Justia Civil Rights Opinion Summaries

Professor James Wetherbe, known for his anti-tenure views, claimed he faced retaliation from Lance Nail, the then-dean of the business school at Texas Tech University (TTU), for his public criticisms of tenure. Wetherbe alleged that Nail's retaliatory actions included removing him from teaching assignments, falsely accusing him of misconduct, and revoking his emeritus status, among other adverse actions. Wetherbe sued Nail under 42 U.S.C. §1983 for violating his First Amendment rights and sought injunctive and declaratory relief against the current dean, Margaret Williams.The United States District Court for the Northern District of Texas denied the defendants' second amended Rule 12(c) motion, holding that Wetherbe sufficiently alleged a constitutional violation and that Nail’s actions were objectively unreasonable in light of clearly established law. The defendants appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court concluded that the contours of First Amendment law regarding retaliation were not clearly established at the time the events occurred. Specifically, the court found that it was not clearly established that Wetherbe’s speech regarding tenure was on a matter of public concern. Consequently, the court reversed the district court’s order and rendered judgment in favor of the defendants, granting Nail qualified immunity from Wetherbe’s First Amendment retaliation claims. The court did not address Wetherbe’s claims for declaratory and injunctive relief against Williams, as the district court had not ruled on those claims. View "Wetherbe v. Texas Tech University" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

A mother was shot and killed by a deputy sheriff while her young children watched. The mother, who had been acting erratically and wielding a knife, advanced towards the deputies despite repeated requests to drop the weapon. The lead deputy fired his service pistol after a backup deputy's taser failed to stop her. The children, through their guardian ad litem, sued the deputies and Nevada County, claiming the use of force was unreasonable.The trial court ruled that the lead deputy acted reasonably and granted summary judgment in his favor, but allowed the claims against the backup deputy to proceed, finding that a reasonable juror could conclude his actions were unreasonable. The backup deputy and the County petitioned for a writ of mandate, arguing that the trial court should have granted their summary judgment motion as well.The California Court of Appeal, Third Appellate District, reviewed the case. The court emphasized the need to assess reasonableness from the perspective of a reasonable officer at the scene, considering the split-second decisions officers must make. The court concluded that the backup deputy acted reasonably as a matter of law, noting that the mother advanced towards the deputies with a deadly weapon and that the backup deputy's use of a taser was a reasonable response under the circumstances.The court issued a writ of mandate directing the trial court to set aside its partial denial of the summary judgment motion and to enter a new order granting the motion in its entirety, thus ruling in favor of the backup deputy and the County. View "County of Nevada v. Super. Ct." on Justia Law

On December 15, 2015, police officers responded to a hostage situation at Eagle Nation Cycles in Neenah, Wisconsin. Initial reports indicated a lone gunman had fired a shot and was threatening to kill hostages. When officers attempted to enter the shop, they were met with gunfire and heavy smoke, leading them to suspect an ambush. Several hostages escaped, and the officers detained and questioned them, transporting two to the police station. Three of these hostages later sued the City of Neenah and multiple officers, claiming their Fourth Amendment rights against unreasonable seizures were violated.The United States District Court for the Eastern District of Wisconsin found the plaintiffs' detention reasonable and ruled that no constitutional violation occurred. Additionally, the court held that qualified immunity shielded the officers from liability. The court also dismissed Sergeant Angela Eichmann from the suit due to her lack of involvement in the alleged misconduct. The district court granted summary judgment in favor of the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the officers' actions were reasonable under the circumstances of a violent hostage situation. The court found that the officers were justified in temporarily detaining the plaintiffs to ascertain their identities and ensure safety. The court also affirmed the dismissal of Sergeant Eichmann, as there was no evidence of her direct involvement in the alleged constitutional violations. The court did not address the issue of qualified immunity, as it concluded that no constitutional violation occurred. View "Moderson v. City of Neenah" on Justia Law

The case involves the appellant, Gregory Smith, challenging the Municipality of Anchorage's decision to abate unauthorized campsites in Davis Park. The Anchorage Municipal Code (AMC) outlines procedures for campsite abatement, including posting a notice and allowing for an appeal to the superior court. In June 2022, the Municipality posted a notice in Davis Park, advising that the area was not legal for storage or shelter and that any personal property would be removed and disposed of as waste after ten days. Smith and five others appealed the abatement, arguing it violated due process and the Eighth Amendment.The superior court dismissed the appeal, agreeing with the Municipality that its jurisdiction was limited to reviewing the legal sufficiency of the posted notice, not the abatement decision itself. The court noted that the appellants did not challenge the notice's compliance with the Code, thus leaving no issues for the court to decide. The court also observed that the appellants' claims were not without merit and suggested that a civil suit could address their concerns.The Supreme Court of the State of Alaska reviewed the case and concluded that the superior court's jurisdiction was not limited to the notice's legal sufficiency. The court held that the superior court has jurisdiction to review the substantive decision to abate the campsite, including constitutional challenges. The court reversed the superior court's decision and remanded the case for further consideration of the constitutional issues raised by Smith. The court also directed the superior court to determine if the administrative record was sufficient for meaningful appellate review and to take necessary steps to ensure it has an adequate record. View "Smith v. Municipality of Anchorage" on Justia Law

Charlene Carter, a flight attendant for Southwest Airlines, was terminated after sending graphic anti-abortion messages to the president of the flight attendants' union, Audrey Stone. Carter, a pro-life Christian, opposed the union's leadership and its participation in the Women's March, which she viewed as supporting abortion. After an arbitrator found that Southwest had cause to terminate Carter under its corporate policies, Carter sued Southwest and the union, claiming her termination violated Title VII of the Civil Rights Act and the Railway Labor Act (RLA).The United States District Court for the Northern District of Texas ruled in favor of Carter, finding that Southwest and the union had discriminated against her based on her religious beliefs and practices. The court permanently enjoined Southwest and the union from interfering with the religious expression of any Southwest flight attendant and held Southwest in contempt for failing to comply with its judgment. Both Southwest and the union appealed, and Carter cross-appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of Southwest's motion for judgment as a matter of law on Carter's belief-based Title VII claim and RLA retaliation claim, remanding with instructions to enter judgment for Southwest. The court affirmed the judgment against Southwest on Carter's practice-based Title VII claims and the dismissal of Carter's RLA interference claim. The court also affirmed the judgment against the union on all claims but vacated the permanent injunction and remanded for additional proceedings. Additionally, the court vacated the contempt order against Southwest. View "Carter v. Southwest Airlines Company" on Justia Law

M.R., a high school student and basketball player, was sexually abused by Cody Butler, a women's basketball coach at Yakima Valley Community College (YVCC), starting when she was 17 years old. The abuse continued into her adulthood, including inappropriate touching, sexual comments, and physical advances. Butler's actions had a significant negative impact on M.R.'s life, leading to substance abuse, abusive relationships, and other personal issues. In 2018, M.R. connected her experiences of abuse to her injuries while in therapy.In 2019, M.R. sued the State of Washington, YVCC, and Butler for various claims, including negligence and assault. The trial court denied the State's motion for summary judgment, which argued that M.R.'s claims were time-barred by the three-year statute of limitations in RCW 4.16.080(2). The court found that the abuse was a continuous series of events that could not be segregated. The Court of Appeals reversed, concluding that RCW 4.16.340 only applies to claims based on acts of childhood sexual abuse occurring before the plaintiff turns 18 years old.The Supreme Court of the State of Washington reviewed the case and reversed the Court of Appeals. The court held that RCW 4.16.340 does not preclude complainants from bringing claims of sexual abuse that originate from childhood sexual abuse and extend into the victim’s adulthood. The court found that the statute's plain language and legislative intent support the inclusion of claims for continuing sexual abuse that are based on intentional acts of childhood sexual abuse. The court also noted that the statute accounts for the continuing tort doctrine, allowing for claims involving a common scheme of abuse by the same perpetrator. View "M.R. v. State" on Justia Law

A Turkish graduate student, Rümeysa Öztürk, was lawfully residing in Massachusetts on a student visa when she was arrested by plainclothes officers without warning on March 25, 2025. She was transported across state lines and eventually detained in Louisiana. Her counsel, unaware of her location, filed a habeas petition in the District of Massachusetts, alleging her arrest was based on an op-ed she co-authored. The petition was transferred to the District of Vermont after it was revealed she had been in Vermont during transit.The District of Vermont set a schedule for a bail hearing and to resolve the constitutional claims in the habeas petition. The court ordered the government to transfer Öztürk from Louisiana to Vermont to aid in these proceedings. The government appealed this order, seeking an emergency stay of the transfer.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the government failed to justify a stay. It determined that the District of Vermont was the proper venue for the habeas petition since Öztürk was in Vermont when the petition was filed. The court also found that the government was unlikely to succeed on its arguments that jurisdiction-stripping provisions of the Immigration and Nationality Act deprived the district court of jurisdiction over Öztürk’s detention challenge. Additionally, the court held that the government did not demonstrate irreparable injury absent a stay and that the balance of equities favored Öztürk.The Second Circuit denied the government’s motion for a stay, denied the request for a writ of mandamus, and vacated the administrative stay. The court ordered the government to comply with the district court’s transfer order within one week. View "Öztürk v. Hyde" on Justia Law

A former inmate at the Illinois River Correctional Center (IRCC) filed a lawsuit under 42 U.S.C. § 1983 against several prison officials, including Wardens Walter Nicholson and Gregory Gossett. The plaintiff alleged that the IRCC's failure to treat his chronic kidney disease, which progressed to acute renal failure, constituted deliberate indifference in violation of the Eighth and Fourteenth Amendments. The plaintiff claimed that the wardens were aware of the deficient medical practices that led to his injury.The United States District Court for the Central District of Illinois granted Warden Nicholson's motion to dismiss, concluding that the plaintiff's claim was time-barred and that he failed to state a claim. The court also granted Warden Gossett's motion for summary judgment, finding that the plaintiff did not provide sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. Additionally, the court excluded the plaintiff's expert witnesses, determining that their testimony would not assist the jury and might cause confusion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's dismissal of the claim against Warden Nicholson, agreeing that the plaintiff's complaint contained only general allegations and did not provide specific deficiencies in the IRCC's health care system. The court also upheld the summary judgment in favor of Warden Gossett, concluding that the plaintiff did not present sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. The court found that the district court did not abuse its discretion in excluding the expert testimony, as the experts lacked relevant expertise and their opinions would not assist the jury. View "Ollison v Gossett" on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law