Justia Civil Rights Opinion Summaries

The Fourth Circuit reversed the district court's determination that plaintiff was required to wait longer than 180 days to commence a civil action under Title VII and the Rehabilitation Act after amending his initial administrative complaint before the relevant agency. The court held that the text of Title VII, as well as the legislative context and purpose, plainly states that a claimant may commence a civil action 180 days from "the filing of the initial charge." Accordingly, the court remanded for further proceedings. View "Stewart v. Iancu" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of plaintiff's action challenging various aspects of the Credit Union's website under the Americans with Disabilities Act. Plaintiff, a blind individual, alleged that his attempt to access the Credit Union's website was hindered in various ways. The court held that plaintiff, who is barred by law from making use of the Credit Union's services may not sue under the ADA for an allegedly deficient website. In this case, plaintiff was not eligible for membership in the Credit Union where he does not work for the Department of Labor and never has in the past. Accordingly, the court concluded that plaintiff's injury was not concrete, particularized, or immediately threatening. View "Griffin v. Department of Labor Federal Credit Union" on Justia Law

An April 2016 Chicago Police Accountability Task Force report indicated that the Chicago Police Department’s “response to violence is not sufficiently imbued with Constitutional policing tactics.” In January 2017, the U.S. Department of Justice released a report concluding that the Chicago Police Department exhibits a pattern or practice of the unconstitutional use of force. In August 2017, the state sued the city, alleging that the Chicago Police Department’s use-of-force policies and practices violate the federal constitution and Illinois law. Two days later, the parties moved to stay the proceedings while they negotiated a consent decree. Almost immediately, the Fraternal Order of Police, Lodge 7, publicly opposed any consent decree, citing fears that the decree might impair its collective bargaining rights. For months, the Lodge monitored the ongoing negotiations and met informally with the state’s representatives. The Lodge nonetheless waited until June 2018, to file a motion to intervene in the suit. The district court denied the motion to intervene as untimely. The Seventh Circuit affirmed. The Lodge knew from the beginning that a consent decree might impact its interests but delayed its motion for nearly a year; its allegations of prejudice are speculative. View "Illinois v. Chicago" on Justia Law

Plaintiff, on behalf of himself and seven others, filed suit alleging that a Walker County Sheriff's deputy arrested them without a warrant for undisclosed crimes, that they were detained in the county jail, and that they were denied a judicial determination on whether probable cause supported their arrests in violation of the Fourth Amendment. The Fourth Circuit vacated the district court's judgment, holding that it could not identify from the allegations of the complaint, answer, or motion to dismiss, which of the magistrates purportedly denied plaintiffs' Fourth Amendment rights. Therefore, the court remanded for further proceedings. View "Colburn v. Odom" on Justia Law

Petitioners, Iraqi nationals, were ordered removed years ago because of criminal offenses they committed in the U.S. Iraq refused to repatriate them, so Petitioners remained under orders of supervision by U.S. Immigration and Customs Enforcement. In 2017, Iraq began to cooperate and removal of Iraqi nationals resumed. In April 2017 ICE conducted a removal by charter flight to Iraq, scheduling a second charter for June and arresting more than 200 Iraqi nationals. Iraq declined to issue requisite travel documents and would accept only Iraqi nationals who had unexpired passports and were returning on commercial flights. Petitioners filed a putative class action habeas petition on behalf of all Iraqi nationals with final orders of removal, who have been, or will be, arrested and detained as a result of Iraq’s recent decision,” seeking a TRO or stay of removal, pending arguments on allegedly changed country conditions. Under 8 U.S.C. 1252(g), immigration courts hold exclusive jurisdiction over removal proceedings. The district court stayed the final removal orders and concluded that it had jurisdiction to hear Petitioners’ claims as an as-applied constitutional violation of the Suspension Clause. The Sixth Circuit vacated. The district court lacked the jurisdiction. Rejecting Petitioners’ argument the petition-for-review process is constitutionally inadequate as an alternative to habeas review, the court noted that Petitioners had years to file motions to reopen and the administrative scheme provides multiple avenues to stay removal while pursuing relief. The court was not merely interpreting a statute: it “created out of thin air a requirement for bond hearings that does not exist in the statute; and adopted new standards that the government must meet.” View "Hamama v. Adducci" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his motion for reconsideration of an order that set a partial filing fee of twenty dollars with respect to Appellant’s pro se civil complaint in tort against four persons, holding that the circuit court did not err when it denied the motion for reconsideration.The circuit court denied Appellant’s request for reconsideration because it was not timely filed pursuant to Ark. R. Civ. P. 60(a). The Supreme Court affirmed, holding that because Appellant did not ask for reconsideration of the circuit court’s order until 155 days after the order had been entered, Appellant’s motion was untimely, and therefore, the circuit court did not err in denying it. View "Whitney v. Jenkins" on Justia Law

The Supreme Court remanded the instant appeal of the circuit court’s order denying Appellant’s pro se petition for leave to proceed in forma pauperis in which Appellant sought to proceed with a civil-rights complaint against certain Arkansas Department of Correction (ADC) employees, holding that the order was not sufficient for review, and therefore, the case must be remanded for findings of fact.The order at issue found that Appellant was not indigent and must pay the statutory filing fee for the action. The Supreme Court held (1) contrary to the assertion of Appellee, the director of the ADC, the order was appealable; and (2) the cause must be remanded for a supplemental order on the in forma pauperis petition that contains adequate findings of fact on the issue of whether Appellant was indigent. View "Berger v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court’s order dismissing Appellant’s counterclaim for declaratory and injunctive relief against the Arkansas Department of Human Services (DHS), holding that the Court was unable to address the sole issue raised by Appellant on appeal.On appeal, Appellant argued that the circuit court lacked jurisdiction to consider her counterclaim because DHS was entitled to sovereign immunity and that her case should be dismissed without prejudice due to lack of jurisdiction. The Supreme Court affirmed, holding that Appellant failed to preserve her sovereign-immunity argument, and therefore, the circuit court properly dismissed the counterclaim. View "Wilson v. Arkansas Department of Human Services" on Justia Law

In this case against members of the Rhode Island Board of Bar Examiners the First Circuit reversed the district court’s grant of attorneys’ fees in favor of Plaintiff and affirmed the court’s dismissal of Plaintiff’s amended complaint, holding that Plaintiff’s supposed “prevailing party” status was not justified.Plaintiff, an individual with attention deficit/hyperactivity disorder and anxiety, filed suit against members of the Board challenging the Board’s denial of his request for certain accommodations to assist him in taking the Rhode Island bar exam. The district court issued a temporary restraining order (TRO) requiring the Board to permit Plaintiff the requested accommodations, dismissed Plaintiff’s amended complaint, and allowed Plaintiff’s motion for attorneys’ fees. On review, the First Circuit held (1) Plaintiff’s success in gaining a TRO did not warrant an award of attorneys’ fees; and (2) the district court’s decision to allow the Board’s motion to dismiss the damage claim in the complaint was correct. View "Sinapi v. Rhode Island Board of Bar Examiners" on Justia Law

Petitioner Kyle Guillemette challenged a determination by the Administrative Appeals Unit (AAU) of the New Hampshire Department of Health and Human Services (DHHS) that the notice requirements set forth in RSA 171-A:8, III (2014) and New Hampshire Administrative Rules, He-M 310.07 did not apply when Monadnock Worksource notified Monadnock Developmental Services of its intent to discontinue providing services to petitioner because that act did not constitute a “termination” of services within the meaning of the applicable rules. Petitioner received developmental disability services funded by the developmental disability Medicaid waiver program. MDS was the “area agency,” which coordinated and developed petitioner’s individual service plan. Worksource provides services to disabled individuals pursuant to a “Master Agreement” with MDS. Worksource began providing day services to the petitioner in August 2012. On March 31, 2017, Worksource notified MDS, in writing, that Worksource was terminating services to petitioner “as of midnight on April 30.” The letter to MDS stated that “[t]he Board of Directors and administration of . . . Worksource feel this action is in the best interest of [the petitioner] and of [Worksource].” Petitioner’s mother, who served as his guardian, was informed by MDS of Worksource’s decision on April 3. The mother asked for reconsideration, but the Board declined, writing that because the mother “repeatedly and recently expressed such deep dissatisfaction with our services to your son, the Board and I feel that you and [petitioner] would be better served by another agency . . . .” Thereafter, petitioner filed a complaint with the Office of Client and Legal Services alleging that his services had been terminated improperly and requesting that they remain in place pending the outcome of the investigation of his complaint. Because the New Hampshire Supreme Court concluded that the AAU’s ruling was not erroneous, it affirmed. View "Petition of Kyle Guillemette" on Justia Law