Justia Civil Rights Opinion Summaries

Defendant-Appellee Southwest Airlines graded its new hires based on two overarching categories of criteria: Attitude and Aptitude. By all accounts, Plaintiff-appellant Krista Edmonds-Radford had the necessary Attitude for her position as a Southwest Customer Service Agent. Unfortunately, she failed to exhibit the necessary Aptitude, and Southwest terminated her for failing to meet expectations. That termination led to this disability-based lawsuit, in which Edmonds-Radford sued Southwest for disparate treatment, failure to accommodate, and retaliation under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court granted summary judgment in favor of Southwest on all claims, and Edmonds-Radford appealed. After review, the Tenth Circuit determined: (1) Edmonds-Radford failed to establish her prima facie case or that Southwest’s proffered reason for her termination was pretextual; (2) Edmonds-Radford failed to present evidence she requested any accommodations in connection with her disability (in any event, Southwest provided all requested accommodations); and (3) because there was no proof she made any disability-based accommodation requests, Edmonds-Radford's retaliation claim based on such requests was doomed. "But even if Edmonds-Radford had made disability-based accommodation requests, her retaliation claim would still fail in light of our conclusions that Edmonds-Radford failed to establish that her disability was a determining factor in her termination, or that Southwest’s legitimate, nondiscriminatory reason for the termination was pretextual. Accordingly, the Court affirmed the district court's grant of summary judgment in favor of Southwest on all claims. View "Edmonds-Radford v. Southwest Airlines" on Justia Law

In 2006, a California death row inmate sued, arguing that California’s execution protocol violated the Eighth Amendment. The district court stayed the execution. After the state promulgated a new execution protocol, the District Attorneys of three counties unsuccessfully sought to intervene. While the District Attorneys’ appeal was pending, Governor Newsom withdrew California’s execution protocol and placed a moratorium on executions. The plaintiffs voluntarily dismissed their suit subject to conditions.The Ninth Circuit first held that this appeal was not mooted by Governor Newsom’s Order or by the stipulated dismissal. Nothing prevented Governor Newsom, or a future Governor, from withdrawing the Order and proceeding with preparations for executions. The suit could be revived upon the occurrence of any of three events specified in the Stipulation.The district court properly denied intervention as of right under Fed. R. Civ. P. 24(a) because the District Attorneys had not shown a significant protectable interest in the litigation. California law does not authorize them to defend constitutional challenges to execution protocols. The litigation concerned only the method by which the state may perform executions. The District Attorneys have neither the authority to choose a method of execution nor to represent the state entity that makes that choice. The district court properly denied permissive intervention under Fed. R. Civ. P. 24(b): there was no common question of law or fact between the District Attorneys’ claim or defense and the main action; intervention would delay the already long-drawn-out litigation. View "Cooper v. Newsom" on Justia Law

After Albuquerque Police Officers Demsich and Melvin entered plaintiff-appellant Bradley Soza’s front porch with guns drawn, handcuffed him, and patted him down as part of a burglary investigation, Soza sued the Officers under 42 U.S.C. 1983, alleging the Officers violated his clearly established Fourth Amendment rights when they seized him without probable cause and entered the curtilage of his home without a warrant. The Officers moved for summary judgment, asserting qualified immunity, which the district court granted. Because the law regarding the constitutionality of the Officers’ actions was not clearly established, the Tenth Circuit agreed with the district court that the Officers were entitled to qualified immunity. View "Soza v. Demsich, et al." on Justia Law

In 1994, the jury convicted Desmond and Jesse Rouse, their cousin Russell Hubbeling, and another cousin of sexually abusing five nieces. Defendants ultimately raised claims in Rule 60(b)(6) motions seeking relief from the dismissal of their initial 28 U.S.C. 2255 motions. The district court denied the Rule 60(b)(6) motions as successive section 2255 motions and granted certificates of appealability.The Eighth Circuit affirmed, concluding that newly discovered evidence in support of a claim previously denied and a subsequent change in substantive law justifying relief - fall squarely within the class of Rule 60(b) claims to which the Supreme Court has applied section 2244(b) restrictions. Furthermore, the motions were an improper attempt to circumvent the procedural requirements of the Antiterrorism and Effective Death Penalty (AEDPA). Assuming arguendo that petitioners' Rule 60(b)(6) motions were not unauthorized second or successive motions subject to section 2244(b)(3), the district court did not err in determining that the allegations, including claims of newly discovered victim recantations, medical evidence and claims of juror bias, did not meet the extraordinarily high burden of proving actual innocence, a complete miscarriage of justice, or are evidence that would produce an acquittal in a new trial. View "Rouse v. United States" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se civil rights complaint filed pursuant to the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108, in which he alleged that Arkansas Department of Correction (ADC) officials violated his constitutional rights, holding that the circuit court did not err in dismissing the complaint.Appellant sued Appellees in their official and individual capacities, alleging that they had violated his constitutional rights to free speech, free exercise of his religion, access to the court, due process, and equal protection. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that Appellees were immune from liability because Appellant failed to raise claims that demonstrated the deprivation of a constitutional right. View "Muntaqim v. Payne" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis alleging that he was denied effective counsel prior to his criminal trial and that this violation of his Sixth Amendment right entitled him to coram nobis relief, holding that Petitioner was not entitled to relief.Petitioner was convicted of two counts of capital murder and one count of second-degree murder and sentenced to life imprisonment without parole on the capital murder charges. Petitioner later filed his coram nobis petition, raising claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner's allegations of ineffective assistance of counsel did not support issuance of the writ of error coram nobis. View "Hall v. State" on Justia Law

Plaintiff filed suit alleging claims against two dentists, two unidentified Department of Corrections officials, and several municipal defendants for medical malpractice under state law and violations of his Eighth and Fourteenth Amendment rights under 42 U.S.C. 1983. Plaintiff's claims stemmed from a gum condition that he alleges that was not adequately addressed.The Second Circuit affirmed the district court's dismissal of the complaint for failure to state a claim, concluding that plaintiff failed to plead that defendants acted with deliberate indifference to his serious medical needs. The court concluded that plaintiff's claims against Defendant Greenman failed because he did not allege that Greenman acted with deliberate indifference. Rather, plaintiff disagreed with Greenman's assessment of the severity of plaintiff's condition and recommendation for treatment. The court also concluded that plaintiff's claim of deliberate indifference under the Eighth Amendment against Defendant Hamilton failed for similar reasons. In this case, the allegations failed to establish that Hamilton possessed a sufficiently culpable state of mind where, even if the court were to assume that a dental cleaning was inadequate and that plaintiff should have known this, a complaint that a physician has been negligent in diagnosing or treating a medical condition does not state a valid claim of medical mistreatment under the Eighth Amendment. Finally, plaintiff failed to allege that the Doe Defendants acted with deliberate indifference because he does not allege any personal involvement in alleged constitutional deprivations. View "Darby v. Greenman" on Justia Law

The Supreme Court held that a tax imposed solely upon a small number of billboard operators is a discriminatory tax that violates the rights to freedom of speech and a free press protected by the First Amendment to the United States Constitution.The City of Cincinnati imposed a tax on outdoor advertising signs, but through definitions and exemptions within the city's municipal code, the tax burdens feel predominantly on two billboard operators only. The two billboard operators (Appellants) sought a declaration that the tax violated their constitutional rights to free speech and a free press and requesting an injunction against the tax's enforcement. The trial court permanently enjoined the City from enforcing the tax. The court of appeals reversed in part. The Supreme Court reversed and reinstated the injunction, holding that the billboard tax did not survive strict scrutiny and therefore impermissibly infringed on Appellants' rights to free speech and a free press. View "Lamar Advantage GP Co. v. City of Cincinnati" on Justia Law

The First Circuit affirmed Defendants' convictions of one count each of conspiracy to possess with intent to distribute and to distribute one hundred grams or more of heroin and one count each of possession with intent to distribute and distribution of heroin, holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' pre-trial rulings denying their motions to suppress evidence that resulted from the search of their vehicle, including their statements made during the stop; (2) the district court did not impermissibly limit the questioning of Gutierrez in violation of the Confrontation Clause; (3) the prosecutor improperly made a statement during closing argument that referred to facts not in evidence, but the statement was harmless; (4) the district court properly instructed the jury in response to a question asked during deliberations; and (5) the district court did not err in applying the mandatory minimum sentence under 21 U.S.C. 841(b)(1)(B)(i). View "United States v. Cruz-Rivera" on Justia Law

This appeal stemmed from Alfred Brown’s lawsuit under the Rehabilitation Act, 29 U.S.C. secs. 701–796l, against his former employer, the Defense Health Agency. In April 2010, the Agency hired Brown as a healthcare fraud specialist (HCFS) assigned to the Program Integrity Office (PIO) in Aurora, Colorado. Shortly after joining the Agency, Brown told his supervisors that he had been diagnosed with posttraumatic stress disorder and other panic and anxiety disorders related to his military service. When Brown’s symptoms worsened in September 2011, he was hospitalized and received in-patient treatment for one week. The Agency approved Brown’s request for leave under the Family and Medical Leave Act (FMLA). The district court granted summary judgment for the Agency, determining that there were no triable issues on Brown’s claims that the Agency failed to accommodate his mental-health disabilities and discriminated against him based on those disabilities. Brown appealed, challenging the district court’s rulings that: (1) his requests for telework, weekend work, and a supervisor reassignment were not reasonable accommodations; and (2) he failed to establish material elements of his various discrimination claims. The Tenth Circuit found no reversible error: (1) granting Brown’s telework and weekend-work requests would have eliminated essential functions of his job, making those requests unreasonable as a matter of law; (2) Brown did not allege the limited circumstances in which the Agency would need to consider reassigning him despite the fact that he performed the essential functions of his position with other accommodations; (3) the Court declined Brown’s invitation to expand those limited circumstances to include reassignments that allow an employee to live a “normal life;” and (4) Brown did not allege a prima facie case of retaliation, disparate treatment, or constructive discharge. Summary judgment for the Agency was affirmed. View "Brown v. Austin, et al." on Justia Law