Justia Government & Administrative Law Opinion Summaries

Three business entities and individuals associated with the operation of a retail store in Cedar Park, Texas, were subject to enforcement under a city ordinance banning “head shops”—stores selling items commonly used to ingest or inhale illegal substances. After receiving notices from the City, two of the appellants were charged in municipal court and fined for violating the ordinance, while the third appellant, a related business entity, was not charged. Following the municipal court’s judgment, the two charged parties appealed for a trial de novo in the county court, which annulled the municipal court’s judgment and began new criminal proceedings. They also pursued state habeas relief, which was still ongoing at the time of this appeal.Separately, the appellants filed a lawsuit in the United States District Court for the Western District of Texas, challenging the ordinance’s validity and constitutionality under federal and state law, and seeking declaratory and injunctive relief. The district court dismissed all claims as barred by the doctrine announced in Heck v. Humphrey, which precludes certain civil claims that would imply the invalidity of existing criminal convictions. The district court also dismissed a distinct claim related to termination of utility services.On appeal, the United States Court of Appeals for the Fifth Circuit held that because the municipal court’s judgments were annulled by the trial de novo and criminal proceedings were still pending under Texas law, there were no outstanding convictions to trigger the Heck bar. Thus, the Fifth Circuit reversed the district court’s dismissal of the claims challenging the ordinance and remanded for further proceedings. The court affirmed the district court’s dismissal of the standalone water termination claim, as the appellants had disclaimed any intent to pursue it. View "Kleinman v. City of Cedar Park" on Justia Law

In this case, an individual attended the 2022 Kentucky Derby in Louisville, Kentucky, with a group to engage in expressive activities such as preaching, distributing literature, and displaying signs near the event. The area surrounding Churchill Downs was subject to a special event permit issued by the city government, which allowed Churchill Downs to restrict access to certain public streets and sidewalks to ticket holders and credentialed individuals. The plaintiff and his group entered a fenced-off, restricted area beyond posted “No Trespassing” signs, despite lacking event tickets or credentials. After repeated warnings from private security and law enforcement, the plaintiff was arrested by a Kentucky State Police trooper for criminal trespass.The plaintiff filed suit in the United States District Court for the Western District of Kentucky, asserting claims under 42 U.S.C. § 1983 for violations of his free speech, free exercise, and due process rights, as well as a Monell municipal liability claim against the city government and claims against the arresting officer. The district court granted summary judgment in favor of the defendants on all claims. It found the free speech restriction content-neutral and justified under intermediate scrutiny, concluded the free exercise claim was not properly developed, determined the permitting scheme was not unconstitutionally vague, dismissed the Monell claim for lack of an underlying constitutional violation, and granted qualified immunity to the arresting officer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the restricted area was a limited public forum and the ticketing and access restrictions were content-neutral and survived intermediate scrutiny. The court found no evidence of viewpoint discrimination, held that ample alternative channels for communication existed, and determined that the plaintiff failed to preserve his free exercise claim and did not establish a due process violation. The Monell claim failed for lack of a constitutional violation, and qualified immunity was properly granted to the officer. View "Blankenship v. Louisville-Jefferson Cnty. Metro Gov't" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

A licensed horse trainer was involved in a dispute with a state racing steward after the steward refused to reinstate an assistant trainer’s license. Following a heated phone conversation in which the trainer criticized the steward, the state agency regulating horse racing initiated a disciplinary action against the trainer, alleging conduct that could negatively reflect on the integrity of horse racing. A panel of stewards found a violation and issued a conditional fine. The trainer appealed for a de novo administrative hearing but later withdrew the appeal and instead filed a lawsuit in district court, claiming the agency’s actions were a retaliatory violation of his state constitutional rights under the New Mexico Civil Rights Act.The district court denied the agency’s motion for summary judgment, holding that judicial immunity was not available to the public body under the Civil Rights Act. On interlocutory appeal, the New Mexico Court of Appeals reversed, finding that the statutory language preserved judicial immunity as a defense and that the agency was entitled to quasi-judicial immunity based on its role and the nature of the proceedings, directing entry of summary judgment for the agency.The Supreme Court of the State of New Mexico reviewed whether judicial immunity is a defense available to a public body sued under the New Mexico Civil Rights Act. The Court held that judicial immunity does apply to public bodies in this context, reasoning that the doctrine’s policy goals—protecting independent decision-making and the integrity of judicial or quasi-judicial processes—apply to both individuals and government entities. However, the Court found the record insufficient to decide whether the agency’s conduct warranted immunity under this standard and remanded the matter to the district court for further proceedings consistent with its clarified framework. The Court affirmed in part and reversed in part the Court of Appeals’ decision. View "Bolen v. N.M. Racing Commission" on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law