Justia Civil Rights Opinion Summaries

Articles Posted in Civil Procedure
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In this case, DeShawn Anderson-Santos, a juvenile detainee at the Kent County Juvenile Detention Center, claimed he suffered a head injury after being pushed by corrections officer Derek Leshan. Anderson-Santos filed a lawsuit against Leshan under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Eighth Amendment, alleging the use of excessive force. Leshan sought summary judgment arguing qualified immunity. The district court denied Leshan’s motion, finding that there was a genuine dispute of material fact as to whether Leshan had used excessive force, thus violating the Eighth Amendment. The court also found that Leshan was not entitled to qualified immunity at the summary judgment stage. Leshan appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit dismissed the appeal for lack of jurisdiction. The court noted that while denials of summary judgment are not typically appealable on an interlocutory basis, an exception exists for denials of claims of qualified immunity if the appeal turns on a legal issue. However, the court found that Leshan's appeal ultimately turned on questions of fact rather than an issue of law, divesting the court of jurisdiction. The court explained that a defendant seeking to challenge a denial of qualified immunity based on a genuine dispute of material fact may invoke the court's jurisdiction by conceding the plaintiff's version of the facts. However, the court determined that Leshan did not truly concede Anderson-Santos' version of the facts, thus the court lacked jurisdiction to hear the appeal. View "Anderson-Santos v. Kent County" 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 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 plaintiff, Chicago Joe's Tea Room LLC, had plans to open an adult entertainment business in a suburb of Chicago. However, the Village of Broadview denied the plaintiff's application for a special-use permit, which led to the plaintiff claiming that their constitutional rights were violated. The plaintiff sought millions of dollars in lost profits for the business that never opened. The U.S. District Court for the Northern District of Illinois excluded most of the plaintiff's evidence and theories for lost-profit damages due to substantive and procedural issues. The court then awarded the plaintiff just $15,111 in damages. The plaintiff appealed, but the United States Court of Appeals for the Seventh Circuit affirmed the decision of the lower court, finding no abuses of discretion. The appellate court stated that the plaintiff's calculations of lost profits were beyond the scope of the plaintiff's personal knowledge of a similar business and required expert-like analysis and adjustments. The court also ruled that the plaintiff failed to disclose necessary damages evidence in a timely manner, a violation of the Federal Rules of Civil Procedure. The plaintiff was also denied the opportunity to amend their complaint to challenge a state statute, as the request was made a decade after the issue became relevant. The court found that granting the amendment would have caused undue delay and prejudice to the Village. View "Chicago Joe's Tea Room, LLC v. Village of Broadview" on Justia Law

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The case involves Pablo Abreu, a student who was expelled from Howard University College of Medicine. Abreu appealed his expulsion, arguing that the university violated his rights under Title III of the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1972 by refusing to grant him additional opportunities to retake a required examination, in light of his diagnosed test-taking-anxiety disability. The district court dismissed his complaint, applying a one-year statute of limitations and ruling that his claims were time-barred.The United States Court of Appeals for the District of Columbia Circuit disagreed with the lower court's application of a one-year statute of limitations to Abreu’s ADA and Rehabilitation Act claims. The court pointed to its decision in another case, Stafford v. George Washington University, in which it concluded that a three-year statute of limitations should apply to civil rights claims under Title VI of the Civil Rights Act of 1964. Since Abreu's ADA and Rehabilitation Act claims were also civil rights claims alleging discrimination, the court ruled that the three-year statute of limitations should apply. This made Abreu’s claims timely since he filed the suit less than three years after his expulsion.The court then remanded the case back to the district court for further proceedings on the ADA and Rehabilitation Act claims. However, it affirmed the dismissal of Abreu's contractual claims, agreeing with the district court that Abreu failed to state a claim for breach of contract. View "Abreu v. Howard University" on Justia Law

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In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law

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The case was brought before the United States Court of Appeals for the Fifth Circuit. The plaintiff, Jarius Brown, alleged that officers from the DeSoto Parish Sheriff's Office attacked him without provocation, leaving him to languish in a jail cell with a broken nose and eye socket. Almost two years later, Brown sued Javarrea Pouncy and two unidentified officers in the U.S. District Court for the Western District of Louisiana, seeking relief under 42 U.S.C. § 1983 for the alleged use of unreasonable force in violation of the Fourth and Fourteenth Amendments, as well as under Louisiana state law for battery. However, the district court dismissed Brown's Section 1983 claim as untimely under Louisiana's one-year statute of limitations for personal injury claims. Brown appealed this decision, arguing that the one-year period should not apply to police brutality claims brought under Section 1983 as it discriminates against such claims and practically frustrates litigants' ability to bring them.The Court of Appeals affirmed the district court's decision, holding that precedent required them to do so. The Court reasoned that while Brown's arguments that a one-year limitations period is too restrictive to accommodate the federal interests at stake in a civil rights action, the Supreme Court has yet to clarify how lower courts should evaluate practical frustration without undermining the solution it has already provided for the absence of a federal limitations period for Section 1983 claims. This was based on the principle that the length of the limitations period and related questions of tolling and application are governed by state law. The Court also noted that states have the freedom to modify their statutes to avoid being outliers in this regard. View "Brown v. Pouncy" on Justia Law

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The case involves Clifton Park Apartments, LLC and its attorney (collectively referred to as "Pine Ridge"), CityVision Services, Inc. ("CityVision"), and the New York State Division of Human Rights ("DHR"). CityVision is a Texas-based not-for-profit corporation that tests whether housing facilities engage in discrimination. In 2016, CityVision placed a test call to Pine Ridge and subsequently filed a discrimination complaint with DHR, alleging familial status discrimination. DHR dismissed the complaint due to lack of probable cause. Following this, Pine Ridge's attorney sent a letter to CityVision stating that Pine Ridge considered the allegations in CityVision's complaint to be "false, fraudulent, and libelous" and threatened to seek damages. In response, CityVision filed a second complaint with DHR, alleging that Pine Ridge retaliated against them for filing the first discrimination complaint.The Appellate Division annulled DHR's determination of retaliation and the case was brought before the Court of Appeals of New York. The Court of Appeals held that a threat of litigation could constitute the requisite adverse action to support a retaliation claim under New York State Human Rights Law. In this case, DHR rationally concluded that the element of adverse action had been established when Pine Ridge sent the threatening letter to CityVision. However, the Court also held that a remittal was necessary because DHR improperly shifted the burden when analyzing whether CityVision had engaged in protected activity. The Court of Appeals ruled that DHR should have determined whether CityVision reasonably believed that Pine Ridge had engaged in a discriminatory practice during the test call. Consequently, the judgment was reversed, and the matter remitted to the Appellate Division with directions to remand to DHR for further proceedings. View "Clifton Park Apts., LLC v New York State Division of Human Rights" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, One Love Housing, LLC, a company that operates a residential sober living home in Anoka, Minnesota, sued the City of Anoka for refusing to grant a waiver from the city's zoning regulations. The regulations permit only a single family or a group of not more than four unrelated persons to reside together in the area where the sober home is located. One Love wanted to accommodate seven unrelated recovering addicts in the home. One Love and two residents of the home alleged that the city violated the Americans with Disabilities Act and the Fair Housing Act by refusing to grant this waiver.The district court granted One Love summary judgment on its claim that the city failed to reasonably accommodate the sober home's request. The court ordered the city to grant the waiver for One Love to house seven unrelated individuals recovering from substance abuse. The city appealed this decision.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision and remanded the case for further proceedings. The appellate court held that the district court erred by considering evidence that was not presented to the city council when it denied One Love's request for a waiver. The appellate court also found that the district court erred in granting summary judgment to One Love because there was a genuine dispute over whether the requested accommodation was reasonable and necessary. The court stated that the financial viability of One Love's sober home is relevant only if One Love can prove that the service it offers provides a therapeutic benefit that is necessary for people recovering from alcohol or drug abuse to successfully live in a residential neighborhood without relapsing. The court concluded that there are genuine issues of disputed fact on these issues. The court also declined to rule on One Love's disparate treatment and disparate impact claims, leaving those for the district court to address on remand. View "One Love Housing, LLC v. City of Anoka, MN" on Justia Law

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The case involves Robert Mestanek, a citizen of the Czech Republic, who filed two Form I-130 petitions to establish his eligibility for lawful permanent residence in the United States based on his marriages to two different U.S. citizens. The first petition was filed by his then-wife Angel Simmons, and the second by his current wife Mary Mestanek. The United States Citizenship and Immigration Services (USCIS) denied both petitions, the first on the grounds that Robert’s marriage to Angel was fraudulent, and the second based on the “marriage fraud bar” which prohibits approval of Form I-130 petitions for any noncitizen who has previously been found to have entered into a fraudulent marriage to circumvent immigration laws. The Mestaneks filed suit in federal district court seeking judicial review of USCIS’s denial of Mary’s Form I-130 petition. The district court granted summary judgment in favor of USCIS, and the Mestaneks appealed. The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision, agreeing that USCIS’s denial was neither arbitrary nor contrary to law. The court rejected all of the Mestaneks’ arguments, including their contention that USCIS applied the wrong legal standard for marriage fraud, and their assertion that the administrative record was incomplete and insufficient for judicial review. The court also found no due process violation by USCIS. View "Mestanek v. Jaddou" on Justia Law