Latest 2 Cases: Morris v. Cradduck (Civil Rights), United States v. Dickerman (Criminal Law)

Local Control: Massachusetts Law Provides Stronger Protection Against Sexual Harassment than Federal Law

JOANNA L. GROSSMAN

SMU Dedman School of Law professor Joanna L. Grossman comments on a recent decision by a federal district court applying Massachusetts law that demonstrates the power of tough state antidiscrimination laws. Grossman describes the facts of the case and the differences between Massachusetts and federal law and explains why robust state laws have the power to hold institutions liable when they delegate authority to those who abuse it.

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Morris v. Cradduck

Docket: 17-3079

Opinion Date: March 30, 2020

Judge: Steven M. Colloton

Areas of Law: Civil Rights, Constitutional Law

Plaintiff, a former detainee at the detention center, filed suit against the sheriff and nurse, alleging that defendants delayed his access to adequate medical treatment for a serious condition while he was detained. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that there was insufficient evidence to support a submissible case. In this case, the nurse's actions demonstrated concern for plaintiff's condition and showed repeated efforts to make arrangements for surgery. Even if the nurse could be second-guessed for not acting more aggressively when the doctor's office delayed, her handling of the situation was at most negligent and does not amount to deliberate indifference that violates the Due Process Clause. Because plaintiff has not presented sufficient evidence that the nurse was deliberately indifferent to his serious medical needs, it follows that the sheriff did not violate plaintiff's rights by supposedly turning a blind eye to his complaints about the nurse. Likewise, claims against defendants in their official capacities, which are treated as claims against the municipality, failed for lack of a constitutional violation.

United States v. Dickerman

Docket: 18-3150

Opinion Date: March 30, 2020

Judge: Jane Louise Kelly

Areas of Law: Criminal Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to possession of child pornography. The court held that the Leon good-faith exception to the exclusionary ruled applied where law enforcement officers had no indication that the state court judge had failed to understand the affidavit or otherwise acted as a rubber stamp. Therefore, because the officers had no evidence that the judge abandoned his judicial role, they acted in good-faith reliance on the warrant's validity.