Justia Civil Rights Opinion Summaries

In this case before the United States Court of Appeals for the Fifth Circuit, the plaintiff, Lebene Konan, alleged that the United States Postal Service (USPS) employees intentionally withheld her mail for two years. Konan, who is African American, owned two properties in Texas that she rented out to tenants. She claimed that USPS employees, Jason Rojas and Raymond Drake, deliberately failed to deliver mail to these residences because they didn't like the idea of a black person owning those properties.Konan filed a lawsuit under the Federal Tort Claims Act (FTCA) and also alleged violations of her equal protection rights. The district court dismissed her claims due to lack of subject matter jurisdiction and failure to state a claim. Konan appealed the decision.The Appeals Court affirmed in part and reversed in part. It ruled that the district court erred in dismissing Konan's FTCA claim, finding that the postal-matter exception to the FTCA's immunity waiver did not apply to intentional acts such as those alleged. The court ruled that Konan's claims did not constitute a "loss," "miscarriage," or "negligent transmission" of mail, which are covered by the exception, as they involved intentional non-delivery of mail.However, the court agreed with the district court's dismissal of Konan's equal protection claims. The court held that Konan did not provide sufficient facts to support her assertion that the USPS employees continued to deliver mail to similarly situated white property owners while denying her mail delivery. It also held that her claims were barred by the intracorporate-conspiracy doctrine, which precludes conspiracy claims against multiple defendants employed by the same governmental entity. Therefore, the court affirmed the dismissal of Konan's equal protection claims. View "Konan v. USPS" on Justia Law

The plaintiff-Appellant, Kristen King, claimed that her employer, Aramark Services Inc., subjected her to a sex-based hostile work environment, discrimination, and retaliation in violation of the New York State Human Rights Law and Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed King’s claims. However, the United States Court of Appeals for the Second Circuit affirmed the lower court’s decision on the New York State Human Rights Law claims but vacated the decision on the Title VII claims.The Court of Appeals agreed with the lower court that the impact of Aramark’s alleged discriminatory acts were only incidentally felt in New York. Regarding the Title VII hostile work environment claim, the court found that King’s termination was not only a discrete act supporting a distinct claim for damages, but also part of the pattern of discriminatory conduct that comprises her hostile environment claim. The court held that because King’s termination occurred within the limitations period, the continuing violation doctrine rendered King’s hostile work environment claim timely. Therefore, the court affirmed the lower court’s dismissal of King’s New York State Human Rights Law claims but vacated the dismissal of King’s Title VII claims and remanded the case for further proceedings on those claims. View "King v. Aramark Services Inc." on Justia Law

In this case, a prisoner, Kyle Brandon Richards, appealed a district court's decision to dismiss his civil rights suit under 42 U.S.C. § 1983. The lawsuit was dismissed because Richards reportedly failed to exhaust his administrative remedies. The plaintiff alleged sexual harassment, retaliation, and destruction of property by Resident Unit Manager Thomas Perttu. Specifically, Richards claimed that Perttu prevented him from filing grievances related to the alleged abuse by destroying or ripping them up.The defendant, Perttu, moved for summary judgment, arguing that Richards had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a). The district court denied the motion due to questions of fact. After an evidentiary hearing, a magistrate judge recommended that the district court find that Richards had failed to exhaust his administrative remedies. Richards appealed, alleging errors by the district court, bias by the magistrate judge, and the need for a free transcript of the evidentiary hearing.The United States Court of Appeals for the Sixth Circuit addressed whether the district court should have ordered an evidentiary hearing to decide the disputed questions of fact intertwined with the exhaustion issue. The Court of Appeals found that the Seventh Amendment required a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff’s substantive case. Therefore, the Court of Appeals reversed the judgment of the district court and remanded the case for further proceedings. View "Richards v. Perttu" on Justia Law

The case involves Yonas Fikre, a U.S. citizen and Sudanese emigree, who brought a lawsuit alleging that the government unlawfully placed him on the No Fly List. Fikre claimed that the government violated his rights to procedural due process and placed him on the list for constitutionally impermissible reasons related to his race, national origin, and religious beliefs. In 2016, the government removed Fikre from the No Fly List, and argued in court that this action rendered Fikre's lawsuit moot. The district court agreed with the government's assessment, but the Ninth Circuit reversed, stating that a party seeking to moot a case based on its own voluntary cessation of challenged conduct must show that the conduct cannot “reasonably be expected to recur.”The Supreme Court of the United States affirmed the Ninth Circuit's decision. It held that the government failed to demonstrate that the case was moot. The Court stated that a defendant's "voluntary cessation of a challenged practice" will moot a case only if the defendant can prove that the practice cannot "reasonably be expected to recur." The Court found that the government's declaration that it will not relist Fikre based on "currently available information" did not suffice to demonstrate that Fikre will not be placed on the No Fly List in the future if he engages in the same or similar conduct. Therefore, the government has not borne its burden of proving that the dispute is moot. View "FBI v. Fikre" on Justia Law

The United States Court of Appeals for the Second Circuit heard an appeal by Christopher Callahan against a judgment by the United States District Court for the Eastern District of New York. The district court had granted summary judgment to Suffolk County Police Officer Thomas Wilson and the County of Suffolk on claims related to the death of Callahan's brother, Kevin Callahan, which Callahan argued violated excessive force regulations under 42 U.S.C. § 1983. The appellate court ruled that the district court violated the mandate rule by not conducting a new trial as earlier instructed by the appellate court. The court found that there were disputed issues of material fact regarding Wilson's entitlement to qualified immunity, thus summary judgment was not warranted. However, the appellate court affirmed the district court's denial of Callahan's motion to amend his complaint to add a state law claim for battery. The case was remanded for a new trial. View "Callahan v. County of Suffolk" on Justia Law

The plaintiff, Ilya Kovalchuk, was driving his vehicle when off-duty police officer Matthew Ward began driving erratically behind him, ordered him to pull over, and held Kovalchuk at gunpoint without any justification. Kovalchuk filed a lawsuit against Ward and the City of Decherd, Tennessee, alleging that Ward violated his Fourth Amendment rights and that the City’s failure to investigate Ward’s background before hiring him led to Kovalchuk’s injuries. The district court dismissed the claims against the City, finding that Kovalchuk failed to adequately plead allegations supporting municipal liability.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court determined that in order to survive a motion to dismiss, a plaintiff must allege facts that, if accepted as true, are sufficient to state a claim to relief that is plausible on its face. The court found that Kovalchuk did not plausibly allege that the City of Decherd was deliberately indifferent to a known or obvious consequence of its decision to hire Ward. According to the court, Kovalchuk's allegations of "issues," "concerns about [Ward’s] demeanor and professionalism," and his "fail[ure] to complete [a] training program" were insufficient to establish a causal link between Ward's hiring and Kovalchuk's injury. The court further stated that a plaintiff cannot use discovery to bridge the gap between a deficient pleading and the possibility that a claim might survive upon further investigation. Therefore, the court affirmed the district court's dismissal of Kovalchuk's claims against the City of Decherd. View "Kovalchuk v. City of Decherd" on Justia Law

The appellant, Samantha Wood, sought to legally change her name to Candi Bimbo Doll, an identity she had pursued for over a decade. Despite no opposition to her request, the trial judge of the San Francisco County Superior Court denied Wood's petition based on the judge's interpretation of the term "bimbo" as inherently offensive. The judge derived this interpretation from various sources, including the Oxford English Dictionary, a law review article, and trends on the social media platform, TikTok.Upon appeal, the Court of Appeal of the State of California First Appellate District Division Two reversed the trial court's decision. The appellate court held that the trial court erred by denying Wood's petition for a name change. The court established that the trial court had incorrectly applied the principle that a name change may be denied only upon a "substantial reason".The appellate court determined that the term "bimbo" was not universally offensive or vulgar. They found that the term was being reclaimed and used as a means of empowerment in certain contexts, including on TikTok. The court also highlighted that the term did not appear to cause any confusion, as evidenced by its use in various business names and personalized license plates.Consequently, the court concluded that the trial court had abused its discretion by not adhering to the applicable legal principles that favor granting a name change, and by failing to identify substantial and principled reasons for denying the name change. The case was remanded to the trial court with instructions to grant Wood's petition for a name change. View "Wood v. S.F. Superior Court" on Justia Law

Samantha Wood, a California resident, petitioned the state's superior court to legally change her name to Candi Bimbo Doll, an identity she had embraced for over a decade. The trial court denied her petition, citing a California case and a law review article to argue that the proposed name could be considered offensive. The trial judge also referenced a 2020's TikTok trend of "Bimbofication," which encourages self-love and reclaims the term "bimbo." The judge, however, viewed the term as offensive and a setback for women's empowerment.Wood appealed this decision to the Court of Appeal of the State of California First Appellate District Division Two. The court found that the trial court had erred in its decision. It cited several precedents emphasizing that a name change should only be denied for "substantial and principled reasons," such as potential confusion or fraud. The court reasoned that "bimbo" is not a fighting word, is not necessarily offensive, and is not inherently confusing. Furthermore, the court underscored that the term is being reclaimed in a positive way as part of a women's empowerment trend. Consequently, the appellate court reversed the trial court's decision and directed it to grant Wood's petition for a name change. View "Wood v. Superior Court" on Justia Law

John D. Whitfield's application for a job as a Youth Development Specialist with the New York City Administration for Children’s Services (ACS) was rejected. Whitfield alleged that the rejection was discriminatory and violated his First and Fourteenth Amendment rights. He initially challenged the decision in New York State Supreme Court through an Article 78 proceeding, which was dismissed. He then initiated a federal court action, which was also dismissed by the District Court on res judicata grounds. The District Court determined that the state court proceeding was a “hybrid” proceeding where Whitfield could have pursued the claims he raises in the federal action.The United States Court of Appeals for the Second Circuit disagreed, concluding that the state court adjudicated the matter as a pure Article 78 proceeding, not as a hybrid. Therefore, the state court lacked the power to award Whitfield the full scope of relief he now seeks in this action, and the District Court erred by dismissing the amended complaint on res judicata grounds. The judgment of the District Court was vacated and the case was remanded for further proceedings. View "Whitfield v. City of New York" on Justia Law

In the early morning hours of September 8, 2018, Mabior Jok was standing outside a bar in Burlington, Vermont, when Joseph Corrow, an officer of the Burlington Police Department, approached the group. The details of what happened next are fiercely disputed, but it's agreed that Corrow took Jok to the ground, resulting in Jok hitting his head, losing consciousness and being taken to the hospital. Jok was charged with disorderly conduct, but the charge was later dismissed. Subsequently, Jok brought a lawsuit against Corrow and others, alleging, among other things, that Corrow used excessive force against him in violation of his Fourth Amendment rights.Corrow moved for summary judgment on several grounds, including that he was entitled to qualified immunity. The United States District Court for the District of Vermont denied the motion, concluding that there were genuine disputes of material fact and hence, summary judgment could not be granted on the basis of qualified immunity. Corrow then filed an interlocutory appeal of the denial.The United States Court of Appeals For the Second Circuit found that Corrow failed to establish appellate jurisdiction because he continued to assert disputes of fact, and no pure question of law was presented for review. The Court concluded that it did not have jurisdiction to review the denial of qualified immunity as the denial was based on the presence of disputed material facts. Therefore, the interlocutory appeal was dismissed due to lack of appellate jurisdiction. View "Jok v. City of Burlington" on Justia Law