Justia Civil Rights Opinion Summaries

The case centers on Orlando González Tomasini, who filed civil rights and tort claims against the United States Postal Service, his former employer, alleging that psychological and medical conditions prevented him from working. His then-wife, Juliette Irizarry-Miranda, was initially a co-plaintiff but eventually became a defense witness after a contentious divorce and ongoing custody dispute over their son. On the eve of trial, the Postal Service accused González of witness tampering, specifically of seeking to dissuade Irizarry from testifying by conditioning custody concessions on her refusal to take the stand. Irizarry recorded part of a phone call between them, and the Postal Service submitted this as evidence.Prior to the current appeal, the case was heard in the United States District Court for the District of Puerto Rico, where a magistrate judge presided by consent of the parties. The magistrate judge held a three-day evidentiary hearing to address the witness tampering allegations. After hearing testimony from González, Irizarry, and a social worker, the court found by clear and convincing evidence that González had engaged in witness tampering. As a sanction for this fraud on the court, the magistrate judge dismissed González’s case.The United States Court of Appeals for the First Circuit reviewed the district court's decisions. The First Circuit affirmed the district court in all respects, holding that the evidentiary hearing was appropriately ordered, the finding of witness tampering was not clearly erroneous, and the sanction of dismissal was within the court’s discretion. The appellate court found that González’s conduct constituted a fraud on the court, justifying dismissal, especially given the egregiousness of the witness tampering and its potential impact on the integrity of judicial proceedings. Judgment was affirmed for the Postal Service. View "Gonzalez Tomasini v. Steiner" on Justia Law

Three parents of students in Philadelphia challenged the School District’s 2022 Admissions Policy for four selective public high schools. Prior to 2022, admissions decisions were made by individual schools using academic criteria, attendance, and sometimes additional requirements such as interviews and writing samples. After a report identified geographic disparities in school representation, and following the School District’s public commitments to anti-racism and equity, a new centralized policy was adopted. This policy introduced revised academic standards, eliminated certain prior requirements, and implemented a zip code preference favoring applicants from six areas with high Black and Hispanic populations. Qualified applicants from these zip codes received automatic admission, while others had to enter a lottery for remaining seats.The parents, whose children lived outside the preferred zip codes and met the new criteria but were not admitted to their first-choice schools, filed suit in the United States District Court for the Eastern District of Pennsylvania. They alleged violations of Title VI, the Equal Protection Clause, and related state constitutional provisions, arguing that the new process was racially discriminatory. The District Court granted summary judgment for the School District, finding that no reasonable factfinder could conclude the policy had a racially discriminatory purpose or impact. The court applied rational basis review, holding the policy was rationally related to legitimate interests such as increasing access for underrepresented geographic areas.On appeal, the United States Court of Appeals for the Third Circuit held that, viewing the evidence in the light most favorable to the parents, a reasonable factfinder could conclude the Admissions Policy had both discriminatory purpose and impact. The Third Circuit vacated the District Court’s judgment and remanded for further proceedings, directing that strict scrutiny must be applied if a discriminatory purpose and impact are found. View "Sargent v. School District of Philadelphia" on Justia Law

Fourteen children who were removed from their biological parents by New York City officials are the plaintiffs in this case. After their removal, relatives sought certification to become foster or adoptive parents for these children, but their applications were denied due to criminal history or reports of child abuse or mistreatment. The children allege that New York’s certification scheme violates their substantive due process rights to family integrity and freedom from harm, and that procedural due process was violated because they were not given notice or an opportunity to challenge the denial of a relative’s application.The United States District Court for the Eastern District of New York dismissed the complaint. It ruled that the plaintiffs lacked standing, reasoning that most of the children did not have a cognizable injury since they were living with relatives, and others could not trace their separation from relatives to the defendants. The district court also found that the plaintiffs were asserting the rights of third-party relatives rather than their own, and that prudential standing barred their claims. The court did not address the procedural due process claims directly.On appeal, the United States Court of Appeals for the Second Circuit held that the plaintiffs have standing to pursue both substantive and procedural due process claims. The court found that denial of certified placement with a relative constituted a concrete and particularized injury, traceable to the defendants, and redressable by a favorable ruling. The court also determined that the plaintiffs were asserting their own rights, not those of their relatives, and rejected the district court’s prudential standing analysis. However, some claims were deemed moot: two plaintiffs are now in the care of a relative foster parent and another has aged out of foster care. Only one plaintiff has standing to challenge the adoption certification rules. The Second Circuit reversed in part, affirmed in part, and remanded the case for further proceedings. View "B.B. v. Hochul" on Justia Law

Several residents of Estherville, Iowa, sued a former police officer, the police chief, the City of Estherville, and its insurance company, alleging that the officer repeatedly accessed and disseminated their confidential criminal history and intelligence data for improper purposes between 2015 and his resignation on May 3, 2019. The officer used this data for personal gain, including assisting with vehicle repossessions and harassing certain plaintiffs. Complaints about his conduct were made to the police chief, who ultimately placed the officer on administrative leave and accepted his resignation. Criminal charges were later brought against the officer in 2022 for his actions.After learning of the wrongful data access between 2021 and 2022, the plaintiffs filed suit on July 7, 2023, in the Iowa District Court for Emmet County, asserting statutory and common law claims, including invasion of privacy and conspiracy, and seeking damages under Iowa Code section 692.6. The defendants moved to dismiss, arguing the two-year statute of limitations under the Iowa Municipal Tort Claims Act (IMTCA) barred the claims, since all alleged misconduct ended by May 3, 2019. The district court denied dismissal, holding that the statutory claim under section 692.6 was subject to a five-year limitation with a discovery rule, and that the remaining claims accrued when plaintiffs discovered the wrongdoing.On appeal, the Iowa Court of Appeals reversed the district court and ordered dismissal, concluding that all claims were governed by the IMTCA’s two-year statute of limitations and that the date of injury was when the data was accessed or disseminated, not when plaintiffs learned of it. The Iowa Supreme Court affirmed the appellate court, holding that the IMTCA’s statute of limitations applied to all claims and began at the time of the wrongful acts, regardless of later discovery or emotional harm. The case was remanded for dismissal. View "Abrahamson v. Scheevel" on Justia Law

Three advocacy organizations filed suit against the South Carolina Department of Juvenile Justice and its executive director, seeking institutional reforms to address alleged unconstitutional and unlawful conditions in the state’s juvenile detention facilities. The plaintiffs alleged that the facilities were overcrowded, understaffed, and dangerous, resulting in violence, isolation, and inadequate services for juveniles. They based their standing on their advocacy and direct representation work with affected youth, and described both the harm to juveniles and the impact on their own organizational missions.The United States District Court for the District of South Carolina dismissed the complaint without prejudice. The district court found that Disability Rights South Carolina (DRSC) had standing to sue on behalf of certain juveniles, but those claims were rendered moot when those juveniles left custody. The court also determined that Justice 360 had standing in its own right but concluded that its claims failed on the merits. The South Carolina State Conference of the NAACP was found to lack standing. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Fourth Circuit held that the advocacy organizations lacked Article III standing to pursue the claims because they failed to demonstrate a sufficient personal stake in the outcome. The court found that DRSC did not meet the requirements for associational standing as its constituents lacked indicia of membership. The court also concluded that none of the organizations suffered a cognizable injury directly caused by the defendants’ actions, but rather incurred self-imposed costs through voluntary advocacy. The court further held that the plaintiffs could not bring claims under 42 U.S.C. § 1983 for the violation of rights belonging to others, as they had not alleged violations of their own federal rights. The dismissal was affirmed. View "South Carolina State Conference of the NAACP v. South Carolina Department of Juvenile Justice" on Justia Law

A group of individuals traveling through Kansas were stopped by Kansas Highway Patrol (KHP) troopers while driving on interstate highways, primarily I-70. In each instance, the drivers and passengers were from out of state, often driving to or from Colorado, and were stopped for alleged traffic violations. After the initial traffic stop was concluded, troopers used a tactic known as the “Kansas Two-Step”—they would briefly disengage, then reinitiate conversation in an attempt to gain consent for further questioning or searches. These stops often led to extended detentions and searches, but no contraband was discovered. The troopers testified that they considered the drivers’ out-of-state status, travel to or from Colorado, and other factors in developing reasonable suspicion.The individuals sued under 42 U.S.C. § 1983 in the United States District Court for the District of Kansas, alleging violations of their Fourth Amendment rights against unreasonable searches and seizures and their constitutional right to travel. Some plaintiffs also brought damages claims, resulting in jury verdicts in their favor. For their claims for injunctive relief, the district court conducted a bench trial and found that KHP had a pattern and practice of targeting out-of-state drivers and using the Two-Step in a manner violating the Fourth Amendment. The court granted a permanent injunction, requiring changes in KHP’s training, documentation, consent procedures, and supervision.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the plaintiffs had standing for injunctive relief and whether the district court abused its discretion in issuing the injunction. The Tenth Circuit held that the plaintiffs had standing because there was a substantial risk they would be stopped again and that KHP had a pattern of unconstitutional conduct. However, the Tenth Circuit found that the injunction was overly broad regarding the use of a driver’s state of origin and the Two-Step tactic. The court affirmed the injunction in part, reversed it in part, and remanded for further proceedings. View "Shaw v. Smith" on Justia Law

Two individuals active in a right-wing political organization alleged that government officials and entities in Portland, Oregon, conspired to arrest and prosecute them without probable cause in order to suppress their political speech. The plaintiffs claimed that city and county officials, various prosecutors, and a police detective orchestrated the investigation and charges after a confrontation at a bar, focusing their efforts on the plaintiffs while allegedly ignoring violent acts by left-wing activists. The plaintiffs were indicted and arrested before a planned protest, but ultimately acquitted at trial. They then sued, asserting violations of federal civil rights statutes and state tort law, including claims of conspiracy, malicious prosecution, and selective enforcement.After the plaintiffs’ acquittal, they filed their action in the United States District Court for the District of Oregon. The district court dismissed the complaint, holding that it was a “shotgun pleading” that failed to satisfy Federal Rule of Civil Procedure 8 because it lumped together claims and factual allegations without specifying which defendants were responsible for which acts. The court also ruled, in the alternative, that several defendants were immune from suit: the Multnomah County District Attorney’s Office (“MCDA”) and prosecutors in their official capacities under the Eleventh Amendment; the prosecutors in their individual capacities under absolute immunity; and the police detective for his grand jury testimony.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the complaint was properly dismissed as a shotgun pleading, but that plaintiffs must be allowed to amend. The court affirmed dismissal with prejudice of all claims against MCDA and prosecutors in their official capacities on sovereign immunity grounds, and against the prosecutors in their individual capacities to the extent their actions were prosecutorial. However, the court reversed the dismissal of claims against a deputy prosecutor for allegedly filing false affidavits, holding that such conduct is not protected by absolute immunity and is not shielded by qualified immunity if false statements were knowingly made to obtain a warrant. The court also reversed dismissal of certain state-law claims against Multnomah County and remanded for further proceedings, allowing plaintiffs to replead those claims not based on the acts of the immune parties. It affirmed immunity for the detective regarding his grand jury testimony. The disposition was affirmed in part, reversed in part, and remanded with instructions to permit amendment of the complaint. View "Gibson v. City of Portland" on Justia Law

A Macon County sheriff’s deputy in Alabama, while off duty but using a police vehicle after caring for his police dog, became intoxicated and drove his police truck at an excessive speed without headlights or emergency lights at night. The deputy struck another vehicle, causing it to overturn and resulting in the death of a passenger, Edwin Moss. After the collision, the deputy fled the scene. He was later indicted for felony reckless manslaughter. The administrator of Moss’s estate filed a lawsuit, bringing state law claims for wrongful death and a federal claim under 42 U.S.C. § 1983, alleging the deputy violated Moss’s substantive due process right to life under the Fourteenth Amendment by acting with deliberate indifference.The case was removed to the United States District Court for the Middle District of Alabama, where the defendant sought dismissal of the federal claim on grounds of qualified immunity and argued he was not acting under color of law. The district court denied the motion, finding that the complaint plausibly alleged the deputy acted under color of law and was not entitled to qualified immunity. Following the deputy’s death, his estate was substituted as appellant and appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed only the denial of qualified immunity, holding that it lacked jurisdiction to review the color of law determination on interlocutory appeal. The appellate court assumed for purposes of appeal that the deputy acted under color of law and within his discretionary authority. It concluded, however, that existing circuit precedent did not clearly establish that the deputy’s conduct constituted a constitutional violation for purposes of § 1983. Therefore, the Eleventh Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Hughes v. Locure" on Justia Law

A Nevada state prisoner claimed that, during the COVID-19 pandemic, staff at High Desert State Prison denied him outdoor exercise, even while requiring him and other inmates in his unit to work together in a prison industry warehouse. He alleged that inmates in other units were permitted outdoor yard time, and that the denial of exercise caused him physical and psychological harm. The plaintiff, housed in a protective segregation unit, asserted that these actions violated his rights under the Eighth and Fourteenth Amendments, as well as similar state constitutional provisions.After filing grievances that were denied at each level by prison officials, the inmate brought a lawsuit in the United States District Court for the District of Nevada against the warden and other prison staff under 42 U.S.C. § 1983. The district court screened the complaint and allowed certain claims, including those regarding denial of outdoor exercise and equal protection, to proceed against the warden. On summary judgment, the district court denied qualified immunity to the warden for both the Eighth Amendment and Fourteenth Amendment claims, prompting the warden to appeal.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court held that the district court correctly denied qualified immunity on the Eighth Amendment claim, finding that the right to outdoor exercise was clearly established and that there were triable issues as to whether the warden’s actions constituted deliberate indifference. However, the Ninth Circuit reversed the denial of qualified immunity on the Fourteenth Amendment claim, concluding that the plaintiff did not provide evidence that ruled out all rational justifications for the difference in yard time between his unit and others. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Cardenas-Ornelas v. Johnson" on Justia Law

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin.After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law.The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law