Justia Civil Procedure Opinion Summaries

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 Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses.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

Richard Hoffer filed a lawsuit against the City of Yonkers, the City of Yonkers Police Department, and several individual police officers under 42 U.S.C. § 1983, claiming that the officers used excessive force during his arrest. The case went to trial, and the jury returned a verdict in favor of the officers. Hoffer appealed the district court's decision, specifically challenging the court's denial of his request for an adverse inference instruction due to a missing video of him being tased.The United States District Court for the Southern District of New York presided over the initial trial. Hoffer requested an adverse inference instruction based on the missing video, arguing that the video was crucial evidence. The district court denied this request, finding insufficient evidence to prove that the video was intentionally destroyed to deprive Hoffer of its use in litigation. The jury ultimately found in favor of the officers, and Hoffer's subsequent motion to set aside the verdict was also denied.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that to impose sanctions under Federal Rule of Civil Procedure 37(e)(2), it must be proven by a preponderance of the evidence that a party acted with an "intent to deprive" another party of the lost information. The court clarified that the lesser "culpable state of mind" standard, which includes negligence, does not apply to Rule 37(e)(2) sanctions. Applying this standard, the Second Circuit concluded that the district court did not err in denying Hoffer's request for an adverse inference instruction and affirmed the judgment of the district court. View "Hoffer v. Tellone" on Justia Law

In 2016, the DOJ sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act, alleging unconstitutional conditions in the county's detention facilities. A consent decree was established to address these issues, but disputes over compliance led to ongoing litigation. The DOJ claimed the county failed to comply, citing worsening conditions, while the county sought to terminate the decree. The district court found partial compliance, held the county in contempt, and issued a new injunction focusing on the Raymond Detention Center (RDC). As a sanction, the court appointed a receiver to oversee compliance.The district court's decision was based on findings of ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, and poor conditions. The court noted that despite some improvements, many issues persisted, such as severe understaffing and inadequate supervision, contributing to violence and unsafe conditions. The court also found deficiencies in use-of-force training, incident reporting, and investigations, which exacerbated the problems.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to retain the new injunction, finding that ongoing constitutional violations justified continued prospective relief. However, the appeals court found the new injunction overly broad in some respects and held that the district court did not abuse its discretion in appointing a receiver. The court also noted that the district court failed to make sufficient need-narrowness-intrusiveness findings for each of the receiver's duties as required under the Prison Litigation Reform Act. Consequently, the appeals court affirmed the district court's decision in part, reversed in part, and remanded for further proceedings to address these issues. View "United States v. Hinds County Board of Supervisors" on Justia Law

John Doe, an individual with a serious mental illness, sued James V. McDonald, M.D., New York’s Commissioner of Health, and other defendants, seeking declaratory and injunctive relief under the Americans with Disabilities Act, the Rehabilitation Act, the Fair Housing Act, and Article 78 of the New York Civil Practice Law and Rules. Doe alleged that New York State regulations discriminated against him by preventing his readmission to Oceanview Manor Home for Adults, a Transitional Adult Home (TAH) where he previously resided. After filing the suit, the State allowed Doe to return to Oceanview, amended the regulations to permit readmission of former TAH residents with serious mental illness, and removed Oceanview’s classification as a TAH.The United States District Court for the Northern District of New York denied the State’s motion for summary judgment, which argued that Doe lacked standing. The district court granted the State leave to file an interlocutory appeal. On appeal, the State contended that the district court erred in finding standing because Doe lacked a concrete plan to leave and seek readmission to Oceanview.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the State’s jurisdictional challenge should be assessed as a question of mootness, not standing, because it addressed events occurring after Doe filed the suit. The court found that Doe’s suit was moot because the State had allowed Doe to return to Oceanview, amended the regulations, and removed Oceanview’s TAH classification. Consequently, there was no reasonable expectation that the alleged violation would recur.The Second Circuit dismissed the appeal, vacated the district court’s order, and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "Doe v. McDonald" on Justia Law

Following public outcry over "Pride Month" displays in St. Tammany Parish's public libraries, the Parish Council passed a resolution that vacated the terms of the Library Board of Control members, staggered those terms in accordance with Louisiana law, and appointed new Board members. Three ousted Board members—Anthony Parr, Rebecca Taylor, and William McHugh, III—sued under 42 U.S.C. § 1983, asserting viewpoint-discrimination, free-speech, retaliation, and substantive-due-process claims against the Council and Councilman David Cougle. They sought declaratory and injunctive relief to prevent the resolution from taking effect.The United States District Court for the Eastern District of Louisiana ruled that the legislative privilege was inapplicable because the resolution was not "legislative" in nature. Defendants brought an interlocutory appeal challenging this ruling. Before addressing the legislative privilege issue, the United States Court of Appeals for the Fifth Circuit examined whether the plaintiffs had standing to bring their claims.The Fifth Circuit concluded that the plaintiffs lacked standing. The court found that the plaintiffs' alleged speech-related injuries were not particularized, as they were tied to their positions as Board members and affected all members equally. Additionally, the court determined that the plaintiffs' alleged reputational injuries were neither fairly traceable to the defendants' conduct nor redressable by a favorable decision. Consequently, the court vacated the district court's order and remanded with instructions to dismiss the plaintiffs' claims for lack of subject matter jurisdiction. View "Parr v. Cougle" on Justia Law

Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law