Justia Civil Rights Opinion Summaries

Plaintiff was hired as a Law Enforcement Officer by the Sisseton, South Dakota, Police Department. Plaintiff and the City signed a Sisseton Police Department Employment Contract (the “Contract”) requiring Plaintiff to reimburse the City for the cost of her training if she left the Department before completing 36 months of employment. In January 2022, Defendant, the City’s Chief of Police, informed Plaintiff that the Police Commission had lost confidence in her, and Defendant asked Plaintiff to resign, which she did. Plaintiff filed this 42 U.S.C. Section 1983 action, asserting, along with other claims, that the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights. The district court granted Defendants’ motion. Plaintiff appealed only the dismissal of her due process claims.   The Eighth Circuit affirmed. The court agreed with the district court the Supreme Court of South Dakota would rule that the Contract did not change an at-will employment relationship. The court explained that for Plaintiff’s claim against the City to survive a motion to dismiss, her complaint must contain “enough facts to state a claim to relief that is plausible on its face.” The court agreed with the district court that the Complaint “failed to allege any unconstitutional policy or custom that enabled” Defendants to deprive Plaintiff of her alleged federal due process rights. Counsel for Plaintiff could only respond that the Complaint plausibly alleged the practice of violating the three-year term in the City’s employee reimbursement contracts. That practice was not alleged in the Complaint and, in any event, is nothing more than a “facially lawful municipal action.” View "Samantha LaCoe v. City of Sisseton" on Justia Law

The Texas Department of Criminal Justice fired Plaintiff after he refused to cut his hair and beard in violation of his religious vow. Plaintiff exhausted his administrative remedies. He then filed a pro se lawsuit against TDCJ and various officers, which alleged claims of religious discrimination and failure to accommodate under Title VII of the Civil Rights Act of 1964. The district court granted summary judgment in favor of Defendants.   The Fifth Circuit, in accordance with the Supreme Court’s recent decision in Groff v. DeJoy, 143 S. Ct. 2279 (2023), reversed. The court explained that Title VII forbids religious discrimination in employment. The statute defines “religion” broadly to include “all aspects of religious observance and practice, as well as belief.” Further, the court explained that Title VII also requires employers to accommodate the religious observances or practices of applicants and employees. The court held that TDCJ breached both duties. TDCJ (A) failed to accommodate Hebrew’s religious practice and (B) discriminated against him on the basis of his religious practice   The court reasoned that the only issue is whether TDCJ has met its burden to show that granting Hebrew’s requested accommodation—to keep his hair and beard—would place an undue hardship on TDCJ. The court held that (1) TDCJ cannot meet the undue hardship standard and (2) the Department’s counterarguments are unavailing. The court noted that, in this case, TDCJ cannot hide behind its “otherwise-neutral policy.” This policy must “give way” to Plaintiff’s requested accommodation. View "Hebrew v. TDCJ" on Justia Law

Appellee Gateway Hotel L.P. (“Gateway”) contends that the standard for awarding costs to ADA Defendants is governed by Federal Rule of Civil Procedure 54(d)(1), which allows courts the discretion to award costs to prevailing parties “unless a federal statute . . . provides otherwise.” Appellant contends that the ADA’s fee- and cost-shifting statute “provides otherwise” because it permits ADA Defendants to receive their costs only where there is a showing that the action was frivolous, unreasonable, or groundless. Therefore, he contends that the district court should have granted his motion to retax costs, which would have, in effect, denied Gateway’s application for costs. The district court denied Appellant’s motion because it concluded that the decision in Brown was irreconcilable with the United States Supreme Court’s intervening opinion in Marx v. General Revenue Corp., 568 U.S. 371 (2013) and was therefore effectively overruled.   The Ninth Circuit affirmed. The panel held that Brown v. Lucky Stores was effectively overruled by Marx v. General Revenue Corp. The panel held that, accordingly, the fee- and cost-shifting provision of the ADA, 42 U.S.C. Section 12205, does not “provide otherwise” within the meaning of Rule 54(d)(1). Rule 54(d)(1), therefore, governs the award of costs to a prevailing ADA defendant and allows such an award in the court’s discretion, thereby keeping the court’s prior award of costs to the defendant intact. View "ORLANDO GARCIA V. GATEWAY HOTEL L.P." on Justia Law

The University of Iowa expelled graduate student John Doe after investigating two accusations of sexual misconduct brought against him by different complainants. The Iowa Board of Regents affirmed the decision. Doe sued the University and University officials, claiming, in part, discrimination on the basis of sex under Title IX, 20 U.S.C. Section 1681(a), and procedural due process violations, 42 U.S.C. Section 1983. The district court granted qualified immunity to the University officials, dismissed the procedural due process claims against them, and granted the University summary judgment on the remaining claims.   The Eighth Circuit affirmed. The court explained that it is not convinced that institutional efforts to prevent sexual misconduct on campus, including educational programs that challenge students to evaluate the impact of gender norms on rape culture, amount to evidence of external pressure on the University that supports an inference of bias. The court held that Doe failed to provide “sufficient evidence to allow a reasonable jury to find that [the University] disciplined him on the basis of sex.” Accordingly, the court affirmed the district court’s grant of summary judgment on Doe’s Title IX claim. Further, the court explained that the University provided adequate notice of the charges. Therefore, the court wrote that because Doe failed to show the University officials’ conduct violated his federal rights, it affirmed the district court’s dismissal of Doe’s claims against the University officials. View "John Doe v. University of Iowa" on Justia Law

Plaintiffs Dominick Martin and Rusty Rendon filed suit under the Unruh Civil Rights Act for disability discrimination, contending that one of Thi E-Commerce’s Web sites discriminated against the blind by being incompatible with screen reading software. Plaintiffs contended the court erred by concluding that a Web site was not a place of public accommodation under the Americans with Disabilities Act (incorporated into the Unruh Act). Although this was an issue that has split the federal courts (and California Courts of Appeal), the appellate court here concluded the ADA unambiguously applied only to physical places. Moreover, even if the Court found ambiguity and decided the issue on the basis of legislative history and public policy, it would still conclude that the ADA did not apply to Web sites. Plaintiffs alternatively contended they stated a cause of action against Thi E-Commerce on a theory of intentional discrimination. To this, the Court of Appeal concluded the allegations of the complaint did not state a claim under that theory either and affirmed the judgment. View "Martin v. THI E-Commerce, LLC" on Justia Law

Plaintiff alleged that two sheriff deputies unlawfully entered his home. The deputies claim Armstrong’s then-wife invited them in. But although they disagree on whether the deputies’ conduct was reasonable, they do not dispute the historical facts as to what happened. Plaintiff filed a claim under 42 U.S.C. Section 1983. The deputies moved for summary judgment on the merits claiming that, even construing the facts in the light most favorable to Plaintiff, their conduct was objectively reasonable. Alternatively, the deputies claimed they should be granted summary judgment based on qualified immunity. The district court agreed with the deputies on the merits, finding the deputies reasonably believed that Roadcap had the authority to consent to the deputies’ entry.   The Fourth Circuit affirmed. The court explained that, construing the evidence in the light most favorable to Plaintiff, the deputies did, as the district court concluded, briefly detain Plaintiff. But the court agreed with the district court that the deputies acted reasonably as a matter of law because they were responding to a domestic situation, there were guns in the house, and Plaintiff was argumentative. Accordingly, the court affirmed the district court’s order granting summary judgment on the seizure of person claim as well. Moreover, the court wrote that, construing the evidence in the light most favorable to Plaintiff, the deputies exercised some care. Thus, the district court properly dismissed the gross negligence claim. Last, as to the conversion claim, the district court properly explained that there is no evidence in the record that the deputies possessed, touched or exercised any authority over Plaintiff’s personal property. View "Adam Armstrong v. Bryan Hutcheson" on Justia Law

The Verona Police Department twice arrested L.B. for his connection to violent shootings. Both times, however, he was released while his charges were pending. Just five months after his second arrest, L.B. drove to Annie Walton’s house and opened fire—killing Annie Walton and injuring her grandson, Aliven Walton. Annie Walton’s wrongful death beneficiaries (collectively, Plaintiffs ) believe the City of Verona and the Verona Chief of Police, J.B. Long, are responsible for the shooting at Annie Walton’s home, so they sued under 42 U.S.C. Section 1983 and the Mississippi Tort Claims Act. At summary judgment, the district court initially dismissed all claims. But Plaintiffs filed a motion for reconsideration, and the district court reversed course—finding the City of Verona was not entitled to sovereign immunity under the Mississippi Tort Claims Act. Plaintiffs and the City of Verona subsequently filed interlocutory appeals.   The Fifth Circuit dismissed Plaintiffs appeal for lack of jurisdiction and reversed the district court’s finding against the City regarding sovereign immunity. The court explained that Long had no special duty to protect Plaintiffs besides his general duty to keep the public safe as the City’s Chief of Police. The court explained that the only evidence that demonstrates Long had knowledge of any connection between L.B. and Plaintiffs comes from Long’s investigative file, where there is a copy of a trespassing complaint that Annie filed against L.B. in 2016. Accordingly, the court held Long did not owe a duty to protect Plaintiffs from L.B.’s drive-by shooting. Thus, Plaintiffs cannot sustain their negligence claims or their MTCA claims against the City. View "Walton v. City of Verona" on Justia Law

For five months when C.V. was a pre-kindergarten student in the Waterford Township School District, she was repeatedly sexually assaulted by Alfred Dean, the seventy-six-year-old bus aide who was supposed to be ensuring her safety. C.V.’s parents only discovered the abuse when C.V. came home without her underwear one day. C.V. and her parents sued the Waterford Township Board of Education and Waterford Township School District (collectively, Waterford) alleging, among other things, discrimination in a “place of public accommodation” “on account of . . . sex” in violation of the New Jersey Law Against Discrimination (LAD). The trial court granted summary judgment in favor of Waterford and dismissed plaintiffs’ LAD claims. The court found plaintiffs could not, as a matter of law, prove to a jury that Dean’s conduct occurred because of C.V.’s sex, or that it would not have occurred but for C.V.’s sex. According to the trial court, “the but for element can’t be satisfied . . . where you have a compulsive sexual predator, a pedophile,” especially one who testified at his deposition “that he is a compulsive sexual abuser of children, boys and girls.” The Appellate Division affirmed, concluding that the LAD did not apply “to a sexual predator’s assault of a student on a school bus where there is no evidence his actions were based solely on the victim’s status as a member of a protected group.” The New Jersey Supreme Court reversed the Appellate Division’s judgment because it conflicted with Lehmann v. Toys ‘R’ Us, Inc., 132 N.J. 587 (1993) and L.W. v. Toms River Regional Schools Board of Education, 189 N.J. 381 (2007). The Court reiterated that under Lehman, sexual touching of areas of the body linked to sexuality happens, by definition, because of sex. The Court affirmed the denial of plaintiffs’ motion to amend their complaint and to obtain certain records, and we remand for further proceedings consistent with this opinion. View "C.V. v. Waterford Township Board of Education" on Justia Law

Plaintiff-appellee Gary Waetzig filed an age discrimination lawsuit against his former employer, Halliburton Energy Services, Inc. Because he was contractually bound to arbitrate his claim, he voluntarily dismissed his suit without prejudice under Federal Rule of Civil Procedure 41(a) and filed for arbitration. The arbitrator sided with Halliburton. Dissatisfied with the outcome, Waetzig returned to federal court. But instead of filing a new lawsuit challenging arbitration, he moved to reopen his age discrimination case and vacate the arbitration award. Relying on Rule 60(b), the district court concluded it had jurisdiction to consider Waetzig’s motion, reopened the case, and vacated the award. The Tenth Circuit found the district court erred: the district court could not reopen the case under Rule 60(b) after it had been voluntarily dismissed without prejudice. Under Federal Rules of Civil Procedure 41(a) and 60(b), a court cannot set aside a voluntary dismissal without prejudice because it is not a final judgment, order, or proceeding. View "Waetzig v. Halliburton Energy Services" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law