Justia Civil Rights Opinion Summaries

A probation officer with the Cook County Juvenile Probation Department alleged that her supervisors created a racially hostile work environment, culminating in her termination for performance issues and insubordination. She cited several workplace incidents, including the enforcement of a no-children-in-the-workplace policy, reprimands related to her work product and interactions with colleagues, and a 2016 meeting where the department director, while reading from a document, said the N-word in front of African American employees (an incident the plaintiff learned about secondhand). The plaintiff’s children occasionally waited in her office after school, and she was reminded of the policy prohibiting this practice. She also disagreed with supervisors over the content of reports submitted to the court, and she was ultimately terminated after an internal investigation found repeated insubordination and issues regarding her communications with clients and the court.The plaintiff first challenged her termination through union arbitration but lost. She then brought a lawsuit under Title VII in the United States District Court for the Northern District of Illinois, alleging that her employer subjected her to a race-based hostile work environment. The district court granted summary judgment in favor of her employer, concluding that the incidents cited, even when considered together, were not sufficiently severe or pervasive as required by Title VII, nor did the plaintiff demonstrate that the alleged harassment was based on race.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed, holding that the plaintiff did not present evidence of harassment that was severe or pervasive enough to alter the conditions of employment, nor did she establish that the alleged conduct was based on race. The court also found no error in the exclusion of late-disclosed witness testimony. The judgment for the employer was affirmed. View "Jones v. Das" on Justia Law

While detained at the Hancock County Jail in Indiana, Nicholas Zemlick underwent an elective abdominal surgery. Following his return to the jail, he developed an abdominal infection, experiencing worsening symptoms over several days. Jail medical staff monitored and treated him, ultimately prescribing antibiotics and arranging for a hospital transport after a nurse expressed concern about his condition. Zemlick underwent emergency surgery, recovered, and returned to the jail, where his wound continued to heal without further complications.Zemlick filed suit in the United States District Court for the Southern District of Indiana against the Hancock County Sheriff and two jail officers, alleging violations of his Fourteenth Amendment rights under 42 U.S.C. § 1983 for deliberate indifference to his medical needs. He also brought a Monell claim, asserting that the Sheriff failed to ensure adequate medical resources and training at the jail. The district court granted summary judgment to all defendants on the federal claims, finding no genuine dispute of material fact and relinquished jurisdiction over state-law claims. Zemlick subsequently settled with the medical staff defendants, leaving only the claims against the Sheriff and two officers for appeal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that the individual defendants did not violate Zemlick’s Fourteenth Amendment rights, either because the claims failed on the merits or because the officers were entitled to qualified immunity, as their conduct was not clearly established as unlawful. Regarding the Monell claim, the court found Zemlick’s theories were waived under district court procedures and unsupported by the record. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Zemlick v. Burkhart" on Justia Law

The case concerns a California statute that makes it a crime to knowingly file a false allegation of police misconduct and requires complainants to sign an advisory warning of potential criminal liability before their complaint is accepted. The Los Angeles Police Protective League sought an injunction compelling the City of Los Angeles to enforce this advisory requirement. The City had previously entered into a consent decree with the federal government prohibiting enforcement of the advisory, and even after the consent decree expired, continued not to require the advisory due to concerns about the statute’s constitutionality.The Superior Court of Los Angeles County, relying on the California Supreme Court’s earlier decision in People v. Stanistreet, granted the injunction and ordered the City to require the statutory advisory. The California Court of Appeal affirmed, adhering to Stanistreet’s reasoning that had upheld the statute’s constitutionality. The City then petitioned to the Supreme Court of California, arguing that subsequent federal decisions—especially Chaker v. Crogan by the Ninth Circuit—cast serious doubt on the continuing validity of Stanistreet and the constitutionality of the statute.Reviewing the case, the Supreme Court of California reconsidered its prior Stanistreet decision in light of more recent U.S. Supreme Court rulings, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that the statutory scheme—combining criminal penalties with a mandatory and prominently worded advisory—created a consequential risk of chilling truthful or well-intentioned complaints of police misconduct. The court concluded that this risk triggered heightened constitutional scrutiny under the First Amendment. The statute failed intermediate scrutiny because it was not narrowly tailored and burdened substantially more speech than necessary to serve the state’s legitimate interests. The court therefore reversed the judgment of the Court of Appeal. View "L.A. Police Protective League v. City of L.A." on Justia Law

A Kansas man was convicted in 2009 for the murder of a woman, Kathleen, but was acquitted of killing her husband, Carl. After spending twelve years in prison, he was exonerated when evidence emerged showing Kathleen had killed both herself and her husband, framing him for the crime. The exonerated man died shortly after his release. His widow, as executor of his estate, filed a federal civil rights suit under 42 U.S.C. § 1983, alleging constitutional violations by the police during the investigation that led to his conviction. Specifically, the claims against the two lead detectives included fabrication and suppression of evidence (Count I) and malicious prosecution (Count II).The United States District Court for the District of Kansas denied the detectives’ motion for summary judgment on both counts, rejecting their assertion of qualified immunity. The district court found that a jury could conclude the detectives withheld material exculpatory evidence, failed to preserve potentially exculpatory evidence, and fabricated inculpatory evidence. The court also found that a reasonable jury could determine the detectives acted at least recklessly, and that clear legal precedent established the officers’ obligations. The district court further denied summary judgment to the Unified Government (the detectives’ employer) on municipal liability claims, because those claims depended on the detectives’ alleged constitutional violations.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed only the legal questions related to qualified immunity. The appellate court affirmed the district court’s denial of qualified immunity on both counts, concluding the estate’s claims were supported by controlling law and sufficient factual allegations. The Tenth Circuit dismissed the Unified Government’s appeal for lack of pendent appellate jurisdiction, since it did not independently resolve the underlying constitutional claims. View "Coones v. Board of County Commissioners" on Justia Law

Solomon Jones, acting without an attorney, brought a civil rights lawsuit in federal court against several local government entities in Illinois. He alleged that his constitutional rights had been violated during a series of events in 2023, including his being ticketed and arrested for trespassing and disorderly conduct. Subsequent to filing his lawsuit, Jones filed multiple motions, including one requesting the district judge’s recusal.The United States District Court for the Central District of Illinois denied Jones’s motion for recusal. Acting on its own initiative, the court also determined it should abstain from hearing Jones’s claims under the doctrine established in Younger v. Harris, because a related state criminal case was still pending. The district court stayed the federal case, instructing Jones to provide a status update after the conclusion of the state proceedings. While this appeal was pending, Jones notified the court that he had been acquitted in the state criminal case.The United States Court of Appeals for the Seventh Circuit determined it lacked jurisdiction to review the denial of the recusal motion, as no final judgment had been entered. However, it found the stay order based on Younger abstention was immediately appealable. Since the state court proceedings had ended, the appellate court held that the basis for abstention no longer existed. Consequently, the Seventh Circuit vacated the district court’s stay order and remanded the case for further proceedings, directing the district court to address any new developments, such as additional state charges Jones reported, and determine their relevance to the federal case. View "Jones v. Kankakee County Sheriff's Department" on Justia Law

The case centers on Taiwan Orran Reed, who was convicted by a jury in August 2020 of multiple offenses, including pimping, pandering, human trafficking, and rape involving two victims. The jury also found special circumstances under California’s one strike law, resulting in Reed’s sentence of 21 years four months in prison, plus 30 years to life. Reed, who is African American, later filed a petition for writ of habeas corpus in the Riverside County Superior Court, seeking relief under the California Racial Justice Act of 2020. He alleged that racially discriminatory language—specifically being referred to as a “gorilla pimp”—was used by the prosecutor and expert law enforcement witnesses during his trial.After Reed’s retained counsel withdrew due to personal reasons and lack of payment, the superior court appointed the Riverside County Public Defender to represent Reed at an evidentiary hearing on his habeas petition. The Public Defender objected to the appointment, arguing that under Government Code section 27706, subdivision (g), his office has discretionary authority to decline representation in postconviction habeas matters, unlike mandatory representation required in trial proceedings under subdivision (a). The trial court disagreed and compelled the Public Defender to accept the appointment, finding that the Public Defender had not demonstrated unavailability.The California Court of Appeal, Fourth Appellate District, Division Two, granted the Public Defender’s petition for writ of mandate. The appellate court held that section 27706(g) governs public defenders’ representation of habeas petitioners, granting them discretion to decline such appointments without a showing of unavailability. The trial court’s order compelling the Public Defender to represent Reed was vacated, and the superior court was directed to appoint alternate counsel for Reed’s habeas petition. View "Harmon v. Superior Ct." on Justia Law

Several female students at a public university alleged that the school violated Title IX by failing to offer varsity-level women’s teams in equestrian, field hockey, and lacrosse. Although the university provided club-level opportunities for these sports, the plaintiffs contended that this did not satisfy the school’s obligation to offer equal athletic opportunities. Over the previous decade, the percentage of female students and female varsity athletes at the university increased, but women still comprised a smaller share of varsity athletes than of the total student body. The university periodically surveyed students to assess interest and ability for new varsity teams and maintained a review committee to monitor athletic opportunities.The United States District Court for the Eastern District of Kentucky held a three-day bench trial, considering testimony from students, coaches, and university staff, as well as survey data regarding student interest and ability in the relevant sports. The district court found that while women were underrepresented relative to the student body, the plaintiffs failed to show there were enough female students with the requisite interest and ability to compete at the Division I varsity level in equestrian, field hockey, or lacrosse. The court concluded the university had sufficiently accommodated the athletic interests and abilities of its female students and denied relief to the plaintiffs.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the district court did not clearly err in finding insufficient interested and able female students to form viable varsity teams in the disputed sports. The court also upheld the exclusion of an expert witness who lacked relevant survey design expertise. The Sixth Circuit affirmed the judgment in favor of the university, holding that Title IX does not require the creation of new varsity teams in the absence of demonstrated unmet demand and ability. View "Niblock v. University of Kentucky" on Justia Law

A cloud-based real estate services company faced persistent and grave allegations that two top agents, along with several others, drugged and sexually assaulted company agents at events. Reports began surfacing in 2020, including a viral social media post and a memo sent to company executives detailing numerous incidents. Despite these warnings, the board initially terminated one perpetrator but continued paying him, and allowed others implicated to continue working. A whistleblower director raised these issues repeatedly at board meetings and with outside counsel, but the board’s responses were limited to internal investigations led by insiders and did not result in meaningful change. The company only took further action after survivors filed federal anti-trafficking lawsuits in 2023 and the story became public.Prior to the current litigation, federal courts sustained anti-trafficking claims against the company and its leadership, finding sufficient allegations that the leadership benefited from retaining perpetrators due to the company’s revenue-sharing structure. The defendants in this derivative action are not accused of direct misconduct, but of harming the company by allowing and covering up systemic sexual abuse. The plaintiff, a shareholder, alleges the board and certain officers actively covered up abuse and breached their fiduciary duties, and that some board members failed their oversight obligations in the face of numerous red flags.The Delaware Court of Chancery reviewed the defendants’ motions to dismiss. It held that workplace sexual misconduct can constitute a corporate trauma supporting a breach of fiduciary duty claim under Delaware law. The court denied dismissal as to claims against the officer alleged to have benefited from covering up abuse, and against the directors for failing to respond in good faith to clear red flags. However, it granted dismissal of a novel claim seeking to extend oversight duties to a control group of shareholders, declining to make new law in that area. View "Los Angeles City Employees' Retirement System v. Sanford" on Justia Law

Jaryan Gills, an inmate at East Moline Correctional Center, was assaulted by another prisoner, suffering a broken arm that required two surgeries. Following the incident, Gills was placed in medical segregation for a month in a cell lacking a sink or toilet, relying on guards for bathroom access and provided with portable urinals and waste bags. He alleges that prison staff frequently denied him timely bathroom access, resulting in unsanitary conditions. Gills also contends that he received delayed or inadequate medical care for his injuries and other health issues, and that a prison doctor and staff were deliberately indifferent to these needs.The United States District Court for the Central District of Illinois reviewed cross-motions for summary judgment. In its decision, the district court disregarded Gills’s declarations, which largely repeated allegations from his complaint and added details not disclosed in his deposition, and granted summary judgment to the defendants. The court determined that Gills failed to present sufficient evidence to establish genuine disputes of material fact regarding his Eighth Amendment claims for unconstitutional conditions of confinement and inadequate medical care, as well as his conspiracy and intentional infliction of emotional distress claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s rulings. The Seventh Circuit held that the district court did not abuse its discretion in excluding Gills’s declarations under the sham affidavit rule. While the conditions Gills experienced may have been unpleasant, the appellate court found that the evidence did not support a finding of deliberate indifference by prison officials or the medical director. The court also concluded that Gills’s conspiracy claim failed because no underlying constitutional violation was proven and there was no non-speculative evidence of an agreement among defendants. The judgment in favor of the defendants was affirmed. View "Gills v. Hamilton" on Justia Law

Ajay, a recent immigrant from India with limited English proficiency, was investigated for alleged sexual assault and attempted sexual assault against a child under 14 in Reno, Nevada. The accusations stemmed from an incident involving a 13-year-old boy, A.P., whom Ajay met at his workplace and with whom he allegedly engaged in sexual acts. During a custodial police interrogation, Detective DeSantis read Ajay his Miranda rights in English. Ajay repeatedly expressed confusion, stated he was not good in English, and requested to speak in Hindi or have an interpreter. Despite this, DeSantis continued explaining the rights in English, using props and hypotheticals, until Ajay acquiesced and the interrogation proceeded, resulting in a confession.Ajay moved to suppress his statements before the Second Judicial District Court, Washoe County, arguing he had not knowingly and intelligently waived his Miranda rights due to his limited English proficiency. At a pretrial hearing, Ajay testified through an interpreter, detailing his lack of formal English education and unfamiliarity with the American legal system. The district court denied his motion, finding the waiver valid and voluntary, citing DeSantis’s efforts to clarify the warnings and Ajay’s apparent understanding.On appeal, the Supreme Court of Nevada reviewed whether Ajay’s Miranda waiver was knowing and intelligent. The court found that Ajay's limited English skills and explicit requests for an interpreter demonstrated he did not understand his rights. The court held that law enforcement must recognize when a language barrier prevents meaningful waiver and provide an interpreter as necessary. The district court’s admission of Ajay’s confession was not harmless beyond a reasonable doubt given its significance at trial. Therefore, the Supreme Court of Nevada reversed the conviction and remanded for further proceedings. View "Ajay v. State" on Justia Law