Justia Civil Rights Opinion Summaries

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Plaintiff filed suit against defendants under the Americans with Disabilities Education Act (ADA), 42 U.S.C. 12101 et seq.; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; and state and local law. Plaintiff alleged that he was discriminated against at his workplace due to, inter alia, his HIV‐positive status and his failure to conform to gender stereotypes. The district court dismissed the federal claims for failure to state a claim and declined to exercise supplemental jurisdiction over his state and local claims. The district court concluded that Simonton v. Runyon and Dawson v. Bumble & Bumble, holding that Title VII does not prohibit discrimination on the basis of sexual orientation, precluded plaintiff's Title VII claim. The court concluded that it lacked power to reconsider Simonton and Dawson. The court concluded, however, that the district court erred by determining that plaintiff failed to plausibly allege a Title VII claim based on the gender stereotyping theory of sex discrimination articulated in Price Waterhouse v. Hopkins. In this case, plaintiff's complaint identified multiple instances of gender stereotyping discrimination. The court clarified that gay, lesbian, and bisexual individuals do not have less protection under Price Waterhouse against traditional gender stereotype discrimination than do heterosexual individuals. Simonton and Dawson merely held that being gay, lesbian, or bisexual, standing alone, does not constitute nonconformity with a gender stereotype that can give rise to a cognizable gender stereotyping claim. Accordingly, the court reversed the dismissal of the Title VII claim and remanded. The court affirmed in all other respects. View "Christiansen v. Omnicom Group, Inc." on Justia Law

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M.C. filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A), alleging that the district violated the IDEA by (1) failing to adequately document the services provided by a teacher of the visually impaired (TVI), (2) failing to specify the assistive technology (AT) devices provided, and (3) failing to file a response to the due process complaint. The court concluded that the district's failure to adequately document the TVI services and AT devices offered to M.C. violated the IDEA and denied M.C. a free appropriate public education (FAPE); these procedural violations deprived M.C.'s mother of her right to participate in the individualized education program (IEP) process and made it impossible for her to enforce the IEP and evaluate whether the services M.C. received were adequate; and, at the very least, plaintiffs were entitled to have the district draft a proper IEP and receive compensatory education he would have occupied but for the school's violations of the IDEA. Accordingly, the court reversed the judgment and remanded. View "M.C. v. Antelope Valley Union High School District" on Justia Law

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Plaintiff, an African-American, filed suit against defendants after her application to lease a space for her hair salon was denied. Plaintiff alleged that the denial infringed her right to freedom from racial discrimination in the making of a contract. The district court granted summary judgment for defendants. The court affirmed the district court's alternative conclusion that plaintiff failed to rebut the legitimate, nondiscriminatory reasons defendants proffered for denying her lease application. Defendants' reasons included: odors emanating from the salon would disturb the residential tenants on the upper floors; plaintiff's business would not survive given the number of other salons in the area; a salon would not generate cross-shopping with other commercial tenants; plaintiff's credit score was too low; and defendants would not break even given the high cost of building out the unit. View "Flournoy v. CML-GA WB, LLC" on Justia Law

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In 1998, Breeden was found dead in the Kentucky River. King was a suspect because of her sporadic relationship with Breeden, because she had bullet holes inside her home, and because, after Breeden’s disappearance, King had shared premonitions of “Breeden being found in water.” Officers unsuccessfully attempted to obtain a search warrant for King’s residence. In 2006 Detective Harwood obtained a warrant. His affidavit omitted that Breen’s bullet wounds were non-exiting and could not have caused bullet holes in King’s floor and that King had one leg and weighed 100 pounds, while Breeden weighed 187 pounds. There was no evidence that King had destroyed evidence; gunshot evidence at her home did not match bullets recovered from Breeden. King entered an “Alford plea,” maintaining her innocence. In 2012, a serial murderer (Jarrell) confessed that he had killed Breeden and recounted the crime with specific details that had not been released. Harwood visited Jarrell in jail. King alleges that Harwood intimidated Jarrell into recanting. In 2014, charges against King were dismissed. The district court dismissed King’s suit under 42 U.S.C. 1983 as time-barred and citing qualified immunity. The Sixth Circuit reversed as to King’s malicious-prosecution claim against Harwood. King raised genuine issues of material fact: whether Harwood set King’s prosecution in motion by applying for warrants and an indictment despite the lack of probable cause; whether Harwood's false statements, together with his material omissions were material to King’s prosecution; and whether any false statements, evidence, and omissions were “laying the groundwork for an indictment," not “preparatory activity” for a grand-jury hearing that would provide absolute immunity. View "King v. Harwood" on Justia Law

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Plaintiffs brought a lawsuit against their insurance carrier (Defendant), claiming that Defendant had incorrectly denied coverage. The case proceeded to a jury trial. The jury’s unanimous verdict was for Defendant. Thereafter, Plaintiffs filed a motion for a new trial after learning that the jury foreperson had a prior felony conviction, arguing that the juror was not qualified to serve on the jury under 28 U.S.C. 1865(b)(5). The district court denied the motion for a new trial, concluding that Plaintiffs had not shown that the juror’s service deprived them of a fundamentally fair trial. The First Circuit affirmed, holding that the juror’s inclusion was not fatal to the jury’s verdict, and therefore, the district court properly denied Plaintiffs’ new-trial motion. View "Faria v. Harleysville Worcester Insurance Co." on Justia Law

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After a jury trial, Defendant was convicted of first degree murder and use of a firearm to commit a felony. The Court of Appeals affirmed, holding that the district court did not err by (1) failing to grant Defendant’s motion to suppress Defendant’s statements made to law enforcement because the statements were not obtained in violation of Miranda v. Arizona; (2) denying Defendant’s Batson challenge claiming that the prosecution impermissibly struck prospective jurors on the basis of race; and (3) denying Defendant’s motion for mistrial that alleged that the court improperly allowed testimony in violation of Brady v. Maryland. View "State v. Clifton" on Justia Law

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After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law

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Plaintiffs filed suit challenging the constitutionality of a collection of New York regulations and laws that together prevent for‐profit law firms from accepting capital investment from non‐lawyers. The district court dismissed the complaint for failure to allege the infringement of any cognizable constitutional right. On de novo review, the court concluded that neither as a for-profit partnership nor as a professional limited liability company do plaintiffs have the associational or petition rights that they claim. Even if the court were to assume, given the evolving nature of commercial speech protections, that they possess First Amendment interests, the regulations at issue here were adequately supported by state interests and have too little effect on the attorney‐client relationship to be viewed as imposing an unlawful burden on plaintiffs' constitutional interests. Accordingly, the court affirmed the judgment. View "Jacoby & Meyers v. The Presiding Justices of the First, Second, Third, and Fourth Departments" on Justia Law

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Plaintiffs filed suit seeking to hold the Palestinian Authority vicariously liable for an attack of a holy site in the West Bank by an armed gunman. The court rejected plaintiffs' claim that the Fifth Amendment's Due Process Clause imposes personal jurisdiction restrictions that are less protective of defendants than those imposed by the Fourteenth Amendment, explaining that precedent foreclosed this claim. Therefore, the court concluded that plaintiffs failed to carry their burden of demonstrating that personal jurisdiction over the Palestinian Authority in this case would meet the requirements of the Fifth Amendment's Due Process Clause. Accordingly, the court affirmed the district court's denial of plaintiffs' motions for jurisdictional discovery and its grant of the Palestinian Authority's motions to dismiss for lack of personal jurisdiction. View "Livnat v. Palestinian Authority" on Justia Law

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Plaintiffs, three death row inmates in Virginia, filed suit alleging that their conditions of confinement amounted to cruel and unusual punishment in violation of the Eighth Amendment. Death row inmates, among other things, spent 23 hours a day alone; had only non-contact visits and contact visitations with immediate family members were subject to unspecified "extreme circumstances" with the warden maintaining unconstrained discretion to grant or deny such requests; and were barred from joining general population inmates for vocational, educational, or behavioral programming. After plaintiffs filed their complaint, defendants substantially changed the policies governing the conditions of confinement for inmates on Virginia's death row, addressing virtually all of the issues raised in plaintiffs' complaint. The district court concluded that plaintiffs' action was moot. The court agreed with plaintiffs that defendants' voluntary cessation of the challenged practice has not yet mooted this action because defendants failed to meet the Supreme Court's requirement of showing that it was absolutely clear the allegedly wrongful behavior could not reasonably be expected to recur. In this case, nothing bars the Corrections Department from reverting to the challenged policies in the future. Accordingly, the court reversed and remanded. View "Porter v. Clarke" on Justia Law