Justia Civil Rights Opinion Summaries

A petitioner challenged actions taken by a county justice court in Montana, claiming his First Amendment rights were violated when the presiding judge ordered the arrest of his friend for recording a pre-jury selection proceeding. The petitioner argued he had authorized his friend to make the recording, noting that similar recordings had occurred in prior hearings without incident. The petitioner asserted that the judge’s background as a retired police officer and current role in the courthouse created a conflict of interest. He also sought to protect what he viewed as his free speech rights in the courtroom.The Fergus County Justice Court, presided over by Judge Kelly Mantooth, imposed penalties on the friend for recording the proceeding. The petitioner requested the Montana Supreme Court to exercise supervisory control under M. R. App. P. 14(3), arguing that constitutional rights were at stake and that the normal appeal process was inadequate. He alleged the Justice Court was proceeding under a mistake of law and causing a gross injustice.The Supreme Court of the State of Montana reviewed the petition for writ of supervisory control. The Court held that while there is a constitutional right for the public to observe court proceedings, there is no constitutional entitlement to record them. A court may impose reasonable, content-neutral time, place, and manner restrictions within its courtroom. The Justice Court’s actions did not violate the petitioner’s First Amendment rights, and the record of the proceeding was available through official channels. The Court found no conflict of interest and concluded supervisory control was not warranted. The petition was denied and dismissed, and the matter was closed. View "Miller v. Fergus Co. Justice Court" on Justia Law

Three transgender children in Arizona, representing a class of all transgender individuals born in Arizona who wish to amend the sex marker on their birth certificates without undergoing a sex change operation, challenged the requirements for amending birth certificates. Arizona law, specifically A.R.S. § 36-337(A)(3), requires the registrar to amend a person’s birth certificate upon receiving a written request and a physician’s statement verifying a sex change operation. The plaintiffs argued that this “surgical requirement” violates the Equal Protection and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Arizona granted summary judgment for the plaintiffs, finding that the statute discriminated based on transgender status and burdened fundamental rights, thus applying heightened and strict scrutiny. The district court concluded the statute failed these standards and entered a permanent injunction, striking the word “operation” from the statute and its implementing regulation to allow amendments without proof of surgery.Upon review, the United States Court of Appeals for the Ninth Circuit clarified that Arizona’s statute provides two avenues for amending the sex marker on a birth certificate: through a physician’s verification of a sex change operation or by obtaining a court order. The court found that the law does not classify based on transgender status, but rather on whether an individual has undergone surgery, and that all individuals—including transgender people who have not had surgery—can seek a court order for amendment. Applying rational basis review, the court concluded the statute is rationally related to a legitimate state interest in ensuring adequate evidentiary support for amendments. The court also held that the statute does not violate due process, as it does not burden fundamental rights in all its applications. The Ninth Circuit reversed the district court’s summary judgment for the plaintiffs, vacated the permanent injunction, and remanded for further proceedings. View "ROE V. PETERSEN" on Justia Law

Several plaintiffs, including the founder of a religious group called Singularism, used psilocybin as part of their religious ceremonies in Utah, where the drug is classified as a controlled substance. Authorities seized a large quantity of psilocybin from them and notified Singularism’s landlord that the drug use constituted a nuisance. Shortly after, the plaintiffs initiated a state lawsuit, which was removed to the United States District Court for the District of Utah. The federal court issued a temporary restraining order requiring the return of seized items and, after state authorities filed criminal charges, enjoined state prosecution against the religious leader to prevent a potential First Amendment violation.On appeal, the state authorities argued that the federal district court should have abstained from interfering with ongoing state criminal proceedings under the Younger abstention doctrine, and that prosecution did not violate the First Amendment. The United States Court of Appeals for the Tenth Circuit reviewed the district court’s refusal to abstain de novo and found the requirements for abstention were satisfied. The court concluded that the state authorities had not waived the abstention argument through their litigation conduct. The plaintiffs failed to show that the prosecution was brought in bad faith, was harassing, or created a threat of irreparable injury, as required for exceptions to abstention.On the merits, the Tenth Circuit held the district court erred in finding a likely First Amendment violation. The court found Utah law’s regulatory scheme for secular, supervised medical use of psilocybin was not comparable to the unsupervised religious use, and thus did not treat secular activity more favorably than religious activity. The court vacated the injunction and the denial of the motion to dismiss as to preferential treatment for secular use, remanding the issue of individualized exemptions for further district court proceedings, and dismissed the appeal regarding the Fourth Amendment claim for lack of jurisdiction. View "Jensen v. Utah County" on Justia Law

In August 2021, a city implemented a COVID-19 vaccination policy for its employees, requiring them to either receive the vaccine or request a medical or religious exemption. Employees granted an exemption were required to undergo weekly COVID-19 testing and wear masks in shared spaces. One employee, a forensic specialist, requested and received a religious exemption but objected to the testing and masking requirements, claiming they revealed his unvaccinated status and created a hostile work environment. He was placed on unpaid leave for refusing to comply but eventually agreed to the requirements and returned to work. He continued to challenge the policy until it was rescinded in March 2022.The employee filed suit in the United States District Court for the Central District of California, asserting federal and state claims against the city and several employees related to the testing and masking requirements. The district court found that the Public Readiness and Emergency Preparedness (PREP) Act applied but initially did not grant immunity to all individual defendants for each claim. Ultimately, the court dismissed the complaints, denied the employee’s motion for reconsideration, and entered judgment for the defendants.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that both the city and individual defendants were “covered persons” under the PREP Act, and that COVID-19 tests and masks constituted “covered countermeasures” authorized for emergency use. The court clarified that the causation requirement for PREP Act immunity is satisfied if the injury alleged arises from the administration or use of a covered countermeasure, regardless of the legal theory. Because the employee’s alleged harms were directly linked to the city’s COVID-19 safety policy, the court affirmed the district court’s dismissal and denial of reconsideration, holding that PREP Act immunity barred all claims. View "SCHMIDT V. CITY OF PASADENA" on Justia Law

A registered nurse working in a hospital’s Mother Baby Unit requested a religious exemption from her employer’s mandatory COVID-19 vaccination policy. Her request, which cited Christian beliefs regarding the sanctity of life and objections to the use of abortion-derived cell lines in vaccine development and testing, was denied. The hospital had followed an executive order issued by the Oregon governor, requiring all healthcare workers to be vaccinated unless granted a medical or religious exemption. The nurse was subsequently terminated for failure to comply with the vaccination mandate.The nurse filed suit in the United States District Court for the District of Oregon. She alleged a Free Exercise claim under 42 U.S.C. § 1983 against individual members of the hospital’s Board of Directors and Vaccine Exception Review Committee, and a Title VII claim against the hospital for failure to accommodate her religious beliefs. The district court granted the individual defendants’ motion to dismiss the Free Exercise claim on qualified immunity grounds, finding that the right to refuse a state-mandated vaccine on religious grounds was not clearly established in 2021. The court denied the hospital’s motion to dismiss the Title VII claim but later granted summary judgment for the hospital, holding that accommodating the nurse’s request would have imposed undue hardship due to health, safety, operational, and financial risks.The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s dismissal of the Free Exercise claim, holding that the individual defendants were entitled to qualified immunity because no clearly established law in 2021 recognized a healthcare worker’s religious right to a vaccine exemption under those circumstances. The court also affirmed summary judgment for the hospital on the Title VII claim, concluding that the hospital demonstrated undue hardship in accommodating the nurse without substantial risk to patients and operations. View "MACDONALD V. OREGON HEALTH AND SCIENCE UNIVERSITY" on Justia Law

A politically active resident of East Cleveland, Ohio, who had long used a sound truck to broadcast political messages, supported a challenger in a mayoral primary. After this involvement, city officials began enforcing rarely used parking and noise ordinances against him. The plaintiff was warned, cited, had his truck impounded, and was prosecuted for a noise violation. He alleged that these actions were motivated by his support for the challenger and criticism of the administration. The plaintiff, along with his company, brought claims under 42 U.S.C. § 1983 against the city, the mayor, the mayor’s chief of staff, and the police chief, asserting First Amendment retaliation and prior-restraint violations, as well as Fourth and Fourteenth Amendment claims.The United States District Court for the Northern District of Ohio resolved all claims in favor of the defendants. Some claims—including First Amendment retaliation claims against the mayor and chief of staff—were dismissed at the pleading stage, while others were resolved at summary judgment. The court found that the ordinances were facially valid and that the plaintiff had either failed to establish the required elements for his claims or had forfeited certain arguments on appeal.On appeal, the United States Court of Appeals for the Sixth Circuit revived certain First Amendment retaliation claims. It held that the district court erred in applying the probable cause requirement to the retaliation claims against the mayor and chief of staff, reversing their dismissal. The court affirmed summary judgment for the police chief on qualified immunity grounds, finding no clearly established law that would make him liable as a conduit for another’s retaliatory motive. As to the city, the court vacated summary judgment on retaliation, remanding for further proceedings on whether municipal policy directly caused a constitutional violation. The court affirmed the district court on all other claims, including the prior-restraint and Fourth Amendment seizure claims, and noted that the plaintiff had forfeited his selective enforcement arguments on appeal. View "Fambrough v. City of E. Cleveland" on Justia Law

A faith-based auto repair company, which exclusively franchises to professing Christians, denied a franchise application from an individual who is both ethnically and religiously Jewish. The applicant had advanced through several steps in the franchise process before being informed that his Jewish faith disqualified him. The company’s franchisees include people of various ethnic backgrounds, including some ethnic Jews who are Christians.The applicant sued the company in the United States District Court for the Southern District of Texas, alleging racial discrimination under 42 U.S.C. § 1981. He claimed the denial was based on his Jewish ethnicity or that no meaningful distinction exists between Jewish ethnicity and Jewish faith. The company argued its decision was based solely on religious criteria, not ethnicity, and moved to dismiss. The district court denied the motion, finding that the applicant had adequately alleged racial discrimination. Later, on summary judgment, the district court applied the McDonnell Douglas framework, found the applicant established a prima facie case, but concluded the company provided a legitimate, race-neutral reason—its Christian-only policy—and there was no evidence of pretext. Summary judgment was granted for the company.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the grant of summary judgment de novo. The court held that § 1981 prohibits racial but not religious discrimination in contracting, reaffirming Supreme Court and circuit precedent. It found no evidence that the company’s policy was a pretext for ethnic discrimination, distinguishing between Jewish ancestry (covered by § 1981) and Jewish faith (not covered). The Fifth Circuit affirmed the district court’s judgment, holding that § 1981 does not reach religious discrimination and that the applicant’s claim failed for lack of evidence of racial discrimination. View "Domanic v. Christian Brothers" on Justia Law

The plaintiff, who was the CEO of a private company with government contracts and a security clearance, was arrested in December 2021 for felony domestic violence. Although no charges were filed, police prepared an investigative report. In February 2022, the San Francisco Superior Court ordered the arrest and related records sealed under California Penal Code sections 851.91 and 851.92. Despite this, the police department released the incident report to a third party without restriction, and it was later sent anonymously to an independent journalist who published articles about the plaintiff’s arrest online, including the report. The plaintiff sought to have the posts removed and subsequently sued the journalist, the platform hosting the articles, and another entity associated with the journalist, alleging multiple causes of action including privacy violations and statutory breaches.The San Francisco County Superior Court reviewed anti-SLAPP motions filed by all defendants, which argued the suit arose from constitutionally protected activity and was barred by the First Amendment and the Communications Decency Act (CDA). The court found that the plaintiff’s claims were based on the defendants’ speech—specifically, online publication in a public forum about a matter of public interest, given the plaintiff’s role and the company's government work. It also determined that statutory protections for sealing did not override constitutional protections, and rejected the argument that defendants’ actions were illegal as a matter of law. The court granted the anti-SLAPP motions and awarded attorney fees to the defendants.The Court of Appeal of the State of California, First Appellate District, Division Four affirmed the trial court’s orders. The main holding was that the First Amendment protects the lawfully obtained, truthful publication of information of public significance, even if the information was originally subject to statutory sealing, and that section 230(c)(1) of the CDA bars claims against interactive computer service providers for hosting such content. The attorney fee award was also affirmed. View "Blackman v. Substack" on Justia Law

Three transgender individuals sought to amend the sex designations on their Oklahoma birth certificates to align with their gender identities. They obtained state court orders directing these changes, but when presented to the Oklahoma State Department of Health, the applications were denied. The denial was based on an executive order issued by the Governor, which instructed the agency to cease amending birth certificates in ways not explicitly permitted by Oklahoma law.Plaintiffs filed suit in the United States District Court for the Northern District of Oklahoma, raising equal protection and due process claims against state officials. The District Court granted the defendants’ motion to dismiss, and plaintiffs appealed to the United States Court of Appeals for the Tenth Circuit. The Tenth Circuit affirmed dismissal of the due process claim but reversed on the equal protection claim. Defendants sought certiorari in the United States Supreme Court, which issued a Grant, Vacate, Remand order directing the Tenth Circuit to reconsider in light of United States v. Skrmetti, 605 U.S. 495 (2025). Subsequently, the Tenth Circuit certified three questions of Oklahoma law to the Supreme Court of Oklahoma.The Supreme Court of the State of Oklahoma held that Oklahoma Statute 63 O.S. § 1-321, as amended by § 1-321(H), prohibits changes to the sex designation on an Oklahoma birth certificate. The court further determined that neither current nor prior versions of the statute have ever permitted such changes, whether based on gender identity or otherwise. The answers to the certified questions were: 1) yes, the statute prohibits changes; 2) no, it has never permitted such changes; and 3) no, it does not now nor has ever permitted changes based on gender identity. View "FOWLER v. STITT" on Justia Law

A woman was arrested in Randolph County, Alabama, under a system that required arrestees to pay a predetermined bail amount based on the charged offense for immediate release. Those unable to pay had to wait until an initial appearance, which could take up to three days, and frequently did not result in a release determination. Instead, release decisions were often deferred until a preliminary hearing up to four weeks later. The plaintiff, unable to afford bail, filed a class action alleging that the county’s bail practices discriminated against indigent individuals and violated their constitutional rights.The United States District Court for the Middle District of Alabama initially granted a temporary restraining order, releasing the plaintiff. While the case was pending, Randolph County adopted a new, more permissive bail policy. Defendants moved to dismiss the case as moot, arguing the new policy ended the challenged conduct. The district court certified a class of arrestees unable to pay secured bail, but after the Supreme Court denied certiorari in a similar case, Schultz v. Alabama, the district court dismissed most claims as moot, limiting plaintiffs to facial challenges against the new policy, and concluded those remaining claims failed to state a plausible claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The court held that the voluntary cessation doctrine precludes defendants from mooting the case simply by changing the bail policy during litigation. The class may proceed with facial and as-applied challenges to the prior bail practices, as well as as-applied challenges to the current bail practices. However, the court affirmed the district court’s dismissal of facial challenges to the current bail policy. The case was remanded for further proceedings consistent with these holdings. View "Edwards v. Randolph County Sheriff" on Justia Law