v. Thomas" on Justia Law

Tyler Venema, an inmate with a history of mental illness and suicide attempts, committed suicide by asphyxiation with a plastic bag while in the custody of the Michigan Department of Corrections (MDOC) at Woodland Center Correctional Facility (WCC). Venema's estate filed a lawsuit under 42 U.S.C. § 1983 against Jodi DeAngelo, the warden of WCC, alleging that her failure to train and supervise corrections officers led to Venema's death, violating his Eighth Amendment rights. The estate claimed that DeAngelo knew about the risk posed by plastic bags and the officers' failure to remove them from at-risk inmates' cells.The United States District Court for the Eastern District of Michigan denied DeAngelo's motion to dismiss based on qualified immunity, finding that the estate's allegations were sufficient to establish that DeAngelo implicitly authorized or knowingly acquiesced in the unconstitutional conduct of her subordinates. DeAngelo appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the estate plausibly alleged that DeAngelo knowingly acquiesced in the unconstitutional conduct of her subordinates by failing to train and supervise them properly. The court also found a causal connection between DeAngelo's actions and Venema's death, as her failure to enforce policies against providing plastic bags to at-risk inmates could reasonably be expected to result in harm. The court concluded that Venema's Eighth Amendment rights were clearly established at the time of the violation, and thus, DeAngelo was not entitled to qualified immunity. View "Venema v. West" on Justia Law