Justia Civil Rights Opinion Summaries

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This case concerned an appeal by Matthew Ware, a former correctional officer, against the substantive reasonableness of his sentence. Ware was convicted by a jury of two counts of deprivation of rights under color of law and was sentenced to concurrent terms of 46 months of imprisonment. The United States Court of Appeals for the Tenth Circuit affirmed this sentence.Ware was a correctional officer at the Kay County Detention Center in Oklahoma. The charges against him arose from two incidents where he was found to have abused his power and caused harm to inmates. In one incident, Ware ordered the transfer of two inmates to a different level of the detention center, despite knowing that this would likely result in a fight, which it did. In another incident, Ware ordered a detainee to be handcuffed in a painful position for an extended period of time.Ware appealed his sentence, arguing that the court did not give adequate weight to his personal history and lack of criminal record. However, the Court of Appeals found that the district court had thoroughly weighed each of the sentencing factors and detailed its reasoning. The Court of Appeals held that the district court did not abuse its discretion in sentencing Ware to 46 months of imprisonment, and affirmed the sentence. View "United States v. Ware" on Justia Law

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In a case before the United States Court of Appeals for the Fifth Circuit, Ivan Cantu, who was convicted of capital murder and sentenced to death in 2001, sought to authorize the district court to consider a successive petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2244. He claimed a violation of the Due Process Clause of the Fourteenth Amendment and suppression of evidence by the state in violation of Brady v. Maryland. The Fifth Circuit denied his motion for authorization, holding that Cantu had failed to meet the requirements of 28 U.S.C. § 2244(b)(2)(B).The court found that Cantu failed to exercise due diligence to discover the evidence he was now relying on and that he failed to provide clear and convincing evidence that no reasonable factfinder would have found him guilty. The court also noted that Cantu's last-minute filing was an attempt at manipulation and did not serve the public interest or the interest of the victims in the timely enforcement of the sentence. Consequently, the court denied Cantu's motion for a stay of execution. View "In Re: Ivan Cantu" on Justia Law

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In the case before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Kristin Cosby, claimed that the South Carolina Probation, Parole & Pardon Services (SCPPP) had discriminated against her based on her gender and retaliated against her for filing discrimination complaints in violation of Title VII of the Civil Rights Act of 1964. Cosby had previously worked for SCPPP, left, and then reapplied in 2012. When she was not rehired, Cosby filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which found in her favor. SCPPP rehired her, but Cosby alleged that she was subsequently subjected to gender discrimination and retaliation, including being denied a promotion, being investigated for inappropriate relationships with subordinates, and ultimately forced to resign.The court affirmed the district court's granting of summary judgment to SCPPP. The court held that Cosby had failed to establish her gender discrimination claim under both the disparate treatment and hostile work environment theories. For the disparate treatment claim, Cosby failed to identify a valid comparator — a similarly situated individual of a different gender who was treated more favorably. In her hostile work environment claim, Cosby's internal complaint did not constitute protected activity under Title VII because it did not oppose an unlawful employment practice. The court also found no causal connection between Cosby's 2012 EEOC charge and any adverse employment action taken by SCPPP in 2018, defeating her retaliation claim. View "Cosby v. South Carolina Probation, Parole & Pardon Services" on Justia Law

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In this case, the plaintiffs, Susan Johnson and Jocelyne Welch, brought an action against the City of Biddeford, Chief of Police Roger P. Beapure, and Officer Edward Dexter of the Biddeford Police Department, alleging a violation of substantive due process rights under the state-created danger test. Johnson and Welch's action stems from a violent incident involving their landlord, James Pak. Pak became agitated about the number of cars parked in the driveway of the property he rented to Johnson and her son, Thompson. During a confrontation, Pak made gun-shaped hand gestures and said "bang." Thompson called the police and Officer Dexter responded.Officer Dexter spoke with both parties separately. During his conversation with Pak, Pak expressed his anger and frustration, making various threatening remarks. Despite these threats, Officer Dexter did not arrest, detain, or initiate a mental health intervention for Pak. After speaking with Pak, Officer Dexter returned to Johnson and Thompson's apartment, informing them that Pak was "obviously extremely upset" but did not relay the specific threats made by Pak. A few minutes after Officer Dexter left, Pak entered Johnson and Thompson's apartment and shot Johnson, Thompson, and Welch.On appeal, the United States Court of Appeals for the First Circuit held that Officer Dexter was entitled to qualified immunity against the plaintiffs' claim of violation of substantive due process rights under the enhancement-of-danger prong of the state-created danger test. The court found that a reasonable officer in Dexter's position would not have understood, based on the facts of the case, that he was violating any such rights by his actions and inactions. View "Johnson v. City of Biddeford" on Justia Law

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In this case, the plaintiff, an African-American male, brought an employment discrimination lawsuit against his former employer, Genzyme Therapeutic Products, LP, and one of its executives. The plaintiff alleged racial discrimination, harassment, and retaliation. The district court granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient proof that the employer's stated rationale for certain adverse employment actions was pretextual. The court also found that the plaintiff did not provide enough evidence to demonstrate a causal connection between the alleged protected conduct (filing a complaint against another employee for racial discrimination) and the adverse action (a poor performance review).On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the plaintiff failed to establish that there was a genuine issue of material fact as to whether the employer's proffered reason for the negative performance review was a pretext for discrimination. The court noted that the plaintiff's argument relied heavily on speculation and conjecture rather than definite and competent evidence. The court also highlighted that even if the plaintiff's direct manager thought he was deserving of a higher rating, this did not shed light on the executive's view, nor did it allow a reasonable juror to find that the executive's stated rationale was pretextual. The court concluded that a single racially tinged comment made by the executive was not sufficient to prove discriminatory intent. View "Boykin v. Genzyme Therapeutic Products, LP" on Justia Law

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The US Court of Appeals for the Third Circuit dealt with two consolidated cases involving two New Jersey parents, who claimed they were retaliated against for protesting school policies related to mandatory masking during the COVID-19 pandemic. One parent, George Falcone, was issued a summons for defiant trespass after refusing to wear a mask at a school board meeting, while another parent, Gwyneth Murray-Nolan, was arrested under similar circumstances. Falcone claimed retaliation for exercising his First Amendment rights, while Murray-Nolan argued the same and also claimed she was deprived of substantive due process. The district court dismissed both cases. On appeal, the court found that Falcone had standing to sue, reversing and remanding the lower court's decision. However, the court affirmed the dismissal of Murray-Nolan's case, concluding that refusing to wear a mask during a pandemic was not protected conduct under the First Amendment. View "Murray-Nolan v. Rubin" on Justia Law

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In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

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In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

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In a case before the United States Court of Appeals for the Eighth Circuit, the plaintiffs, The Arc of Iowa and several parents of children with disabilities, sought to challenge a provision of the Iowa Code that prevents schools from imposing mask mandates unless required by other laws. They had received a preliminary injunction from a lower court that had been vacated by this court due to changing circumstances related to the COVID-19 pandemic. On remand, the district court granted the plaintiffs' motion for summary judgment, declaring that the phrase 'other provisions of law' in the contested Iowa Code section includes Title II of the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act, and that the contested Iowa Code section cannot be cited as the sole basis for denying a student's request for reasonable modification or accommodation under the ADA or the Rehabilitation Act that requires others to wear masks.The defendants, the Governor of Iowa and the Director of the Iowa Department of Education, appealed to the Eighth Circuit, raising issues of exhaustion of remedies under the Individuals with Disabilities Act (IDEA), standing of the plaintiffs, and the propriety and necessity of the relief granted by the district court.The appellate court, after de novo review, found that the plaintiffs failed to meet the requirements for standing, which include having suffered an injury in fact, traceability of the injury to the defendant's conduct, and the likelihood of redress by a favorable judicial decision. The court found that the general risks associated with COVID-19 were not enough to constitute "imminent and substantial" harm for standing. It also concluded that the plaintiffs had not demonstrated that the alleged injuries were fairly traceable to the conduct of the Governor or the Director of the Department of Education. As a result, the court vacated the district court's order and remanded the case with instructions to dismiss due to lack of standing. View "The Arc of Iowa v. Reynolds" on Justia Law

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In this case, the United States Court of Appeals for the Fifth Circuit ruled on a civil rights lawsuit filed by James Everard and Christopher Grisham against the City of Olmos Park and several police officers. Everard and Grisham, self-identified "Second Amendment protestors", claimed their arrests on March 27, 2018, violated their First, Fourth, and Fourteenth Amendment rights. They were arrested after 911 operators received several calls about a man "with an AK-47" around his neck, standing on a busy street corner in Olmos Park. The officers arrived and found Everard with a large gun in a holster in front of his chest, and Grisham with a handgun in a holster on his hip. Everard and Grisham were charged with disorderly conduct and interference with the duties of a public servant respectively, but all charges were dismissed for insufficient evidence.The district court granted summary judgment in favor of the City and the officers, a decision that Everard and Grisham appealed. The Court of Appeals, however, affirmed the district court's decision, agreeing that the officers had probable cause to believe that Plaintiffs were engaging in criminal activity and that the officers were not objectively unreasonable in believing such probable cause existed.The court also rejected the Plaintiffs’ First Amendment claims, stating that officers cannot execute their law enforcement duties while someone is engaging in speech, where probable cause exists. The court ruled that the officers had probable cause to make the arrests for disorderly conduct and resisting arrest, thus precluding the arrestees’ retaliatory arrest claims. The court further rejected the Plaintiffs’ Fourth Amendment claims, stating that the officers are protected by qualified immunity since both Everard and Grisham could not point to any clearly established law that such force was unreasonably excessive under the circumstances. Lastly, the court affirmed the dismissal of the Plaintiffs' municipal liability claims, as they failed to establish that there were constitutional violations. View "Grisham v. Valenciano" on Justia Law