Correspondent
Federal courthouse correspondent, covers civil rights, employment discrimination, housing rights, and Second Amendment disputes.
The Third Circuit affirmed the dismissal of a pro se plaintiff's claim that a store's Wi-Fi policy discriminated against international visitors based on national origin. The court held that the complaint failed to plausibly allege discriminatory animus and modified the dismissal of state-law claims to be without prejudice.
The Seventh Circuit affirmed that prison officials violated an inmate's Eighth Amendment rights by using her as bait to catch a sexual predator, but reversed the damages award due to insufficient evidence and procedural errors. The court ordered a new trial on compensatory and punitive damages while leaving the liability finding intact.
The Seventh Circuit affirmed that prison officials acted with deliberate indifference by using an inmate as bait to catch a staff member who was sexually assaulting her, rejecting their qualified immunity defense. However, the court reversed the damages award, ordering a new trial because the jury lacked sufficient evidence to link the officials to the abuse prior to their specific knowledge and because the exclusion of evidence regarding the inmate's state of mind prejudiced the punitive damages calculation.
The Third Circuit affirmed the dismissal of Jeniqua Bradley's Section 1983 lawsuit against a Magisterial District Judge. The court held that judicial immunity protected the judge because entering a default judgment is a judicial act performed within his jurisdiction.
The Supreme Court held that a pretrial order denying Yearsley protection is not immediately appealable because the doctrine provides a merits defense rather than an immunity from suit. Consequently, the denial fails the third prong of the collateral-order doctrine, as the issue remains effectively reviewable after a final judgment.
The Seventh Circuit affirmed summary judgment for prison medical providers, ruling that conservative treatment of reducible hernias did not constitute deliberate indifference under the Eighth Amendment. The court held that the Constitution guarantees adequate medical care, not the specific surgical treatment a prisoner desires.
The Seventh Circuit affirmed the dismissal of a Section 1983 lawsuit alleging that a protective order and subsequent criminal convictions were obtained through fraud. The court held that the plaintiff's claims were barred by Heck v. Humphrey because a favorable ruling would necessarily imply the invalidity of his standing criminal convictions.
The Seventh Circuit dismissed David McNamara's appeal because he failed to file a brief containing legal arguments challenging the district court's decision. The underlying civil rights suit was properly dismissed by the lower court based on immunity doctrines, the statute of limitations, and federal abstention principles.
The Third Circuit affirmed the dismissal of a pro se plaintiff's federal civil rights claims arising from a state custody dispute, ruling that state officials and judges are protected by immunity doctrines. The court held that the plaintiff failed to plead an ongoing violation of federal law necessary to bypass sovereign immunity and did not allege that judicial actors acted outside their jurisdiction.
The Third Circuit affirmed summary judgment for a prison psychologist but reversed the lower court's ruling against two medical defendants in an Eighth Amendment suicide prevention case. The court held that while the psychologist's actions were reasonable, the medical defendants' failure to personally evaluate a suicidal inmate created a genuine dispute of material fact regarding deliberate indifference.
