Justia Civil Procedure Opinion Summaries

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

Sherita Hicks was mistakenly identified and arrested for an assault she did not commit. Detective Gregory Pamer, leading the investigation, showed the victim, Devante Allen, a photo lineup that included Hicks, whom Allen incorrectly identified as the female assailant. Pamer also discovered that a van used in the assault was registered to Hicks and that the attack was retribution for a prior break-in at her home. Despite later receiving exculpatory information implicating another woman, Pamer proceeded with Hicks' arrest. Hicks was jailed for one night before posting bond, and the charges against her were eventually dismissed.Hicks filed a civil rights lawsuit under 42 U.S.C. § 1983 against multiple parties, including Pamer and Anne Arundel County, alleging unlawful arrest, detention, and malicious prosecution. The case proceeded to trial against Pamer and the County on claims of malicious prosecution and gross negligence. During the trial, a juror was dismissed for violating court instructions by speaking to Hicks, despite objections from Hicks' counsel. The jury ultimately found in favor of Pamer on all counts, leading Hicks to file a motion for a new trial, which was denied.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the district court did not abuse its discretion in dismissing the juror for good cause under Federal Rule of Civil Procedure 47(c). The court also found no reversible error in the jury instructions, which adequately stated the controlling law. The jury's verdict in favor of Pamer on all counts was upheld, and the court did not need to address issues related to punitive damages or the inclusion of the County on the verdict sheet, as there was no underlying liability. View "Hicks v. Anne Arundel County" on Justia Law

Eva Mae Givens applied for Medicaid assistance in Washington, D.C., but the District miscalculated her copay, requiring her to pay an extra $2,000 per month. Givens requested an administrative hearing to contest the miscalculation, but D.C. did not provide a timely hearing as required by federal law. Givens then filed a lawsuit under 42 U.S.C. § 1983, seeking injunctive and declaratory relief for a fair hearing and monetary damages for the overpayments. While the case was pending, D.C. held a hearing, corrected the miscalculation, and sent back-payments to the nursing homes, but not to Givens. Givens passed away shortly after the hearing.The United States District Court for the District of Columbia dismissed the case with prejudice, ruling that the claims were moot because D.C. had provided the hearing and corrected the miscalculation. The court also held that Givens failed to state a claim for relief. Givens' children, who sought to be substituted as plaintiffs, appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the dismissal of the fair-hearing claims as moot but noted that the dismissal should have been without prejudice. The court found that the calculation claim was not moot because Givens had not received compensation for the overpayments she made. However, the court held that the calculation claim failed to plausibly allege a violation of federal rights under § 1983, as Givens did not identify a specific municipal policy or custom that caused the miscalculation.The appellate court vacated the district court's order dismissing the case with prejudice and remanded the case. The district court was instructed to dismiss the moot fair-hearing claims without prejudice and to either dismiss the calculation claim without prejudice or provide a detailed explanation for a dismissal with prejudice. View "Givens v. Bowser" on Justia Law

Law enforcement officers executed a search warrant at Lee Marvin Harris, Sr.'s home, discovering a significant amount of cocaine in an old Cadillac parked in the yard. Harris, Sr. was arrested for possession with intent to distribute and spent five months in pretrial detention before charges were dismissed. He then sued the Town of Southern Pines and the officers involved, alleging malicious prosecution under the Fourth Amendment and fabrication of evidence under the Fourteenth Amendment, claiming officers omitted material evidence from prosecutors and grand juries.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the defendants. The court found that probable cause existed for Harris, Sr.'s arrest based on the discovery of cocaine on his property and dismissed the fabrication of evidence claim, reasoning that such claims are not viable if the plaintiff was not convicted. Harris, Sr. appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and found genuine disputes of material fact regarding whether Harris, Sr. was arrested and charged without probable cause. The court held that the officers were not entitled to qualified immunity for the Fourth Amendment malicious prosecution claim. Additionally, the court determined that a plaintiff who was arrested and detained but not convicted could still state a Fourteenth Amendment fabrication of evidence claim. Consequently, the court reversed the district court's summary judgment on the Fourth Amendment malicious prosecution claim, vacated the summary judgment on the Fourteenth Amendment fabrication of evidence claim, and remanded for further proceedings. The court affirmed the district court's summary judgment on the state law malicious prosecution claim, the failure to intervene claim, and the Monell claim against the Town of Southern Pines and the Chief of Police. View "Harris v. Town of Southern Pines" on Justia Law

An inmate in the Arkansas Department of Corrections (ADC) filed a pro se 42 U.S.C. § 1983 action, alleging that several ADC employees retaliated against him for exercising his First Amendment rights. The inmate claimed retaliation occurred after he filed a grievance, circulated a memorandum encouraging other inmates to file grievances against a new administrative directive, and threatened a lawsuit. The directive in question imposed a three-page limit on non-privileged correspondence between inmates and non-incarcerated individuals. The inmate was charged with rule violations, placed in isolation, and later moved to administrative segregation.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants, concluding that they had valid, non-retaliatory reasons for their actions, as the inmate had violated prison rules. The district court also denied the inmate's request for an extension of time to file his own summary judgment motion, citing a lack of good cause and the age of the case. The inmate appealed both decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment, finding that the inmate’s circulation of the memorandum was protected conduct under the First Amendment and that there was insufficient evidence to demonstrate a security concern justifying the disciplinary actions. The court also found that the district court erred in relying on a written charge of a rule violation that was dismissed on procedural grounds and on the inmate’s deposition testimony given years later. However, the court affirmed the district court’s denial of the inmate’s request for an extension of time to file a summary judgment motion, finding no abuse of discretion. View "Lamar v. Payne" on Justia Law

A high school football coach's contract was not renewed by the Valdosta Board of Education in 2020. The vote split along racial lines, with all white members voting to renew and all black members voting against renewal. The coach believed the decision was racially motivated.In 2020, the coach sued the five black board members individually under 42 U.S.C. §§ 1981 and 1983, seeking monetary damages. The district court denied the board members' motions to dismiss based on qualified immunity, but the Eleventh Circuit reversed, finding the coach failed to state a claim. The case was remanded for dismissal.In 2021, the coach filed a new lawsuit against the same board members and the Board itself, this time under Title VII of the Civil Rights Act of 1964. The new complaint included more detailed allegations but was based on the same core facts. The district court granted summary judgment for the Board, ruling that the new lawsuit was barred by res judicata because the Board was in privity with the individual board members and the two cases involved the same cause of action.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that the Board was in privity with the individual board members because they acted as the Board when they voted not to renew the coach's contract. The court also found that both lawsuits arose from the same nucleus of operative facts, thus meeting the criteria for res judicata. View "Rodemaker v. City of Valdosta Board of Education" on Justia Law

Christopher Drew was arrested after officers responded to a harassment complaint from his neighbor, who reported that Drew had threatened her and her child. When officers arrived at Drew's apartment, they found him in a confrontation with another woman. During the arrest, Officer Hemsted pepper-sprayed Drew without warning after Drew refused to comply with orders and warned the officer not to touch him. Drew later pleaded guilty to second-degree harassment and subsequently sued the officers and the City of Des Moines under 42 U.S.C. § 1983 for excessive force, failure to intervene, and Monell liability.The United States District Court for the Southern District of Iowa granted summary judgment in favor of the defendants, finding that Officer Hemsted's use of force was objectively reasonable. The court concluded that the officers did not violate Drew's Fourth Amendment rights and dismissed all claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Officer Hemsted was entitled to qualified immunity because it was not clearly established that using pepper spray in this context violated Drew's constitutional rights. The court noted that Drew was suspected of a serious crime involving threats of violence and was noncompliant during the arrest. The court distinguished this case from others involving less severe crimes and minimal safety threats. Consequently, the court also found that Officer Ulin and the City of Des Moines were not liable, as they were not on fair notice that their actions were unconstitutional. The Eighth Circuit affirmed the district court's judgment and granted the motion to supplement the record with bodycam footage. View "Drew v. City of Des Moines" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law