Justia Civil Procedure Opinion Summaries

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

Kevin Brooks, an inmate at a federal prison camp, suffered from appendicitis, which was misdiagnosed by medical personnel as constipation and COVID-19. Despite his worsening condition, he was not sent to a hospital for over ten days, resulting in a ruptured appendix and peritonitis. Brooks eventually recovered but experienced severe pain during the ordeal. He filed a lawsuit seeking damages from five federal employees, three of whom treated him and two who were supervisors.The United States District Court for the Northern District of Illinois dismissed Brooks's suit, ruling that it presented a new context to which the doctrine of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics does not extend. The court reasoned that Brooks's case differed from previous Bivens cases, particularly Carlson v. Green, due to the duration of his medical issue and the involvement of supervisory personnel.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's reasoning. The Seventh Circuit held that Brooks's claim did not present a new context, as it was similar to Carlson v. Green, where a prisoner alleged constitutionally inadequate medical care. The court found that the distinctions made by the district court regarding the duration of the medical issue and the involvement of supervisors were not sufficient to create a new context. The Seventh Circuit affirmed the dismissal of claims against the two supervisors but vacated the dismissal of claims against the three treating personnel, remanding the case for further proceedings. View "Brooks v. Richardson" on Justia Law

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

Anna Gristina, the plaintiff-appellant, sought to unseal transcripts related to her 2012 New York State criminal conviction for promoting prostitution. Nearly ten years after her guilty plea, she filed motions before Justice Juan Merchan, requesting the unsealing of several transcripts. After her motion was partially denied and while the decision was under review by higher state courts, Gristina filed a federal suit under 42 U.S.C. § 1983 against Justice Merchan and New York District Attorney Alvin Bragg, seeking declaratory and injunctive relief to unseal three specific transcripts.The United States District Court for the Southern District of New York dismissed Gristina's complaint for lack of subject-matter jurisdiction, citing the Younger abstention doctrine. The district court concluded that it was required to abstain from exercising jurisdiction because the state court order denying the unsealing of transcripts was a pending matter in New York State court involving a judicial function. Alternatively, the district court held that the Rooker-Feldman doctrine prohibited it from reviewing the state court order as it was a final state court judgment.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court properly abstained from exercising jurisdiction under the Younger abstention doctrine. The court found that the state court's order denying the unsealing of transcripts, which was still under review by higher state courts at the time Gristina filed her federal suit, was a pending civil proceeding uniquely in furtherance of the state court's ability to perform its judicial functions. Therefore, Younger abstention was required, and the district court's dismissal of the complaint was affirmed. View "Gristina v. Merchan" on Justia Law

Brian Farabee, who suffers from borderline personality disorder, has spent his adult life in hospitals or prison for crimes committed while hospitalized. He filed a lawsuit under 42 U.S.C. § 1983 against Dr. Robert Gardella, Dr. Christy McFarland, and Daniel Herr, alleging violations of his constitutional rights and the Americans with Disabilities Act. Farabee claimed that the defendants denied him clinically recommended treatment, unnecessarily restrained and isolated him, forcibly medicated him, and discriminated against him.The United States District Court for the Western District of Virginia granted summary judgment in favor of the defendants without allowing Farabee to conduct discovery or ensuring he was informed of Federal Rule of Civil Procedure Rule 56’s requirements. The court concluded that there was no material dispute of fact and that the defendants were entitled to summary judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in granting summary judgment before allowing Farabee to conduct discovery. The appellate court emphasized that summary judgment should only be granted after adequate time for discovery and that the district court should have provided Farabee, a pro se litigant, with an opportunity to gather evidence. The Fourth Circuit reversed and vacated the district court’s summary judgment decision and remanded the case for further proceedings. The appellate court also recommended that the district court appoint counsel to assist Farabee in litigating the case due to its complexity and Farabee’s limited ability to conduct discovery on his own. View "Farabee v. Gardella" on Justia Law

Tracy Langiano alleged that he was shot and injured by Officer Landon Rollins in violation of the Fourth Amendment and that the City of Fort Worth’s policies contributed to this violation. Langiano was accused of sexually abusing his step-granddaughters and left his home after writing a suicide note. He checked into a motel with a loaded handgun, intending to kill himself. His son informed the police about the suicide note and the handgun. Police located Langiano at the motel, and Officer Rollins, without knocking, entered the room. Rollins claimed Langiano pointed a gun at him, prompting Rollins to shoot Langiano multiple times. Langiano disputed pointing the gun at Rollins but admitted holding it.The United States District Court for the Northern District of Texas denied Langiano’s motion to stay the civil suit while criminal charges were pending. The court granted summary judgment in favor of Officer Rollins and the City of Fort Worth, dismissing Langiano’s civil suit. Langiano appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the stay, as Langiano did not demonstrate substantial and irreparable prejudice. The court also affirmed the summary judgment in favor of Officer Rollins, finding that Rollins’ use of force was reasonable given the circumstances and that Langiano’s Fourth Amendment rights were not violated. Additionally, the court held that the warrantless entry into the motel room was justified due to the exigent circumstances of Langiano being armed and suicidal. The court also affirmed the summary judgment in favor of the City, as there was no constitutional violation to support a Monell claim. The district court’s judgment was affirmed. View "Langiano v. City of Fort Worth" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law

The plaintiffs, Thomas Ghelf, Tricia Hansen, Constance and Thomas Klein, Maureen Sommerfeld, and Mississippi Sports and Recreation, Inc. (MSR), own abutting properties in the Town of Wheatland, Vernon County, Wisconsin. They alleged that the Town, its officials, Vernon County, the County Treasurer, and unknown agents and employees engaged in a harassment campaign against them. This included coordinated complaints about their businesses, unlawful arrests, failures to respond to emergency services, excessive property tax assessments, a foreclosure action, and the designation of a private driveway as a public road.The United States District Court for the Western District of Wisconsin dismissed the plaintiffs' tax assessment and road claims for lack of subject matter jurisdiction, abstained from exercising jurisdiction over the foreclosure claims, and dismissed the remaining claims for failure to state a claim. The court held that the Tax Injunction Act and principles of comity barred the tax assessment and foreclosure claims. It also found that the plaintiffs' claims related to events before September 15, 2016, were time-barred by the statute of limitations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal of the tax assessment and foreclosure claims, agreeing that the Tax Injunction Act and comity principles deprived the district court of jurisdiction. The appellate court also upheld the dismissal of claims related to events before September 15, 2016, as time-barred. However, the Seventh Circuit reversed the dismissal of the plaintiffs' road claims, finding that these claims were not barred by claim or issue preclusion. The case was remanded for further proceedings on the road claims, and the court held that Town Chairman Jayne Ballwahn should not be dismissed from the suit at this stage. View "Ghelf v Town of Wheatland" on Justia Law

Misty Coleman alleges that she fell and broke her ankle after slipping on a wet shower floor in a county jail. She pursued constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county, corrections officers, and medical personnel. Coleman claimed that the slippery shower violated the Due Process Clause and that a county policy or custom was behind her poor medical care. She also questioned whether the county could invoke state-law immunity from her negligence claim at the pleading stage.The United States District Court for the Southern District of Ohio dismissed all claims against all parties. The court found that Coleman failed to allege a plausible constitutional violation regarding the slippery shower and did not connect the inadequate medical care to a county policy or custom. The court also held that Ohio law granted immunity to Hamilton County on the negligence claim. The court allowed Coleman to conduct limited discovery to identify unnamed officers and nurses, but her subsequent amended complaint was dismissed as it was filed outside the statute of limitations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's dismissal, holding that Coleman’s claims accrued on the date of her accident and that her amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15. The court also found that Coleman did not meet the requirements for equitable tolling, as she did not allege facts showing that she was intentionally misled or tricked into missing the deadline. The Sixth Circuit affirmed the district court's dismissal of Coleman’s complaint. View "Coleman v. Hamilton County Bd. of County Commissioners" on Justia Law