Justia Civil Rights Opinion Summaries

Sylvia Gonzalez, a city council member in Castle Hills, Texas, was involved in a campaign to remove the city manager, Ryan Rapelye. She gathered signatures for a petition, which was introduced at a city council meeting. After the meeting, the mayor, Edward Trevino, II, asked Gonzalez for the petition. Gonzalez found the petition in her binder, which she claimed was unintentional. Trevino reported this to the city police, leading to an investigation. A private attorney concluded that Gonzalez likely violated a Texas anti-tampering statute, leading to her arrest. The charges were later dismissed, but Gonzalez claimed this incident led her to step away from politics.Gonzalez filed a lawsuit under 42 U.S.C. §1983 in Federal District Court against Trevino, the police chief, and the private attorney, alleging that her arrest was in retaliation for her role in the petition and violated her First Amendment rights. The District Court denied the defendants' motion to dismiss the complaint, finding that it fell within an exception to the no-probable-cause rule recognized in Nieves. However, the Fifth Circuit reversed this decision, stating that Gonzalez's claim could only fall within the Nieves exception if she provided "comparative evidence" of similarly situated individuals who engaged in the same criminal conduct but were not arrested.The Supreme Court of the United States disagreed with the Fifth Circuit's interpretation of the Nieves exception. The Court found that the Fifth Circuit's requirement for specific comparator evidence was overly restrictive. The Court clarified that to fall within the Nieves exception, a plaintiff must produce objective evidence to prove that his arrest occurred in circumstances where officers typically exercise their discretion not to make arrests. The Court held that Gonzalez's evidence, showing that no one had ever been arrested for similar conduct, was a permissible type of evidence. The Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings. View "Gonzalez v. Trevino" on Justia Law

The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

The case involves Sharon Lewis, an African-American woman who worked as an assistant athletic director for Louisiana State University’s (LSU) football team. Lewis alleges that she experienced and witnessed numerous instances of racist and sexist misconduct from former head football coach Les Miles and that she received complaints of sexual harassment from student workers that she oversaw. In 2013, LSU retained Vicki Crochet and Robert Barton, partners of the law firm Taylor, Porter, Brooks & Phillips LLP, to conduct a Title IX investigation of sexual harassment allegations made against Miles. The report and its contents were kept confidential, and allegations brought by the student complainants were privately settled.The district court dismissed Lewis's Racketeer Influenced and Corrupt Organization Act (RICO) claims against Crochet and Barton because Lewis’s claims were time-barred and she failed to establish proximate causation. On appeal of the dismissal order, a panel of this court affirmed the district court on the grounds that Lewis knew of her injuries from alleged racketeering as early as 2013, and thus the four-year statute of limitations had expired before she filed suit in 2021.The district court ordered Lewis to file a motion to compel addressing the lingering “issues of discoverability and the application of [its Crime-Fraud Exception Order].” The district court denied Crochet and Barton’s motion for a protective order and compelled the depositions of Crochet and Barton and the disclosure of documents drafted during the 2013 investigation. Crochet and Barton timely appealed.The United States Court of Appeals for the Fifth Circuit reversed the district court’s Crime-Fraud Exception Order and remanded for proceedings consistent with this opinion. The court concluded that the district court clearly erred in holding that Lewis established a prima facie case that the Board violated La. R.S. 14:132(B) and that the alleged privileged communications were made in furtherance of the crime and reasonably related to the alleged violation. View "Lewis v. Crochet" on Justia Law

Michael Jones, a pretrial detainee, filed a lawsuit against the City of St. Louis and four city employees, alleging that they held him in custody for eight months after his criminal charges were dismissed and failed to inform him of his right to be released. Jones's lawsuit, filed under 42 U.S.C. § 1983, included claims under both state and federal law. The defendants moved to dismiss all fourteen counts of the lawsuit. The district court dismissed seven counts, leaving no federal due process claims against the individual defendants at issue on appeal. The defendants appealed the denial of their motion to dismiss the remaining counts, arguing that Jones failed to allege plausible constitutional violations and that they were entitled to qualified immunity from damage claims.The United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo, accepting the factual allegations in Jones's First Amended Complaint as true. The court found that Jones failed to allege specific facts of personal involvement in, or direct responsibility for, a deprivation of his constitutional rights by the individual defendants. The court also found that Jones's allegations that the defendants "should have known" that he was incarcerated despite his charges being dismissed failed to state a claim under either the Fourth Amendment or the Due Process Clause.The court reversed the denial of qualified immunity and directed that the remaining counts be dismissed with prejudice. The case was remanded for further proceedings consistent with the court's opinion. The court did not rule on the state law claims of false imprisonment, leaving that for the district court to resolve on remand. View "Jones v. City of St. Louis" on Justia Law

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

The case involves two sets of plaintiffs, Douglas Bienvenu et al. and John Doe et al., who filed lawsuits against two defendants for alleged sexual abuse of minors. The plaintiffs argued that the revival provisions of Section 2 of 2021 La. Acts 322 and Section 2 of 2022 La. Acts 386, which were designed to revive previously prescribed claims related to sexual abuse of minors, were constitutional and should apply retroactively. The defendants, on the other hand, contended that the retroactive application of the amended statute would unconstitutionally deprive them of a vested property right to claim the accrued defense of liberative prescription.The case was initially heard in the 16th Judicial District Court, Parish of St. Martin. The district court ruled in favor of the plaintiffs, overruling the exception of prescription and finding that Act 322, as interpreted by Act 386, was constitutional and applied retroactively to revive all causes of action related to sexual abuse of a minor that previously prescribed under any Louisiana prescriptive period.The Supreme Court of Louisiana granted a rehearing to address the plaintiffs' contention that the original opinion erred in its due process analysis. The court vacated its original opinion and affirmed the district court's judgment. The court held that the legislature's intent to apply the amended provisions of La. R.S. 9:2800.9 retroactively by reviving previously prescribed claims was clearly and explicitly stated in Act 386. The court also held that when a party acquires the right to plead the defense of liberative prescription, that right becomes a vested property right protected by the constitution’s due process guarantees. However, the court found that the revival provision in Act 386 was rationally related to a legitimate government interest and therefore did not violate the due process clause. The case was remanded to the district court for further proceedings consistent with the Supreme Court's opinion. View "Bienvenu v. Defendant 1" on Justia Law

Survivors of the 1921 Tulsa Race Massacre and representatives of the estate of a deceased survivor filed a lawsuit against the City of Tulsa, the Tulsa Regional Chamber, the Board of County Commissioners for Tulsa County, the Sheriff of Tulsa County, and the Oklahoma Military Department. The plaintiffs alleged that the defendants' actions and omissions, beginning with the massacre and continuing to the present day, constituted a public nuisance. They also claimed that the defendants had unjustly enriched themselves by exploiting the massacre for their own economic and political gain.The District Court of Tulsa County dismissed the plaintiffs' claims. It found that the plaintiffs had failed to state a justiciable public nuisance claim and had not proposed a legally cognizable abatement remedy. The court also dismissed the unjust enrichment claim, citing a failure to correct a defective pleading.The plaintiffs appealed to the Supreme Court of the State of Oklahoma. They argued that the district court had erred in dismissing both their public nuisance and unjust enrichment claims. The Supreme Court retained the case for review.The Supreme Court affirmed the district court's decision. It held that the plaintiffs' grievances did not fall within the scope of Oklahoma's public nuisance statute. The court also found that the plaintiffs' allegations did not support a claim for unjust enrichment under the equitable doctrine. The court noted that the plaintiffs' grievances were legitimate but stated that the law did not permit the court to extend the scope of the public nuisance doctrine or the doctrine of unjust enrichment to provide the plaintiffs with the justice they sought. View "Randle v. City of Tulsa" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

Seattle Pacific University (SPU), a religious institution, filed a lawsuit against the Washington Attorney General, alleging First Amendment violations arising from the Attorney General's investigation into the university's employment policies and history under the Washington Law Against Discrimination (WLAD). SPU prohibits employees from engaging in same-sex intercourse and marriage. After receiving complaints, the Attorney General requested documents related to SPU's employment policies, employee complaints, and job descriptions. SPU sought to enjoin the investigation and any future enforcement of WLAD.The district court dismissed the suit, citing lack of redressability and Younger abstention. The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that SPU failed to allege a cognizable injury for its retrospective claims, as the Attorney General's request for documents carried no penalties for non-compliance. However, the court found that SPU had standing for its prospective pre-enforcement injury claims, as SPU intended to continue employment practices arguably proscribed by WLAD, the Attorney General had not disavowed its intent to investigate and enforce WLAD against SPU, and SPU's injury was redressable. The court also held that Younger abstention was not warranted as there were no ongoing enforcement actions or any court judgment. The case was remanded to the district court to consider prudential ripeness. View "SEATTLE PACIFIC UNIVERSITY V. FERGUSON" on Justia Law

The case revolves around the fatal shooting of Jabari Asante-Chioke by police officers in Jefferson Parish, Louisiana. The officers, including Nicholas Dowdle, allegedly shot Asante-Chioke after he raised a gun in their direction. An autopsy revealed that thirty-six rounds were fired by the officers, with twenty-four hitting Asante-Chioke. The plaintiff, Asante-Chioke's daughter, filed a lawsuit against the officers and Colonel Lamar Davis, superintendent of the Louisiana State Police, under 42 U.S.C. §§ 1983 and 1988, alleging unlawful seizure and excessive force.The defendants moved to dismiss the case, asserting qualified immunity. The district court denied the motion, stating that the plaintiff had pled sufficient facts to overcome the defense of qualified immunity. The court also denied the defendants' request to limit discovery. The defendants appealed the denial of limited discovery, and the district court stayed discovery only as to claims against Dowdle and issues regarding his qualified immunity on appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court's order. The court found that it had jurisdiction to review the order under the collateral order doctrine, as the district court's failure to limit discovery was tantamount to the denial of qualified immunity. The court vacated the district court's order and remanded the case, directing the lower court to limit discovery to uncover only the facts necessary to rule on qualified immunity. View "Asante-Chioke v. Dowdle" on Justia Law