Justia Civil Rights Opinion Summaries

The case involves the American Alliance for Equal Rights (the Alliance), a membership organization dedicated to ending racial classifications and preferences in America, and Fearless Fund Management, LLC (Fearless), a venture capital fund that invests in businesses led by women of color. Fearless organized the "Fearless Strivers Grant Contest," a funding competition open only to businesses owned by black women. The Alliance, representing several members who wished to participate in the contest but were not black women, sued Fearless, alleging that the contest violated 42 U.S.C. § 1981, which prohibits private parties from discriminating on the basis of race when making or enforcing contracts.The district court denied the Alliance's request for a preliminary injunction to prevent Fearless from closing the application process. The court concluded that the Alliance had standing to sue and that § 1981 applied to Fearless's contest. However, it also concluded that the First Amendment "may bar" the Alliance's § 1981 claim on the ground that the contest constitutes expressive conduct, and that the Alliance hadn't demonstrated that it would suffer irreparable injury.The United States Court of Appeals for the Eleventh Circuit held that the Alliance has standing and that preliminary injunctive relief is appropriate because Fearless's contest is substantially likely to violate § 1981, is substantially unlikely to enjoy First Amendment protection, and inflicts irreparable injury. The court affirmed the district court's determination that the Alliance has standing to sue but reversed its decision and remanded with instructions to enter a preliminary injunction. View "American Alliance for Equal Rights v. Fearless Fund Management, LLC, et al" on Justia Law

The case involves a group of former detainees at the Medium Security Institution (MSI) in St. Louis, who alleged that they were subjected to inhumane conditions in violation of the Eighth and Fourteenth Amendments. They sought to represent classes of pre-trial and post-conviction detainees, asserting that both categories of detainees were subjected to poor physical conditions and inadequate operations. After the district court denied their first motion to certify, the plaintiffs returned with new proposed classes and renewed their motion. The district court granted the renewed motion, and the City of St. Louis appealed.The district court had initially denied the plaintiffs' motion to certify four classes, citing the open-ended class periods and the City's undisputed improvements to conditions at MSI over time. However, the court suggested that a more focused claim covering a more discrete time period and a more uniform class might be appropriate for class certification. In response, the plaintiffs filed a renewed motion for class certification, proposing four new, more narrowly defined classes. The district court granted the renewed motion, certifying the four new classes.The City of St. Louis appealed the district court's decision to the United States Court of Appeals for the Eighth Circuit, challenging both the decision to certify the classes and several of its procedural aspects. The appellate court reversed the certification of the classes and remanded the case for further proceedings. The court found that the district court had abused its discretion in certifying the classes, as the classes were not "sufficiently cohesive to warrant adjudication by representation." The court also found that the district court had erred in describing the standard for liability and had failed to conduct a rigorous analysis of the requirements for class certification. View "Cody v. City of St. Louis" on Justia Law

The case involves a defamation lawsuit filed by Louis M. Bouvier, Jr., Karen Andrea Niehans, Samuel R. Niehans, and Joseph D. Golden against William Clark Porter, IV, Holtzman Vogel Josefiak Torchinsky PLLC, Steve Roberts, Erin Clark, Gabriela Fallon, Steven Saxe, and the Pat McCrory Committee Legal Defense Fund. The plaintiffs were accused of voting in two states in an election protest filed by the defendants. The plaintiffs claimed that these accusations, which were later proven to be false, defamed them and damaged their reputations.The case was initially heard in the Superior Court, Guilford County, where the plaintiffs' motion for summary judgment was granted as to the defendants' affirmative defenses, and the defendants' motion for summary judgment was denied. The case was then appealed to the Court of Appeals, which affirmed in part and reversed in part the lower court's decision. The Court of Appeals held that the absolute privilege, which protects individuals from defamation claims for statements made in the course of a judicial or quasi-judicial proceeding, applied to the election protests. However, the court also introduced a "participation" requirement, stating that the privilege only applied to those who participated as a party, counsel, or witness in the proceeding.The case was then reviewed by the Supreme Court of North Carolina. The court held that the absolute privilege broadly protects all individuals involved in any aspect of election protests from defamation claims. The court rejected the "participation" requirement introduced by the Court of Appeals, stating that the privilege applies to the occasion, not the individual. The court concluded that the defendants were protected by the absolute privilege and were therefore entitled to summary judgment. The court reversed the decision of the Court of Appeals and remanded the case to the lower court for dismissal with prejudice. View "Bouvier v. Porter" on Justia Law

Cory Sessler, a religious preacher, and his group were preaching loudly at a commercial festival in Davenport, Iowa. The festival was held in a fenced-off area of the city's downtown streets and sidewalks, which were typically considered a "traditional public forum". However, during the festival, pedestrian access was controlled and vendors had rented spaces to sell goods. Sessler and his group, who were not paying vendors, were asked by police officers to relocate outside the fences due to complaints from nearby vendors. Sessler later sued the officers and the city, alleging a violation of his First Amendment rights.The district court denied Sessler's request for a preliminary injunction, a decision which was affirmed by the appellate court. After discovery, the district court granted summary judgment to the defendants, concluding that the officers did not violate Sessler's rights and that they were protected by qualified immunity. The court also granted summary judgment to the city on the official-policy claims.The United States Court of Appeals for the Eighth Circuit agreed that qualified immunity applied to the claims against the officers. The court found that it was unclear whether the fenced-off city streets and sidewalks remained a "traditional public forum" or served as a less-protected "limited public forum" during the festival. The court also found that no reasonable trier of fact could conclude that the officers' actions were anything but content neutral or that such actions were unreasonable. The court affirmed the judgment of the district court. View "Sessler v. City of Davenport, Iowa" on Justia Law

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

The plaintiff, Ronald Hittle, was the Fire Chief for the City of Stockton, California. He alleged that he was terminated from his position due to his religion, specifically his attendance at a religious leadership event. The City of Stockton, former City Manager Robert Deis, and former Deputy City Manager Laurie Montes were named as defendants. The City had hired an independent investigator, Trudy Largent, to investigate various allegations of misconduct against Hittle. Largent's report sustained almost all of the allegations, including Hittle's use of city time and a city vehicle to attend a religious event, his failure to properly report his time off, potential favoritism of certain Fire Department employees based on a financial conflict of interest not disclosed to the City, and endorsement of a private consultant's business in violation of City policy.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. The court also found that Hittle failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that employment discrimination claims under Title VII and the California Fair Employment and Housing Act are analyzed under the McDonnell Douglas burden-shifting framework. The court concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants. The court found that the district court's grant of summary judgment in the defendants' favor was appropriate where the defendants' legitimate, non-discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual. View "HITTLE V. CITY OF STOCKTON" on Justia Law

The case involves two attorneys, Jeffrey Peterzalek and Molly Weber, who sought to quash subpoenas for their depositions in a civil rights case brought by Charis Paulson against her employers, the State of Iowa and the Iowa Department of Public Safety (DPS). Paulson alleged gender-motivated discrimination and retaliation. Weber had represented DPS in its response to Paulson's civil rights complaint before the Iowa Civil Rights Commission (ICRC), while Peterzalek had represented DPS and its leaders in various other matters over the years. The district court declined to quash the subpoenas but ordered that the depositions be sealed. The attorneys then filed a petition for writ of certiorari with the Supreme Court of Iowa.The Supreme Court of Iowa granted the writ and retained the case. The attorneys argued that the court should adopt the Shelton test, which narrowly limits the circumstances in which opposing counsel may be deposed. They also argued that they should not be deposed or, alternatively, that substantial limitations should be imposed if their depositions were allowed.The Supreme Court of Iowa agreed with the attorneys' argument to adopt the Shelton test. Applying the test, the court concluded that Weber's deposition should be quashed as she was opposing counsel in the ongoing dispute and the information sought could be obtained by other means and was protected by the work-product doctrine. However, the court affirmed the district court's refusal to quash the subpoena for Peterzalek's deposition, as he was not opposing counsel in the ongoing dispute. The court remanded the case for further proceedings, including the entry of an order quashing the subpoena for Weber's deposition. View "Peterzalek v. Iowa District Court for Polk County" on Justia Law

The case involves Terrance Henderson, an inmate in the Virginia Department of Corrections, who filed a lawsuit seeking to prevent prison officials from deducting money from his prison trust account as restitution for an assault he committed on a fellow inmate in 2015. He also sought to compel the return of money already taken. Henderson claimed that the nearly six-year gap between the guilt-finding phase of his disciplinary hearing and his reconvened restitution hearing violated principles of due process.The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants on Henderson's 42 U.S.C. § 1983 claim and dismissed his Virginia state-law claim without prejudice. Henderson appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed that Henderson had a protected property interest in his prison trust account. However, the court found that even if the nearly six-year delay between the guilt-finding phase and the restitution hearing violated due process, the error was harmless because no evidence that could have aided Henderson's ability to contest the amount of restitution was lost due to the delay. The court also affirmed the district court's decision to decline to exercise supplemental jurisdiction over the remaining state-law claim. View "Henderson v. Harmon" on Justia Law

The case involves two petitioners, Halima Culley and Lena Sutton, who loaned their cars to others who were subsequently arrested for drug-related offenses. The cars were seized under Alabama's civil forfeiture law, which allowed for the seizure of a car "incident to an arrest" as long as the state promptly initiated a forfeiture case. The State of Alabama filed forfeiture complaints against the cars 10 and 13 days after their seizure, respectively. While the forfeiture proceedings were pending, Culley and Sutton each filed purported class-action complaints in federal court, claiming that state officials violated their due process rights by retaining their cars during the forfeiture process without holding preliminary hearings.The Eleventh Circuit affirmed the dismissal of the petitioners' claims, holding that a timely forfeiture hearing affords claimants due process and that no separate preliminary hearing is constitutionally required. The petitioners argued that the Due Process Clause requires a separate preliminary hearing before the forfeiture hearing.The Supreme Court of the United States affirmed the Eleventh Circuit's decision. The Court held that in civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing. The Court's decision was based on its precedents, which established that a timely forfeiture hearing satisfies due process in civil forfeiture cases. The Court also noted that historical practice reinforces its conclusion that due process does not require preliminary hearings in civil forfeiture cases. View "Culley v. Marshall" on Justia Law

A prisoner, Khalfan Khamis Mohamed, alleged that officials from the Federal Bureau of Prisons (BOP) beat him while others watched. He brought claims under the Eighth Amendment for excessive force and failure to intervene, arguing that the BOP officials' actions gave him a cause of action under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The BOP officials moved to dismiss the claims, arguing that Bivens did not extend to Mohamed's claims. The district court denied their motion.The BOP officials appealed the district court's decision, seeking interlocutory review. However, the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction. The court found that the BOP officials had not shown that the district court's order extending Bivens to Mohamed's Eighth Amendment excessive force and failure to intervene claims qualified for interlocutory review under the collateral order doctrine. The court noted that the BOP officials bore the burden of establishing the court's appellate jurisdiction and had failed to convince the court to create an exception to the final judgment rule for all district court orders extending a Bivens remedy. The court also noted that the BOP officials had not shown that Bivens extension orders were effectively unreviewable after final judgment and therefore had not satisfied the third Cohen factor. View "Mohamed v. Jones" on Justia Law