Supreme Court to Inmate: Three Strikes and You’re Out!

April 2016 | Category: Significant Cases

In Coleman v. Tollefson, 135 S. Ct. 1759 (2015), the Supreme Court held that a district court’s dismissal of an inmate’s complaint under 28 U.S.C. § 1915(g)—frivolous, malicious, or fails to state a claim—counts as a “strike” for purposes of determining an inmate’s eligibility for in forma pauperis (IFP) status, even […]

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Ninth Circuit Holds Jail Design Constitutional Monell Policy

April 2016 | Category: Significant Cases

In Castro v. County of Los Angeles, 785 F.3d 336 (9th Cir. 2015), the Ninth Circuit held that the design of a jail cell constitutes a formal policy for purposes of Monell liability. But because the Eighth Amendment’s deliberate-indifference element is a subjective standard, there must be proof that a policymaker with authority […]

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Supreme Court Strikes Down Prison’s Grooming Policy

April 2016 | Category: Significant Cases

In Holt v. Hobbs, 135 S.Ct. 853 (2015), the Supreme Court held that a prison’s grooming policy that prohibited inmates from growing ½-inch beards violated the Religious Land Use and Institutionalized Persons Act because it imposed a substantial burden on the inmate’s exercise of his Muslim faith. The court held that […]

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Arizona Supreme Court: State Entitled to Absolute Immunity for Road’s Original Design Despite Subsequent Material Change to Travel Conditions

April 2016 | Category: Significant Cases

In Glazer v. State, 237 Ariz. 160 (2015), the Arizona Supreme Court held that A.R.S. § 12-820.03—an affirmative defense against claims for injuries arising out of an original plan or design for the construction of a roadway so long as the original plan or design complied with generally accepted standards—is available […]

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Ninth Circuit Clarifies Punitive Damages Standard in § 1983 Action

April 2016 | Category: Significant Cases

In Castro v. County of Los Angeles, 785 F.3d 336 (9th Cir. 2015), the Ninth Circuit held that the deliberate-indifference standard for constitutional violations and the reckless-indifference standard for punitive damages in § 1983 cases are synonymous. Thus, juries “have the discretion to impose punitive damages if they believe further punishment […]

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