Case: Lopera v. Town of Coventry

On April 7, 2008, twelve individuals, all represented by private counsel, filed a civil rights lawsuit in the U.S. District Court of Rhode Island against the town of Coventry and individual members of the town's police force (Police). Plaintiffs brought suit under 42 U.S.C. § 1983 and state law alleging denial of due process and equal protection, unreasonable search and seizure, invasion of privacy, racial profiling and race/national origin intimidation.

Specifically, plaintiffs, Hispanic members of the Central Falls High School boys soccer team, claimed that they were treated improperly when traveling to Coventry, a predominately white neighborhood, for a high school soccer game. When the game was over, members of the home team stopped the Central Falls coach and accused his team of stealing electronic devices from the locker room. The coach searched his players' bags but found nothing. The police arrived on the scene, blocking the team's bus, and asked the coach if they could search the players. The coach consented. The police searched the boys' property as members of the Coventry community looked on and shouted racist epithets and accused the boys of theft. The search lasted approximately one hour and none of the allegedly stolen items were found.

On September 9, 2009, the district court (Judge William Smith) granted defendants' motion for summary judgment on the basis of qualified immunity. The district court held that the plaintiffs could not overcome qualified immunity in their claims. On the Fourth Amendment claim, the court found plaintiffs' case to be insufficient to overcome qualified immunity because the police officers did not violate the plaintiffs' clearly established rights, because the coach may have been acting in loco parentis when he consented to the police officers' request to search members of the team and their belongings. The court also held that the plaintiffs' invasion of privacy claim arose out of conduct for which the police officers were immune from suit. On the Equal Protection claim, the court held that the plaintiffs failed to show that the officers had a racial motive, even if they exhibited poor judgment in searching the boys in front of an angry crowd; for the same reasons, the court granted summary judgment for the defendants on the plaintiffs' state racial profiling claim. Finally, the court held there was insufficient evidence for plaintiffs' claim of supervisory and municipal liability.

Plaintiffs appealed to the First Circuit. On April 1, 2011, the Circuit Court (Chief Judge Lynch, Judge Selya, and Judge Thompson) upheld the district court's grant of summary judgment. The appellate court found that the officers' conduct was subject to qualified immunity. As to the plaintiffs' Fourth Amendment and state privacy claims, the court found that it was not unreasonable for the officers to consider the coach's consent to search the team. The court also held that the plaintiffs could not overcome qualified immunity on their equal protection and state discrimination claims.