Justia Civil Procedure Opinion Summaries

Lamar Catchings, a 20-year-old pretrial detainee, died from undiagnosed acute leukemia while in custody at the St. Louis County Buzz Westfall Justice Center in February 2019. His mother, Tashonda Troupe, filed a 42 U.S.C. § 1983 lawsuit against St. Louis County and numerous jail officials, medical staff, and correctional officers, alleging deliberate indifference to her son’s serious medical needs and failure to train or supervise the staff responsible for his care.The United States District Court for the Eastern District of Missouri dismissed the claims against most defendants at the pleading stage, citing qualified immunity and insufficient factual allegations. The court found that many of Troupe’s allegations were based on “information and belief” and lacked specific factual support. The district court allowed the claim against defendant Anthony Young, a practical nurse, to proceed, but dismissed the claims against other defendants, including correctional officers and medical staff, for lack of sufficient allegations of personal involvement or knowledge of Catchings’s condition.The United States Court of Appeals for the Eighth Circuit reviewed the case and addressed whether Troupe’s “upon information and belief” allegations were sufficient to state a claim. The court held that such allegations are permissible if the facts are within the possession and control of the defendants or based on factual information that makes the inference of culpability plausible. The court found that Troupe’s allegations met this standard and reversed the district court’s dismissal of claims against certain defendants, including Swims, Beard, Oliver, Doucette, and Murphy. The court affirmed the dismissal of claims against Mohler and Williams and partially reversed the dismissal of claims against the County, allowing the failure-to-train-or-supervise claim to proceed. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Troupe v. St. Louis County, Missouri" on Justia Law

Thomas Hamann brought a lawsuit against Heart Mountain Irrigation District (HMID) and its manager, Randy Watts, alleging that HMID, through Watts' actions, damaged his property and caused him bodily injury. Hamann sought damages based on claims of inverse condemnation and violation of his constitutional rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of HMID and Watts, dismissing Hamann’s lawsuit entirely. Hamann appealed only the dismissal of his inverse condemnation claim against HMID.The district court found that HMID had not taken any official action to authorize Watts to enter Hamann’s property beyond the limited scope of work on the Riolo bowl, which Hamann had consented to. The court held that without such authorization, Hamann’s inverse condemnation claim could not survive summary judgment. Hamann argued that there was a material issue of fact regarding whether Watts was acting under the scope, authority, and direction of HMID’s board.The Wyoming Supreme Court reviewed the case and found that there were genuine issues of material fact regarding the extent of Watts’ authority and whether his actions were authorized by HMID. The court noted that HMID’s bylaws allowed for delegation of responsibilities to its manager and other agents, and there was evidence suggesting that Watts had general discretion as HMID’s manager. Additionally, there was conflicting testimony about whether Watts had specific authorization to access Hamann’s property beyond the Riolo bowl.The court concluded that the district court erred in granting summary judgment to HMID, as there were unresolved factual issues regarding the authorization of Watts’ actions and the extent of damage to Hamann’s property due to activities on adjoining land. The Wyoming Supreme Court reversed the district court’s order and remanded the case for further proceedings. View "Hamann v. Heart Mountain Irrigation District" on Justia Law

James King sued the United States under the Federal Tort Claims Act (FTCA) and individual government employees under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging physical abuse by U.S. officials. The district court granted summary judgment to the defendants on both claims. King appealed only the Bivens claim, making the FTCA judgment final. The individual defendants argued that the FTCA's "judgment bar" precluded the Bivens claim. The Supreme Court ultimately ruled in favor of the defendants, stating that the FTCA judgment barred the Bivens claim.King then filed a Rule 60(b) motion in the district court to reopen the FTCA judgment to withdraw his FTCA claim and avoid the judgment bar. The district court denied the motion, reasoning that attorney error or strategic miscalculation is not a valid basis for reopening under Rule 60. King appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The court held that the district court did not abuse its discretion, as attorney error or strategic miscalculation does not justify reopening a final judgment under Rule 60. The court emphasized the public policy favoring the finality of judgments and noted that Rule 60(b)(6) relief is only available in exceptional or extraordinary circumstances, which were not present in this case. View "King v. United States" on Justia Law

Shawn Bell was charged with several violent crimes. During jury selection, the State used a peremptory challenge to exclude juror 39, prompting an objection from the defense under GR 37, which addresses potential racial or ethnic bias in jury selection. The prosecutor justified the challenge by claiming juror 39 was inattentive, while the defense argued that the COVID-19 mask requirement made it difficult for jurors to follow the questioning. The trial court denied the GR 37 objection, relying on the juror's admission of inattention and the judge's own observations. Bell was subsequently convicted.Bell appealed, and the Washington Court of Appeals reversed his convictions, finding that the trial court had violated GR 37 by allowing the peremptory challenge against juror 39. The appellate court concluded that the trial court's decision was incorrect and warranted a reversal of Bell's convictions.The Supreme Court of the State of Washington reviewed the case and held that a de novo standard of review is required for GR 37 objections. The court emphasized that the analysis must consider whether an objective observer could view race or ethnicity as a factor in the peremptory challenge. The court found that the trial judge's subjective impressions of juror 39's demeanor were insufficient to justify the challenge. The court also noted that similar responses from other jurors who were not challenged raised concerns about potential bias.The Supreme Court affirmed the Court of Appeals' decision, concluding that an objective observer could view race as a factor in the State's peremptory challenge against juror 39. The court reversed Bell's convictions and remanded the case for a new trial. View "State v. Bell" on Justia Law

Plaintiff Karim Codrington was subjected to an unlawful traffic stop, search, and arrest by Louisville Metro Police Department officers. During the criminal proceedings, a Kentucky state court suppressed the evidence seized from his vehicle and dismissed the charges. Over three years later, Codrington filed a 42 U.S.C. § 1983 lawsuit, alleging that the officers planted drugs on him, provided those drugs to prosecutors, and stole thousands of dollars from him.The United States District Court for the Western District of Kentucky granted summary judgment in favor of the defendants on all claims, finding that Codrington’s claims were either barred by the statute of limitations or failed on their merits. Specifically, the court found that the unlawful search and seizure, selective enforcement, and false arrest/imprisonment claims were time-barred. The court also found that Codrington failed to provide sufficient evidence to support his fabrication-of-evidence and malicious-prosecution claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment on the unlawful search and seizure, selective enforcement, false arrest/imprisonment, malicious prosecution, and state-law conversion claims. However, the court reversed the district court’s grant of summary judgment on the fabrication-of-evidence claim, finding that there was a genuine dispute of material fact regarding whether the officers fabricated evidence. The court also vacated the district court’s judgment on Codrington’s Monell claims and remanded for further proceedings. View "Codrington v. Dolak" on Justia Law

Ruben Santoyo, proceeding without counsel, filed a lawsuit under 42 U.S.C. § 1983 against the City of Chicago and two police officers, challenging the constitutionality of his arrest. Over three years, Santoyo repeatedly filed frivolous motions, many of which attacked the competence and integrity of the district judge. Despite numerous warnings from the judge that further frivolous filings would result in sanctions, Santoyo continued his behavior.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants and denied Santoyo's motions to vacate the judgment. While Santoyo's appeal of the denial was pending, the defendants moved to recover their costs. Instead of addressing the merits of this motion, Santoyo accused the defendants of bad faith and requested disciplinary action against their counsel. The district judge, having lost patience, granted the defendants' motion for costs, imposed a $1,500 sanction on Santoyo, and referred him to the district's Executive Committee, which barred future filings until the sanction was paid.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santoyo argued that the district judge violated his due process rights by not notifying him of the sanction or giving him an opportunity to respond. The appellate court disagreed, noting that Santoyo had been warned multiple times about the consequences of further frivolous filings. The court held that the district judge provided sufficient notice and opportunity for Santoyo to respond, satisfying due process requirements. The Seventh Circuit affirmed the district court's imposition of sanctions. View "Santoyo v. City of Chicago" on Justia Law

Joel Aaron Burrell, a prisoner, filed a lawsuit against several correctional officers under 42 U.S.C. § 1983. Burrell sought to proceed in forma pauperis, which allows indigent prisoners to file lawsuits without prepaying filing fees. The district court denied his request, citing the three-strike rule under the Prison Litigation Reform Act, which prevents prisoners from proceeding in forma pauperis if they have had three prior lawsuits dismissed for being frivolous, malicious, or failing to state a claim. The district court identified three such dismissals in Burrell's case history and dismissed his current action when he did not pay the filing fee.Burrell appealed, arguing that two of the prior dismissals should not count as strikes. The first case was dismissed under the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state proceedings. The second case was dismissed after Burrell failed to amend his complaint following a court order that found his initial complaint failed to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that a dismissal under Younger abstention does not count as a strike because it does not assess the merits of the complaint. Regarding the second case, the court determined that while a failure to amend following a finding of failure to state a claim can count as a strike, it should not be counted if the dismissal occurred after the current lawsuit was filed.The Fourth Circuit held that the district court erred in applying the three-strike rule to Burrell's case. Since Burrell had only one valid strike at the time he filed the current lawsuit, the district court's dismissal was vacated and the case was remanded for further proceedings. View "Burrell v. Shirley" on Justia Law

Faya Rose Toure sued the City of Selma, Chief of Police Spencer Collier, and police officer Devon McGuire following her arrest for fourth-degree theft of property and attempting to elude. Toure claimed McGuire and Collier committed assault and battery, false arrest, unlawful imprisonment, invasion of privacy, negligence, wantonness, abuse of legal process, unreasonable seizure, and defamation/libel. She also accused the City of negligent hiring, training, and supervision, and fostering a custom of police abuse. Toure sought $1,000,000 in compensatory damages and $3,000,000 in punitive damages.The defendants filed for summary judgment, citing peace-officer and State-agent immunity. They provided evidence including deposition testimonies, incident reports, and body camera footage showing McGuire witnessed Toure removing a campaign sign and subsequently attempting to elude him. Toure argued she removed the sign believing it was illegally placed and felt intimidated by McGuire, who was in an unmarked vehicle. The trial court granted summary judgment for the City but denied it for McGuire and Collier.The Supreme Court of Alabama reviewed the case. It found that McGuire and Collier were performing discretionary functions within their law enforcement duties, entitling them to immunity. The court determined that McGuire had at least arguable probable cause for Toure's arrest, and Toure failed to provide substantial evidence that McGuire or Collier acted willfully, maliciously, or beyond their authority. Consequently, the court held that McGuire and Collier were entitled to peace-officer and State-agent immunity and directed the trial court to enter summary judgment in their favor. The petition for a writ of mandamus was granted, and the writ was issued. View "Ex parte McGuire" on Justia Law

Nickolas Trabucco parked at a gas station in Hernando, Mississippi, where Officer Andres Rivera was filling up his patrol car. Rivera approached Trabucco’s car, and after a brief interaction, Trabucco exited his vehicle. The subsequent events, partially obscured by the car, are disputed. Trabucco claimed Rivera grabbed and tackled him without provocation, while Rivera testified that Trabucco resisted and attempted to flee, prompting Rivera to tackle him. Surveillance footage showed Rivera restraining Trabucco, who continued to struggle. Rivera then used a taser on Trabucco, who fell and was subsequently arrested.In the United States District Court for the Northern District of Mississippi, Trabucco sued Rivera under 42 U.S.C. § 1983 for excessive force. The jury found that Rivera used excessive force but was entitled to qualified immunity. Trabucco’s motions for judgment as a matter of law or a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court first addressed whether Trabucco waived his right to challenge the sufficiency of the evidence by not properly moving for judgment as a matter of law. The court found that Trabucco’s actions sufficiently alerted the court and Rivera to the sufficiency issue, allowing the court to consider the evidence. The court then held that Rivera’s use of force was not unreasonable in light of clearly established law, distinguishing this case from precedents like Trammell v. Fruge and Hanks v. Rogers due to factual differences. The court also found no error in the jury instructions and upheld the district court’s denial of Trabucco’s motion for a new trial, concluding that the evidence supported the jury’s verdict. The Fifth Circuit affirmed the district court’s judgment. View "Trabucco v. Rivera" on Justia Law

An inmate at Rayburn Correctional Center in Louisiana, Torriana Clark, filed a lawsuit under 42 U.S.C. § 1983 against prison officials, alleging that Lt. Lance Wallace used excessive force against him, violating his constitutional rights. Clark claimed that after feeling sick and seeking medical help, he was forcibly restrained and assaulted by Wallace, resulting in injuries. The prison officials' reports contradicted Clark's account, stating that Clark was combative and resisted orders, necessitating the use of force to restrain him.The United States District Court for the Eastern District of Louisiana granted partial summary judgment in favor of the defendants, ruling that Clark's § 1983 claim was barred by Heck v. Humphrey, which prevents prisoners from seeking damages under § 1983 if a judgment in their favor would imply the invalidity of their conviction or sentence. The district court also denied Clark's motion to amend his petition and remanded his state-law claims to state court.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Clark's § 1983 claim was indeed barred by Heck because success on his claim would require proof of facts inconsistent with his disciplinary convictions, which resulted in the loss of good-time credits. The court also agreed with the district court's denial of Clark's motion to amend his petition, concluding that any amendment would be futile as it would not change the Heck analysis. The appellate court's decision upheld the partial summary judgment and the denial of the motion to amend. View "Clark v. Dept of Public Safety" on Justia Law