Justia Civil Procedure Opinion Summaries

Articles Posted in Civil Rights
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In the case between Jennifer Harris and FedEx Corporate Services, Inc., Harris alleged race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964. The United States Court of Appeals for the Fifth Circuit found that Harris's § 1981 claims were time-barred under her employment contract, making them fail as a matter of law. However, the court found sufficient evidence to support the jury’s verdict for Harris on her Title VII retaliation claim. In view of Title VII’s $300,000 cap on damages and the evidence presented at trial, the court remitted Harris’s compensatory damages to $248,619.57 and concluded she was not entitled to punitive damages. FedEx was not entitled to a new trial because of the court’s evidentiary ruling. View "Harris v. FedEx Corporate Services" on Justia Law

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In March 2019, the Waxahachie Police Department (WPD) SWAT Team mistakenly executed a search warrant on the wrong house, which was the home of Karen Jimerson, James Parks, and their two young children, instead of the intended target house. The error was due to Mike Lewis, the WPD SWAT Team Commander, incorrectly identifying the target house. The plaintiffs sued the officers under Section 1983 for violations of the Fourth Amendment and several state laws. The United States Court of Appeals for the Fifth Circuit reversed the district court's denial of summary judgment to Lewis on the issue of qualified immunity. The appellate court held that while Lewis's efforts to identify the correct residence were deficient, they did not violate clearly established law. The court found no genuine disputes of material fact, and it concluded that the disputed issue was one of law. The case was remanded for dismissal. View "Jimerson v. Lewis" on Justia Law

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The case involves an appeal by a plaintiff against the dismissal of his lawsuit against the City of Buffalo and some of its police officers. The plaintiff was arrested and charged with violating a city noise ordinance after he shouted at a police officer, who was driving without headlights, to turn his lights on. The plaintiff filed a lawsuit, asserting that his arrest violated his First Amendment right to free speech and amounted to false arrest and malicious prosecution.The United States Court of Appeals for the Second Circuit found that the district court erred in ruling that the plaintiff's shout was not protected by the First Amendment, given that it was a warning about a public safety issue. The court further concluded that there were genuine issues of fact concerning whether there was probable cause to arrest the plaintiff, which should have been resolved by a jury rather than at summary judgment.The court vacated the part of the district court's judgment dismissing the plaintiff's claims of false arrest, malicious prosecution, and First Amendment retaliation, as well as his claims related to failure to intervene and respondeat superior. The court affirmed the part of the district court's dismissal of the plaintiff's claim that the noise ordinance was unconstitutional as applied to him. The case was remanded for trial on the reinstated claims. View "Rupp v. City of Buffalo" on Justia Law

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In this case, the Supreme Court of the State of Nevada considered whether the Nevada State Engineer had the authority to combine multiple existing hydrographic basins into one "superbasin" for the purposes of water administration and management based on a shared source of water. The State Engineer had combined seven basins into one superbasin, the Lower White River Flow System (LWRFS), after determining that the waters of these basins were interconnected such that withdrawals from one basin affected the amount of water in the other basins. The State Engineer also found that the previously granted appropriations of water exceeded the rate of recharge in the LWRFS. Various entities who owned water rights throughout the new superbasin challenged the State Engineer's decision, claiming that he lacked the authority to manage surface waters and groundwater jointly and that his decision violated their due process rights.The Supreme Court of the State of Nevada held that the State Engineer indeed had the authority to manage surface waters and groundwater conjunctively and to jointly administer multiple basins. The court also found that the State Engineer did not violate the rights holders' due process rights because they received notice and had an opportunity to be heard. The court reversed the lower court's decision that had granted the rights holders' petitions for judicial review and remanded the matter back to the lower court for further proceedings to determine whether substantial evidence supported the State Engineer's factual determinations. View "Sullivan v. Lincoln County Water District" on Justia Law

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In this case decided by the United States Court of Appeals for the Ninth Circuit, the court considered whether the claims filed by Adriana Holt, her children, and her mother Beatriz Lukens against Orange County and several deputy sheriffs were barred by the applicable statutes of limitations. The plaintiffs alleged unlawful search and arrest and brought claims under 42 U.S.C. § 1983 and California state law. The case involved multiple filings and dismissals in different courts, raising the question of whether the tolling provision of the supplemental jurisdiction statute, 28 U.S.C. § 1367, applied to their claims.The court held that the plaintiffs' claims were not tolled and were therefore properly dismissed as untimely. The court reasoned that § 1367 tolls the applicable statute of limitations for a federal-law claim that is contained in the same federal court complaint as a supplemental state-law claim and that is “voluntarily dismissed at the same time as or after the dismissal of the [supplemental] claim.” However, this tolling provision does not apply when the supplemental claim is voluntarily dismissed, as occurred in Holt's first suit, or when a supplemental claim is dismissed for improper joinder, as occurred in the separate class action.Finally, the court also held that the plaintiffs' state-law claims were not tolled by a Covid-19 pandemic emergency tolling order and rule because the limitations periods for those claims had already lapsed before either the order or rule went into effect. Therefore, the court affirmed the lower court's dismissal of the plaintiffs' claims as time-barred. View "HOLT V. COUNTY OF ORANGE" on Justia Law

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The Supreme Court of Louisiana was asked by the United States Court of Appeals for the Fifth Circuit on whether the commencement of a suit in a court of competent jurisdiction and venue interrupts prescription as to causes of action, understood as legal claims rather than the facts giving rise to them, not asserted in that suit. This query arose from the case of Randall Kling who initially filed suit in state court alleging his dismissal from the Louisiana Office of Alcohol and Tobacco Control was in retaliation for submitting written complaints about workplace and ethics violations. He later filed a complaint in federal district court citing substantially similar facts and seeking relief for violations of his federal First and Fourteenth Amendment rights.The Supreme Court of Louisiana answered the certified question by stating that prescription or the period within which a lawsuit may be filed is interrupted when notice is sufficient to fully inform the defendant of the nature of the claim of the plaintiff, and what is demanded of the defendant. The Court explained that the essence of interruption of prescription by suit is notice to the defendant of the legal proceedings based on the claim involved. The court emphasized that notice is sufficient when it fully informs the defendant of the nature of the plaintiff's claim, and what is demanded of the defendant. Thus, the court took a balanced approach between a broad interpretation of interruption and a narrow one, placing emphasis on notice to the defendant, addressed on a case-by-case basis. View "KLING VS. HEBERT" on Justia Law

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Larry Trent Roberts spent 13 years in prison for a murder that he did not commit. After being exonerated, he sued several state actors involved in obtaining his wrongful conviction, including Assistant District Attorney John C. Baer. The United States Court of Appeals for the Third Circuit held that Baer is not entitled to absolute immunity from liability under 42 U.S.C. § 1983 because his actions of seeking a new witness to establish a motive for the murder served an investigatory function, not a prosecutorial one. The court noted that prosecutors are not entitled to absolute immunity when they perform investigative functions normally performed by a detective or police officer. Baer argued that he was immune from liability as his conduct occurred post-charge and was designed to produce inculpatory evidence for trial. However, the court clarified that the timing of a prosecutor's actions as pre- or post-indictment and the presence or absence of a connection to a judicial proceeding are only "relevant considerations" in determining whether a prosecutor’s action served a prosecutorial function. They are not enough to establish that a prosecutor's post-charge effort to fabricate evidence for trial served a quasi-judicial function. The court affirmed the District Court's decision denying Baer's motion to dismiss. View "Roberts v. Lau" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

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In this case, Alyssa Reid, a former faculty member at James Madison University (JMU) in Virginia, was accused of violating JMU’s Title IX policy against non-consensual relationships based on her past relationship with a graduate student. JMU and its officials investigated the accusation and held a hearing, leading to a decision that Reid violated the policy. Reid appealed the decision to JMU’s provost, who denied her appeal. Subsequently, Reid sued JMU and several officials, raising three due process claims under both 42 U.S.C. § 1983 and the Virginia Constitution, as well as a sex discrimination claim under Title IX.The United States District Court for the Western District of Virginia held that Reid’s claims accrued when the dean made his decision, and thus they were barred by the applicable two-year statute of limitations. Reid appealed this decision, arguing that her claims accrued not when the dean issued his decision, but when the provost denied her appeal.The United States Court of Appeals for the Fourth Circuit agreed with Reid. The court found that Reid did not have a complete and present cause of action until JMU reached a final decision in her Title IX proceedings. The court determined that JMU did not make clear that the dean’s decision was its official position. Rather, JMU’s official position was made clear to Reid when the provost denied her appeal with a “final,” non-appealable decision. Therefore, Reid’s due process and Title IX claims were not barred by the applicable two-year statute of limitations, and the court reversed the district court's dismissal of Reid’s claims and remanded for further proceedings. View "Reid v. James Madison University" on Justia Law

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This case revolves around Kenneth Bailey's lawsuit against Deputy Shawn Swindell, claiming that Swindell violated his civil rights when he tackled Bailey through the door of Bailey's parents' home and arrested him without a warrant or exigent circumstances. Bailey's suit was filed under Section 1983. The United States District Court for the Northern District of Florida initially granted summary judgment in favor of Swindell based on qualified immunity. However, the United States Court of Appeals for the Eleventh Circuit reversed this decision, concluding that Swindell violated clearly established law when he entered Bailey's parents' home to arrest him without a warrant or exigent circumstances, and was therefore not entitled to qualified immunity.On remand, the case went to trial and the jury returned a verdict for Bailey, awarding him $625,000 for his injuries. However, the district court later granted Swindell's motion for judgment as a matter of law, setting aside the jury's verdict. Bailey appealed this decision.The Eleventh Circuit reversed the district court's grant of judgment as a matter of law. The appellate court found that the jury's factual findings, including that the arrest was initiated outside the home but no exigent circumstances existed allowing for a warrantless entry into the home, should have been used by the district court in making its legal conclusions about qualified immunity. The court emphasized that it was clearly established that an officer violates the Constitution by initiating an arrest outside of a home and then entering the home without a warrant to complete the arrest in the absence of exigent circumstances. Therefore, Swindell was not entitled to qualified immunity, and the jury's verdict in favor of Bailey should be reinstated. View "Bailey v. Swindell" on Justia Law