Justia Civil Rights Opinion Summaries

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law

Sean Hart and Tiffany Guzman filed a lawsuit against the City of Grand Rapids and three police officers, alleging excessive force during a 2020 Black Lives Matter demonstration. Hart and Guzman claimed that the officers used excessive force and that the City ratified this conduct. The officers sought summary judgment based on qualified immunity, and the City argued that the plaintiffs failed to establish municipal liability.The United States District Court for the Western District of Michigan granted summary judgment in favor of the City and the officers, dismissing the federal claims with prejudice and declining jurisdiction over the state claims. The plaintiffs appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment based on qualified immunity for Officer Johnson and Sergeant Bush, finding that the plaintiffs did not show that the officers violated clearly established rights. However, the court reversed the grant of summary judgment for Officer Reinink, determining that a reasonable jury could find that he used excessive force when he fired a Spede-Heat canister at Hart at close range, which could be considered deadly force. The court remanded the case for further proceedings on this claim.The court also affirmed the grant of summary judgment in favor of the City, concluding that the plaintiffs did not provide sufficient evidence to support their claim of municipal liability based on ratification of unconstitutional conduct. The plaintiffs' evidence, a spreadsheet of excessive force complaints, lacked qualitative specifics to show a pattern of inadequate investigations by the City. View "Hart v. City of Grand Rapids, Mich." on Justia Law

In 1985, Douglas Carter was convicted and sentenced to death for the murder of Eva Olesen in Provo, Utah. There was no physical evidence linking Carter to the crime scene, but he signed a confession, and two witnesses, Epifanio and Lucia Tovar, provided testimony corroborating aspects of his confession. Decades later, the Tovars signed declarations stating that the police had threatened them, pressured them to make untrue statements, and instructed them to lie at Carter’s trial about financial support they had received from the police. Based on these revelations, Carter petitioned for postconviction relief.The Fourth Judicial District Court held an evidentiary hearing and found that Carter’s trial and sentencing were tainted by serious misconduct by the lead prosecutor, the lead investigator, and another police officer. The court found that the police had suborned perjury, threatened the Tovars with deportation and separation from their son, and provided them with financial assistance, which they were instructed to lie about. The prosecutor did not disclose this information to the defense or correct the false testimony at trial.The Utah Supreme Court reviewed the case and agreed with the lower court’s findings. The court concluded that the State had violated Carter’s constitutional right to due process by suppressing evidence favorable to Carter and by failing to correct false testimony. The court determined that these violations prejudiced Carter at both the guilt and sentencing stages of his trial. The court affirmed the lower court’s decision to grant Carter’s petition for postconviction relief, vacate his conviction and sentence, and order a new trial. View "Carter v. State" on Justia Law

Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law

Boyle Ventures, LLC (Boyle) operates franchised retail pet stores selling cats and dogs from USDA-regulated breeders. After obtaining a business license in Fayetteville, the City Council passed Ordinance No. 6587, prohibiting such sales unless the animals were obtained from approved shelters or rescue organizations. Boyle filed suit against the City, seeking a declaratory judgment that the Ordinance violated Arkansas statutes, injunctive relief, and damages under the Arkansas Civil Rights Act. The parties agreed to a temporary restraining order, preventing the Ordinance from taking effect. Before the circuit court could rule, the City repealed the Ordinance, rendering the declaratory relief moot. The circuit court ultimately ruled in favor of the City, finding the Ordinance conflicted with state law but that the City was protected by qualified immunity.The Benton County Circuit Court dismissed Boyle's complaint, finding that the Ordinance conflicted with state law but that the City was immune from damages as it did not violate clearly established constitutional rights. Boyle appealed, arguing the Ordinance violated the Arkansas Constitution and that the City was not immune from damages. The City cross-appealed, arguing the Ordinance did not violate state law.The Supreme Court of Arkansas reviewed the case and held that the circuit court erred in finding the Ordinance violated state law because it never went into effect and did not deprive Boyle of any rights or cause damages. Consequently, the court reversed the circuit court's decision on the cross-appeal and remanded for dismissal. The direct appeal and any remaining issues were dismissed as moot. View "BOYLE VENTURES, LLC V. CITY OF FAYETTEVILLE" on Justia Law

In 2021, the Turtle Mountain Band of Chippewa Indians, Spirit Lake Tribe, and three individual Native American voters filed a lawsuit against North Dakota’s Secretary of State. They claimed that the state's 2021 redistricting plan diluted Native American voting strength, violating Section 2 of the Voting Rights Act (VRA) and 42 U.S.C. § 1983. Section 2 of the VRA prohibits vote dilution, which can occur through packing a minority group into one district or dividing them among several districts to weaken their voting power.The United States District Court for the District of North Dakota denied the Secretary's motion to dismiss, which argued that private plaintiffs lacked a cause of action under Section 2 and could not use § 1983 to enforce it. The district court allowed the case to proceed, and after a bench trial, it ruled that the 2021 redistricting map violated Section 2. The court permanently enjoined the Secretary from using the map and ordered the North Dakota Legislative Assembly to adopt a remedial map. When the Assembly failed to do so, the court imposed the plaintiffs' proposed map.The United States Court of Appeals for the Eighth Circuit reviewed the case. The main issue was whether private plaintiffs could enforce Section 2 of the VRA through § 1983. The court held that Section 2 does not unambiguously confer an individual right enforceable under § 1983. The court emphasized that Section 2 focuses on the entities regulated (states and political subdivisions) rather than unambiguously creating individual rights. Consequently, the court vacated the district court's judgment and remanded the case with instructions to dismiss it for lack of a cause of action. View "Turtle Mountain Band of Chippewa Indians v. Howe" on Justia Law

Theresa Brooke, a woman with disabilities who uses a wheelchair, visited the Ramada by Wyndham Burbank Airport hotel in August 2023. She alleged that architectural barriers at the hotel deterred her from entering. Brooke sued the hotel's owner, Tsay JBR, LLC, for violations of Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act. She sought injunctive relief under the ADA and statutory damages under the Unruh Act.The United States District Court for the Central District of California granted partial summary judgment in favor of Brooke, finding that Tsay JBR had violated the ADA due to the lack of an access aisle in the hotel's passenger loading zone. This ADA violation also constituted a violation of the Unruh Act. However, the court found that there was a factual issue regarding whether Brooke personally encountered the violation or was deterred by it, which is necessary for statutory damages under the Unruh Act. The district court scheduled a bench trial, concluding that the Seventh Amendment right to a jury trial did not apply to claims for statutory damages under the Unruh Act.The United States Court of Appeals for the Ninth Circuit reviewed the case and granted Tsay JBR's petition for a writ of mandamus. The Ninth Circuit held that the Seventh Amendment entitles parties in federal court to a jury trial on claims for statutory damages under section 52(a) of the Unruh Act. The court determined that Brooke's claim was legal in nature, both in terms of its historical analog to 18th-century English public accommodations law and the punitive and deterrent nature of the statutory damages sought. The court directed the district court to set the matter for a jury trial. View "TSAY JBR LLC V. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA" on Justia Law

Yolanda Welch Atkins, a court clerk for Macon, Mississippi, since 2003, was placed on leave in October 2020 after $3,200 in municipal court fines and fees went missing, leading to her arrest and indictment for embezzlement. Despite this, she was reinstated by the board of aldermen. In January 2021, after running unsuccessfully for mayor against Patrick Hopkins's preferred candidate, Atkins was not reappointed as court clerk when Hopkins and other aldermen did not second the motion for her reappointment.Atkins sued Hopkins and others, claiming First Amendment retaliation. The United States District Court for the Southern District of Mississippi granted summary judgment to all defendants except Hopkins, finding a genuine dispute of material fact regarding whether Hopkins's refusal to second the motion was due to Atkins's protected speech. Hopkins appealed the denial of summary judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that under the doctrine of qualified immunity, government officials are protected from liability unless they violate clearly established statutory or constitutional rights. The court found that existing precedent, including Sims v. City of Madisonville, did not clearly establish that Hopkins's specific conduct—refusing to second a motion—violated the First Amendment. Consequently, the court held that Hopkins was entitled to qualified immunity.The Fifth Circuit reversed the district court's denial of summary judgment for Hopkins and remanded the case for further proceedings, without indicating what those proceedings should entail. View "Atkins v. Hopkins" on Justia Law

A mother was shot and killed by a deputy sheriff while her young children watched. The mother, who had been acting erratically and wielding a knife, advanced towards the deputies despite repeated requests to drop the weapon. The lead deputy fired his service pistol after a backup deputy's taser failed to stop her. The children, through their guardian ad litem, sued the deputies and Nevada County, claiming the use of force was unreasonable.The trial court ruled that the lead deputy acted reasonably and granted summary judgment in his favor, but allowed the claims against the backup deputy to proceed, finding that a reasonable juror could conclude his actions were unreasonable. The backup deputy and the County petitioned for a writ of mandate, arguing that the trial court should have granted their summary judgment motion as well.The California Court of Appeal, Third Appellate District, reviewed the case. The court emphasized the need to assess reasonableness from the perspective of a reasonable officer at the scene, considering the split-second decisions officers must make. The court concluded that the backup deputy acted reasonably as a matter of law, noting that the mother advanced towards the deputies with a deadly weapon and that the backup deputy's use of a taser was a reasonable response under the circumstances.The court issued a writ of mandate directing the trial court to set aside its partial denial of the summary judgment motion and to enter a new order granting the motion in its entirety, thus ruling in favor of the backup deputy and the County. View "County of Nevada v. Super. Ct." on Justia Law

Michael Poffenbarger, a First Lieutenant in the Air Force Reserve, filed a lawsuit challenging the Air Force’s COVID-19 vaccine mandate, claiming it violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. He sought a religious exemption, which was denied, and subsequently refused the vaccine. As a result, he received a letter of reprimand and was placed on inactive status, losing pay and retirement points. Poffenbarger sought declaratory and injunctive relief, including restoration of lost pay and points.The United States District Court for the Southern District of Ohio initially granted a preliminary injunction preventing the Air Force from taking further punitive action against Poffenbarger. In a related case, Doster v. Kendall, the same court certified a class of affected service members and issued similar injunctions. The Sixth Circuit affirmed these injunctions, but the Supreme Court later vacated the decision on mootness grounds after Congress directed the rescission of the vaccine mandate. The district court then dismissed Poffenbarger's case as moot.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Poffenbarger’s claim for lost drill pay and retirement points was barred by federal sovereign immunity. The court explained that RFRA’s waiver of sovereign immunity does not unequivocally include claims for money damages against the federal government. Since Poffenbarger’s claim sought retrospective compensation for a previous legal wrong, it constituted money damages, which are not covered by RFRA’s waiver. Consequently, the Sixth Circuit affirmed the district court’s dismissal of the case. View "Poffenbarger v. Kendall" on Justia Law