Justia Civil Rights Opinion Summaries

In 2006, an individual was civilly committed to the North Dakota State Hospital as a sexually dangerous person. Over the years, he repeatedly sought discharge from commitment, with several applications denied and those denials affirmed on appeal. In July 2024, he again applied for discharge. The State’s expert, a clinical and forensic psychologist, testified at a review hearing, while the individual’s independent examiner did not testify. The individual’s girlfriend, a former hospital employee, also testified. The district court found that the individual’s antisocial personality disorder and history of sexually predatory conduct made him likely to reoffend, and concluded he would have serious difficulty controlling his sexual behavior if released. The court ordered continued commitment in January 2025.The individual appealed the district court’s order to the North Dakota Supreme Court, arguing that the court erred in finding clear and convincing evidence that he has serious difficulty controlling his behavior. He did not challenge the court’s findings on the statutory elements required for civil commitment, but contended that the court’s findings on his ability to control his behavior were conclusory and unsupported by specific evidence. While the appeal was pending, he filed another application for discharge, but the Supreme Court’s review was limited to the January 2025 order.The North Dakota Supreme Court held that the district court failed to make sufficiently specific findings of fact regarding whether the individual has serious difficulty controlling his behavior, as required by substantive due process and precedent. The Supreme Court reversed the district court’s order and remanded the case for further specific findings on this issue, unless the pending application for discharge renders the matter moot. View "Interest of Hoff" on Justia Law

The plaintiff, who is civilly committed as a sexually violent predator at the Texas Civil Commitment Center, brought a pro se lawsuit under 42 U.S.C. § 1983 against the Commissioner of the Texas Department of Family Protective Services and the Executive Commissioner of the Texas Health and Human Services Commission. He alleged that these agencies failed to investigate his reports of misconduct and abuse at the facility, claiming violations of his Fourteenth Amendment rights to equal protection and due process, as well as rights under the Bill of Rights for Mental Health Patients. The plaintiff asserted that he should be able to file complaints with these agencies rather than being required to use the internal grievance procedure of the Texas Civil Commitment Office.The United States District Court for the Western District of Texas screened the complaint under 28 U.S.C. § 1915(e)(2)(B) because the plaintiff was proceeding in forma pauperis. The district court found that the plaintiff failed to state a claim for relief and that amendment would be futile, so it dismissed the complaint without prejudice. The plaintiff appealed, arguing that he had adequately stated equal protection and due process claims, that he should have been allowed to amend his complaint, and that the district court was biased.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to state an equal protection claim because he was not similarly situated to other Texas citizens and the different grievance procedures had a rational basis. The court also found no protected liberty or property interest to support a due process claim and concluded that the alleged conduct did not rise to the level of a substantive due process violation. The court further held that amendment would have been futile and found no evidence of judicial bias. The plaintiff’s motion for appointment of counsel was denied. View "Dunsmore v. Muth" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

Jill Esche, who was seven months pregnant, was admitted to Renown Regional Medical Center in Nevada with severe hypertension and erratic behavior. Hospital staff, believing she was mentally ill and a danger to herself and her fetus, petitioned for her involuntary commitment under Nevada law. While the petition was pending, Esche was kept in the hospital, given psychiatric and medical treatment against her will, restricted from visitors and phone use, and not informed that a public defender had been appointed for her. After giving birth by C-section, the hospital decided to withdraw the commitment petition but allowed Esche to leave while she was still in fragile condition. She died outside near the hospital that night. Her estate and survivors sued the hospital and several staff members, alleging violations of her constitutional rights under 42 U.S.C. § 1983 and Nevada law.The United States District Court for the District of Nevada granted summary judgment to the defendants on some claims, including unreasonable seizure and procedural due process claims, but denied summary judgment on others, such as substantive due process, conspiracy, and failure-to-train-or-supervise claims. The court also denied the defendants’ assertion of a good-faith defense to § 1983 liability, finding that the defense did not apply because the hospital was not required by law or directed by a public official to hold Esche involuntarily. Both sides appealed: the defendants challenged the denial of the good-faith defense, and the plaintiffs cross-appealed the dismissal of other constitutional claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court’s denial of the good-faith defense was not immediately appealable under the collateral order doctrine, as the defense is a defense to liability, not an immunity from suit. The court dismissed both the defendants’ appeals and the plaintiffs’ cross-appeal for lack of jurisdiction. View "Estate of Esche v. Bunuel-Jordana" on Justia Law

A North Carolina police officer, Clarence Belton, was shot multiple times by fellow officer Heather Loveridge during the execution of a search warrant. The incident, which resulted in serious injuries to Belton and ended his law enforcement career, was captured on video and body camera footage. Belton sued Loveridge and the City of Charlotte, alleging excessive force and other claims. During the litigation, both parties moved to seal the video exhibits related to the shooting, and the district court granted these motions, placing the footage under seal.After the district court denied Loveridge’s motion for summary judgment, which was later vacated and remanded by the United States Court of Appeals for the Fourth Circuit, a local television station, WBTV, sought to intervene in the case to unseal the video footage. Belton supported WBTV’s motion, but Loveridge opposed it, arguing that unsealing would jeopardize her right to a fair trial. The United States District Court for the Western District of North Carolina denied WBTV’s motion to intervene, citing lack of jurisdiction due to the pending appeal, and also denied the motion to unseal, finding no right of access under the common law or the First Amendment and concluding that Loveridge’s fair trial rights outweighed any public interest.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of WBTV’s motion to intervene, agreeing that the district court lacked jurisdiction at that stage. However, the appellate court treated WBTV’s appeal regarding the sealing order as a petition for a writ of mandamus. The Fourth Circuit held that the district court’s order sealing the video exhibits violated the First Amendment right of access to judicial records. The court vacated the sealing order and remanded with instructions to unseal the video footage, finding that Loveridge had not met her burden to justify continued sealing. View "Gray Media Group, Inc. v. Loveridge" on Justia Law

A 78-year-old inmate in a Texas men’s prison, who identifies as a transgender woman, sought sex-reassignment surgery after being diagnosed with gender dysphoria in 2013. The inmate received hormone therapy and was chemically castrated, but was ultimately denied surgery by prison medical staff. The inmate alleged that state officials discriminated by providing reconstructive vaginoplasty to female inmates while denying similar surgery to transgender inmates, claiming a violation of the Equal Protection Clause.The United States District Court for the Southern District of Texas initially denied motions to dismiss based on sovereign immunity, finding that the inmate was similarly situated to cisgender female inmates and that the claims met the requirements of the Ex parte Young exception to sovereign immunity. On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit vacated the district court’s orders, holding that the inmate had not adequately pled that any defendant was sufficiently connected to enforcement of the challenged policy. On remand, after further proceedings and discovery, the district court granted judgment on the pleadings, concluding that the defendants were either improper under Ex parte Young or that the requested relief was not permitted, and dismissed the lawsuit for lack of jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal, holding that the inmate lacked standing. The court found that the alleged injury was not fairly traceable to the defendants, as there was no evidence that any treating physician had determined the inmate was a suitable candidate for surgery or would refer the inmate for the procedure. Without such evidence, the injury could not be redressed by a favorable judicial decision against the defendants. View "Haverkamp v. Linthicum" on Justia Law

A hotel in the Town of Newburgh, New York, agreed to provide long-term housing to asylum seekers as part of a program initiated by New York City. In response, the Town alleged that the hotel’s actions violated local zoning and occupancy ordinances, which limited hotel stays to transient guests for no more than 30 days. The Town inspected the hotel, found modifications suggesting long-term use, and filed suit in the Supreme Court of the State of New York, Orange County, seeking to enjoin the hotel from housing asylum seekers for extended periods. The state court issued a temporary restraining order, but allowed the asylum seekers already present to remain pending further orders.The hotel removed the case to the United States District Court for the Southern District of New York, arguing that the Town’s enforcement was racially motivated and violated Title II of the Civil Rights Act of 1964, thus justifying removal under 28 U.S.C. § 1443(1). The district court found that removal was improper because the hotel had not sufficiently pleaded grounds for removal under § 1443(1), and remanded the case to state court.While the hotel’s appeal of the remand order was pending before the United States Court of Appeals for the Second Circuit, the underlying state court action was discontinued with prejudice after the asylum seekers left and the City ended its program. The Second Circuit determined that, because the state court case was permanently terminated, there was no longer a live controversy regarding removal. The court held the appeal was moot and, following standard practice when mootness occurs through no fault of the appellant, vacated the district court’s remand order and dismissed the appeal. View "Town of Newburgh v. Newburgh EOM LLC" on Justia Law

A plaintiff alleged that, between 1965 and 1969, while he was a young child attending an elementary school in a California school district, he was repeatedly sexually assaulted by the school’s principal. The complaint stated that school staff and faculty were aware or suspected the abuse, and that similar abuse occurred to other students. The plaintiff claimed ongoing psychological and emotional harm as a result. He brought four negligence-based causes of action against the school district, asserting that he was not required to present a government tort claim before filing suit due to statutory changes exempting such claims.The Superior Court of Merced County sustained the school district’s demurrer without leave to amend, dismissing the complaint. The court found that the plaintiff’s failure to comply with the Government Claims Act’s claim presentation requirement was fatal to his case, and concluded that legislative changes extending the statute of limitations for childhood sexual assault did not alter the deadline for filing a claim against a public entity.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed whether Assembly Bill No. 218’s retroactive waiver of the Government Claims Act’s claim presentation requirement for claims under Code of Civil Procedure section 340.1 violated the California Constitution’s gift clause. The appellate court held that the retroactive waiver did not create a new liability or cause of action, but merely removed a procedural barrier to suit. The court further found that the legislative purpose of aiding victims of childhood sexual assault served a valid public purpose and did not constitute an unconstitutional gift of public funds. The judgment of dismissal was reversed and the case remanded for further proceedings. View "Doe R.L. v. Merced City School District" on Justia Law

A pretrial detainee in the St. Tammany Parish Jail, who has had a prosthetic eye for decades, reported his chronic condition to jail medical staff upon intake. In June 2022, a jail doctor prescribed antibiotics and twice-weekly wound care for an infection in the detainee’s eye socket. Although the detainee was initially scheduled for wound care, he was not taken to his appointments, and his infection worsened over several weeks. The detainee filed multiple grievances, alleging that a deputy failed to escort him to medical care and that a refusal-of-treatment form was falsely completed without his knowledge or signature. After further investigation, jail officials determined that the medical records inaccurately reflected wound care visits, which were actually medication distributions, and ultimately found the detainee’s grievance substantiated.The detainee filed a pro se civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Louisiana, naming jail officials and medical staff as defendants. The district court, through a magistrate judge, granted a motion to dismiss for some defendants and summary judgment for others, entering final judgment against the detainee and dismissing his claims with prejudice. The court denied the detainee’s motions to compel discovery and to amend his complaint, and did not address some discovery requests before entering judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the magistrate judge committed plain error by treating a report and recommendation as a final judgment before it was formally adopted, thereby denying the detainee a full and fair opportunity for discovery. The appellate court reversed the grant of summary judgment for the doctor-defendants, affirmed the dismissal of claims against most jail officials, but found that dismissal should have been without prejudice to allow for amendment. The case was remanded for further proceedings consistent with these holdings. View "James v. Smith" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law