Justia Civil Rights Opinion Summaries

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

A Sedona resident, who has obsessive-compulsive disorder, often sleeps in her car because her disability prevents her from entering her apartment. The City of Sedona has a criminal ordinance prohibiting sleeping in a vehicle on public or private property. The resident was twice warned by police for sleeping in her car and requested reasonable accommodation under the Americans with Disabilities Act (ADA) to exempt her from enforcement of this ordinance. The city denied her requests, and her landlord threatened not to renew her lease if she continued sleeping in her car. She alleges that the city’s actions caused her emotional distress and loss of income, and she continues to sleep in her car several times a week.The United States District Court for the District of Arizona dismissed her claims for lack of standing, finding that the prior police warnings were insufficient to support a specific threat of prosecution and that she failed to allege a history of enforcement against similarly situated individuals. The district court addressed only her standing to seek injunctive relief, despite her claims for damages as well. Her requests to amend her complaint were denied, and she appealed.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s dismissal. The Ninth Circuit held that she had Article III standing to bring an ADA claim for both damages and injunctive relief, based on the city’s denial of her request for accommodation and a credible threat of future enforcement. The court further held that Title II of the ADA applies to requests for reasonable accommodation to comply with municipal criminal ordinances. The ADA claim was remanded for further proceedings, allowing her to amend her complaint, while the dismissal of her Eighth Amendment claim was affirmed. View "BERAM V. CITY OF SEDONA" on Justia Law

Stefanie Boone, a parent with children enrolled in Lowell Area Schools, publicly criticized the district’s curriculum and practices, particularly those she saw as promoting diversity, equity, inclusion, and social justice issues. She shared her views on a Facebook page, often referencing specific district employees. In response to one post, the high school principal sent Boone a letter requesting that she stop referencing district employees on social media and warning her that failure to comply could result in legal action. The letter also directed her not to contact staff without prior permission. Boone felt threatened and stopped making public comments or contacting teachers directly.Boone filed suit in the United States District Court for the Western District of Michigan, naming the district and several officials in their official capacities. She alleged violations of her First and Fourteenth Amendment rights under 42 U.S.C. § 1983, a Title IX violation, and state law claims. The district court granted the defendants’ motion to dismiss, concluding that neither the “Social Media Policy” nor the “Communication Policy” constituted unconstitutional restraints on speech—characterizing the request as non-binding and the communication restriction as merely channeling her speech. The court also rejected her Fourteenth Amendment and Title IX claims and declined to exercise supplemental jurisdiction over her state law claims.Reviewing the case de novo, the United States Court of Appeals for the Sixth Circuit held that Boone plausibly alleged a First Amendment violation regarding the Social Media Policy, as the district’s letter amounted to a coercive threat of legal action capable of chilling protected speech. However, the Communication Policy, which required Boone to channel communications through administrators, did not violate her speech rights. The court affirmed the dismissal of her Fourteenth Amendment and Title IX claims, reversed the dismissal of her First Amendment claim as to the Social Media Policy, and remanded for further proceedings, including consideration of her state law claims. View "Boone v. Lowell Area Schools" on Justia Law

Five individuals, who were either peaceful protesters or independent journalists, attended demonstrations at the U.S. Immigration and Customs Enforcement facility in Portland, Oregon. During these events, they were exposed to tear gas and pepper balls used by federal agents to disperse crowds. The protests involved both peaceful activities and significant unrest, including vandalism, blocking entrances, and attacks on law enforcement. The plaintiffs claimed that federal agents specifically targeted them in retaliation for exercising their First Amendment rights.The plaintiffs filed suit in the United States District Court for the District of Oregon against federal officials and the Department of Homeland Security. After discovery and an evidentiary hearing, the District Court issued a preliminary injunction restricting the use of non-lethal munitions to situations involving an imminent threat of physical harm, prohibiting their use on certain parts of the body, imposing limits on pepper spray, and requiring redesign of agent uniforms for better identification. Additionally, the District Court provisionally certified a class of all individuals who had protested or reported on DHS activities at the Portland ICE facility. The government’s motion to stay the injunction pending appeal was denied by the District Court but granted by the Ninth Circuit.On appeal, the United States Court of Appeals for the Ninth Circuit vacated both the preliminary injunction and the provisional class certification. The court held that the plaintiffs were not likely to succeed on the merits of their First Amendment retaliation claim, as law enforcement may use non-lethal force to clear crowds and restore order without facing an imminent threat of physical harm. The record did not support claims of an unwritten policy or intent to retaliate against First Amendment activity. The court also found the injunction overbroad and unworkable, and the class failed to meet Rule 23’s commonality and indivisible remedy requirements. The preliminary injunction and class certification were vacated. View "DICKINSON V. TRUMP" on Justia Law

Several tenants of an apartment complex located across the street from a federal Immigration and Customs Enforcement (ICE) facility in Portland, Oregon, claimed harm from exposure to tear gas used by federal law enforcement officers to disperse disruptive crowds during demonstrations. The plaintiffs, including individuals and entities associated with the apartment complex, argued that the government’s deployment of tear gas infringed their substantive-due-process rights under the Fifth Amendment.The United States District Court for the District of Oregon granted a preliminary injunction, enjoining several federal agencies from using tear gas for crowd control outside the ICE facility. The district court found that the plaintiffs were likely to succeed on the merits of their substantive-due-process claim and determined that the government’s actions could violate a constitutional right to bodily integrity.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. Applying de novo review to the underlying legal issues, the Ninth Circuit reaffirmed its prior stay of the injunction and concluded that the plaintiffs lacked a substantive-due-process right to be free from incidental exposure to tear gas used for non-lethal crowd control. The court held that such a right is not deeply rooted in the nation’s history and tradition nor implicit in the concept of ordered liberty, as required by Supreme Court precedents, including Washington v. Glucksberg and Dobbs v. Jackson Women’s Health Organization. The panel further clarified that a substantive-due-process challenge to executive action requires both conscience-shocking conduct and deprivation of a historically rooted right, rejecting the plaintiffs’ argument that only the shocks-the-conscience standard should apply. Accordingly, the Ninth Circuit vacated the district court’s preliminary injunction. View "REACH COMMUNITY DEVELOPMENT V. UNITED STATES DEPARTMENT OF HOMELAND SECURITY" on Justia Law

The plaintiff operated an animal rescue in New York and was formerly employed by the Ulster County Society for the Prevention of Cruelty to Animals (SPCA). After her termination from the SPCA, she opened her own rescue, but was accused by SPCA officers and a competing rescuer of neglecting and abusing animals. Based on these accusations, an arrest warrant and search warrant were obtained, leading to her arrest and a search of her home. She was charged with misdemeanors under New York animal welfare laws. The prosecution ultimately ended in an adjournment in contemplation of dismissal (ACOD), with the charges dismissed after the government admitted it could not prove its case.In the U.S. District Court for the Northern District of New York, the plaintiff brought claims under 42 U.S.C. § 1983 and § 1985, alleging unlawful search, false arrest, malicious prosecution, and violations of her First and Fourteenth Amendment rights, along with state-law claims. Some defendants moved to dismiss only certain claims, but the district court dismissed the entire complaint with prejudice, including claims no party had moved to dismiss, and denied leave to amend most claims. The court reasoned that the ACOD did not constitute a favorable termination for malicious prosecution and found deficiencies in the other claims.The United States Court of Appeals for the Second Circuit reviewed the case de novo. The court held that an ACOD can constitute a favorable termination for Section 1983 malicious prosecution claims, overruling prior circuit precedent in light of Thompson v. Clark, 596 U.S. 36 (2022). However, it affirmed dismissal of the malicious prosecution claim because the complaint did not allege any post-arraignment deprivation of liberty. The court vacated dismissal of certain claims, finding the district court abused its discretion in denying leave to amend, and remanded for further proceedings, while affirming dismissal of other claims on futility grounds. View "Brill v. Ulster County" on Justia Law

Five individuals who participated as peaceful protesters and independent journalists at demonstrations outside the U.S. Immigration and Customs Enforcement (ICE) facility in Portland, Oregon, alleged that federal law enforcement officers targeted them with non-lethal crowd-control munitions such as tear gas and pepper balls. The plaintiffs claimed this was retaliation for exercising their First Amendment rights. The protests, which occurred between June 2025 and February 2026, often involved both peaceful dissent and significant unrest, including vandalism, trespassing, and obstruction of law enforcement. The plaintiffs were exposed to crowd-control devices during these protests, frequently while in proximity to unlawful activity.The United States District Court for the District of Oregon issued a preliminary injunction prohibiting federal officers from using non-lethal munitions except against individuals posing an imminent threat of physical harm, and ordered that agents’ uniforms be redesigned with conspicuous identifying markings. The district court also certified a provisional class encompassing all individuals who had protested or reported on DHS activities at the Portland ICE facility since June 2025, and denied the government’s motion to stay the injunction pending appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s orders. The Ninth Circuit vacated the preliminary injunction and provisional class certification, holding that the plaintiffs did not demonstrate a likelihood of success on their First Amendment claim. The court found no evidence of an unwritten policy or pattern of retaliation by DHS and held that law enforcement may use non-lethal force to clear crowds and restore order without waiting for an imminent threat of physical harm. The injunction was found to be overbroad, improperly granting relief to non-parties, and unworkable. The class certification was vacated for lack of commonality and failure to satisfy Rule 23(b)(2)’s indivisible-remedy requirement. View "United States v. Robinson" on Justia Law

A real estate developer in Michigan entered into a lease agreement with a machinery manufacturer, promising to construct a facility on its property within a tight ten-month timeline. The property lacked access to a public sewer, requiring the developer to obtain a septic permit from the county health division before construction could begin. The developer and the township attempted to negotiate an arrangement to allow construction to proceed without the permit, but negotiations failed. The developer applied for necessary site plan approvals and began the permitting process, but did not combine lots as required by the health division, resulting in delays. Eventually, the lease was terminated after construction could not proceed on schedule.The developer filed suit in the United States District Court for the Eastern District of Michigan against the township and its supervisor, alleging violations of equal protection, due process, and First Amendment retaliation under 42 U.S.C. § 1983, along with a state-law claim. The district court granted summary judgment in favor of the defendants on all federal claims except for one First Amendment retaliation claim and the state-law claim, which settled before trial. The developer appealed the district court’s summary judgment rulings on its equal protection, due process, and First Amendment retaliation claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The Sixth Circuit affirmed the district court’s judgment, holding that the township had a rational basis for its permitting decisions, did not deprive the developer of a protected property interest without due process under Michigan law, and imposed constitutionally permissible, content-neutral restrictions on communications to comply with Michigan’s Open Meetings Act. The court concluded that no constitutional violations occurred and affirmed summary judgment for the township and its supervisor. View "GSL Holdings, LLC v. Charter Township of Lyon Township" on Justia Law

A group of nine tenured professors at a public Kansas university were terminated after the Kansas Board of Regents (KBOR) temporarily amended its policy, citing COVID-19-related financial pressures. The amendment permitted universities to suspend or terminate tenured faculty without the usual protections, including hearings or proof of financial exigency. ESU administrators drafted a framework for implementing these terminations, which KBOR approved. The professors received termination letters referencing general financial concerns, but allegedly lacking specific reasons. The professors claimed ESU was not facing financial exigency, and that their terminations were motivated by their political activities and beliefs. All nine appealed through the Office of Administrative Hearings (OAH); six had their terminations reversed and three had them affirmed. Litigation ensued, with the professors asserting constitutional violations under 42 U.S.C. § 1983, including due process, liberty, association, and equal protection claims.The United States District Court for the District of Kansas denied the defendants’ motion to dismiss most claims, finding that qualified immunity did not bar them. It ruled the professors had adequately alleged deprivation of a property interest in continued employment without due process and allowed other constitutional claims to proceed. The court dismissed liberty interest claims against KBOR and some administrators where no statements were attributed to them, but denied dismissal for others allegedly involved in drafting termination letters.The United States Court of Appeals for the Tenth Circuit reviewed the appeal at the motion-to-dismiss stage, adopting facts as alleged. It held that the professors had a state-created property interest in tenure and that the process used to terminate their employment plausibly violated clearly established procedural due process rights. The court affirmed denial of dismissal for procedural due process and related conspiracy claims, but reversed as to substantive due process claims, finding no clearly established violation. It also reversed denial of dismissal for liberty, association, equal protection, and conspiracy claims against KBOR and certain administrators, instructing the district court to dismiss those claims, while leaving claims against the university president intact. View "Miracle v. Hush" on Justia Law

A mother reported to the City Schools of Decatur, Georgia, that her five-year-old Black daughter had been sexually assaulted by a male classmate in a kindergarten restroom. She was dissatisfied with the school district’s response to the report, alleging that school staff delayed action, failed to adequately investigate the incident, and made a child protective services referral that implicated her in neglect. The mother also claimed the district’s response was influenced by the race of her family, given that her daughter is Black and the alleged perpetrator was a Black boy adopted by White parents.After the report, the school principal and staff took several steps: contacting a school resource officer and social workers, informing district administrators, ensuring both children were supervised during restroom visits, and referring the matter to the Department of Family and Children Services (DFCS) for both the victim and alleged perpetrator. The mother took her daughter to the hospital for examination, and the girl was later moved to a different classroom and eventually transferred to another school at her mother’s request. DFCS investigated and closed the case against the mother as unsubstantiated. The Department of Education’s Office for Civil Rights later found the district’s Title IX response was inadequate under its regulations, though it found no retaliation.In the United States District Court for the Northern District of Georgia, summary judgment was granted for the school district on both the Title IX (sex discrimination) and Title VI (race discrimination) claims. The court found the district’s response did not amount to deliberate indifference, as required under Title IX, and that there was insufficient evidence of racial discrimination under Title VI.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the district’s actions—including an immediate investigation, protective measures, and student transfers—were not clearly unreasonable and did not constitute deliberate indifference under Title IX. The court also held that the plaintiff failed to present sufficient evidence of intentional race discrimination under Title VI. View "Thomas v. City Schools of Decatur" on Justia Law