Justia Civil Rights Opinion Summaries

Two plaintiffs, a middle school teacher and an assistant principal, were employed by a school district in Oregon. They created the "I Resolve" campaign, which included a website and a video uploaded to YouTube, advocating for policies on gender identity, parental rights, and education. They used their own devices and time but also sent emails from their school accounts to district employees with links to the campaign. Following complaints from employees, students, and concerned citizens, and an independent investigator's determination that they violated district policies, the district terminated them but later reinstated them and transferred them to other positions.The United States District Court for the District of Oregon granted summary judgment in favor of the school district and individual defendants on all claims. The plaintiffs alleged that their termination was in retaliation for their protected speech and that they were discriminated against based on their religion and viewpoint. The district court concluded that the defendants' interests in avoiding disruption outweighed the plaintiffs' First Amendment rights and that the individual defendants were entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed in part and vacated in part the district court's summary judgment. It held that there were genuine disputes regarding the circumstances of the plaintiffs' expressive conduct and the extent of the resulting disruption. The court affirmed the summary judgment for the individual defendants on the First Amendment claim for damages due to qualified immunity but vacated the summary judgment for the district on the First Amendment claim for damages and the related claims for declaratory and injunctive relief. The court also vacated the summary judgment on the plaintiffs' Fourteenth Amendment Equal Protection claim and the Title VII claim, finding genuine issues of material fact regarding the credibility of the district's proffered reasons for the terminations. View "DAMIANO V. GRANTS PASS SCHOOL DISTRICT NO. 7" on Justia Law

Ryan Barry, a probationer subject to warrantless search conditions, was implicated in drug trafficking by an anonymous tipster who reported that a person named "Ryan" was selling drugs from an apartment in Van Nuys, California. The tipster also mentioned that "Ryan" drove a red convertible Ford Mustang. Officer Giovanni Espinoza of the LAPD investigated and found Barry, who matched the description and was on post-release community supervision for felony convictions. Barry was observed driving a red Mustang near the apartment. During a subsequent encounter, Barry was found with drugs and did not deny living at the apartment when informed of the impending search. Barry's possession of a key to the apartment further supported the officers' belief that he resided there.The United States District Court for the Central District of California denied Barry's motion to suppress the evidence found in the warrantless search of the apartment, as well as his request for an evidentiary hearing. Barry entered a conditional plea agreement, reserving the right to appeal the suppression motion, and was sentenced to 180 months' imprisonment.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the search was consistent with the Fourth Amendment and the standard articulated in United States v. Grandberry, which requires probable cause to believe that a parolee resides at the location to be searched. The court found that the totality of the circumstances, including Barry's responses to Officer Espinoza, the anonymous tip, and Barry's possession of a key, established probable cause that Barry resided at the apartment. The court also held that the district court did not abuse its discretion in declining to hold an evidentiary hearing. View "USA V. BARRY" on Justia Law

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

Kenneth Anderson, Jr. was involved in a car accident in Harris County, Texas, and was found by Deputy Crystal Estrada in a drug-induced state. Anderson was initially compliant but later became uncooperative and resisted officers' attempts to secure him in a police vehicle. Deputy Mohanad Alobaidi used a taser in drive-stun mode on Anderson multiple times during the struggle. Anderson was later found unresponsive and pronounced dead at the hospital.The United States District Court for the Southern District of Texas dismissed several claims against the officers but allowed an excessive force claim against Alobaidi and bystander liability claims against the other officers to proceed. The officers appealed the denial of qualified immunity on these claims.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Alobaidi's use of force was not objectively unreasonable given Anderson's active resistance, the seriousness of the DUI offense, and the threat posed to the officers. The court concluded that Alobaidi's actions were measured and proportional to Anderson's escalating resistance, and therefore did not violate Anderson's Fourth Amendment rights. Consequently, the bystander liability claims against the other officers were also dismissed. View "Anderson v. Estrada" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

Steve Eggleston sued Clark County and Georgina Stuart, a social worker, alleging violations of his due process rights under 42 U.S.C. § 1983 and intentional infliction of emotional distress (IIED). Eggleston claimed that Stuart coerced him into signing temporary guardianship papers for his children during an ongoing child abuse/neglect investigation by threatening that his children would be permanently removed from his care if he did not comply. Stuart and Clark County moved for summary judgment, arguing that their actions were protected by qualified immunity and discretionary-act immunity. The district court denied their motion.The Eighth Judicial District Court of Nevada denied the motion for summary judgment, leading Stuart and Clark County to file a petition for a writ of mandamus challenging the order. The district court found that there were genuine issues of material fact regarding whether Stuart's conduct violated clearly established law and whether her actions were protected by discretionary-act immunity.The Supreme Court of Nevada reviewed the case and granted the petition for a writ of mandamus. The court held that Stuart was entitled to qualified immunity on Eggleston's substantive and procedural due process claims because her conduct did not violate any clearly established constitutional rights. The court also held that Stuart was entitled to discretionary-act immunity on Eggleston's IIED claim, as her actions involved individual judgment and were based on considerations of social policy. The court directed the district court to vacate the order denying summary judgment and to enter an order granting summary judgment in favor of Stuart and Clark County. View "Clark County v. District Court" on Justia Law

Brandon Duane Wagstaff was convicted by a jury of felony false imprisonment and related offenses stemming from a domestic violence incident. The trial court sentenced him to 16 months in prison. Wagstaff, who is Black, claimed that the trial court violated the California Racial Justice Act of 2020 (RJA) during various stages of the proceedings. However, his trial counsel did not object to these statements under the RJA, leading to the forfeiture of these claims on appeal. Wagstaff also argued that his trial counsel was ineffective for not objecting to a specific statement made by the trial court at sentencing, but the appellate court found this claim to be without merit.In the lower court, the prosecution charged Wagstaff with five counts, including felony false imprisonment, attempted second-degree robbery, contempt of court, threatening to commit a crime, and battery upon a person in a dating relationship. The jury found him guilty on four counts but acquitted him of attempted robbery. Wagstaff admitted to a prior conviction, and the trial court imposed an aggregate sentence of nine years and four months, including a term from a separate case.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that Wagstaff's claims under the RJA were forfeited due to the lack of objections by his trial counsel. The court also concluded that the trial court's failure to instruct the jury on misdemeanor false imprisonment as a lesser included offense was not erroneous because there was no substantial evidence to support such an instruction. The appellate court affirmed the judgment, finding no merit in Wagstaff's claims. View "P. v. Wagstaff" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law