Justia Civil Procedure Opinion Summaries

Plaintiffs Tiffaney Whitt, on behalf of her minor children, and Jeremiah Parker, Whitt’s adult son, filed a lawsuit against Kearney School District and Durham School Services, L.P., due to racial harassment experienced by Parker and his siblings on a school bus operated by Durham. Plaintiffs alleged a 42 U.S.C. § 1981 claim against Durham, asserting they were third-party beneficiaries of the contract between Kearney and Durham, which required safe, harassment-free transportation.The United States District Court for the Western District of Missouri denied Durham’s motion to dismiss and motion for summary judgment, which challenged the validity of Plaintiffs’ § 1981 claim. Durham then filed a motion to compel arbitration based on an arbitration clause in its contract with Kearney. The district court denied this motion, concluding that Durham waived its right to enforce the arbitration clause by not raising it earlier in the litigation. Durham appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Durham knew of its right to arbitrate, as it possessed the contract containing the arbitration clause, and acted inconsistently with that right by engaging in extensive litigation and discovery before filing the motion to compel arbitration. The court also noted that the district court’s consideration of prejudice to Plaintiffs, although erroneous, did not affect the substantial rights of the parties. The appellate court rejected Durham’s argument that it could not have known to seek arbitration until the district court’s summary judgment ruling and found that Durham’s actions were inconsistent with preserving its right to arbitrate. The court also denied Plaintiffs’ request to adopt a process for certifying interlocutory appeals as frivolous and their request for costs under Fed. R. App. P. 38. View "Parker v. Durham School Services, L.P." on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

Several property management companies advertised their apartment buildings on Facebook, targeting users who are 50 years old or younger. Neuhtah Opiotennione, who is older than 50, did not see these advertisements and claimed that the companies discriminated against her based on her age. She filed a lawsuit seeking a declaratory judgment, a permanent injunction, and damages.The United States District Court for the District of Maryland dismissed Opiotennione’s complaint, ruling that she lacked standing to sue because she had not suffered a concrete and particularized injury in fact. The court found that Opiotennione had not demonstrated how the alleged discrimination personally affected her.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s decision. The Fourth Circuit held that Opiotennione failed to allege a concrete and particularized injury in fact. The court noted that merely being a member of the disfavored age group did not constitute a particularized injury. Additionally, the court found that Opiotennione did not allege that she was personally denied information or housing opportunities by the defendants, as she had not actively sought information from them. The court also rejected her claims of informational and stigmatic injuries, concluding that she had not demonstrated a personal denial of information or a concrete stigmatic injury. Thus, the Fourth Circuit affirmed the district court’s dismissal of the case for lack of standing. View "Opiotennione v. Bozzuto Management Co." on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, "All Lives Matter to Our Lord & Savior Jesus Christ." This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.In the District Court for the Central District of Illinois, Beathard filed a section 1983 action against Larry Lyons, the Athletic Director, and Brock Spack, the head football coach, asserting that his termination violated his First Amendment rights. The defendants moved to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity because it was not clear that Beathard's speech was protected as personal rather than official speech. The district court denied the motion to dismiss, stating that factual development was necessary before resolving the qualified immunity question.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision, indicating that further factual development was needed. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the disputed question. Consequently, the appeal was dismissed for want of appellate jurisdiction. View "Beathard v. Lyons" on Justia Law

Dawn Lui, a longtime employee of the United States Postal Service (USPS), alleged disparate treatment, a hostile work environment, and unlawful retaliation under Title VII of the Civil Rights Act. Lui, a woman of Chinese ethnicity, claimed she was targeted with false complaints and grievances by employees at the Shelton Post Office due to her race, sex, and national origin. She was demoted from her position as Postmaster in Shelton, Washington, to a lower-paying Postmaster position in Roy, Washington, and replaced by a white man. Lui filed an informal discrimination complaint through USPS’s Equal Employment Opportunity (EEO) System and later a formal EEO complaint.The United States District Court for the Western District of Washington granted summary judgment to USPS on all of Lui’s claims. The court found that Lui failed to establish a prima facie case of discrimination, did not exhaust her administrative remedies for her hostile work environment claim, and failed to establish a causal connection for her retaliation claim.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Lui’s disparate treatment claim, holding that Lui established a prima facie case of discrimination by showing she was replaced by a white man, which gave rise to an inference of discrimination. The court also found a genuine dispute of material fact about whether the decision to demote Lui was influenced by subordinate bias.The Ninth Circuit vacated the district court’s summary judgment on Lui’s hostile work environment claim, concluding that Lui exhausted her administrative remedies and remanded the case for the district court to address the merits of this claim. However, the court affirmed the district court’s grant of summary judgment on Lui’s retaliation claim, finding that Lui failed to establish a causal connection between her protected activity and the demotion. View "LUI V. DEJOY" on Justia Law

Michael Chapman, an Alabama inmate, sued prison officials and staff for deliberate indifference to his medical needs, violating the Eighth Amendment. Chapman alleged that an untreated ear infection led to severe injuries, including mastoiditis, a ruptured eardrum, and a brain abscess. He also claimed that the prison's refusal to perform cataract surgery on his right eye constituted deliberate indifference. The district court granted summary judgment for all defendants except the prison’s medical contractor, which had filed for bankruptcy.The United States District Court for the Middle District of Alabama found Chapman’s claim against nurse Charlie Waugh time-barred and ruled against Chapman on other claims, including his request for injunctive relief against Commissioner John Hamm, citing sovereign immunity. The court also concluded that Chapman’s claims against other defendants failed on the merits and dismissed his state-law claims without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court reversed the district court’s determination that Chapman’s claim against Waugh was time-barred, finding that Chapman’s cause of action accrued within the limitations period. The court vacated the district court’s judgment for Waugh and remanded for reconsideration in light of the recent en banc decision in Wade, which clarified the standard for deliberate indifference claims. The court also vacated the judgment for Hamm on Chapman’s cataract-related claim for injunctive relief, as sovereign immunity does not bar such claims. Additionally, the court vacated the summary judgment for all other defendants due to procedural errors, including inadequate notice and time for Chapman to respond, and remanded for further consideration. View "Chapman v. Dunn" on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

A man on probation was subject to a domestic violence protective order (DVPO) requiring him to give a day's notice to security personnel before visiting the medical center where his former girlfriend worked. The woman alleged that the man violated this notice provision multiple times over three years, causing her severe emotional distress and job loss. The probation officer investigated the alleged violations but decided not to revoke the man's probation or penalize him.The Superior Court of Alaska, Third Judicial District, Anchorage, granted summary judgment for the State, finding no genuine issues of material fact, that the probation officer fulfilled her duty of reasonable care, and that her actions were shielded by discretionary function immunity. The woman appealed the decision.The Supreme Court of the State of Alaska reviewed the case and concluded that there was no genuine issue of material fact to preclude summary judgment for the State regarding whether the probation officer fulfilled her operational duty to investigate the alleged violations. The court further concluded that the probation officer's subsequent decisions were shielded from suit by discretionary function immunity. The Supreme Court affirmed the superior court's grant of summary judgment. View "Smith v. Department of Corrections" on Justia Law

Manuel Antonio Herrera Hernandez, an inmate at Waupun Correctional Institution, alleged that his legal paperwork was misplaced during his temporary transfer to restrictive housing in October 2021. Before entering restrictive housing, Hernandez surrendered his personal property, including legal documents. Upon return, he signed a form indicating receipt of all his property but later realized his legal paperwork was missing. Hernandez claimed that Sergeant Theresa Lee assured him he would receive his paperwork once he returned to the general population, but it remained missing. Hernandez filed a grievance, which was rejected as untimely by the complaint examiner, and the warden affirmed this decision.Hernandez then filed a lawsuit in federal court under 42 U.S.C. § 1983, claiming that Sergeant Lee and other prison officials deprived him of his right of access to the courts. The United States District Court for the Eastern District of Wisconsin granted summary judgment for the defendants, ruling that Hernandez failed to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. Hernandez argued that his time in restrictive housing complicated his ability to file a timely grievance and that he was not provided a handbook explaining the grievance process in Spanish. The court found that Hernandez did not preserve the handbook issue in the district court. However, the court determined that there were genuine disputes regarding whether Hernandez had any reason to file a grievance before learning his paperwork was missing and whether Sergeant Lee's assurances excused his failure to exhaust administrative remedies.The Seventh Circuit reversed the district court's summary judgment and remanded the case for an evidentiary hearing to resolve the factual disputes regarding the exhaustion of administrative remedies. The court also noted the need to determine the personal involvement of the other defendants in the alleged deprivation. View "Hernandez v Lee" on Justia Law

Michael Horton, an Alabama prisoner, filed a pro se lawsuit against two correctional officers, alleging that they subjected him to an unconstitutional body-cavity search. Horton claimed that during an institution-wide search, he was ordered to strip and undergo a body-cavity search in the presence of female officers, which violated his religious beliefs. Horton's complaint included claims under the First and Fourteenth Amendments and sought injunctive relief.The United States District Court for the Southern District of Alabama required the officers to provide documents and evidence, and Horton was given an opportunity to respond. The district court granted summary judgment in favor of the officers and dismissed Horton’s lawsuit with prejudice. Horton argued that the district court erred by not allowing him to amend his complaint to include new factual allegations before granting summary judgment.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the rule requiring a pro se plaintiff to be given an opportunity to amend their complaint before dismissal with prejudice applies only in the context of Rule 12(b)(6) dismissals, not summary judgment. The court found that the district court did not err in granting summary judgment without sua sponte allowing Horton to amend his complaint. The court also noted that Horton had been given sufficient notice and opportunity to respond to the summary judgment motion but failed to provide a signed declaration with new facts.The Eleventh Circuit affirmed the district court's judgment, concluding that Horton was not entitled to amend his complaint sua sponte before the summary judgment was granted. View "Horton v. Captain Gilchrist" on Justia Law