Justia Class Action Opinion Summaries

Articles Posted in Constitutional Law
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Inmates who were housed by three Illinois Department of Corrections centers between April-July 2014, alleged that the prison-wide shakedowns conducted violated their constitutional and statutory rights, 42 U.S.C. 1983. The shakedowns involved uniformed tactical teams called “Orange Crush” that operated according to a uniform plan, which involved a loud entry, strip searches, handcuffing, and other procedures involving allegedly humiliating physical contact. The inmates allege that the planning and execution of the shakedowns violated the Eighth Amendment because it was designed to inflict pain and humiliation.The Seventh Circuit affirmed class certification. The plaintiffs satisfied the “commonality” requirement because they alleged that the defendants acted pursuant to a common policy and implemented the same or similar procedures at each institution and that the challenge was to the constitutionality of that common plan as enacted. The claims require resolution of key common factual and legal questions, specifically: “whether Defendants developed and carried out a uniform policy and practice that had the effect of depriving the putative class members of their Eighth Amendment right to be free from cruel and unusual punishment; whether the shakedowns were executed in the manner Defendants contend or as Plaintiffs claim; whether Defendants engaged in a conspiracy to deprive the putative class members of their constitutional rights through the shakedowns; and whether the Defendants knew of, approved, facilitated and/or turned a blind eye to the alleged unconstitutional shakedowns.” Those questions do not require individualized consideration. View "Ross v. Gossett" on Justia Law

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In November 2017, Saul Cisneros was charged with two misdemeanor offenses and jailed. The court set Cisneros’s bond at $2,000, and Cisneros’s daughter posted that bond four days later, but the County Sheriff’s Office did not release him. Instead, pursuant to Sheriff Bill Elder’s policies and practices, the Sheriff’s Office notified U.S. Immigration and Customs Enforcement (“ICE”) that the jail had been asked to release Cisneros on bond. ICE then sent the jail a detainer and administrative warrant, requesting that the jail continue to detain Cisneros because ICE suspected that he was removable from the United States. Cisneros was placed on an indefinite “ICE hold,” and remained in detention. During his detention, Cisneros, along with another pretrial detainee, initiated a class action in state court against Sheriff Elder, in his official capacity, for declaratory, injunctive, and mandamus relief. The Colorado Supreme Court granted certiorari to consider whether the appellate court erred in concluding that section 24-10-106(1.5)(b), C.R.S. (2021), of the Colorado Governmental Immunity Act (“CGIA”) did not waive sovereign immunity for intentional torts that result from the operation of a jail for claimants who were incarcerated but not convicted. The Supreme Court concluded section 24-10-106(1.5)(b) waived immunity for such intentional torts. "In reaching this determination, we conclude that the statutory language waiving immunity for 'claimants who are incarcerated but not yet convicted' and who 'can show injury due to negligence' sets a floor, not a ceiling. To hold otherwise would mean that a pre-conviction claimant could recover for injuries resulting from the negligent operation of a jail but not for injuries resulting from the intentionally tortious operation of the same jail, an absurd result that we cannot countenance." Accordingly, the judgment of the division below was reversed and the case remanded for further proceedings. View "Cisneros v. Elder" on Justia Law

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Appellants Raymond and Michelle Plata were property owners in the City of San Jose and customers of Muni Water. Muni Water’s annual budget was reflected each year in a document called a source and use of funds statement, which was part of the City’s annual operating budget. In 2013, the Platas filed with the City a claim pursuant to Government Code sections 910 and 910.2, accusing Muni Water of violating Proposition 218 ab initio by collecting money from customers and illegally transferring it to the City’s own general fund. The City rejected the claim, so in early 2014, the Platas brought a class action lawsuit seeking declaratory and injunctive relief against the City under Proposition 218, as well as recovery of the amounts overpaid. After a lengthy bench trial, the trial court issued a statement of decision finding: (1) the late fees charged by Muni Water were not a fee or charge covered by Proposition 218; (2) any claims accruing prior to November 4, 2012 were time-barred because of the statute of limitations provided under Government Code section 911.2, and there was no basis for applying any equitable tolling doctrine; (3) as for tiered water rates, the discussion of high rates in the Platas’ government claims adequate to gave notice to the City that its rate structure was being questioned; and (4) “[a] more significant complication” raised by the City in its class decertification motion. The tiered rate structure would impact different class members differently from month to month, thus making it potentially “impossible” to draw a “line between ‘winners’ and ‘losers’ based on monthly water consumption[.]” The court granted the City’s motion to decertify the class, and refused to grant the Platas any relief as to their tiered rate argument. The Platas appealed. The Court of Appeal reversed judgment only as to the trial court’s findings on the tiered rate structure. In all other respects, it was affirmed. View "Plata v. City of San Jose" on Justia Law

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Santiago, a severely disabled Chicago resident, would leave her van parked on the street near her home for extended periods of time. In 2018, pursuant to the Chicago Municipal Code, her van was towed, impounded, and destroyed. She sued the city on her own behalf and on behalf of others similarly situated, challenging the constitutionality of various aspects of the ordinance. The district court granted, in part, her motion to certify her suit as a class action. With respect to the “Tow Class,” the court concluded that Santiago “is asserting only a facial challenge: the ordinance is unconstitutional because it fails to require adequate notice before a vehicle has been towed.” Concerning the Vehicle Disposal Class, the court rejected Chicago’s assertion that state law requires the class to show prejudice from the city’s failure to strictly follow its ordinance.The Seventh Circuit vacated. The class certification order does not fully demonstrate the “rigorous analysis” required by FRCP 23 and constituted an abuse of discretion. Considering whether questions of law or fact common to class members predominate begins with the elements of the underlying cause of action. The district court did not discuss any of the elements of the underlying causes of action or what the causes of action are. View "Santiago v. City of Chicago" on Justia Law

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The First Circuit affirmed the rulings of the district court denying the Commission of the New Hampshire Department of Health and Human Services' motion to dismiss Plaintiffs' complaints against her, holding that Plaintiffs' allegations of error were without merit.Plaintiffs were (1) a class of individuals who claimed to have been held against their will without due process on the basis of a certification of their need for emergency mental health treatment, and (2) a group of hospitals who claimed to have been forced to retain persons certified to be in need of such treatment. The Commissioner moved to dismiss the claims based on Eleventh Amendment immunity and Plaintiffs' asserted lack of standing. The district court denied the motion to dismiss. The First Circuit affirmed, holding that there was no merit to the Commissioner's challenges to the district court's standing and Eleventh Amendment immunity rulings. View "Doe v. Shibinette" on Justia Law

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This case arose out of several days of street protests during the September 2017 riots that occurred following the acquittal of a former St. Louis police officer for the on-duty shooting of a black man. Plaintiffs are a protester who allegedly was maced, a person whose cell phone was seized and searched as he filmed arrests, and an observer who was allegedly exposed to chemical agents and arrested on September 17.The Amended Complaint alleged that the City (i) violated the First Amendment by retaliating against plaintiffs for engaging in protected expressive activity; (ii) violated the Fourth Amendment because its custom, practice, and failure to train and supervise caused unlawful seizures and the use of excessive force by police officers; and (iii) violated the Fourteenth Amendment when officers failed to warn before deploying chemical agents, failed to provide opportunities to disperse, and arbitrarily enforced two ordinances of the St. Louis Code. The City subsequently appealed the district court's order denying its motion to dissolve the preliminary injunction that included affirmative mandates pending a prompt trial on the merits of plaintiffs' claims for a permanent injunction, and the district court's order granting class certification.The Eighth Circuit affirmed the district court's denial of the City's motion to dissolve the temporary injunction and remanded with directions to vacate and dissolve the injunction no later than October 31, 2021, if it has not been replaced with a final order either granting a permanent injunction or denying injunctive relief. The court explained that, given the rigorous 42 U.S.C. 1983 burdens of proof, the evidence at the preliminary injunction hearing relating to the events of September 2017, while relevant and sufficient to persuade the court to grant a preliminary injunction pendente lite, will not be sufficient to warrant permanent injunctive relief imposing the same levels of indefinite federal court control over the City's law enforcement responsibilities.The court vacated the class certification order without prejudice to plaintiffs renewing their request after a final order has been entered on their claim for permanent injunctive relief, at which point the district court can better assess whether a Federal Rule of Civil Procedure 23(b)(2) class is appropriate and necessary to afford proper equitable relief. The court explained that, given the individualized inquiries plaintiffs' disparate claims require, the massive class action certified neither promotes the efficiency and economy underlying class actions nor pays sufficient heed to the federalism and separation of powers principles in Supreme Court and Eighth Circuit precedent. View "Ahmad v. City of St. Louis" on Justia Law

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The Supreme Court affirmed the judgment of the circuit granting summary judgment for Defendants on all claims contained in Plaintiffs' second amended complaint seeking class certification, relief in mandamus, lost wages, and other monetary damages against six State Offices and their respective officeholders, holding that summary judgment was proper.In 2014, the Legislature amended W. Va. Code 6-7-1, changing the pay cycle for state employees from a semi-monthly to a bi-weekly basis. Plaintiffs, state employees who were paid one pay cycle in arrears pursuant to the provisions of section 6-7-1, claimed that when the statue was amended the result was a taking of five days of salary from every state employee in violation of W. Va. Const. Art. III, 10 or, alternatively, the imposition of a second arrearage beyond what is authorized by the statute. The circuit court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding that summary judgment was proper. View "Wilkinson v. W. Va. State Office of the Governor" on Justia Law

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Members of the plaintiff class were former Alaska State employees. When they enrolled in the State employee retirement system, a statute provided that if they left eligible employment, withdrew their contributions to the system, and later returned to eligible employment, they could repay their withdrawn contributions, be reinstated to their original benefits level, and have their credited service time restored. The statute was later repealed. The superior court ruled on summary judgment that this repeal did not diminish or impair the former employees’ accrued benefits and was therefore constitutional. The Alaska Supreme Court concluded the statutory reinstatement right was an accrued benefit of the retirement system protected against diminishment or impairment by article XII, section 7 of the Alaska Constitution. The Court therefore reversed the superior court’s judgment and remanded the case for further proceedings. View "Metcalfe v. Alaska" on Justia Law

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A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication.The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings. View "Doe v. Shenandoah Valley Juvenile Center Commission" on Justia Law

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The Cook County Jail houses primarily people who have not yet been convicted. Under the jail’s “paper triage” policy, a detainee who has dental pain and wants treatment must submit a health service request form (HSRF). Staff review the HSRF and categorize it as “routine,” “priority,” or “urgent.” The detainee is referred to a dentist for treatment in three to 30 days, depending on the categorization. Most detainees do not receive a face-to-face assessment from a nurse or higher-level practitioner before they see a dentist. An assessment could identify bona fide complaints of dental pain or reveal serious medical issues and would allow a nurse to dispense over-the-counter pain medication.McFields, a former detainee, filed a putative class action, alleging that detainees suffered gratuitous pain as a result of the paper triage policy. They alleged that the standard of care for processing a health service request requires a face-to-face assessment within 48 hours and that the jail’s policy is objectively unreasonable. The Seventh Circuit affirmed the denial of class certification, noting that each detainee presents a different situation that involved a different type of pain, took place at a different time, and involved different medical professionals and prison staff. McFields failed to satisfy the commonality and typicality requirements of Rule 23. Individual issues predominate over common questions. View "McFields v. Dart" on Justia Law