Justia Civil Rights Opinion Summaries

In 1997, Frederic Sannmann pleaded guilty to felony robbery which rendered him ineligible to own firearms. In 2003, he successfully moved to set aside his conviction for most purposes: by statute, this relief did not restore Sannmann's right to own firearms. In 2011, Sannmann successfully moved, with the prosecutor's concurrence, to set aside the earlier set-aside order, to withdraw his 1997 felony guilty plea, and to instead plead guilty to misdemeanor theft nunc pro tunc to the date of his original plea. Sannmann immediately notified the California Department of Justice (DOJ) of these changes and the DOJ eventually updated its records accordingly. However, six years later, when Sannmann tried to buy a shotgun from a gun store, the DOJ blocked the purchase based on Sannmann's original 1997 felony conviction. Sannmann filed a petition for writ of mandamus seeking an order directing the DOJ to release any holds on his ability to purchase firearms based on the 1997 felony conviction. The trial court believed it lacked the authority to determine the validity of the 2011 set-aside order entered by another superior court judge. Thus, finding Sannmann's record in the criminal case disclosed only a misdemeanor conviction (by virtue of the 2011 set-aside order), the court entered judgment for Sannmann and ordered the DOJ to release its hold on Sannmann's purchase. On appeal, the DOJ contended the trial court erred by awarding mandamus relief based on the 2011 set-aside order because the 2011 order was an unauthorized act in excess of the superior court's jurisdiction. The DOJ did not otherwise seek to invalidate the 2011 set-aside order. On the narrow issue before it, the Court of Appeal agreed the trial court erred by granting mandamus relief based on the 2011 set-aside order and reversed the judgment. View "Sannmann v. Dept. of Justice" on Justia Law

The First Circuit dismissed this interlocutory appeal for lack of appellate jurisdiction and remanded the matter to the district court, holding that Appellant's challenge to the district court's denial of summary judgment was not a final, appealable order.Plaintiff, an inmate at Souza Baranowski Correctional Center (SBCC), brought this lawsuit alleging that Appellant, an SBCC prison official, and other SBCC officials failed to protect him from a substantial risk of serious harm in violation of his constitutional rights. Appellant and the remaining defendants filed for summary judgment on grounds of qualified immunity. The district court granted summary judgment to all SBCC officials except Appellant. Appellant filed a timely interlocutory appeal, alleging that the district court erred because the undisputed material facts showed Appellant was not deliberately indifferent to a substantial risk of harm to Plaintiff. The First Circuit dismissed the appeal, holding that Appellant's challenge rested on factual, rather than legal, grounds, and therefore, this Court lacked appellate jurisdiction. View "Norton v. Rodrigues" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the trial court's grant of summary judgment without addressing its legal merit, holding that the trial court's recital in its final summary judgment order that it considered "the pleadings, evidence, and arguments of counsel" included a late-filed response and attached evidence.Plaintiff sued Defendant alleging that she had been sexually assaulted at work. Defendant moved for summary judgment, presenting traditional and no evidence grounds. The trial court granted the motion. On remand from the Supreme Court, the court of appeals affirmed, concluding that Plaintiff failed to file a timely response to the no-evidence motion and that the trial court did not consider the late-filed response. The court of appeals declined to consider the evidence that Defendant had attached to its combined motion because no timely response pointed out a fact issue raised by that evidence. The Supreme Court reversed, holding (1) the trial court's recital that it considered the "evidence and arguments of counsel," without limitation, was an "affirmative indication" that the trial court considered Plaintiff's response and the evidence attached to it; and (2) therefore, the court of appeals should have considered that evidence as well in its review of the trial court's summary judgment. View "B.C. v. Stake N Shake Operations, Inc." on Justia Law

The Fifth Circuit reversed and vacated the district court's order denying vacatur of sealing orders. The court held that the decision denying vacatur of the sealing orders is appealable under the collateral order doctrine, because the decision is conclusive; the decision addresses important and unsettled questions of law concerning the Louisiana Public Records Law and appellants' First Amendment and common law rights to access settlement agreement information contained in a sealed court recording and sealed minutes, particularly where a minor's privacy interests are involved; the subject of the decision is completely separable from the merits of the litigation; and the decision would be effectively unreviewable on appeal from final judgment.On the merits, the court held that the district court abused its discretion in denying appellants' motion for vacatur by relying on erroneous conclusions of law and misapplying the law to the facts. In this case, the settlement agreement involves public officials or parties of a public nature and matters of legitimate public concern, and it does not appear that the district court weighed as a factor in favor of disclosure the presumption of the public's right of access. View "Bradley v. Ackal" on Justia Law

The plaintiffs, current and former inmates of the Illinois Department of Corrections (IDOC), have been diagnosed with hepatitis C. They filed suit against IDOC, Wexford (which provides inmate health services) and doctors more than 10 years ago after fruitless efforts to receive treatment for their disease while incarcerated. Their 42 U.S.C. 1983 complaint alleges that the diagnostic and treatment protocols for IDOC inmates with hepatitis C violate the Eighth and Fourteenth Amendments.The Seventh Circuit reversed the grant of class certification and vacated a preliminary injunction. After discussing numerosity and commonality of facts and issues, the court noted that the district court failed to name a class representative or explain its omission, leaving no way to assess the adequacy of representation. On the assumption that the court would have accepted the proposed representatives, the record does not reveal whether they would be adequate. The lack of a named representative also makes it impossible to find typicality--that the “claims or defenses of the representative parties are typical of the claims or defenses of the class.” The individual plaintiffs have not shown that they are likely to suffer irreparable harm absent the preliminary injunction, so it was error to grant injunctive relief. View "Orr v. Shicker" on Justia Law

Aliens who lived in the U.S. committed drug crimes and were ordered removed. Neither moved to reopen his removal proceedings within 90 days, 8 U.S.C. 1229a(c)(7)(C)(i). Each later unsuccessfully asked the Board of Immigration Appeals to reopen their removal proceedings, arguing equitable tolling. Both had become eligible for discretionary relief based on judicial and Board decisions years after their removal. The Fifth Circuit denied their requests for review, holding that under the Limited Review Provision, 8 U.S.C. 1252(a)(2)(D), it could consider only only “constitutional claims or questions of law.”The Supreme Court vacated. The Provision’s phrase “questions of law” includes the application of a legal standard to undisputed or established facts. The Fifth Circuit had jurisdiction to consider claims of due diligence for equitable tolling purposes. A strong presumption favors judicial review of administrative action and a contrary interpretation of “questions of law” would result in a barrier to meaningful judicial review. The Provision’s statutory context, history, and precedent contradict the government’s claim that “questions of law” excludes the application of the law to settled facts. Congress has consolidated virtually all review of removal orders in one proceeding in the courts of appeals; the statutory history suggests it sought an “adequate substitute” for habeas review. If “questions of law” in the Provision does not include the misapplication of a legal standard to undisputed facts, then review would not include an element that was traditionally reviewable in habeas proceedings. View "Guerrero-Lasprilla v. Barr" on Justia Law

ESN, an African-American-owned television-network operator, sought to have cable television conglomerate Comcast carry its channels. Comcast refused, citing lack of demand, bandwidth constraints, and a preference for different programming. ESN alleged that Comcast violated 42 U.S.C. 1981, which guarantees “[a]ll persons . . . the same right . . . to make and enforce contracts . . . as is enjoyed by white citizens.” The Ninth Circuit reversed the dismissal of the suit, holding that ESN needed only to plead facts plausibly showing that race played “some role” in the decision-making process.The Supreme Court vacated. A section 1981 plaintiff bears the burden of showing that the plaintiff’s race was a but-for cause of its injury; that burden remains constant over the life of the lawsuit. The statute’s text suggests but-for causation and does not suggest that the test should be different in the face of a motion to dismiss. When the “motivating factor” test was added to Title VII in the Civil Rights Act of 1991, Congress also amended section 1981 without mentioning “motivating factors.” The burden-shifting framework of McDonnell Douglas provides no support for the reading ESN seeks. The court of appeals should determine how ESN’s amended complaint fares under the proper standard. View "Comcast Corp. v. National Association of African-American Owned Media" on Justia Law

Bennett was assigned to Cook County Jail Division 10, which houses detainees who need canes, crutches, or walkers. He filed suit under the Americans with Disabilities Act, 42 U.S.C. 12131–34, and the Rehabilitation Act, 29 U.S.C.794, alleging that Division 10 lacks grab bars and other necessary fixtures. Bennett claims that he fell and was injured. He unsuccessfully sought to represent a class. The court reasoned that the appropriate accommodation of any detainee’s situation depends on personal characteristics, so common questions do not predominate under FRCP 23(b)(3). Bennett proposed an alternative class to avoid person-specific questions, contending that Division 10, which was constructed in 1992, violates 28 C.F.R. 42.522(b)'s requirement that as of “1988 … construction[] or alteration of buildings” must comply with the Uniform Federal Accessibility Standards. The Standards require accessible toilets to have grab bars nearby and accessible showers to have mounted seats. The district court rejected this proposal, reasoning that to determine whether the Structural Standards control, thereby mooting the reasonable accommodation inquiry, would require a ruling on the merits, which would “run[] afoul of the rule against one-way intervention.”The Seventh Circuit vacated. The "view that a class cannot be certified unless the plaintiff has already prevailed on the central legal issue is a formula for one-way intervention rather than a means to avoid it." Bennett proposes a class that will win if the Standards apply and were violated, to detainees’ detriment and otherwise will lose. View "Bennett v. Dart" on Justia Law

Petitioner Christynne Lili Wrene Wood contacted the California Department of Fair Employment and Housing (DFEH) to report alleged gender discrimination by her Crunch fitness club, which was owned and operated by CFG Jamacha, LLC and John Romeo (collectively, Crunch). After an investigation, DFEH filed a lawsuit against Crunch alleging unlawful discrimination on the basis of gender identity or expression (Wood intervened as a plaintiff in the lawsuit). During discovery, Crunch requested that Wood produce all communications with DFEH relating to Crunch. As relevant here, Wood refused to produce one such communication, a prelitigation email she sent to DFEH lawyers regarding her DFEH complaint, on the grounds of attorney-client privilege. Crunch moved to compel production of the email, and the trial court granted the motion. Wood petitioned the Court of Appeal for a writ of mandate, arguing the trial court erred by overruling her objection based on the attorney-client privilege and compelling production of the email. The Court summarily denied the petition. The California Supreme Court granted review and transferred the matter back to the appellate court with directions "to vacate [our] order denying mandate and to issue an order directing the superior court to show cause why the relief sought in the petition should not be granted." The Court of Appeal issued the order to show cause as directed, and these proceedings followed. After further review, the Court concluded Wood did not show the attorney-client privilege applied to the email at issue. "DFEH lawyers have an attorney-client relationship with the State of California. Wood has not shown DFEH lawyers formed an attorney-client relationship with her. As such, any communications between Wood and DFEH lawyers were not made in the course of an attorney-client relationship and were not privileged." Therefore, the petition for mandamus relief was denied. View "Wood v. Super. Ct." on Justia Law

Donald and Lauretta Bauer purchased land from Donald’s parents and executed promissory notes and a mortgage. When Donald’s parents died, their interest in the notes transferred to Donald's siblings, who sought foreclosure. A state court entered a foreclosure judgment and a deficiency judgment. No judicial sale occurred. The Bauers tried to redeem the property by satisfying the judgment. The foreclosure plaintiffs issued citations to discover assets and sought additional interest. The state court found that the Bauers owed an additional $33,782.96 in interest. The Bauers paid; the plaintiffs filed a satisfaction of judgment. The Bauers then sued, alleging tampering with evidence and abuse of process by seeking to extort money through the issuance of citations to discover assets. The state appellate court upheld the dismissal of the case.The Bauers filed a federal suit, 42 U.S.C. 1983, alleging that the defendants, including the state-court judge, conspired to introduce a forged document into evidence during the foreclosure trial and that the judge and the clerk allowed the plaintiffs to issue baseless citations to discover assets. The district court dismissed the case under the Rooker-Feldman doctrine, which precludes federal district-court jurisdiction “over cases brought by state-court losers challenging state-court judgments rendered before the district court proceedings commenced.” The Seventh Circuit affirmed, rejecting the Bauers’ argument that they did not seek to set aside the state court’s order or judgment but only mean to challenge the “collection practices” of the defendants and their collusion. Any finding in favor of the Bauers would require the federal court to contradict the state court’s orders. View "Bauer v. Koester" on Justia Law