Justia Civil Procedure Opinion Summaries

In 2017, when Plaintiff was in elementary school, he was diagnosed with autism spectrum disorder, language disorder, and anxiety. Between 2017 and 2021, Plaintiff's parents asked Defendant School District at least four times to allow Plaintiff to be accompanied at school by an ABA therapist, at no cost to the school district. The school district denied the first three requests and did not respond to the fourth request.Plaintiff's father filed a three-count complaint against the school under the Rehabilitation Act on behalf of his child. The complaint did not mention the Individuals with Disabilities in Education Act. The district court denied Plaintiff's claim based on his failure to exhaust administrative remedies. Plaintiff appealed.The Fourth Circuit held that the district court erred in concluding Plaintiff needed to exhaust administrative remedies under the IDEA before bringing this suit because his complaint was not brought under the IDEA. View "Z. W. v. Horry County School District" on Justia Law

Younger claims that during his pretrial detention in a Maryland state prison, Lieutenant Dupree ordered guards to attack him. Younger sued Dupree for damages under 42 U.S.C. 1983. The district court denied Dupree’s summary judgment motion, finding no dispute that the Maryland prison system had internally investigated Younger’s assault, which satisfied Younger’s exhaustion obligation. At trial, Dupree did not present evidence relating to his exhaustion defense. The jury found Dupree and four codefendants liable and awarded Younger $700,000 in damages. The Fourth Circuit—bound by its prior holding that any claim or defense rejected at summary judgment is not preserved for appellate review unless it was renewed in a post-trial motion—dismissed an appeal.The Supreme Court vacated. A post-trial motion under Federal Rule of Civil Procedure 50 is not required to preserve for appellate review a purely legal issue resolved at summary judgment. The factual record developed at trial supersedes the record existing at the time of the summary-judgment motion; that is not true for pure questions of law resolved on summary judgment, which are not “supersede[d]” by later developments in the litigation and merge into the final judgment. A reviewing court does not benefit from having a district court reexamine a purely legal pretrial ruling. While an interlocutory order denying summary judgment is typically not immediately appealable, 28 U.S.C. 1291 does not insulate interlocutory orders from appellate scrutiny but rather delays their review until final judgment. The Court did not decide whether Dupree's issue on appeal was purely legal, and remanded for the Fourth Circuit to evaluate that question. View "Dupree v. Younger" on Justia Law

Plaintiffs brought multiple claims against various defendants pursuant to 42 U.S.C. Section 1983. As relevant here, they asserted two general categories of claims—that the officers used excessive force in executing the search warrant and that the search and seizure were unlawful. As against the individual officers, Plaintiffs asserted both direct claims and claims premised on failure to intervene. And as against Lieutenants, Plaintiffs asserted that the two lieutenants are directly liable for excessive-force and search-and-seizure and liable on a failure to supervise theory. Finally, Plaintiffs also asserted wrongful death and survival as separate “causes of actions,” in their words. Several of the officers moved to dismiss, asserting qualified immunity.   The Fifth Circuit affirmed in part, reversed in part, and vacated in part. The court affirmed the aspects of the judgment denying the motions to dismiss the excessive-force claims asserted against several co-Defendants and denying one Lieutenant’s motion to dismiss as to Plaintiffs’ excessive force and search-and-seizure claims premised on a failure-to-supervise theory.   The court reversed the district court’s ruling denying the Lieutenant’s motion to dismiss the excessive force and search-and-seizure claims based on direct liability. The court concluded that this was error because the Lieutenant was not personally involved in obtaining the search warrant or in effectuating the search. “Personal involvement is an essential element” of demonstrating liability under Section 1983. View "Tuttle v. Sepolio" on Justia Law

Plaintiff obtained a $425,562 jury verdict in his favor on his claim that the California Department of Tax and Fee Administration (the Department) retaliated against him for filing an internal complaint with its Equal Opportunity Office (EEO). The Department appealed, contending that four erroneous evidentiary rulings by the trial court deprived it of a fair trial.   The Second Appellate District reversed. The court agreed that the trial court erred in admitting evidence about activity that occurred before the filing of his EEO complaints. The court also concluded that admission of the first EEO complaint and supplement was prejudicial and prevented the Department from receiving a fair trial. The court explained that there is no doubt that the fact that Plaintiff filed an EEO complaint for age and race discrimination is highly relevant. It is the protected activity needed for his claim; more colloquially, it provides a motive for the retaliation. The details of the discrimination are not relevant. This was not a trial about whether Plaintiff’s co-worker engaged in race or age discrimination; Plaintiff waived those claims in the prior settlement agreement. Accordingly, the court reversed the judgment and remanded for further proceedings. The court wrote that it need not and does not reach the Department’s other claims of error. View "Kourounian v. Cal. Dept. of Tax & Fee Administration" on Justia Law

Plaintiff is a deaf man who can understand only about 30% of verbal communication through lipreading. He communicates primarily through American Sign Language (ASL). Plaintiff worked for O’Reilly Auto Parts (O’Reilly) as an inbound materials handler. He claims that the company discriminated against him in violation of Title I of the Americans with Disabilities Act (ADA) because it did not provide him with the reasonable accommodations that he requested for his disability. He alleged that he requested but did not receive an ASL interpreter for various meetings, training, and a company picnic. He also alleged that he asked for text messages summarizing nightly pre-shift meetings but did not receive them either. The district court, acting by consent through a magistrate judge, granted O’Reilly’s motion for summary judgment on Plaintiff’s ADA claim.   The Eleventh Circuit reversed the district court’s grant of summary judgment in favor of O’Reilly. The court remanded for further proceedings involving Plaintiff’s claim that O’Reilly violated the ADA by failing to provide him with reasonable accommodations regarding the nightly pre-shift safety meetings and regarding his disciplinary proceedings involving attendance issues. The court concluded that genuine issues of material fact do exist about whether two of Plaintiff’s requested accommodations relate to his essential job functions and whether the failure to provide those two accommodations led to an “adverse employment decision.” If Plaintiff’s allegations turn out to be the actual facts, there was a violation of Title I of the ADA, and that means summary judgment against him was inappropriate. View "Teddy Beasley v. O'Reilly Auto Parts" on Justia Law

Plaintiff was arrested for driving while intoxicated. She sued under 42 U.S.C. Section 1983 and related state laws. The district court granted summary judgment to Defendants, dismissing all of Plaintiff’s claims. On appeal, Plaintiff contests the summary judgment for the Section 1983 claims of false arrest and excessive force along with the state law claims of false arrest, excessive force, negligence, and vicarious liability.   The Fifth Circuit affirmed. The court concluded that the officers had probable cause to arrest Plaintiff for driving while intoxicated. The court explained that the following facts are confirmed: (1) A witness reported to the police that Plaintiff was driving in a dangerous manner;(2) there is video footage of Plaintiff’s car swerving out of the lane and recorded audio of the officers noting the swerve, and (3) The officers could not conclusively determine that she had not taken drugs. Those facts alone are sufficient to give rise to probable cause that Plaintiff was driving while intoxicated. Further, the court found that the officer’s limited use of force (in such a short time frame) to restrain Plaintiff and place her in handcuffs as a response to Plaintiff’s perceived resistance does not amount to excessive force.   Moreover, the court found that the officers had probable cause to arrest Plaintiff for driving while intoxicated, and accordingly, there was no false arrest. Finally, because Plaintiff’s underlying state law claims were properly dismissed, there is no basis for her vicarious liability claim against the municipal Defendants. View "Scott v. City of Mandeville, et al" on Justia Law

Plaintiff is the former Vice President of Program and Community of the Eugene and Agnes E. Meyer Foundation. She received largely positive feedback during her tenure, but less than two years after she was hired, the CEO of the Foundation fired her for purported interpersonal and communication-related issues. Plaintiff, who is African-American, believes these stated reasons were pretext to mask discriminatory animus. Plaintiff and the Foundation signed a severance agreement, under which Plaintiff agreed to release employment-related claims against the Foundation and its employees, and which contained a mutual non-disparagement clause. But roughly a month after Plaintiff was fired, the CEO told another leader in the non-profit space that Plaintiff was let go because she was “toxic,” created a “negative environment.” Plaintiff sued the Foundation and its CEO for breaching the severance agreement, for doing so in a racially discriminatory manner in violation of 42 U.S.C. Section 1981, and for defaming her. The district court dismissed all three claims.   The DC Circuit held that the district court erred in dismissing all three claims. As to Plaintiff’s breach of contract claim, the non-disparagement clause could reasonably be interpreted to preclude the Foundation from disparaging Plaintiff, and dismissal under Federal Rule of Civil Procedure 12(b)(6) is therefore inappropriate. As to her Section 1981 claim, the court found that she has plausibly alleged a prima facie case that the Foundation, through the CEO, breached the severance agreement due to racial animus. And lastly, the CEO’s statements are not protected by the common interest privilege, which requires a showing of good faith on the part of the speaker. View "Terri Wright v. Eugene & Agnes E. Meyer Foundation" on Justia Law

Over a four-day stretch during his incarceration at Walker State Prison in Georgia, Plaintiff failed to receive his prescribed seizure medication. On the fourth night, Plaintiff had two seizures that he claimed caused permanent brain damage. Proceeding under 42 U.S.C. Section 1983, Plaintiff sued five prison employees, alleging that they were deliberately indifferent to his medical needs in violation of the Eighth Amendment. The district court granted summary judgment to all five defendants on the ground that they were entitled to qualified immunity. Shortly thereafter, Plaintiff died from causes unrelated to the seizures that he suffered while in prison. His sister pursued his claims on appeal as the personal representative of his estate.   The Eleventh Circuit affirmed. The court concluded that none of them was deliberately indifferent to Plaintiff’s medical needs and, accordingly, that none of them violated the Eighth Amendment—and, accordingly, that the district court was correct to grant all of them summary judgment. The court held that a deliberate-indifference plaintiff must prove (among other things) that the defendant acted with “more than gross negligence.” The court wrote that it echoes the district court’s lament that Defendants’ “careless actions and their systemic communication failures caused Plaintiff serious suffering” and “irreparably altered his life.” And the court reiterated that “while engaged in the business of prison medicine”—no less so than on the outside, so to speak—“the essential command of the Hippocratic Oath is ‘first, do no harm.’” Even so, the bar to proving an Eighth Amendment deliberate-indifference claim is appropriately high, and the court concluded that Plaintiff hasn’t met it. View "Betty Wade v. Georgia Correctional Health, LLC, et al" on Justia Law

In this § 1983 lawsuit, Plaintiff sought declaratory and injunctive relief to stop ongoing physician disciplinary proceedings in which the Iowa Board of Medicine (“the Board”), represented by the Attorney General of Iowa, charges Wassef with violating Iowa law by inappropriately accessing patient records during his residency at the University of Iowa Hospitals and Clinics (“UIHC”). The Board is responsible for regulating the practice of medicine in Iowa and is authorized to discipline doctors who do not meet minimum practice standards established by the Board and by the Iowa Legislature. Plaintiff alleged the ongoing proceedings violate federal law -- the Health Insurance Portability and Accountability Act (“HIPAA”). The district court dismissed the action, concluding that it must abstain pursuant to Younger v. Harris, 401 U.S. 37 (1971). The court also dismissed the due process claim because Plaintiff failed to exhaust state remedies and failed to plausibly allege a claim.   The Eighth Circuit modified the dismissal to be without prejudice, vacated the district court’s due process ruling, and granted Plaintiff’s unopposed Motion To Substitute Parties. The court concluded the district court properly abstained under Younger. However, as the state disciplinary proceedings are ongoing, the court should have declined to reach the merits of the due process claim, which Plaintiff can litigate in the state proceedings. Accordingly, the court modified the dismissal to be without prejudice, which is usually the proper disposition when a court abstains under Younger. View "Shafik Wassef v. Dennis Tibben" on Justia Law

Plaintiff brought an action against several police officers and the City of New York, asserting various claims under 42 U.S.C. Section 1983 and New York state law based on his allegation that police officers falsely claimed that they observed him selling drugs. After his criminal trial, Plaintiff was acquitted of a drug sale charge and convicted of a drug possession charge. Plaintiff subsequently filed this civil action, and the district court dismissed all of Plaintiff’s claims.   The Second Circuit affirmed in part and vacated in part the district court’s dismissal of Plaintiff’s claims and remanded. The court wrote that it agreed with the district court’s dismissal of all of the federal claims except for the dismissal of Plaintiff’s due process claim based on the use of fabricated evidence regarding the drug sale charge of which he was acquitted. Specifically, the district court erred in concluding that because Plaintiff was arrested, detained, prosecuted, and convicted for drug possession simultaneous to the drug sale proceedings, this precludes, as a matter of law, his ability to plead a deprivation of liberty caused by the drug sale prosecution. Because the prosecution of an individual based on fabricated evidence may itself constitute a deprivation of liberty, even in the absence of custody or a conviction, Plaintiff was not required to show that his drug sale prosecution resulted in additional custody or a conviction in order to sufficiently allege a claim at the pleading stage. View "Barnes v. City of New York" on Justia Law