Justia Civil Rights Opinion Summaries

Samantha Wood, a resident of California, filed a petition to legally change her name to Candi Bimbo Doll, a name she had been using for over a decade. There was no opposition to her petition and no hearing was held. However, the trial judge denied her petition, citing a California case, a law review article, and a TikTok trend. The court asserted that no person has a statutory right to officially change their name to a term that is universally recognized as offensive.Wood appealed the decision. The Court of Appeal of the State of California First Appellate District examined previous case law and found that a change of name may only be denied when there is a 'substantial reason.' In this case, the court ruled that the term 'Bimbo,' while historically derogatory, is not universally recognized as offensive. The court also noted that the term is being reclaimed in a positive way through social media trends, such as on TikTok.The court found that the trial judge had not provided a substantial reason to deny the name change and had not properly exercised discretion according to the legal principles of the subject. Therefore, the Court of Appeal reversed the trial court's decision and remanded the case to the trial court to grant the name change. View "Wood v. Super. Ct." on Justia Law

The plaintiff-appellant, Maurice Cotton, an inmate, filed a civil rights lawsuit against corrections officials at the Green Haven Correctional Facility. He alleged that he was wrongfully denied a transfer to another prison facility and retaliated against for filing grievances related to the transfer request. Cotton sought permission to proceed in forma pauperis (IFP), which allows indigent prisoners to pay filing fees through a structured payment plan linked to their prison accounts. The district court denied Cotton's IFP request, concluding that he had accumulated "at least three" strikes under the Prison Litigation Reform Act (PLRA) due to previous lawsuit dismissals.The United States Court of Appeals for the Second Circuit vacated and remanded the district court's decision, ruling that the district court erred in its interpretation of the three previous lawsuits. According to the appellate court, not all of Cotton's previous lawsuits counted as PLRA strikes. The court further explained that a dismissal under Heck v. Humphrey does not automatically count as a PLRA strike, arguing that the key consideration is whether the dismissal is based on the merits of the case or if it was merely a matter of timing or sequencing. Therefore, the appellate court concluded that the district court incorrectly denied Cotton's request for IFP status, warranting a remand for further proceedings. View "Cotton v. New York State Office" on Justia Law

In this lawsuit, Keith Sylvester alleged that Detective James Barnett violated his Fourth Amendment rights by causing his arrest and detention without probable cause. Sylvester's parents were murdered and their house set on fire. Detective Barnett led the investigation and suspected Sylvester was the culprit, ultimately obtaining an arrest warrant for him. Sylvester spent over a year in jail until the charges were dropped. Sylvester claimed that Barnett lacked probable cause when he applied for the arrest warrant, arguing that key exonerating evidence was omitted from the affidavit.The district court granted Detective Barnett summary judgment, stating that the record did not establish that Barnett knew about the exonerating information when he wrote the warrant affidavit. The court concluded that, based on the totality of circumstances known to Barnett at the time of the arrest, his suspicion of Sylvester was reasonable.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision. The appellate court found that there were material facts omitted from the warrant affidavit. When those omissions were corrected, the affidavit failed to establish even arguable probable cause for Sylvester's arrest. The court further held that a reasonable jury could find that Barnett intentionally or recklessly left out information that exonerated Sylvester. If a jury finds such misconduct, qualified immunity would not shield Barnett from liability. Therefore, the case was remanded for further proceedings. View "Sylvester v. Barnett" on Justia Law

The plaintiff, Joshua Young, an employee of the Colorado Department of Corrections, claimed that mandatory Equity, Diversity, and Inclusion (EDI) training he was subjected to created a hostile work environment. Young resigned from the Department and filed a lawsuit claiming violations of Title VII and the Equal Protection Clause. He alleged that the training program violated Title VII by creating a hostile work environment and violated the Equal Protection Clause by promoting race-based policies. The district court dismissed both claims without prejudice. Young appealed the decision.The United States Court of Appeals for the Tenth Circuit examined Young's allegations and affirmed the district court's dismissal of Young's claims. The court found that while Young had plausibly alleged he was subjected to unwelcome harassment, he failed to adequately allege that the harassment was so severe or pervasive that it altered the terms of his employment and created an abusive working environment.The court also affirmed the district court's dismissal of Young's equal protection claim, agreeing that Young lacked standing to pursue the claim since he was no longer employed by the Department of Corrections and had not asked for reinstatement as part of his equal protection claim.Finally, the court held that the district court did not abuse its discretion when it declined to grant Young leave to amend his complaint, noting that Young neither requested leave to amend in his briefing nor filed a separate motion to amend. View "Young v. Colorado Department of Corrections" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit ruled on an appeal brought by Randall Artis, a former city councilman for East Chicago, Indiana. Artis was previously convicted of misappropriating public money for personal political gain. After returning to public service as a junior clerk, he was fired by his boss, Adrian Santos. Artis alleged that Santos fired him in retaliation for exercising his First Amendment free speech rights. The case went to trial, and a jury found in favor of Santos.Artis appealed, arguing that the district court erred in admitting the testimony of an expert witness, in denying him an impartial jury, and in issuing inaccurate and confusing jury instructions and verdict forms. He also questioned the jury's verdict. The appeals court affirmed the district court's judgment, finding no error or reason for a new trial.The court held that the district court did not abuse its discretion in allowing the expert witness to testify, and it did not err in denying Artis's for-cause challenge to a prospective juror. Moreover, the court ruled that the district court did not abuse its discretion in its choice of jury instructions and verdict form. Finally, the court found no inconsistency in the jury's verdict. View "Artis v. Santos" on Justia Law

The case revolves around plaintiff Rynold Dwayne Jackson, who alleged malicious prosecution and unfair business practices after an altercation at a hotel lounge. Jackson was refused service on the basis of intoxication. Following a dispute, Jackson and the hotel's director of security, Mario Lara, had physical contact leading to Jackson's prosecution for battery. After being found not guilty, Jackson filed a civil complaint against Lara and DT Management, LLC, the company managing the hotel and lounge.Jackson alleged malicious prosecution against Lara, claiming the criminal prosecution was based on a false assault accusation. He also alleged DT Management violated the Unfair Competition Law by denying equal access, permitting discriminatory behavior by employees, and selectively deleting incident footage.The defendants filed a motion for summary judgment, which the lower court granted. The court considered Jackson's failure to appear at the motion hearing as a submission on the tentative ruling. Jackson appealed this judgment.The Court of Appeal, Fourth Appellate District Division One, State of California, affirmed the lower court's judgment. They cited the interim adverse judgment rule, which establishes that a trial court judgment in favor of the plaintiff or prosecutor, unless obtained fraudulently, forms probable cause to bring the underlying action. The court found this rule applicable as Jackson's motion for acquittal in his criminal trial was denied, thus establishing probable cause for Lara's accusation.As for the unfair business practices claim, Jackson failed to substantiate his allegations with legal authority or argument, resulting in the dismissal of his claim. Furthermore, a new theory he proposed on appeal was disregarded as it was raised for the first time and not considered in the trial court. View "Jackson v. Lara" on Justia Law

In the United States Court of Appeals for the Seventh Circuit, Parents Protecting Our Children, an association of parents, sought an injunction against the Eau Claire Area School District in Wisconsin to stop the enforcement of the District’s Administrative Guidance for Gender Identity Support. The parents argued that the policy violated the Due Process and Free Exercise Clauses of the U.S. Constitution by interfering with their right to make decisions on behalf of their children. The District Court dismissed the case due to lack of subject matter jurisdiction, stating that the parents failed to identify any instance where the policy was applied in a way that infringed on parental rights.The Court of Appeals affirmed the lower court's ruling. The court held that the parents' concerns about potential applications of the policy did not establish standing to sue unless the policy resulted in an injury or created an imminent risk of injury. The court stated that the parents had brought a pre-enforcement facial challenge against the policy without any evidence of the School District applying the policy in a manner detrimental to parental rights.The court also noted that the Administrative Guidance did not mandate exclusion of parents from discussions or decisions regarding a student’s gender expression at school. The court found that the alleged harm was dependent on a speculative "chain of possibilities," which was insufficient to establish Article III standing. Therefore, the court upheld the dismissal of the lawsuit for lack of subject matter jurisdiction. View "Parents Protecting Our Children, UA v. Eau Claire Area School District" on Justia Law

The United States Court of Appeals for the Second Circuit reviewed a decision made by the United States District Court for the Southern District of New York. The plaintiff, Do No Harm, a membership organization, filed a suit against Pfizer Inc., alleging that a Pfizer fellowship program unlawfully excluded white and Asian-American applicants on the basis of race. The plaintiff sought a preliminary injunction, which was denied by the district court. The district court dismissed the case without prejudice because Do No Harm lacked Article III standing. The court reasoned that the organization failed to identify by name a single injured member.The Court of Appeals affirmed the district court's decision. It upheld that to establish standing under Article III, an association relying on injuries to individual members must name at least one injured member. The court also held that if a plaintiff fails to establish standing in the context of a motion for a preliminary injunction, the district court must dismiss their claims without prejudice rather than allowing the case to proceed if the plaintiff alleged sufficient facts to establish standing under the less onerous standard applicable at the pleading stage. View "Do No Harm v. Pfizer Inc." on Justia Law

The United States Court of Appeals for the Seventh Circuit reviewed a case involving David A. Schlemm, an inmate who had filed a First Amendment retaliation claim against Brendan Pizzala, Jay Van Lanen, and Michael Donovan. Schlemm's claim was based on accusations made against him for theft of sage from the chapel of the Green Bay Correctional Institution, which led to a conduct report being issued against him. The report was later dismissed after another correctional officer testified that he had given the sage to Schlemm. Schlemm then filed complaints against the defendants through the Inmate Complaint Review System (ICRS), claiming retaliation.The lower court had dismissed Schlemm's case, ruling it was time-barred due to the six-year statute of limitations. The court noted that Schlemm's lawsuit, filed in 2019, was more than six years after the 2012 search of his cell. On appeal, the defendants conceded that Schlemm had properly exhausted his administrative remedies, but argued his action was time-barred due to the six-day gap between the accrual of his claim and the filing of his administrative complaints.The Appeals Court reviewed the district court's dismissal de novo and concluded that the defendants had waived their specific statute of limitations argument regarding the six-day gap. They had raised this argument for the first time on appeal, having previously argued that Schlemm had not properly exhausted his administrative remedies. The court reversed the dismissal and remanded for further proceedings, noting that it did not need to address the question of whether the gap between claim accrual and grievance filing is included in the tolling period due to the defendants' waiver of their argument. View "Schlemm v. Pizzala" on Justia Law