Justia Civil Rights Opinion Summaries

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In the Fourth Amended Complaint (FAC), plaintiffs alleged that they are the victims of an extensive, long-lasting conspiracy designed to prevent African-American individuals in Beaumont from gaining power and influence in order to perpetuate "white dominion over Beaumont local politics." The Fifth Circuit affirmed the dismissal of all claims and all parties named in the complaint. In regard to RICO claims, the court held that plaintiffs failed to allege a RICO enterprise and pattern of racketeering activity. The court also held that the district court did not err by determining that government attorneys were entitled to prosecutorial immunity from their acts as prosecutors and officers of the court. Furthermore, there was no error in the district court's dismissal of the International Brotherhood of Electrical Workers defendants. The court also held that claims premised on allegedly defamatory statements made prior to July 16, 2014 were time-barred. In regard to the timely filed defamation claims against the Beaumont Enterprise defendants, the court held that these claims failed on the elements of actual malice and falsity, and when considered against the fair reporting defense. Finally, the court rejected plaintiff's tortious interference, equal protection, immunity, and state-law civil conspiracy claims. View "Walker v. Beaumont Independent School District" on Justia Law

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The Ninth Circuit affirmed the district court's dismissal of the Association's complaint, seeking injunctive and declaratory relief under Section 504 of the Rehabilitation Act regarding the Association's provision of diabetes-related care in the U.S. Army's Child, Youth, and School Services (CYSS) programs. When this action began in 2016, the Army had in place United States Army Regulation 608-10 and a 2008 Family and Morale, Welfare and Recreation Command Memorandum (collectively, "Old Policy"), which together prohibited CYSS staff from providing essential medical care for diabetic children. In 2017, defendants revoked the Old Policy and replaced it with a New Policy that provides for possible diabetes-related accommodations. The panel held that the Association's challenge to the Old Policy was moot. In this case, defendants have satisfied their burden of clearly showing that they cannot reasonably be expected to reinstitute the Old Policy's blanket ban. Therefore, because the Association seeks only prospective relief, its challenge to the policy, and the injuries incurred thereunder, were moot. The panel also held that the Association lacked standing to challenge the New Policy, because the Association lacked organizational standing by failing to show an injury in fact, and representational standing where none of its members had standing to sue in their own right. View "American Diabetes Assoc. v. United States Department of the Army" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Commissioner of the Department of Human Services (DHS) determining that Appellant was permanently disqualified from working in a capacity where he may have contact with people who access services from a DHS-licensed program, holding that Appellant's claims on appeal failed. After DHS discovered a 2002 child-protection report that Appellant had sexually abused his son sometime around 1998, Appellant was disqualified from employment as a residence manager at a DHS-licensed substance abuse treatment program. The court of appeals affirmed DHS's decision. The Supreme Court affirmed, holding (1) Defendant's right to due process was not violated; (2) the Department of Human Services Background Studies Act, Minn. Stat. ch. 245C, does not create a permanent, irrebuttable presumption that DHS's decision was correct; and (3) Appellant was provided constitutionally sufficient notice of his rights under the Act. View "Jackson v. Commissioner of Human Services" on Justia Law

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Gresham is serving a 75-year sentence in a Marquette, Michigan state prison. He filed a 42 U.S.C. 1983 action against prison employees, alleging that they improperly forced him to take antipsychotic medication. The Sixth Circuit affirmed that Gresham must pay a $400 filing fee (28 U.S.C. 1914) before proceeding. The right to proceed “in forma pauperis” and avoid filing fees may be removed for prisoner plaintiffs who abuse the privilege. Prisoners become ineligible to file free lawsuits if the courts have dismissed three or more of their lawsuits as “frivolous, malicious, or [for] fail[ure] to state a claim,” 28 U.S.C. 1915(g). Gresham has at least eight baseless lawsuits. The statute frees poor prisoners from the rule if they are “under imminent danger of serious physical injury.” Gresham alleged that the forced medication caused him “chest pains, akathisia [muscular restlessness], seizures, vomiting, stomach cramps, and dizz[iness].” Those side effects did not amount to an imminent “serious physical injury.” They are typically temporary and rarely life-threatening and are not the kinds of injuries that can lead to impending death or other severe bodily harms. Gresham has not remotely alleged how his complaints could lead to such harms while he is under medical supervision. View "Gresham v. Meden" on Justia Law

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Salters, an Illinois pretrial detainee, swallowed cleaning fluid. He was taken to Delnor Hospital for treatment. Guards were instructed to keep him shackled. One guard, Loomis, disobeyed that order when Salters wanted to use the bathroom. Salters grabbed Loomis’s gun and escaped. While Salters terrorized the staff, patients, and visitors, Loomis ran away and hid. Salters took nurses hostage and assaulted two nurses. After three hours a SWAT team killed Salters. Plaintiffs brought 42 U.S.C. 1983 claims. Loomis moved to dismiss the complaint, citing qualified immunity. The district judge held that the complaint presented a valid claim for liability, citing the “state-created danger exception,” under which a public employee is liable for increasing the danger to which other persons are exposed. The Seventh Circuit reversed. The “state-created danger exception” is a generality that does not tell any public employee what to do, or avoid, in any situation. The appropriate level of generality would establish a rule that tells a public employee what the Constitution requires in the situation that an employee faces. No constitutional obligation to keep a prisoner under control has been “clearly established.” The Due Process Clause generally does not condemn official negligence. Plaintiffs depict themselves as frightened but not otherwise injured, and, even in tort law, negligent actors are not liable for conduct that threatens bodily harm but produces only emotional distress. View "Weiland v. Loomis" on Justia Law

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Plaintiff filed suit against Habitat for Humanity under the Fair Housing Amendments Act, which prohibits an entity from discriminating against a disabled individual by failing to make reasonable accommodations in policies and practices that are necessary to afford the individual an equal opportunity to use and enjoy a dwelling. Plaintiff also alleged that Habitat's minimum-income requirement has a disparate impact on disabled individuals receiving social-security-disability income. The Eleventh Circuit held that a court must first consider whether a plaintiff has shown that a requested accommodation is facially reasonable and then whether a defendant has demonstrated that the accommodation would result in an undue burden or fundamental alteration to its program or policy; a plaintiff's financial state in any particular case could be unrelated, correlated, or causally related to his disability and that, in some cases, an accommodation with a financial aspect—even one that appears to provide a preference—could be necessary to afford an equal opportunity to use or enjoy a dwelling within the meaning of the Act; and plaintiff failed to create a genuine issue of material fact as to whether Habitat's minimum-income requirement disproportionately excludes SSDI recipients. Accordingly, the court affirmed the disparate-impact claim, but vacated the failure-to-accommodate claim and remanded for further proceedings. View "Schaw v. Habitat for Humanity of Citrus County, Inc." on Justia Law

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Minton, a transgender man diagnosed with gender dysphoria, sued under the Unruh Civil Rights Act, Civil Code 51(b), which guarantees “full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind.” Minton’s physician, Dr. Dawson, scheduled Minton's hysterectomy at Mercy, which is part of Dignity Health. Minton told a Mercy nurse that he is transgender. The following day, Mercy notified Dawson that the procedure was canceled. Mercy’s president, Ivie, informed Dawson that she would “never” be allowed to perform Minton's hysterectomy at Mercy because it was “part of a course of treatment for gender dysphoria, as opposed to any other medical diagnosis.” At Ivie's suggestion, Dawson was able to get emergency admitting privileges at Methodist Hospital, a non-Catholic Dignity hospital about 30 minutes away. Dawson performed Minton’s hysterectomy at Methodist three days later. Dignity argued that as a Catholic hospital, Mercy is bound to follow its facially neutral “Ethical and Religious Directives for Catholic Health Care Services” issued by the U.S. Conference of Catholic Bishops, which prohibit direct sterilization and require that bodily and functional integrity be preserved. The court of appeal reversed the dismissal of Minton’s complaint. Without determining the right of Dignity to provide its services in such cases at alternative facilities, the complaint alleges that Dignity initially failed to do so and that the subsequent rectification of its denial, while likely mitigating plaintiff’s damages, did not extinguish his discrimination claim. View "Minton v. Dignity Health" on Justia Law

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The Department of Justice filed suit against the State of Florida, seeking declaratory and injunctive relief under Title II of the Americans with Disabilities Act (ADA) and 28 C.F.R. 35.130(d). The Department alleged that Florida was failing to meet its obligations under Title II by unnecessarily institutionalizing hundreds of children with disabilities in nursing facilities. The Department also alleged that Florida's Medicaid policies and practices placed other children who have "medically complex" conditions, or who are "medically fragile," at risk of unnecessary institutionalization. The Eleventh Circuit held that the Attorney General has a cause of action to enforce Title II of the ADA. The court held that when Congress chose to designate the "remedies, procedures, and rights" in section 505 of the Rehabilitation Act, which in turn adopted Title VI, as the enforcement provision for Title II of the ADA, Congress created a system of federal enforcement. The court also held that the express statutory language in Title II adopts federal statutes that use a remedial structure based on investigation of complaints, compliance reviews, negotiation to achieve voluntary compliance, and ultimately enforcement through "any other means authorized by law" in the event of noncompliance. Therefore, courts have routinely concluded that Congress's decision to utilize the same enforcement mechanism for Title II as the Rehabilitation Act, and therefore Title VI, demonstrates that the Attorney General has the authority to act "by any other means authorized by law" to enforce Title II, including initiating a civil action. Accordingly, the court reversed the district court's judgment and remanded. View "United States v. State of Florida" on Justia Law

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Plaintiffs filed suit against officials of the Arizona Department of Corrections (ADC), challenging aspects of the Arizona execution process. Plaintiffs contend that Arizona's practices violate their First Amendment right of access to governmental proceedings and violate inmates' rights of access to the courts. The Ninth Circuit held that the First Amendment right of access to governmental proceedings encompasses a right to hear the sounds of executions in their entirety. Furthermore, on the facts alleged, Arizona's restrictions on press and public access to the sounds of executions impermissibly burden that right. However, the panel held that neither the public nor the press has a First Amendment right of access to information regarding the manufacturers, sellers, lot numbers, National Drug Codes, and expiration dates of lethal-injection drugs, as well as documentation regarding the qualifications of certain execution team members. Finally, the court held that plaintiffs' claim that Arizona's restrictions violate the inmates' First Amendment right of access to the courts failed as a matter of law. Accordingly, the panel affirmed in part and reversed in part the district court's dismissal of plaintiff's second amended complaint. View "First Amendment Coalition of Arizona v. Ryan" on Justia Law

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Jury selection in Howell’s 2004 prosecution consisted of two venire panels. The first included 35 individuals, two of whom were black; both were excused for hardship. The second panel included 25 potential jurors, all of whom were white. Howell, a black man, was convicted for the 2002 felony murder of a white man by an all-white jury. Before jury selection, Howell filed a Motion to Ensure Representative Venire, arguing that he was entitled to a jury pool that represented a fair cross-section of the community, particularly with respect to race. The court held a hearing on Howell’s allegations that black individuals were systemically under-represented in Allegheny County’s jury pools and considered expert testimony that black individuals made up 4.87% of Allegheny County’s jury pool but made up 10.7% of the population of Allegheny County eligible for jury service. The court denied Howell’s motion. The Pennsylvania Superior Court held that Howell had not been denied a trial by a fair cross-section of the community. In Howell’s federal habeas proceeding, the court assumed, without deciding, “that the Superior Court erred in requiring [Howell] to show discriminatory intent,” but concluded that Howell failed to establish a Sixth Amendment violation because other courts found no constitutional violation in cases with higher percentages of disparity. The Third Circuit affirmed. Any underrepresentation in Howell’s jury pool was not caused by a systematically discriminatory process. View "Howell v. Superintendent Rockview SCI" on Justia Law