Justia Civil Rights Opinion Summaries

A mother and the Connecticut Fair Housing Center sued a company that provides tenant screening reports, alleging that its practices contributed to the denial of a housing application for the mother’s disabled son. The apartment manager used the defendant’s screening platform to review applicants’ criminal histories, and the son’s application was denied based on a flagged shoplifting charge. The mother later had the charge dismissed. She also sought a copy of her son’s screening report from the defendant, but was told she needed to provide a power of attorney. She instead submitted documentation of her conservatorship, but the defendant rejected it as facially invalid due to a missing court seal.The United States District Court for the District of Connecticut held a bench trial. It found that the Fair Housing Act (FHA) did not apply to the defendant because it was not the decision-maker on housing applications; only the housing provider made those determinations. The district court also found the defendant’s requirement for a valid conservatorship certificate reasonable and not discriminatory toward handicapped individuals. However, the district court found the defendant liable under the Fair Credit Reporting Act (FCRA) for a period when it insisted on a power of attorney, making it impossible for the mother to obtain her son’s consumer file.On appeal, the United States Court of Appeals for the Second Circuit concluded that the Connecticut Fair Housing Center lacked standing because its diversion of resources to address the defendant’s actions did not constitute a concrete injury. The court also held that, although the FHA does not exclude certain defendants, the defendant here was not the proximate cause of the housing denial, and the mother failed to establish a prima facie case of disparate-impact discrimination. Furthermore, because she never provided a facially valid conservatorship certificate, she could not show that the defendant’s documentation requirements prevented her from obtaining the report. The court vacated, affirmed, and reversed in part, dismissing the Center’s claims, affirming no FHA liability, and reversing FCRA liability. View "CFHC v. CoreLogic Rental Prop. Sols." on Justia Law

In 2000, Tommie Lawson Lynex, an African American man, was convicted by a jury of first degree murder and received a firearm enhancement under California Penal Code section 12022.53, subdivision (d), resulting in a sentence of 50 years to life. Twenty years later, California enacted the Racial Justice Act, allowing prisoners to seek habeas relief if their conviction or sentence was influenced by race, ethnicity, or national origin. Lynex filed a habeas petition under this Act, including statistical evidence showing racial disparities in the prosecution of murder charges with firearm enhancements in Los Angeles County.The Superior Court of Los Angeles County initially denied Lynex’s habeas petition and his request for appointment of counsel, finding the petition procedurally barred as successive and concluding that Lynex had not made a prima facie showing of entitlement to relief under the Racial Justice Act. The court also determined that Lynex did not sufficiently allege facts indicating racial animus or bias in the police investigation or prosecution.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. It held that the trial court applied the wrong legal standard by requiring a prima facie showing for appointment of counsel. Under the Racial Justice Act and section 1473, subdivision (e), a petitioner need only plead a plausible allegation of a violation to obtain counsel. The appellate court also found that the trial court erred by not recognizing its discretion to permit amendment of the petition and by improperly invoking procedural bars at the initial stage. The Court of Appeal issued a writ of mandate directing the trial court to vacate its denial and conduct further proceedings consistent with its opinion. View "In re Lynex" on Justia Law

The defendant, while on supervised release following a federal conviction for being a felon in possession of a firearm, was arrested in May 2023 for new state charges involving drug trafficking, possession of marijuana and drug paraphernalia, and being a felon in possession of a handgun. These events occurred after violations that led to his second supervised release revocation but before the hearing for those violations, and were not discovered by the federal probation office until several months later. Upon learning of the May 2023 incident, after the defendant had completed his sentence and was again on supervised release, the probation office initiated the proceedings at issue, seeking a third revocation based on the new conduct.The United States District Court for the Eastern District of Kentucky held a hearing to determine if the defendant could knowingly and voluntarily waive his right to counsel in the revocation proceeding, ultimately allowing him to represent himself. After a subsequent hearing, the district court found violations of supervised release, classified the new conduct as a Grade A violation, and imposed a 24-month term of imprisonment, the statutory maximum. The defendant timely appealed, challenging the validity of his waiver of counsel, the sentencing procedure, and the constitutionality of his underlying conviction.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the right to counsel in a supervised release revocation is not derived from the Sixth Amendment but is governed by statutory and due process considerations. The court reviewed the waiver of counsel for abuse of discretion and found the district court’s inquiry sufficient under the totality of the circumstances. The court also found no procedural error in sentencing, concluding that the district court did not improperly rely on prohibited factors. Finally, the court declined to consider the challenge to the underlying conviction, holding that such arguments must be raised on direct appeal or collateral review. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Spence" on Justia Law

Two police officers responded to a report of an armed suspect in a Cleveland boarding house. While searching the darkened building, the officers encountered the suspect, leading to a confrontation and retreat down the stairs. One officer, Gannon, fired his weapon twice; the first, intentional shot struck his fellow officer, Kilnapp, causing significant injury. The officers did not identify themselves as police during the incident, and the body camera footage did not clearly depict critical moments. Both sides disputed details such as whether the suspect fired first, but agreed that Gannon’s first shot, meant to stop the suspect, hit Kilnapp as she followed behind him.Kilnapp sued Gannon, the City of Cleveland, and its Chief of Police, alleging excessive force under both the Fourth and Fourteenth Amendments. Gannon sought qualified immunity and dismissal, arguing his actions did not violate clearly established rights. The United States District Court for the Northern District of Ohio denied his motion to dismiss and later his motion for summary judgment on qualified immunity grounds. The Sixth Circuit previously affirmed the denial of the motion to dismiss, but Gannon continued to challenge the denial of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of summary judgment de novo. The court held that when an officer intentionally fires a weapon in circumstances objectively manifesting an intent to restrain, any person struck is seized under the Fourth Amendment, regardless of whether they were the officer’s specific intended target. However, because the Supreme Court’s decision in Torres v. Madrid (2021) clarified this principle after Kilnapp’s shooting, the law was not clearly established at the time. The Sixth Circuit vacated the district court’s decision and remanded with instructions to grant Gannon qualified immunity on the Fourth Amendment claim and for further proceedings on the Fourteenth Amendment claim. View "Kilnapp v. City of Cleveland" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law

Daqua Ritter was indicted for three federal crimes connected to the murder of Ernest “Dime” Doe, a transgender woman in rural South Carolina. Ritter and Doe had a secretive sexual relationship, and Ritter was sensitive about public knowledge of this relationship, especially since Doe openly referred to Ritter as her boyfriend. Evidence at trial showed Ritter pressured Doe to keep their relationship hidden and reacted angrily when others mentioned it. Doe was found shot dead in a car, and Ritter was last seen with her hours before her death. After the murder, Ritter disposed of his gun and burned his clothes. A federal grand jury indicted Ritter for willfully causing bodily injury based on Doe's gender identity resulting in death, using a gun during a crime of violence, and making false statements to investigators.The United States District Court for the District of South Carolina presided over Ritter’s trial. A jury convicted Ritter on all charges, and the district court sentenced him to life in prison. Ritter moved for a new trial, claiming juror bias and prejudicial hearsay testimony, and challenged the sufficiency of evidence for two counts. The district court held an evidentiary hearing regarding juror bias and denied the motion for a new trial, finding the juror credible and impartial. It also denied the motion for a mistrial based on hearsay, issuing a curative instruction to disregard the testimony.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in finding no juror bias or in denying a mistrial based on hearsay, as the curative instruction was sufficient. The court also found that, viewed in the light most favorable to the government, there was sufficient evidence for the jury to convict Ritter on all counts, including motive based on gender identity and the likelihood that false statements would be communicated to federal law enforcement. The judgment was affirmed. View "United States v. Ritter" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

While incarcerated in the general population at Central Prison in North Carolina, an individual was violently attacked by a “safekeeper”—a pre-trial detainee designated as requiring strict separation due to risk of violence. On the day in question, prison correctional officers responsible for enforcing separation between safekeepers and the general population failed to keep key security doors closed, contrary to prison policy. This lapse allowed the safekeeper to encounter and assault the plaintiff, resulting in severe facial injuries and lasting pain.The plaintiff brought a lawsuit under 42 U.S.C. § 1983 against three correctional officers, alleging deliberate indifference to his safety in violation of the Eighth Amendment. The United States District Court for the Eastern District of North Carolina granted summary judgment to the officers, finding that the record did not support a jury finding of Eighth Amendment liability and concluding that, even if it did, the officers were entitled to qualified immunity. The district court also allowed the officers, over the plaintiff’s objection, to file a late response to a summary judgment motion without applying the “excusable neglect” standard required under Federal Rule of Civil Procedure 6(b).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that genuine disputes of material fact remained regarding both the officers’ liability for deliberate indifference and the applicability of qualified immunity. The Fourth Circuit further found that the district court had abused its discretion by failing to consider the correct standard when granting an extension of time for the officers’ late filing. The court vacated the district court’s summary judgment and extension orders, and remanded the case for further proceedings with instructions to apply the proper legal standards. View "Case v. Beasley" on Justia Law

The plaintiff, an inmate in an Arkansas correctional facility, was placed in isolation for approximately six weeks during the summer, in a cell lacking air conditioning. He claimed that, as a dialysis patient subject to fluid restrictions, exposure to excessive heat caused him significant discomfort and posed a risk to his health. Throughout his confinement, he submitted several grievances to prison officials, asserting that his medical condition required air-conditioned housing. Although medical staff and other personnel were consulted, no documented medical restriction indicated that air conditioning was medically necessary for him, and prison officials relied on a physician’s opinion that his situation did not constitute an emergency.After discovery, the plaintiff brought a civil rights action under 42 U.S.C. § 1983 against three prison officials, alleging cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The United States District Court for the Western District of Arkansas granted summary judgment in favor of the defendants, finding them entitled to qualified immunity. The plaintiff’s motion for reconsideration was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court assumed, for purposes of analysis, that the plaintiff’s medical condition presented an objectively serious risk. However, the court concluded that the record lacked evidence of deliberate indifference by the defendants: they consulted medical professionals, responded to grievances, implemented measures to mitigate heat, and treated the plaintiff’s medical complaints. Because the defendants did not violate a clearly established constitutional right, they were entitled to qualified immunity. The Eighth Circuit affirmed the district court’s judgment, holding that the prison officials were not deliberately indifferent to the plaintiff’s serious medical needs and did not subject him to cruel and unusual punishment. View "Hamilton v. Earl" on Justia Law

Soscia Holdings, LLC operated the Flat River Reservoir Dam in Rhode Island. In July 2022, the Rhode Island Department of Environmental Management (DEM), acting under state law, ordered Soscia to reduce the Dam’s water flow to maintain specific water levels in Johnson’s Pond. Soscia was later assessed monetary penalties by DEM for alleged violations of the permitting statute. During these proceedings, the Town of Coventry condemned the Dam and Johnson’s Pond, paying Soscia just compensation for the property.The case was first reviewed by the United States District Court for the District of Rhode Island. This court dismissed all claims against the State of Rhode Island and DEM based on Eleventh Amendment immunity. The court also dismissed the § 1983 individual capacity claims against two DEM officials on the grounds of qualified immunity, and rejected Soscia’s claim under the Rhode Island Constitution. However, the court allowed § 1983 official capacity claims for prospective injunctive relief against the DEM officials to proceed. After Soscia amended its complaint, the district court ultimately dismissed the remaining federal constitutional claims and declined to exercise jurisdiction over the remaining state law claims.The United States Court of Appeals for the First Circuit reviewed the appeal. Soscia argued that it continued to face ongoing enforcement actions and monetary penalties, and thus maintained a property interest and the right to seek injunctive and declaratory relief. The First Circuit found that the district court’s opinions thoroughly and correctly explained why Soscia’s federal claims failed to state a plausible claim for relief, and that new arguments raised on appeal were either waived or did not meet the standard for plain error review. The First Circuit affirmed the judgment of the district court. View "Soscia Holdings, LLC v. Rhode Island" on Justia Law