Justia Civil Procedure Opinion Summaries

Plaintiffs Moses Lugo and Cheryl Seaton, who use motorized wheelchairs, sued the City of Troy, New York, under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 (RA). They alleged that the city failed to maintain accessible pedestrian pathways. After discovery, Plaintiffs moved for summary judgment, while the City of Troy moved to dismiss the complaint for lack of standing or, alternatively, for summary judgment. The district court dismissed the complaint, finding the factual allegations insufficient to establish standing, without considering the full summary-judgment record.The United States District Court for the Northern District of New York dismissed the complaint based on the pleadings, concluding that the allegations were too generic to establish standing for city-wide remedies and that the specific obstacles mentioned had been remedied, thus mooting those claims. The court did not evaluate whether the evidence from discovery could establish standing.The United States Court of Appeals for the Second Circuit reviewed the case. The appellate court found that the district court erred by resolving the standing issue based solely on the pleadings rather than the full summary-judgment record. The appellate court held that the district court should have considered the evidence developed during discovery to determine whether Plaintiffs had standing. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the lower court to evaluate the standing issue based on the complete evidentiary record and to determine if summary judgment is warranted or if Plaintiffs should be allowed to amend their complaint. View "Lugo v. The City of Troy, New York" on Justia Law

The case involves a long-standing litigation concerning the Orleans Parish Sheriff’s Office and the conditions at Orleans Parish Prison. Plaintiffs, including detainees and the United States, argued that the jail provided constitutionally inadequate housing and medical care. In 2013, a district court approved a consent decree to address these issues, which included a plan to construct a mental health annex, known as Phase III. Despite years of delays, the district court ordered the construction to proceed. No party appealed these orders at the time.The United States District Court for the Eastern District of Louisiana oversaw the case initially. In 2016, the parties entered a stipulated order to develop a plan for appropriate housing for prisoners with mental health issues. The Compliance Director later proposed the construction of Phase III, which was agreed upon by the former Sheriff and the City. However, the City later sought to explore alternatives, leading to further court orders in 2019 to proceed with Phase III. The City’s subsequent motion to halt the project was denied, and this decision was affirmed by the United States Court of Appeals for the Fifth Circuit in Anderson v. City of New Orleans.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The new Sheriff, Susan Hutson, moved to terminate all orders concerning Phase III, arguing that the Prison Litigation Reform Act (PLRA) prohibits the construction of a new jail facility. The district court denied this motion, and the Fifth Circuit dismissed the appeal for lack of jurisdiction. The court held that it could review the denial of the motion but not the underlying orders, as the Sheriff’s motion was not a proper procedural mechanism under the PLRA to challenge the 2019 Orders and Stipulated Order. The appeal was dismissed, and the construction of Phase III continues. View "Anderson v. Hutson" on Justia Law

Alexis Guerrero, a Black Dominican-American, sued Ollie’s Bargain Outlet under 42 U.S.C. § 1981 for race discrimination. Guerrero alleged that while shopping for flowerpots at an Ollie’s store in Salisbury, Maryland, an employee named Richard Murray threatened him with a knife and shouted racial slurs, preventing him from purchasing the items. Guerrero claimed that this discriminatory conduct interfered with his right to make and enforce contracts.The United States District Court for the District of Maryland granted Ollie’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The court reasoned that Guerrero failed to sufficiently allege that he was denied the opportunity to contract for goods or services that was otherwise afforded to white customers. Specifically, the court found that Guerrero did not claim that Ollie’s actually prevented him from purchasing a flowerpot and noted that he voluntarily left the store without attempting to make a purchase.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Guerrero sufficiently alleged a contractual interest by demonstrating his intent to purchase the flowerpots and that Murray’s actions, including wielding a knife and shouting racial slurs, interfered with this interest. The court found that Guerrero’s allegations were enough to show that he was denied the opportunity to contract based on his race. Consequently, the Fourth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Guerrero v. Ollie's Bargain Outlet, Inc." on Justia Law

Bobby Stevenson, a prisoner at the Louisiana State Penitentiary, claims he was forced to labor in the prison’s agricultural fields despite severe ankle pain caused by two broken surgical screws. He alleges that two prison physicians, Dr. Randy Lavespere and Dr. Paul M. Tocé, refused to fix the screws or relieve him from field labor. Stevenson asserts that the broken screws caused him tremendous pain and secondary injuries, and that the physicians ignored his complaints and medical recommendations for surgery.The United States District Court for the Middle District of Louisiana reviewed the case. The magistrate judge allowed Stevenson to file an amended complaint and recommended denying the defendants' motion to dismiss, which argued for qualified immunity. The district court accepted this recommendation and denied the motion, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Stevenson sufficiently alleged that the defendants violated his Eighth Amendment rights by ignoring his severe medical needs and forcing him to work despite his condition. The court also determined that the defendants had fair warning from existing case law that their actions were unconstitutional. Consequently, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss, rejecting the defendants' claim of qualified immunity. View "Stevenson v. Toce" on Justia Law

In February 2016, two Seattle police officers, Scott Miller and Michael Spaulding, fatally shot Che Andre Taylor during an attempted arrest. Kshama Sawant, a Seattle City Council member, publicly referred to the incident as a "blatant murder" and later reiterated that Taylor was "murdered by the police." Following an inquest, prosecutors declined to file charges against the officers due to insufficient evidence of malice. Miller and Spaulding subsequently filed a lawsuit alleging defamation and outrage under state law, as well as a federal defamation claim against Sawant.The United States District Court for the Western District of Washington dismissed the federal defamation claim but retained jurisdiction over the state law claims. The court later granted Sawant's motion for summary judgment on the state law claims and awarded her expert witness deposition expenses, including fees for preparation time. Miller and Spaulding appealed the decision, challenging the award of expert witness fees and the admissibility of the expert's opinions.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that Federal Rule of Civil Procedure 26 allows for the recovery of reasonable expenses for time an expert witness spends preparing for a deposition. The court joined other circuits in concluding that such preparation fees are recoverable under Rule 26. The court found that the expert witness deposition preparation fees awarded to Sawant were reasonable and did not result in manifest injustice. The Ninth Circuit also noted that objections to the admissibility of the expert's opinions did not negate the obligation to pay a reasonable fee under Rule 26. The court affirmed the district court's grant of summary judgment and the award of expert witness deposition expenses. View "Miller v. Sawant" on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law

In 2018, Officer Patrick Kaine of the City of Wauwatosa Police Department stopped a vehicle based on a citizen's tip about a potential robbery. The vehicle contained Akil Carter, Paulette Barr, and Sandra Adams. Officer Kaine handcuffed Carter and placed him in the back of his squad car while he investigated. He soon realized the tip was mistaken, uncuffed Carter, and allowed the group to leave. Carter, Barr, and Adams subsequently sued Officer Kaine, other officers, and the City of Wauwatosa, alleging violations of their Fourth Amendment rights.The case was initially heard in the United States District Court for the Eastern District of Wisconsin, where the jury found in favor of the defendants. The plaintiffs appealed, challenging several pretrial and trial decisions, including the bifurcation of the trial, jury instructions, exclusion of their police-practices expert, and the judge's failure to recuse himself. They also contested the district judge's denial of their Batson challenge to a peremptory strike.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found no error in the district judge's decisions regarding bifurcation, jury instructions, exclusion of the expert, or recusal. However, the court determined that the district judge did not properly conduct the third step of the Batson inquiry, which requires assessing whether the race-neutral reasons for the peremptory strike were pretextual. The court remanded the case for further findings on the Batson challenge to Juror 10, instructing the district judge to complete the three-step Batson process and make the necessary credibility determinations on the record. The court affirmed the district court's decisions in all other respects. View "Carter v. City of Wauwatosa" on Justia Law

Trevor Davis filed a lawsuit against Deputy Christopher Allen under 42 U.S.C. § 1983, claiming that Allen violated his Fourth Amendment rights by using excessive force during his arrest. Davis had several outstanding warrants for violent felonies, and when officers arrived to arrest him, he fled into a trailer. Deputy Allen used his police dog, Koda, to locate Davis inside the trailer. Despite Davis lying face-down with his hands over his head, Koda bit him, causing severe injury. Davis alleged that Allen failed to recall Koda after Davis had surrendered.The United States District Court for the Western District of Wisconsin denied Deputy Allen’s motion for summary judgment. The court found that there were material disputes of fact regarding the circumstances and timing of the use of the police dog, which precluded a finding of qualified immunity at this stage. Specifically, the court noted that a jury could find that a reasonable officer would have known that Davis had surrendered and that continuing to allow Koda to bite him constituted excessive force.The United States Court of Appeals for the Seventh Circuit reviewed the case and dismissed the appeal for lack of appellate jurisdiction. The court noted that the district court’s denial of qualified immunity was based on disputed facts, which are not subject to interlocutory appeal. The Seventh Circuit emphasized that the reasonableness of Deputy Allen’s actions depended on resolving these factual disputes, such as whether Davis was visibly unarmed and compliant. The court concluded that it could not address the merits of the qualified immunity claim without first resolving these factual issues, which must be done by a jury. View "Davis v. Allen" on Justia Law

A Columbia County resident, Roderick McDaniel, was shot and killed by Deputy Charles McClinton outside an apartment complex in Magnolia, Arkansas. McDaniel was a suspect in a first-degree murder case, and an arrest warrant had been issued for him. Deputy McClinton encountered McDaniel in a white SUV, which matched the description of the vehicle used in the crime. When McDaniel attempted to flee by reversing into McClinton's patrol car and then accelerating forward, McClinton fired a single shot, killing McDaniel. A loaded handgun, later confirmed to be the murder weapon, was found near McDaniel.The United States District Court for the Western District of Arkansas denied Deputy McClinton's motion for summary judgment based on qualified immunity. The court found that there were material factual disputes, particularly regarding whether McDaniel was driving the SUV forward toward McClinton when he was shot. The court concluded that McClinton was not entitled to qualified immunity because it was clearly established that using deadly force against a suspect merely for fleeing, even in a vehicle, was unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that Deputy McClinton was entitled to qualified immunity. The court reasoned that McClinton had probable cause to believe McDaniel was a dangerous felon who had committed first-degree murder and was still armed. Therefore, using deadly force to prevent McDaniel's escape was constitutionally permissible. The court also noted that McClinton's conduct did not violate McDaniel's clearly established rights, as existing precedent did not clearly prohibit the use of deadly force in such circumstances. The case was remanded with instructions to enter summary judgment in favor of Deputy McClinton and dismiss the case. View "Arnold v. McClinton" on Justia Law