Justia Civil Rights Opinion Summaries

In 2016, the DOJ sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act, alleging unconstitutional conditions in the county's detention facilities. A consent decree was established to address these issues, but disputes over compliance led to ongoing litigation. The DOJ claimed the county failed to comply, citing worsening conditions, while the county sought to terminate the decree. The district court found partial compliance, held the county in contempt, and issued a new injunction focusing on the Raymond Detention Center (RDC). As a sanction, the court appointed a receiver to oversee compliance.The district court's decision was based on findings of ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, and poor conditions. The court noted that despite some improvements, many issues persisted, such as severe understaffing and inadequate supervision, contributing to violence and unsafe conditions. The court also found deficiencies in use-of-force training, incident reporting, and investigations, which exacerbated the problems.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to retain the new injunction, finding that ongoing constitutional violations justified continued prospective relief. However, the appeals court found the new injunction overly broad in some respects and held that the district court did not abuse its discretion in appointing a receiver. The court also noted that the district court failed to make sufficient need-narrowness-intrusiveness findings for each of the receiver's duties as required under the Prison Litigation Reform Act. Consequently, the appeals court affirmed the district court's decision in part, reversed in part, and remanded for further proceedings to address these issues. View "United States v. Hinds County Board of Supervisors" on Justia Law

John Doe, an individual with a serious mental illness, sued James V. McDonald, M.D., New York’s Commissioner of Health, and other defendants, seeking declaratory and injunctive relief under the Americans with Disabilities Act, the Rehabilitation Act, the Fair Housing Act, and Article 78 of the New York Civil Practice Law and Rules. Doe alleged that New York State regulations discriminated against him by preventing his readmission to Oceanview Manor Home for Adults, a Transitional Adult Home (TAH) where he previously resided. After filing the suit, the State allowed Doe to return to Oceanview, amended the regulations to permit readmission of former TAH residents with serious mental illness, and removed Oceanview’s classification as a TAH.The United States District Court for the Northern District of New York denied the State’s motion for summary judgment, which argued that Doe lacked standing. The district court granted the State leave to file an interlocutory appeal. On appeal, the State contended that the district court erred in finding standing because Doe lacked a concrete plan to leave and seek readmission to Oceanview.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the State’s jurisdictional challenge should be assessed as a question of mootness, not standing, because it addressed events occurring after Doe filed the suit. The court found that Doe’s suit was moot because the State had allowed Doe to return to Oceanview, amended the regulations, and removed Oceanview’s TAH classification. Consequently, there was no reasonable expectation that the alleged violation would recur.The Second Circuit dismissed the appeal, vacated the district court’s order, and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "Doe v. McDonald" on Justia Law

Following public outcry over "Pride Month" displays in St. Tammany Parish's public libraries, the Parish Council passed a resolution that vacated the terms of the Library Board of Control members, staggered those terms in accordance with Louisiana law, and appointed new Board members. Three ousted Board members—Anthony Parr, Rebecca Taylor, and William McHugh, III—sued under 42 U.S.C. § 1983, asserting viewpoint-discrimination, free-speech, retaliation, and substantive-due-process claims against the Council and Councilman David Cougle. They sought declaratory and injunctive relief to prevent the resolution from taking effect.The United States District Court for the Eastern District of Louisiana ruled that the legislative privilege was inapplicable because the resolution was not "legislative" in nature. Defendants brought an interlocutory appeal challenging this ruling. Before addressing the legislative privilege issue, the United States Court of Appeals for the Fifth Circuit examined whether the plaintiffs had standing to bring their claims.The Fifth Circuit concluded that the plaintiffs lacked standing. The court found that the plaintiffs' alleged speech-related injuries were not particularized, as they were tied to their positions as Board members and affected all members equally. Additionally, the court determined that the plaintiffs' alleged reputational injuries were neither fairly traceable to the defendants' conduct nor redressable by a favorable decision. Consequently, the court vacated the district court's order and remanded with instructions to dismiss the plaintiffs' claims for lack of subject matter jurisdiction. View "Parr v. Cougle" on Justia Law

Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law

Frankie Greer filed a lawsuit against the County of San Diego under 42 U.S.C. § 1983, claiming he suffered serious injuries while incarcerated in the San Diego Central Jail. During discovery, Greer requested documents from the County’s Critical Incident Review Board (CIRB) meetings related to in-custody deaths. The CIRB’s purpose is to consult with legal counsel on incidents that may lead to litigation, assess civil exposure, and recommend remedial actions. The district court ruled that the CIRB documents were not protected by attorney-client privilege, as the CIRB served multiple purposes beyond obtaining legal advice. After Greer settled his claims, several media organizations intervened to unseal the CIRB documents.The United States District Court for the Southern District of California denied the County’s motion for reconsideration and ordered the production of the CIRB documents, which were then produced under an attorneys’-eyes-only protective order. The district court also granted the media organizations' motion to intervene and unseal the documents, leading to the County’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the appeal was not moot, as effective relief could still be provided by ordering the return or destruction of the CIRB documents. The court determined that the attorney-client privilege applied to the CIRB documents, as the primary purpose of the CIRB meetings was to obtain legal advice regarding potential litigation and to avoid future liability. The court found that the district court had made significant legal errors in its determination and that the County had not waived the privilege. The Ninth Circuit reversed the district court’s order and remanded with instructions to require the return and/or destruction of the privileged documents. View "GREER V. COUNTY OF SAN DIEGO" on Justia Law

Plaintiffs, a group of charter-boat operators and trade associations in Maryland, sued the Atlantic States Marine Fisheries Commission to enjoin the Commission’s striped-bass plan. The Commission, formed in 1942, recommends fishery management plans to its member states. Plaintiffs argued that the plan, which included a one-fish limit for charter boats, would significantly harm their businesses. They sought an injunction to prevent the implementation of the plan.The United States District Court for the District of Maryland denied Plaintiffs’ motion for a preliminary injunction. The court found that Plaintiffs likely lacked standing because they were regulated by Maryland, not the Commission. The court noted that even if the Commission’s plan were enjoined, it was unlikely that Maryland would rescind its own regulations, which were stricter than the Commission’s recommendations. The court also found that Plaintiffs did not plausibly state a claim for relief under 42 U.S.C. § 1983, as the Commission is not a “person” under the statute and does not act under “color of state law.”The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Plaintiffs lacked standing to sue. The court held that Plaintiffs failed to plausibly allege that Maryland would likely rescind its regulations if the Commission’s plan were enjoined. The court emphasized that Maryland voluntarily adopted the regulations and had the authority to impose stricter measures than those recommended by the Commission. As a result, the court vacated the district court’s order denying the preliminary injunction and remanded the case with instructions to dismiss for lack of jurisdiction. View "Delmarva Fisheries Association, Inc. v. Atlantic States Marine Fisheries Commission" on Justia Law

In June 2015, Dylann Roof shot and killed nine people at Mother Emanuel AME Church in Charleston, South Carolina, including M.P.'s father, Reverend Clementa Pinckney. M.P., a minor, filed a lawsuit against Meta Platforms, Inc. (formerly Facebook, Inc.) and its subsidiaries, alleging that Facebook's algorithm recommended harmful content that radicalized Roof, leading to the murders. M.P. asserted claims of strict products liability, negligence, and negligent infliction of emotional distress under South Carolina law, as well as a federal claim under 42 U.S.C. § 1985(3) for conspiracy to deprive her of her civil rights.The United States District Court for the District of South Carolina dismissed M.P.'s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Section 230 of the Communications Decency Act barred her state law tort claims. The court also found that M.P. failed to plausibly allege a claim under 42 U.S.C. § 1985(3).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that M.P.'s state law tort claims were barred by Section 230 because they sought to hold Facebook liable as a publisher of third-party content. The court also determined that M.P. failed to plausibly allege proximate causation under South Carolina law, as her complaint did not provide sufficient factual foundation linking Roof's Facebook use to his crimes. Additionally, the court found that M.P. forfeited her challenge to the dismissal of her Section 1985 claim by not adequately addressing it in her appellate brief. The court also concluded that any potential claim under 42 U.S.C. § 1986 was barred by the one-year statute of limitations. Thus, the Fourth Circuit affirmed the district court's judgment granting Facebook's motion to dismiss. View "M.P. v. Meta Platforms Inc." on Justia Law

Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law