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The Eleventh Circuit vacated a district court dismissal of parents' negligence claims against the United States regarding child abuse at a government daycare. The appellate court held that the government's duty to protect the children was independent of the abusers' employment status, placing the claims outside the Federal Tort Claims Act's intentional tort exception.
The United States Court of Appeals for the First Circuit issued an errata sheet to correct the caption and clarify the representation of the government in a criminal appeal. The amendment clarifies that the U.S. Attorney's Office for the District of Puerto Rico litigated the case while an attorney from the Criminal Division of the Department of Justice presented the appeal.
The Seventh Circuit reversed a district court ruling that applied the substantial compliance doctrine to validate a decedent's fax request to change a retirement beneficiary. The appellate court held that sending a fax did not constitute the positive action required by the plan's strict terms, leaving the ex-wife as the rightful primary beneficiary.
The Seventh Circuit affirmed summary judgment for prison officials, holding that disciplinary segregation and a transfer to a maximum-security facility did not deprive the prisoner of a constitutionally protected liberty interest. Because no liberty interest was implicated, the court declined to rule on whether the disciplinary hearing procedures were constitutionally deficient.
The Seventh Circuit affirmed summary judgment for prison medical staff and their employer, ruling that delays in post-operative care did not constitute deliberate indifference to a prisoner's serious medical needs. The court held that providers acted within professional discretion and that the plaintiff failed to prove an unconstitutional policy by the employer.
The Seventh Circuit dismissed an appeal filed by a pro se litigant who failed to argue that the district court lacked subject matter jurisdiction over his claims. The appellate court deemed the appeal frivolous because the appellant did not engage with the court's dispositive determination that his complaints failed to allege violations of federal law or establish diversity jurisdiction.
The Seventh Circuit affirmed a district court ruling granting summary judgment to local officials in a civil rights suit challenging the revocation of a liquor license. The appellate court upheld the lower court's findings that the officials were protected by absolute immunity and that the plaintiff failed to provide sufficient evidence of due process violations or racial discrimination.
The Seventh Circuit held that a law enforcement officer's 'temporary felony want' does not constitute a valid warrant sufficient to justify entering a home without a judge's authorization. While the court affirmed the dismissal of claims regarding arrest and malicious prosecution due to probable cause, it reversed the dismissal of the plaintiff's Fourth Amendment claim for unlawful warrantless entry.
The First Circuit affirmed the dismissal of an employment discrimination lawsuit after finding the plaintiff committed witness tampering on the eve of trial. The court held that conditioning a custody agreement on a witness's refusal to testify constituted a fraud on the court warranting the severe sanction of dismissal.
The First Circuit reversed the district court's summary judgment in a legal malpractice suit, holding that a genuine issue of material fact exists regarding when the statute of limitations began to run. The court further ruled as a matter of law that an attorney-client relationship existed between the tech company and the law firm, rejecting the lower court's dismissal of the claims.
