Justia Civil Procedure Opinion Summaries

Following the fatal police shooting of Daunte Wright, protests erupted in Brooklyn Center, Minnesota. Sam Wolk, a protester, filed a lawsuit under 42 U.S.C. § 1983, alleging First and Fourth Amendment violations and civil conspiracy against various law enforcement officials and agencies. Wolk claimed he was injured by tear gas, flashbang grenades, pepper spray, and rubber bullets used by officers during the protests, resulting in chronic knee pain.The United States District Court for the District of Minnesota denied the defendants' motions to dismiss most of Wolk's claims but dismissed his Fourteenth Amendment due process claim. The defendants appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of the Minnesota Department of Natural Resources' (DNR) motion to dismiss, citing Eleventh Amendment immunity. The court also reversed the denial of qualified immunity for former Brooklyn Center Police Chief Tim Gannon, as he had resigned before Wolk's injuries occurred. Additionally, the court found that the Fourth Amendment claims for excessive force and failure to intervene were not clearly established as constitutional violations at the time of the incident, granting qualified immunity to the supervisory defendants on these claims.However, the court affirmed the district court's denial of qualified immunity for the First Amendment retaliation claims against the supervisory defendants, except for Gannon. The court found that more facts were needed to determine whether the officers' actions were driven by retaliatory animus. The court also reversed the district court's denial of the supervisory defendants' motion to dismiss the civil conspiracy claims, finding the allegations insufficient to show a meeting of the minds.The court reversed the district court's denial of the municipal defendants' motion to dismiss the Fourth Amendment and conspiracy claims but lacked jurisdiction over the First Amendment retaliation claim against the municipal defendants. The case was remanded for further proceedings consistent with the opinion. View "Wolk v. Hutchinson" on Justia Law

Emilee Carpenter, a wedding photographer, filed a preenforcement challenge against New York’s public accommodations laws, which prohibit discrimination based on sexual orientation. Carpenter argued that these laws violated her First and Fourteenth Amendment rights by compelling her to provide photography services for same-sex weddings, which she claimed conflicted with her religious beliefs. She sought declaratory and injunctive relief, including a preliminary injunction to prevent enforcement of the laws against her.The United States District Court for the Western District of New York dismissed all of Carpenter’s claims. The court found that Carpenter had not sufficiently pled that the public accommodations laws violated her rights to free speech, free association, free exercise of religion, or the Establishment Clause. The court also rejected her claims that the laws were unconstitutionally overbroad or vague. Consequently, the court denied her request for a preliminary injunction as moot.The United States Court of Appeals for the Second Circuit reviewed the case. Following the Supreme Court’s decision in 303 Creative LLC v. Elenis, the appellate court agreed that Carpenter had plausibly stated a free speech claim. However, the court denied her request for a preliminary injunction at this stage, remanding the case to the district court for further proceedings to develop a factual record. The appellate court affirmed the district court’s dismissal of Carpenter’s other claims, including those related to free association, free exercise of religion, the Establishment Clause, and vagueness. The court concluded that the public accommodations laws were neutral, generally applicable, and did not provide for individualized exemptions that would undermine their general applicability. The court also found that Carpenter had waived her overbreadth claim due to inadequate pleading and briefing.The Second Circuit thus affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings. View "Carpenter v. James" on Justia Law

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

The case revolves around the tragic death of sixteen-year-old Peyton Alexander Ham. His mother, Kristee Ann Boyle, acting as the representative of his estate, filed a lawsuit against State Trooper Joseph Charles Azzari Jr. for excessive force under 42 U.S.C. § 1983, and for assault, battery, and intentional infliction of emotional distress under Maryland state law. The incident occurred when Azzari responded to a dispatch reporting a suspicious man with a gun. Upon arrival, Azzari encountered Ham, who he believed was holding a gun. Azzari fired at Ham, who was actually holding a replica of a Sig Sauer. Azzari then noticed Ham had a knife and fired additional shots, resulting in Ham's death.The district court denied Boyle's request for additional time for discovery and granted Azzari's pre-discovery motion for summary judgment. The court determined that the evidence Boyle sought could not create a triable issue of fact regarding her claims and held that Azzari was entitled to summary judgment because his actions were reasonable even under Boyle’s proffered account of the relevant events.The United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court concluded that discoverable evidence could create a material dispute of fact and thus the district court abused its discretion in denying Boyle an opportunity to conduct discovery. The court did not assess the lower court's determination on the merits, but reversed its denial of Boyle’s motion for discovery, vacated its grant of summary judgment to Azzari as premature, and remanded the case for additional proceedings. View "Boyle v. Azzari" on Justia Law

The case involves Johnnie Simmons, Jr., who filed a pro se action against Hampton Roads Regional Jail corrections officers R. Whitaker, Benjamin Hull, and Derrick Brown. Simmons claimed that during an incident on February 8, 2019, Officer Whitaker choked him, which was caught on videotape. The district court granted summary judgment to Officers Hull and Brown, finding that their conduct did not violate the Eighth Amendment. Simmons appealed the decision.The district court had dismissed Officer Whitaker from the case due to lack of service. Officers Hull and Brown filed motions for summary judgment, arguing that the video footage and multiple officer affidavits established that Simmons could not prevail on his § 1983 bystander liability claims. The district court granted summary judgment for the defendants, crediting the video and the officers’ version of the event.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its summary judgment analysis. The court held that the video evidence did not blatantly contradict Simmons's account, and the district court improperly ignored material admissible evidence in Simmons’s affidavit. The court also found that the district court applied the wrong legal standard, using the Eighth Amendment standard instead of the Fourteenth Amendment standard applicable to pre-trial detainees. The court affirmed in part, reversed in part, and remanded in part the district court's decision. View "Simmons v. Whitaker" on Justia Law

Samantha Peifer, an employee of the Pennsylvania Board of Probation and Parole, filed a lawsuit against her employer alleging pregnancy discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Pregnancy Discrimination Act. Peifer, who was diagnosed with multiple sclerosis and later became pregnant, requested accommodations from her employer due to her inability to perform certain tasks. Her requests were initially denied, but later granted after she filed a charge with the Equal Employment Opportunity Commission (EEOC). However, she was not allowed to work from home as requested due to her high-risk pregnancy and exposure to COVID-19. Peifer eventually resigned, citing discriminatory treatment, and filed additional charges with the EEOC.The United States District Court for the Eastern District of Pennsylvania granted the Board's motion for summary judgment, concluding that Peifer could not establish a prima facie case for any of her claims. Peifer appealed this decision.The United States Court of Appeals for the Third Circuit affirmed in part and vacated in part the District Court's decision. The Court of Appeals agreed with the lower court that Peifer's claims partly failed but concluded that the District Court was best situated to analyze the impact of the Supreme Court’s recent holding in Muldrow v. City of St. Louis on whether Peifer makes out a prima facie case under an adverse employment action theory. The Court of Appeals also concluded that Peifer makes out a prima facie case of pregnancy discrimination based on the Board’s denials of her light-duty requests under a failure to accommodate theory. The case was remanded for further analysis on Peifer’s adverse employment theory and failure to accommodate theory, while the District Court’s decisions on Peifer’s constructive discharge allegation and retaliation claim were affirmed. View "Peifer v. Pennsylvania Board of Probation and Parole" on Justia Law

In April 2018, Benjamin Evans was shot and killed by Police Deputy Brian Krook in Lake Elmo, Minnesota, after Evans knelt in a crosswalk with a loaded gun pointed at his own head. Following a criminal trial, Krook was acquitted of a second-degree manslaughter charge. Subsequently, Evans' father, William O. Evans, Jr., filed a civil lawsuit against Krook under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. Krook sought summary judgment based on qualified immunity, a defense unavailable when an officer uses deadly force against someone who does not pose an immediate threat of serious physical harm to another.The District Court for the District of Minnesota denied Krook's motion for summary judgment, citing genuine factual disputes over whether Evans' gun was ever pointed at the officers and whether Evans posed an immediate threat to them. Krook appealed this decision, challenging the denial of qualified immunity.The United States Court of Appeals for the Eighth Circuit, in reviewing the case, first addressed the question of jurisdiction. The court noted that it did not have jurisdiction to review the district court's determination regarding evidence sufficiency, i.e., what facts a party may or may not be able to prove at trial. The court's jurisdiction was limited to the purely legal question of whether the conduct that the district court found was adequately supported in the record violated a clearly established federal right.The court found that the availability of qualified immunity in this case hinged on whether Krook acted reasonably under the circumstances by shooting Evans because Evans either pointed his gun at another or otherwise wielded his gun in a menacing fashion. The court concluded that the inconclusive nighttime videos of Evans' actions did not clearly contradict the district court's factual determinations. Therefore, resolving the underlying factual dispute was beyond the court's limited review. As such, the court dismissed the appeal, stating it lacked the jurisdiction to resolve it. View "Evans v. Krook" on Justia Law

A group of plaintiffs sued multiple defendants, including white nationalists, white supremacists, and neo-Nazis, for their roles in the violent "Unite the Right" rally in Charlottesville, Virginia, in 2017. The plaintiffs alleged that the defendants conspired to commit racially motivated violence. A jury awarded the plaintiffs over $26 million in damages, including a historic $24 million in punitive damages. However, the district court reduced the punitive damages to $350,000, applying Virginia's punitive damages cap across all plaintiffs.The defendants appealed, challenging the district court's decision to hold them jointly and severally liable for the compensatory damages award. The plaintiffs cross-appealed, challenging the district court's application of Virginia's punitive damages cap.The United States Court of Appeals for the Fourth Circuit affirmed the district court's imposition of joint-and-several liability for the compensatory damages. However, the court held that Virginia's punitive damages cap applies on a per-plaintiff basis, not across all plaintiffs. Therefore, the court vacated the district court's ruling on the punitive damages cap and remanded the case with instructions to apply the cap accordingly. View "Sines v. Hill" on Justia Law

The case involves the Tennessee Conference of the National Association for the Advancement of Colored People (NAACP) challenging a state policy that requires some convicted felons to submit additional documentation to confirm their eligibility to vote. The NAACP argued that this policy violated the National Voter Registration Act (NVRA). A district court agreed with the NAACP and permanently enjoined the policy in the middle of the 2024 election cycle. Tennessee's Secretary of State and Coordinator of Elections appealed this decision and sought a stay of the injunction pending appeal.The district court's decision was based on the finding that the NAACP had standing to challenge the policy and that the policy violated the NVRA. The court held that the policy was unnecessary for determining the eligibility of those with felony convictions as the state had other information at its disposal to make that decision.The United States Court of Appeals for the Sixth Circuit granted the stay for two reasons. First, the injunction triggered the Supreme Court’s “Purcell principle,” which instructs federal courts not to disrupt state election rules close to an election. Second, the court found that the NAACP likely did not present enough evidence to prove its standing to challenge the Documentation Policy. The court concluded that the NAACP's claim that the policy forced it to divert its resources to help those convicted of felonies track down the records they need to register was not supported by specific facts. View "Tennessee Conference of the NAACP v. Lee" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law