Justia Civil Rights Opinion Summaries

In this case, Whitney Hodges, representing the estate of her late daughter Honestie Hodges, alleges that on December 6, 2017, Grand Rapids Police Department officers detained Honestie, an eleven-year-old African American girl, at gunpoint, handcuffed her, and placed her in a police car. The officers were searching for a stabbing suspect who did not match Honestie’s description. Honestie was not armed, did not pose a threat, and did not attempt to flee. The complaint asserts that the officers lacked probable cause or reasonable suspicion to detain Honestie and used excessive force in doing so.The United States District Court for the Western District of Michigan partially denied the officers' motion to dismiss on qualified-immunity grounds. The district court found that the complaint plausibly alleged violations of Honestie’s Fourth Amendment rights, including unreasonable search and seizure, false imprisonment, and excessive force. The court declined to consider video evidence and police reports provided by the officers, determining that these materials did not blatantly contradict the complaint’s allegations and were subject to reasonable dispute.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The court affirmed the district court’s order, agreeing that the complaint plausibly alleged that the officers violated Honestie’s clearly established rights. The Sixth Circuit held that the officers’ actions, as alleged, lacked reasonable suspicion or probable cause and involved excessive force. The court dismissed the officers' appeal to the extent it sought to resolve disputed factual issues, emphasizing that such issues should be addressed after discovery. View "Hodges v. City of Grand Rapids, Mich." on Justia Law

While incarcerated at Ellsworth Correctional Institution in Wisconsin, the plaintiff was sexually assaulted and physically abused by a correctional officer, James Faulkner. Faulkner was later criminally convicted for these acts and sentenced to a lengthy prison term. The plaintiff subsequently filed a civil suit under 42 U.S.C. §1983 seeking damages from Faulkner and three supervisory officials, alleging violations of her constitutional rights.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the supervisory officials, finding no evidence that they knew or should have known of Faulkner’s risk to inmates. The plaintiff did not appeal these rulings, effectively abandoning her claims against those defendants. Faulkner, having failed to answer the complaint, was found in default. The district court held a hearing to determine damages and ultimately awarded the plaintiff $1 million for pain and suffering and $3 million in punitive damages, but denied additional damages for lost income and future medical expenses due to insufficient and improperly presented evidence.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings and the plaintiff’s arguments regarding the scope of Faulkner’s employment. The appellate court held that the district judge did not abuse his discretion or commit legal error in excluding the plaintiff’s evidence on future damages, as the submissions failed to comply with statutory requirements and evidentiary rules. The court also rejected the plaintiff’s arguments concerning employer liability, noting that the employer was not named as a party and that such issues were not properly before the court. The Seventh Circuit affirmed the judgment of the district court. View "Dotson v. Faulkner" on Justia Law

A private fencing coach alleged that during a flight, a university’s assistant fencing coach sexually harassed and assaulted her. She reported the incident to the university’s head coach, who discouraged her from reporting it further and, along with the assistant coach, allegedly retaliated against her within the fencing community. The university later investigated and confirmed the harassment but found no policy violation. The coach sued the university, the two coaches, and the Title IX coordinator, claiming violations of Title IX and state-law torts.The United States District Court for the Middle District of North Carolina transferred the case to the Middle District of Pennsylvania due to improper venue and judicial efficiency. After the transfer, the plaintiff amended her complaint, and the defendants moved to dismiss. The transferee court dismissed the entire suit, holding that the plaintiff, as neither a student nor an employee, was outside the zone of interests protected by Title IX. It also dismissed the state-law tort claims as untimely or implausible.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the zone-of-interests test applies to Title IX claims and that the plaintiff’s claims related to her exclusion from university-hosted fencing events and retaliation manifesting on campus were within that zone. The court affirmed the dismissal of the state-law tort claims against the university and its employees, except for the claims against the assistant coach, which were not time-barred under North Carolina’s three-year statute of limitations. The case was vacated in part, affirmed in part, and remanded for further proceedings. View "Oldham v. Penn State University" on Justia Law

Professor James Wetherbe, known for his anti-tenure views, claimed he faced retaliation from Lance Nail, the then-dean of the business school at Texas Tech University (TTU), for his public criticisms of tenure. Wetherbe alleged that Nail's retaliatory actions included removing him from teaching assignments, falsely accusing him of misconduct, and revoking his emeritus status, among other adverse actions. Wetherbe sued Nail under 42 U.S.C. §1983 for violating his First Amendment rights and sought injunctive and declaratory relief against the current dean, Margaret Williams.The United States District Court for the Northern District of Texas denied the defendants' second amended Rule 12(c) motion, holding that Wetherbe sufficiently alleged a constitutional violation and that Nail’s actions were objectively unreasonable in light of clearly established law. The defendants appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court concluded that the contours of First Amendment law regarding retaliation were not clearly established at the time the events occurred. Specifically, the court found that it was not clearly established that Wetherbe’s speech regarding tenure was on a matter of public concern. Consequently, the court reversed the district court’s order and rendered judgment in favor of the defendants, granting Nail qualified immunity from Wetherbe’s First Amendment retaliation claims. The court did not address Wetherbe’s claims for declaratory and injunctive relief against Williams, as the district court had not ruled on those claims. View "Wetherbe v. Texas Tech University" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

A mother was shot and killed by a deputy sheriff while her young children watched. The mother, who had been acting erratically and wielding a knife, advanced towards the deputies despite repeated requests to drop the weapon. The lead deputy fired his service pistol after a backup deputy's taser failed to stop her. The children, through their guardian ad litem, sued the deputies and Nevada County, claiming the use of force was unreasonable.The trial court ruled that the lead deputy acted reasonably and granted summary judgment in his favor, but allowed the claims against the backup deputy to proceed, finding that a reasonable juror could conclude his actions were unreasonable. The backup deputy and the County petitioned for a writ of mandate, arguing that the trial court should have granted their summary judgment motion as well.The California Court of Appeal, Third Appellate District, reviewed the case. The court emphasized the need to assess reasonableness from the perspective of a reasonable officer at the scene, considering the split-second decisions officers must make. The court concluded that the backup deputy acted reasonably as a matter of law, noting that the mother advanced towards the deputies with a deadly weapon and that the backup deputy's use of a taser was a reasonable response under the circumstances.The court issued a writ of mandate directing the trial court to set aside its partial denial of the summary judgment motion and to enter a new order granting the motion in its entirety, thus ruling in favor of the backup deputy and the County. View "County of Nevada v. Super. Ct." on Justia Law

On December 15, 2015, police officers responded to a hostage situation at Eagle Nation Cycles in Neenah, Wisconsin. Initial reports indicated a lone gunman had fired a shot and was threatening to kill hostages. When officers attempted to enter the shop, they were met with gunfire and heavy smoke, leading them to suspect an ambush. Several hostages escaped, and the officers detained and questioned them, transporting two to the police station. Three of these hostages later sued the City of Neenah and multiple officers, claiming their Fourth Amendment rights against unreasonable seizures were violated.The United States District Court for the Eastern District of Wisconsin found the plaintiffs' detention reasonable and ruled that no constitutional violation occurred. Additionally, the court held that qualified immunity shielded the officers from liability. The court also dismissed Sergeant Angela Eichmann from the suit due to her lack of involvement in the alleged misconduct. The district court granted summary judgment in favor of the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the officers' actions were reasonable under the circumstances of a violent hostage situation. The court found that the officers were justified in temporarily detaining the plaintiffs to ascertain their identities and ensure safety. The court also affirmed the dismissal of Sergeant Eichmann, as there was no evidence of her direct involvement in the alleged constitutional violations. The court did not address the issue of qualified immunity, as it concluded that no constitutional violation occurred. View "Moderson v. City of Neenah" on Justia Law

The case involves the appellant, Gregory Smith, challenging the Municipality of Anchorage's decision to abate unauthorized campsites in Davis Park. The Anchorage Municipal Code (AMC) outlines procedures for campsite abatement, including posting a notice and allowing for an appeal to the superior court. In June 2022, the Municipality posted a notice in Davis Park, advising that the area was not legal for storage or shelter and that any personal property would be removed and disposed of as waste after ten days. Smith and five others appealed the abatement, arguing it violated due process and the Eighth Amendment.The superior court dismissed the appeal, agreeing with the Municipality that its jurisdiction was limited to reviewing the legal sufficiency of the posted notice, not the abatement decision itself. The court noted that the appellants did not challenge the notice's compliance with the Code, thus leaving no issues for the court to decide. The court also observed that the appellants' claims were not without merit and suggested that a civil suit could address their concerns.The Supreme Court of the State of Alaska reviewed the case and concluded that the superior court's jurisdiction was not limited to the notice's legal sufficiency. The court held that the superior court has jurisdiction to review the substantive decision to abate the campsite, including constitutional challenges. The court reversed the superior court's decision and remanded the case for further consideration of the constitutional issues raised by Smith. The court also directed the superior court to determine if the administrative record was sufficient for meaningful appellate review and to take necessary steps to ensure it has an adequate record. View "Smith v. Municipality of Anchorage" on Justia Law

Charlene Carter, a flight attendant for Southwest Airlines, was terminated after sending graphic anti-abortion messages to the president of the flight attendants' union, Audrey Stone. Carter, a pro-life Christian, opposed the union's leadership and its participation in the Women's March, which she viewed as supporting abortion. After an arbitrator found that Southwest had cause to terminate Carter under its corporate policies, Carter sued Southwest and the union, claiming her termination violated Title VII of the Civil Rights Act and the Railway Labor Act (RLA).The United States District Court for the Northern District of Texas ruled in favor of Carter, finding that Southwest and the union had discriminated against her based on her religious beliefs and practices. The court permanently enjoined Southwest and the union from interfering with the religious expression of any Southwest flight attendant and held Southwest in contempt for failing to comply with its judgment. Both Southwest and the union appealed, and Carter cross-appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of Southwest's motion for judgment as a matter of law on Carter's belief-based Title VII claim and RLA retaliation claim, remanding with instructions to enter judgment for Southwest. The court affirmed the judgment against Southwest on Carter's practice-based Title VII claims and the dismissal of Carter's RLA interference claim. The court also affirmed the judgment against the union on all claims but vacated the permanent injunction and remanded for additional proceedings. Additionally, the court vacated the contempt order against Southwest. View "Carter v. Southwest Airlines Company" on Justia Law

M.R., a high school student and basketball player, was sexually abused by Cody Butler, a women's basketball coach at Yakima Valley Community College (YVCC), starting when she was 17 years old. The abuse continued into her adulthood, including inappropriate touching, sexual comments, and physical advances. Butler's actions had a significant negative impact on M.R.'s life, leading to substance abuse, abusive relationships, and other personal issues. In 2018, M.R. connected her experiences of abuse to her injuries while in therapy.In 2019, M.R. sued the State of Washington, YVCC, and Butler for various claims, including negligence and assault. The trial court denied the State's motion for summary judgment, which argued that M.R.'s claims were time-barred by the three-year statute of limitations in RCW 4.16.080(2). The court found that the abuse was a continuous series of events that could not be segregated. The Court of Appeals reversed, concluding that RCW 4.16.340 only applies to claims based on acts of childhood sexual abuse occurring before the plaintiff turns 18 years old.The Supreme Court of the State of Washington reviewed the case and reversed the Court of Appeals. The court held that RCW 4.16.340 does not preclude complainants from bringing claims of sexual abuse that originate from childhood sexual abuse and extend into the victim’s adulthood. The court found that the statute's plain language and legislative intent support the inclusion of claims for continuing sexual abuse that are based on intentional acts of childhood sexual abuse. The court also noted that the statute accounts for the continuing tort doctrine, allowing for claims involving a common scheme of abuse by the same perpetrator. View "M.R. v. State" on Justia Law