Justia Civil Rights Opinion Summaries

A human trafficker victimized Jane Doe, grooming her through Facebook, which lacked sufficient guardrails for minors. The trafficker convinced Doe to meet in person and advertised her for prostitution on Backpage, leading to her sexual assault at the Texas Pearl Hotel in Houston. Doe sued Facebook and Texas Pearl for violations of Civil Practice and Remedies Code Chapter 98, which imposes civil liability on those who benefit from human trafficking.The MDL pretrial court denied Facebook’s motion to remand the case, and the MDL panel upheld this decision. Facebook argued that its case had no common fact questions with the MDL cases, which involved different defendants, plaintiffs, and incidents. The MDL cases named various hotels and Salesforce as defendants, alleging they facilitated human trafficking through their services. Facebook contended that the lack of common parties or events meant there were no shared fact questions.The Supreme Court of Texas reviewed the case and agreed with Facebook. The court held that the tag-along case did not share any common fact questions with the MDL cases. The MDL cases involved different defendants, criminal perpetrators, and incidents, and there was no connection through common parties or events. The court concluded that general patterns of criminal activity by different perpetrators do not create the required common fact question for MDL inclusion. Consequently, the court conditionally granted mandamus relief and directed the MDL panel to remand the tag-along case to its original trial court. View "IN RE JANE DOE CASES" on Justia Law

Clint Edwards, a pretrial detainee in a Westchester County Department of Corrections (WCDOC) jail, filed a lawsuit under 42 U.S.C. § 1983, alleging violations of his Fourteenth Amendment rights. Edwards claimed that Correction Officer Christopher Arocho failed to protect him and incited other inmates to attack him. He also alleged that several WCDOC officials subjected him to unsanitary and unhealthy conditions in administrative segregation and that his placement in administrative segregation without notice or a hearing violated his procedural due process rights.The United States District Court for the Southern District of New York dismissed Edwards’s conditions of confinement and procedural due process claims for failure to state a claim. The court also granted summary judgment in favor of Arocho on the failure to protect claim, determining that Edwards had not exhausted his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Edwards had adequately stated claims for conditions of confinement and procedural due process violations under the Fourteenth Amendment. The court also found that Edwards raised a factual dispute regarding whether he exhausted his administrative remedies, which precluded summary judgment on the failure to protect claim. The court vacated the District Court’s judgment and remanded the case for further proceedings. View "Edwards v. Arocho" on Justia Law

Jose Villegas, a 39-year-old inmate at Lake Correctional Institution (LCI) in Florida, died following a physical confrontation with correctional officers. The incident began when officers found Villegas unconscious in his cell. Upon regaining consciousness, Villegas resisted the officers' attempts to restrain him. The officers eventually subdued Villegas and transported him to a medical unit, but he was pronounced dead upon arrival. The autopsy reported that Villegas died from restraint asphyxia, with excited delirium as a contributing factor, and noted the presence of synthetic cannabinoids in his system.Douglas B. Stalley, representing Villegas's estate and his minor children, filed a lawsuit against the officers, their supervisors, and the Florida Department of Corrections (FDOC) for negligence, wrongful death, excessive force, deliberate indifference, and supervisory liability. The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants on the constitutional claims and declined to exercise jurisdiction over the state-law wrongful death claim, remanding it to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Stalley appealed the district court's decision regarding the deliberate indifference and supervisory liability claims. The Eleventh Circuit affirmed the district court's ruling, holding that the officers were entitled to qualified immunity. The court found that the officers' decision to transport Villegas to a medical unit rather than provide on-scene care did not violate any clearly established constitutional right. Consequently, the supervisory liability claim also failed, as it was contingent on the underlying constitutional violation. View "Stalley v. Lake Correctional Institution Warden" on Justia Law

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

Krish Singh was shot and seriously injured by Officer Brittany Smith-Petersen in Phoenix, Arizona. Smith-Petersen and another officer, Annie Batway, responded to a report of an attempted robbery with a knife. Upon arrival, Singh held a knife to his own neck and asked the officers to shoot him. Despite commands to drop the knife, Singh did not comply, and Smith-Petersen shot him. Singh sued the City of Phoenix, Smith-Petersen, and Batway, alleging excessive force under 42 U.S.C. § 1983 and various state law claims.The United States District Court for the District of Arizona granted summary judgment in favor of Smith-Petersen on the § 1983 claim, holding that she was protected by qualified immunity. The court found that although a reasonable jury could find a constitutional violation, there was no clearly established law indicating that her use of force was objectively unreasonable. The district court remanded the state law claims to state court for resolution.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment on the § 1983 claim, holding that the case of Glenn v. Washington County, which involved similar facts, provided clearly established law that should have put Smith-Petersen on notice that her use of deadly force was potentially unreasonable. The Ninth Circuit also reversed the district court’s order remanding the state law claims and remanded for reconsideration of whether to exercise supplemental jurisdiction over those claims. The court dismissed Smith-Petersen’s cross-appeal for lack of jurisdiction, as it challenged the district court’s determination of genuine factual disputes, which is not reviewable on appeal. View "SINGH V. CITY OF PHOENIX" on Justia Law

Amity Dimock, the mother of Kobe Dimock-Heisler, sued the City of Brooklyn Center and four police officers, alleging unconstitutional warrantless entry and use of deadly force. The incident began when Kobe's grandfather, Erwin Heisler, called 911 reporting that Kobe had threatened him with a knife and hammer. When officers arrived, they entered the home without a warrant, leading to a confrontation where Kobe, holding a knife, was shot and killed by officers.The United States District Court for the District of Minnesota granted summary judgment in favor of the officers, citing qualified immunity. The court found that the officers reasonably believed exigent circumstances justified their warrantless entry and that they had probable cause to believe Kobe posed an immediate threat, justifying the use of deadly force. Dimock appealed the decision, challenging the grant of qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the officers were entitled to qualified immunity. The court determined that the officers' belief in the existence of exigent circumstances was reasonable given the information they had, including Kobe's previous threats and mental health history. Additionally, the court found that the use of deadly force was justified as the officers had probable cause to believe Kobe posed an immediate threat to his grandmother and the officers, even though Kobe was only holding the knife and not actively attacking anyone at the moment of the shooting. The court concluded that the rights asserted by Dimock were not clearly established in this context, thus affirming the summary judgment in favor of the officers. View "Dimock v. City of Brooklyn Center" on Justia Law

In May 2017, Jorge Rivera-Guadalupe was living in a rooming house in Harrisburg, Pennsylvania. After being mugged, his friend Christopher Valkosak stayed with him. The next night, Valkosak was shot by a man in a black hoodie. Detective Jacob Pierce investigated and obtained a search warrant for Rivera-Guadalupe’s room, finding marijuana and other items but no gun. Rivera-Guadalupe was arrested and charged with multiple offenses, including attempted homicide. At trial, the prosecution dropped some charges, and Rivera-Guadalupe was acquitted of the remaining charges after being incarcerated for over eighteen months.The Middle District of Pennsylvania dismissed claims against other defendants but allowed the malicious prosecution claim against Det. Pierce to proceed. Det. Pierce sought dismissal based on qualified immunity, arguing that probable cause for one charge should shield him from liability for malicious prosecution on other charges. The District Court, referencing Johnson v. Knorr, denied qualified immunity, distinguishing it from Wright v. City of Philadelphia, which applied the "any-crime" rule to false arrest claims.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the right to be prosecuted only on charges supported by probable cause was not clearly established in 2017 due to conflicting precedents in Wright and Johnson. The court noted that the Supreme Court's recent decision in Chiaverini v. City of Napoleon clarified that probable cause for one charge does not defeat a malicious prosecution claim for other charges lacking probable cause. However, this was not clearly established law at the time of Rivera-Guadalupe’s arrest. Therefore, the Third Circuit reversed the District Court’s denial of qualified immunity for Det. Pierce and remanded the case for dismissal on that basis. View "Jorge Rivera-Guadalupe v. City of Harrisburg" on Justia Law

Steven Catlin, a California state prisoner, appealed the district court’s denial of his 28 U.S.C. § 2254 habeas corpus petition challenging his 1990 conviction for the murders of his fourth wife, Joyce Catlin, and his adoptive mother, Martha Catlin, as well as his death sentence. Catlin was convicted of murdering three family members with paraquat, a poisonous herbicide. The habeas petition in this case relates to his convictions for the murders of Joyce and Martha and the death sentence for Martha’s murder.The California Supreme Court (CSC) summarily denied Catlin’s first state habeas petition on the merits in 2007 and rejected his second state habeas petition in 2013 as procedurally barred. The district court denied Catlin’s federal habeas petition and his motion for discovery and evidentiary development in 2019, granting a certificate of appealability on several claims.The United States Court of Appeals for the Ninth Circuit reviewed Catlin’s claims under the deferential standard set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Catlin’s habeas petition, concluding that the CSC reasonably rejected Catlin’s claims. The court held that the CSC acted reasonably in rejecting Catlin’s claims of error arising from the state trial judge’s ex parte discussion with a juror, concluding that there was no ineffective assistance of counsel at both the guilt and penalty phases of Catlin’s trial, and determining that there was no violation of due process rights under Brady v. Maryland and Napue v. Illinois.The Ninth Circuit also declined to issue a certificate of appealability for Catlin’s uncertified claim that the state violated his due process rights by withholding exculpatory evidence and presenting false evidence. The court found that no reasonable jurist could debate the district court’s resolution of this claim. View "CATLIN V. BROOMFIELD" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law