Justia Civil Procedure Opinion Summaries

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

Shawn Sheltra, an inmate with the Idaho Department of Corrections (IDOC), filed a formal grievance in March, identifying safety concerns and threats from other inmates in his housing unit. He warned that he would be attacked in April if he did not make an extortion payment. Despite being briefly isolated, Sheltra was returned to his housing unit and was attacked by another inmate in April. He subsequently filed a lawsuit, asserting violations of the Eighth and Fourteenth Amendments due to the defendants' failure to protect him from a known harm.The United States District Court for the District of Idaho granted summary judgment for the defendants, dismissing the action for failure to exhaust administrative remedies because Sheltra did not file a formal grievance after the April attack. The court also granted summary judgment for the defendants on Sheltra's official-capacity claims, as they were barred by the Eleventh Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and adopted the continuing-violations doctrine for purposes of administrative exhaustion under the Prison Litigation Reform Act (PLRA). The court held that a properly exhausted prison grievance asserting one continuing harm or a single course of conduct can exhaust events arising out of the same alleged violation that occur after the grievance was made. Applying this doctrine, the court concluded that Sheltra's attack was part of the same continuing harm or course of conduct described in his prison grievance before the attack. Therefore, the court reversed the district court's summary judgment on Sheltra's individual-capacity claims against the defendants. However, the court affirmed the district court's grant of summary judgment for the defendants on Sheltra's official-capacity claims due to Eleventh Amendment immunity. View "SHELTRA V. CHRISTENSEN" on Justia Law

A human trafficker victimized Jane Doe, grooming her through Facebook, which lacked sufficient guardrails for minors. The trafficker convinced Doe to meet in person and advertised her for prostitution on Backpage, leading to her sexual assault at the Texas Pearl Hotel in Houston. Doe sued Facebook and Texas Pearl for violations of Civil Practice and Remedies Code Chapter 98, which imposes civil liability on those who benefit from human trafficking.The MDL pretrial court denied Facebook’s motion to remand the case, and the MDL panel upheld this decision. Facebook argued that its case had no common fact questions with the MDL cases, which involved different defendants, plaintiffs, and incidents. The MDL cases named various hotels and Salesforce as defendants, alleging they facilitated human trafficking through their services. Facebook contended that the lack of common parties or events meant there were no shared fact questions.The Supreme Court of Texas reviewed the case and agreed with Facebook. The court held that the tag-along case did not share any common fact questions with the MDL cases. The MDL cases involved different defendants, criminal perpetrators, and incidents, and there was no connection through common parties or events. The court concluded that general patterns of criminal activity by different perpetrators do not create the required common fact question for MDL inclusion. Consequently, the court conditionally granted mandamus relief and directed the MDL panel to remand the tag-along case to its original trial court. View "IN RE JANE DOE CASES" on Justia Law

Clint Edwards, a pretrial detainee in a Westchester County Department of Corrections (WCDOC) jail, filed a lawsuit under 42 U.S.C. § 1983, alleging violations of his Fourteenth Amendment rights. Edwards claimed that Correction Officer Christopher Arocho failed to protect him and incited other inmates to attack him. He also alleged that several WCDOC officials subjected him to unsanitary and unhealthy conditions in administrative segregation and that his placement in administrative segregation without notice or a hearing violated his procedural due process rights.The United States District Court for the Southern District of New York dismissed Edwards’s conditions of confinement and procedural due process claims for failure to state a claim. The court also granted summary judgment in favor of Arocho on the failure to protect claim, determining that Edwards had not exhausted his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Edwards had adequately stated claims for conditions of confinement and procedural due process violations under the Fourteenth Amendment. The court also found that Edwards raised a factual dispute regarding whether he exhausted his administrative remedies, which precluded summary judgment on the failure to protect claim. The court vacated the District Court’s judgment and remanded the case for further proceedings. View "Edwards v. Arocho" on Justia Law

Carl Grant, a Vietnam War veteran suffering from dementia and PTSD, left his home in Conyers, Georgia, on February 2, 2020, and ended up in Birmingham, Alabama. Officer Vincent Larry of the Birmingham Police Department found Grant disoriented and detained him for a misdemeanor. Grant was taken to a hospital, where he was treated for minor injuries. While being escorted to the restroom, Larry allegedly assaulted Grant, causing severe spinal injuries that led to Grant's death on July 24, 2020. William Jenkins, representing Grant's estate, filed a lawsuit against Larry, the City of Birmingham, and various city officials.The Jefferson Circuit Court granted a summary judgment in favor of the City defendants, dismissing Jenkins's claims with prejudice on February 22, 2023. Jenkins filed a postjudgment motion on March 21, 2023, which was denied by operation of law on June 20, 2023. Jenkins also filed a "motion for clarification" on April 28, 2023, which the court purported to grant on June 21, 2023, reinstating claims against Larry and Scott Thurmond. However, this order was a nullity as the court had lost jurisdiction after the postjudgment motion was denied by operation of law.Jenkins filed a notice of appeal on November 3, 2023, which was dismissed as arising from a non-final order. He then filed another appeal on January 24, 2024, which was transferred to the Supreme Court of Alabama. The Supreme Court of Alabama dismissed the appeal, instructing the circuit court to vacate its June 21, 2023, order and all subsequent orders, as they were nullities. The February 22, 2023, judgment was deemed final, and Jenkins's failure to appeal it timely resulted in the dismissal of his current appeal. View "Jenkins v. City of Birmingham" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

Mark Blackwell criticized the city manager of Wayne, Michigan, leading the manager to complain to the police. Two officers convinced a prosecutor to charge Blackwell with stalking, but a judge acquitted him. Blackwell then sued the manager and officers, alleging they violated his First Amendment rights by inducing the prosecution in retaliation for his political speech. The district court found that Blackwell's complaint had enough facts to rebut the city officials' qualified-immunity defense at the pleading stage.The United States District Court for the Eastern District of Michigan denied the city officials' motion to dismiss, leading them to appeal. The district court refused to consider exhibits attached to the motion to dismiss and held that the complaint stated a plausible First Amendment retaliation claim. The court also found that qualified immunity would not protect the officials if Blackwell could prove his allegations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's decision to exclude the outside-the-complaint exhibits and found that Blackwell's complaint plausibly alleged a lack of probable cause for the stalking charge. The court held that the complaint sufficiently pleaded a First Amendment violation and that the law clearly established this violation. The court affirmed the district court's denial of the motion to dismiss, allowing Blackwell's claims to proceed. View "Blackwell v. Nocerini" on Justia Law

Tad Mayfield, a nonpartisan legislative specialist in the assistant chief clerk’s office of the Missouri House of Representatives, was terminated on August 6, 2020, after sending an email on August 3, 2020, to the Speaker of the House and the President Pro Tem of the Missouri Senate advocating for mandatory face masks in the state capitol building due to COVID-19 concerns. Mayfield filed a lawsuit under 42 U.S.C. § 1983, alleging wrongful termination in retaliation for his email, claiming it violated his First Amendment rights.The case proceeded to a jury trial in the United States District Court for the Western District of Missouri. The jury found in favor of Mayfield, awarding him $15,000 in punitive damages and $14,993.93 in actual damages for lost wages. The district court denied the defendants' motions for judgment as a matter of law and awarded Mayfield attorney’s fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Mayfield’s email was protected speech under the First Amendment as it addressed a matter of public concern. The court found that the defendants failed to show that the email had an adverse impact on the efficiency of the House’s operations, which would have necessitated a Pickering balancing test. The court also upheld the jury’s finding that the email was a substantial or motivating factor in Mayfield’s termination and rejected the defendants' claim of qualified immunity, stating that the right to speak on matters of public concern was clearly established.Additionally, the court found sufficient evidence to support the submission of punitive damages to the jury, given the defendants' knowledge that terminating an employee for raising public health concerns could be illegal. The court also upheld the district court’s award of attorney’s fees to Mayfield, finding no abuse of discretion. View "Mayfield v. Miller" on Justia Law

Silvia Cianzio, a retired professor from Iowa State University, filed a lawsuit against the university, the Iowa Board of Regents, and the State of Iowa, alleging wage discrimination in violation of Iowa Code section 216.6A. She claimed that male professors in her department were paid significantly more than female professors, including herself. After conducting a survey on departmental salaries, she discovered that her annual pay was substantially less than that of her male counterparts. She reported these findings to university officials, who dismissed her concerns. Cianzio retired in December 2020 and subsequently filed a complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, followed by a lawsuit in January 2022.The Iowa District Court for Polk County partially granted the university's motion to dismiss, ruling that Cianzio could only seek damages for wage discrimination occurring within the two-year statute of limitations for wage claims, as set forth in Iowa Code section 614.1(8). The court rejected the university's argument that damages should be limited to the 300-day period preceding the filing of her ICRC complaint.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 216.15(9)(a)(9) allows a claimant to recover damages for the entire period of wage discrimination, not limited to the two-year statute of limitations or the 300-day period before filing the ICRC complaint. The court emphasized that the statute's language permits recovery for the entire period of discrimination, as long as the complaint is filed within the statutory time frame. The case was remanded for further proceedings consistent with this interpretation. View "Cianzio v. Iowa State University" on Justia Law

Attorney Stephen Eberhardt filed a 102-page, 19-count complaint against 11 defendants, including the Village of Tinley Park, its officials, attorneys, and residents, alleging a scheme to prevent him from making public comments at Village board meetings and on Village-related Facebook pages, violating his constitutional rights. He also brought claims against the Village’s outside counsel, Patrick Walsh, under the Illinois Open Meetings Act. The district court dismissed the complaint without prejudice for being too lengthy and jumbled. Eberhardt then filed an amended complaint, which was also dismissed, and the court entered final judgment.Following the judgment, Walsh’s attorney filed a motion for sanctions under Rule 11 of the Federal Rules of Civil Procedure, arguing that Eberhardt’s claims were frivolous and filed in bad faith to harass Walsh. The district court granted the motion, ordering Eberhardt to pay $26,951.22 in attorneys’ fees, finding that his claims were frivolous and brought with inadequate investigation into the relevant law and facts. The court noted Eberhardt’s history of filing numerous lawsuits and motions, which indicated bad faith.Eberhardt appealed to the United States Court of Appeals for the Seventh Circuit, challenging the district court’s decision to sanction him and its denial of his motion to reconsider. The Seventh Circuit reviewed the case and found no abuse of discretion in the district court’s decisions. The court affirmed the sanctions order, agreeing that Eberhardt’s claims were frivolous and brought in bad faith, and that a hearing was not necessary as the record was adequate to determine the need for sanctions. The court also affirmed the denial of the motion to reconsider, finding no manifest errors of law or fact. View "Eberhardt v. Walsh" on Justia Law