Justia Civil Rights Opinion Summaries

Dr. Jennifer Seed, a former employee of the Environmental Protection Agency (EPA), filed a lawsuit against the EPA and the United States, alleging age discrimination. Seed claimed that she was involuntarily demoted to a junior position as older managers were replaced with younger employees. The district court granted summary judgment in favor of the EPA, concluding that Seed had not provided sufficient evidence to support her claim of age discrimination.The district court's decision was based on its finding that Seed had not provided direct evidence of discriminatory intent that would entitle her to a trial, nor had she provided indirect evidence that would give rise to an inference of discrimination. The court also found that Seed had not shown that she was treated less favorably than younger employees after her reassignment or that her treatment was based on her age.On appeal, the United States Court of Appeals for the District of Columbia Circuit dismissed Seed's appeal, ruling that the court lacked jurisdiction to address the merits of her reassignment claims because she lacked standing under Article III of the United States Constitution. The court found that Seed had not demonstrated that a favorable court decision would likely redress her claimed injuries. The court therefore remanded the case to the district court with instructions to vacate the grant of summary judgment and to dismiss the reassignment claim for lack of standing. View "Seed v. EPA" on Justia Law

The case involves Christine Savage, a police officer who filed a lawsuit against the Neptune Township Police Department and others for sexual harassment, sex discrimination, and retaliation. The parties entered into a settlement agreement in 2014, which included a non-disparagement clause. Savage filed a second lawsuit in 2016, alleging continued and intensified discrimination, harassment, and retaliation. The parties entered into another settlement agreement in 2020, which also included a non-disparagement clause. After a television interview with Savage aired in 2020, the defendants claimed that Savage violated the non-disparagement provision of the settlement agreement.The trial court granted the defendants' motion to enforce the second settlement agreement, finding that the Law Against Discrimination (LAD) barred only non-disclosure and confidentiality agreements, and that Savage violated a non-disparagement clause. The Appellate Division affirmed in part and reversed in part, finding the non-disparagement clause enforceable but holding that Savage had not violated it.The Supreme Court of New Jersey held that the non-disparagement clause in the settlement agreement is against public policy and cannot be enforced. The court found that the LAD protects Savage’s statements. The court concluded that the non-disparagement clause in the agreement directly conflicts with the LAD as it encompasses and would bar speech the statute protects. The court reversed in part, affirmed in part, and remanded the case. View "Christine Savage v. Township of Neptune" on Justia Law

In this case, Austin Thompson Hughes, a former police officer and Uber driver, reported a drunk driver swerving across a highway in Houston. After the drunk driver crashed, Hughes, still on the phone with 911, performed a citizen's arrest in accordance with Texas law. However, when police officers arrived at the scene, they released the drunk driver and arrested Hughes, charging him with a felony for impersonating a peace officer. Hughes spent thousands of dollars defending against these charges before they were dropped by the City of Houston. Hughes then filed a § 1983 suit against the two officers who arrested him.The case was initially heard in the United States District Court for the Southern District of Texas, where the officers moved to dismiss Hughes's complaint, asserting qualified immunity. The district court denied the officers' motions, leading to an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision, denying the officers' qualified immunity. The court found that Hughes had sufficiently pleaded that the officers violated his Fourth Amendment rights by arresting and prosecuting him without probable cause because they included material misstatements and omissions in their warrant affidavit and materials. The court also found that a corrected warrant affidavit could not have established probable cause to arrest and prosecute Hughes. The court concluded that no reasonable officer could have suspected Hughes committed a felony, given the inconsistencies in the drunk driver's statement, the driver's obvious intoxication, and the evidence supporting Hughes's account. View "Hughes v. Garcia" on Justia Law

The case involves a group of petitioners who challenged a trial court's decision to establish a 200-foot buffer zone around the Norfolk County Superior Court House during the trial of a high-profile murder case. The buffer zone was created in response to protests and demonstrations near the courthouse, which the Commonwealth argued could jeopardize a fair trial. The petitioners, who sought to intervene in the trial court proceedings to oppose the buffer zone, argued that it infringed on their First Amendment rights.The trial judge allowed the Commonwealth's motion for a buffer zone, albeit reducing it from the requested 500 feet to 200 feet. The judge denied the petitioners' motion to intervene, arguing that the buffer zone was necessary to ensure a fair trial and to protect jurors and witnesses from potential intimidation or harassment. The petitioners subsequently filed petitions for relief from both the buffer zone order and the denial of their motion to intervene.The single justice of the Supreme Judicial Court denied the petitions, concluding that the trial judge's decision was an ordinary procedural ruling and did not warrant the court's extraordinary power of general superintendence. The single justice also found that the buffer zone met the "reasonable restriction" requirements, being content-neutral, narrowly tailored to serve a significant governmental interest, and leaving open ample alternative channels for communication.The Supreme Judicial Court affirmed the single justice's decision, rejecting the petitioners' argument that the buffer zone order should be analyzed under strict scrutiny as a prior restraint on speech. The court found that the buffer zone did not forbid protestors from expressing their message, but merely restricted where they could do so. The court also noted that the petitioners failed to provide sufficient evidence to establish that the buffer zone extended onto public sidewalks or other areas constituting a public forum. View "Spicuzza v. Commonwealth" on Justia Law

Leslie Atkinson purchased a 2003 Chevrolet Avalanche through a retail installment sales contract, which granted the seller a security interest in the vehicle. The seller assigned the sales contract and the security interest to Credit Acceptance Corporation. When Atkinson defaulted on her payments, Credit Acceptance hired Carolina Repo to repossess the vehicle. During the repossession, Atkinson attempted to drive off in the vehicle, leading to a confrontation with the Carolina Repo representative. The representative called the Harnett County Sheriff’s Office for assistance, and Deputy Brent Godfrey arrived on the scene. Godfrey ordered Atkinson out of the vehicle so that the Carolina Repo representative could repossess it.Atkinson sued Godfrey and Sheriff Wayne Coats under 42 U.S.C. § 1983, alleging violations of the Fourth, Fifth, and Fourteenth Amendments. She claimed that Godfrey, in his individual capacity, violated her Fourth Amendment right against unreasonable seizures of property by facilitating Carolina Repo’s repossession. She also alleged that Coats, in his official capacity as the sheriff, failed to train officers and created policies that deprived her of the Fourth Amendment’s protection against unreasonable seizures of property.The defendants moved to dismiss Atkinson’s § 1983 claim, asserting that Atkinson did not allege facts showing they acted under color of law, that Godfrey was entitled to qualified immunity, and that, without an underlying constitutional violation, Atkinson failed to bring an actionable claim against the Sheriff’s Office through Coats in his official capacity. The district court denied the motion, finding it could not determine as a matter of law that Godfrey’s actions did not constitute state action, that Godfrey was entitled to qualified immunity, and that the Sheriff’s Office’s liability could be ruled out. Godfrey and Coats appealed the district court’s denial of their motion.The United States Court of Appeals for the Fourth Circuit reversed the district court’s denial of Godfrey’s motion to dismiss based on qualified immunity. The court found that neither the Supreme Court, the Fourth Circuit, the highest court of North Carolina, nor a consensus of other circuit courts of appeals had determined that conduct similar to that of Godfrey was unconstitutional. Therefore, the right alleged to be violated was not clearly established. The court remanded the case with instructions to grant Godfrey’s motion to dismiss. The court dismissed the appeal with respect to the claim against Coats, as the issues it presented were not inextricably intertwined with the resolution of the qualified immunity issues. View "Atkinson v. Godfrey" on Justia Law

A student, John Doe, through his mother, Jane Doe, filed a lawsuit against Rocky Mountain Classical Academy (RMCA), Nicole Blanc, and Cullen McDowell, alleging that the school's dress code, which prohibited boys from wearing earrings, violated his rights under the Fourteenth Amendment's Equal Protection Clause and Title IX. The plaintiff also claimed that the school retaliated against him for complaining about sex discrimination.The United States District Court for the District of Colorado dismissed the plaintiff's claims, applying the "comparable burdens" test from the Seventh Circuit's decision in Hayden ex rel. A.H. v. Greensburg Cmty. Sch. Corp. The district court found that the dress code imposed comparable burdens on both boys and girls, and therefore did not constitute sex discrimination.On appeal, the United States Court of Appeals for the Tenth Circuit disagreed with the district court's application of the "comparable burdens" test. The appellate court held that the district court should have applied the intermediate scrutiny standard, which requires a sex-based classification to serve important governmental objectives and be substantially related to achieving those objectives. The court found that the plaintiff had stated a claim upon which relief could be granted under both the Equal Protection Clause and Title IX, as the school had not provided an "exceedingly persuasive justification" for its sex-based classification. Therefore, the court reversed the district court's dismissal of the plaintiff's sex discrimination claims.However, the appellate court agreed with the district court's dismissal of the plaintiff's Title IX retaliation claim. The court found that the plaintiff had not stated a plausible claim for retaliation, as the complaint only permitted the inference that the school took disciplinary actions because of the plaintiff's dress code violations. View "Doe v. Rocky Mountain Classical Academy" on Justia Law

Diamond S.J. Enterprise, Inc., which operates a nightclub in San Jose, California, had its license suspended for thirty days by the city following a shooting outside the club. The city held an administrative hearing and found that Diamond had operated its venue in a way that caused the shooting and created a public nuisance, violating San Jose's entertainment business licensing provisions. Diamond filed a complaint in federal court, alleging First Amendment and due process violations.The case was first heard in the United States District Court for the Northern District of California, which dismissed Diamond's claims and granted summary judgment for the City of San Jose. The district court ruled that the challenged provisions did not implicate First Amendment rights and that the city had satisfied due process requirements.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's decision, holding that Diamond's facial attack on the city's public entertainment business licensing provisions failed because the provisions did not give city officials unbridled discretion that created a risk of censorship. The court also held that Diamond failed to state a procedural due process claim, as the licensing scheme provided Diamond with notice, an opportunity to be heard, the ability to present and respond to evidence, and a pre-deprivation appeal, followed by post-deprivation review by the California Superior Court. View "Diamond S.J. Enterprise, Inc. v. City of San Jose" on Justia Law

The case involves a challenge to the provisions of the Bipartisan Safer Communities Act of 2022, which expanded background checks for firearm purchases by individuals aged 18 to 20. The plaintiffs, Ethan McRorey, Kaylee Flores, Gun Owners of America, Inc., and Gun Owners Foundation, argued that the government failed to show a historical analogue for the Act's expanded background checks for this age group. They filed a lawsuit requesting a preliminary injunction after their attempts to purchase shotguns were delayed due to the National Instant Criminal Background Check System (NICS) protocols.The United States District Court for the Northern District of Texas denied the plaintiffs' request for a preliminary injunction. The court reasoned that while adults aged 18 to 20 are protected by the Second Amendment, laws barring the mentally ill and felons from possessing firearms are constitutional, and restrictions to further those ends are presumptively lawful. Therefore, the plaintiffs lacked a substantial likelihood of success on the merits and were not entitled to preliminary relief.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court held that background checks preceding firearm sales are presumptively constitutional, and the plaintiffs failed to rebut that presumption. The court also found that the plaintiffs had not shown that the challenged regulations had been put towards abusive ends or had otherwise rebutted the presumption of lawfulness. The court concluded that a period of 10 days for background checks does not qualify as being put towards abusive ends or as a de facto prohibition on possession. View "McRorey v. Garland" on Justia Law

The case involves three plaintiffs, Xingjian Sun, Xing Zhao, and Ao Wang, who sued their professor, Gary Gang Xu, for various allegations. Sun and Zhao, former students at the University of Illinois at Urbana-Champaign, accused Xu of sexual and emotional abuse. Wang, a professor at Wesleyan University, posted online that Xu had a history of sexually assaulting students. In response, Xu allegedly posted negative comments about Wang and sent a letter to his employer. Xu counterclaimed, asserting a defamation claim against Sun and claims for intentional infliction of emotional distress against all three plaintiffs.The case was tried in the United States District Court for the Central District of Illinois, where a jury found in favor of Xu on all issues and awarded him damages against Sun and Wang. The plaintiffs appealed, arguing that the district court erred in denying their motion for judgment as a matter of law regarding Xu’s intentional infliction of emotional distress counterclaims. They also contended that the district court erred in denying their motion for a new trial, based on the court’s decision to admit evidence that Sun had a relationship with another professor.The United States Court of Appeals for the Seventh Circuit reversed the judgment in favor of Xu on his counterclaim against Wang, finding that no reasonable jury could find Wang's conduct extreme and outrageous under Illinois law. However, the court affirmed the judgment in favor of Xu on his counterclaim against Sun, concluding that a reasonable jury could find that Sun's conduct met the requirements for intentional infliction of emotional distress. The court also affirmed the district court's denial of the plaintiffs' motion for a new trial. View "Sun v. Xu" on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law