Justia Civil Rights Opinion Summaries

Columbia Basin College officials terminated R.W. from the nursing program after learning that he had sought medical treatment for homicidal thoughts about three instructors. R.W. filed suit seeking damages, reinstatement in the nursing program, and expungement of his failing grades.   On interlocutory appeal, the Ninth Circuit  (1) affirmed the district court’s order determining that Plaintiff’s suit for injunctive relief against Columbia Basin College officials in their official capacity could proceed under the Ex parte Young exception to Eleventh Amendment sovereign immunity; and (2) dismissed in part defendants’ appeal for lack of jurisdiction in plaintiff R.W.’s action alleging First Amendment violations and other claims arising from his termination from a nursing program at Columbia Basin College.   The panel held that R.W.’s complaint alleged an ongoing violation of his constitutional rights given the uncertainty as to whether he could reenroll in the nursing program or qualify for financial aid; his claim for prospective relief was not moot; and the Dean of Student Conduct was a proper defendant because he was directly involved with the alleged constitutional violations and there was a question of fact as to whether he had authority to implement injunctive relief if so ordered.   the panel held that it lacked jurisdiction to review the district court’s order declining to reconsider its prior partial summary judgment for R.W. on his 42 U.S.C. Section 1983 claim for violation of the First Amendment. The merits of R.W.’s First Amendment claim were severable from, and neither necessary to nor necessarily resolved by, the district court’s ruling on the Ex parte Young issue and were reviewable upon entry of final judgment. View "R. W. V. COLUMBIA BASIN COLLEGE, ET AL" on Justia Law

The Church of St. Theresa (St. Theresa’s) owned and operated the St. Theresa School. St. Theresa’s terminated art teacher and toddler room caregiver Victoria Crisitello for violating the terms of her employment agreement. That agreement required employees to abide by the teachings of the Catholic Church and forbade employees from engaging in premarital sex; Crisitello, who was unmarried, had become pregnant. In response to her firing, Crisitello filed a complaint against St. Theresa’s alleging employment discrimination in violation of the Law Against Discrimination (LAD), based on pregnancy and marital status. St. Theresa’s countered that its decision to terminate Crisitello was protected by both the First Amendment and the LAD. The New Jersey Supreme Court held: (1) the “religious tenets” exception of N.J.S.A. 10:5-12(a) was an affirmative defense available to a religious entity when confronted with a claim of employment discrimination; and (2) the uncontroverted fact was that St. Theresa’s followed the religious tenets of the Catholic Church in terminating Crisitello. The Court thus concluded St. Theresa’s was entitled to summary judgment and that the trial court correctly dismissed the complaint with prejudice. View "Crisitello v. St. Theresa School" on Justia Law

Petitioner is a former employee of International Business Machines Corporation (“IBM”) who signed a separation agreement requiring confidential arbitration of any claims arising from her termination. Petitioner arbitrated an age-discrimination claim against IBM and won. She then filed a petition in federal court under the Federal Arbitration Act (“FAA”) to confirm the award, attaching it to the petition under seal but simultaneously moving to unseal it. Shortly after she filed the petition, IBM paid the award in full. The district court granted Petitioner’s petition to confirm the award and her motion to unseal. On appeal, IBM argued that (1) the petition to confirm became moot once IBM paid the award, and (2) the district court erred in unsealing the confidential award.   The Second Circuit vacated the district court’s confirmation of the award and remanded with instructions to dismiss the petition as moot. The court reversed the district court’s grant of the motion to unseal. The court explained that Petitioner’s petition to confirm her purely monetary award became moot when IBM paid the award in full because there remained no “concrete” interest in enforcement of the award to maintain a case or controversy under Article III. Second, any presumption of public access to judicial documents is outweighed by the importance of confidentiality under the FAA and the impropriety of Petitioner’s effort to evade the confidentiality provision in her arbitration agreement. View "Stafford v. Int'l Bus. Machs. Corp." on Justia Law

Plaintiff, a former employee, sued on behalf of herself and similarly situated employees, claiming that St. Luke’s violated the Fair Labor Standards Act’s (“FLSA”) overtime provisions by failing to fully compensate employees for work performed. She also brought an unjust-enrichment claim under state law. The district court certified two classes with different lookback periods: (1) an FLSA collective comprised of employees who worked for St. Luke’s between September 2016 and September 2018, 1 and (2) an unjust-enrichment class comprised of all employees who worked for St. Luke’s in Missouri between April 2012 and September 2018. Houston also asserted individual claims, one under the Missouri Minimum Wage Law, and one for breach of her employment contract. The district court granted summary judgment to St. Luke’s on all claims.   The Eighth Circuit vacated and remanded. The court explained that Plaintiff has raised a genuine dispute that the rounding policy does not average out over time. The court explained that no matter how one slices the data, most employees and the employees as a whole fared worse under the rounding policy than had they been paid according to their exact time worked. Here, the rounding policy did both. It resulted in lost time for nearly two-thirds of employees, and those employees lost more time than was gained by their coworkers who benefited from rounding. The court concluded that the employees have raised a genuine dispute that the rounding policy, as applied, did not average out over time. The district court, therefore, erred in granting summary judgment on the FLSA and Missouri wage claims. View "Torri Houston v. St. Luke's Health System, Inc." on Justia Law

Petitioner filed a 1983 claim, arguing that he was held in administrative segregation for 300 days over his 30-day disciplinary sentence without additional due process, such as new disciplinary hearings or periodic review of his custody status. The magistrate judge reviewed Petitioner's suit under 28 USC 1915(e) and 1915A and issued a Report and Recommendation recommending that Petitioner's federal claims be dismissed with prejudice as legally frivolous and for failure to state a claim. The district court reviewed and adopted the magistrate judge’s report, dismissing Petitioner's 1983 suit with prejudice as frivolous and for failure to state a claim.The Fifth Circuit reversed, finding that the district court failed to apply the appropriate, multi-faceted legal test considering the conditions and length of confinement, and thus, dismissing the Petition was an abuse of discretion. View "Carmouche v. Hooper" on Justia Law

Plaintiff was a passenger in a car that led West Memphis Police Department (WMPD) officers on a dangerous chase. He was shot and killed when officers tried to stop the car, and his estate sued them under 42 U.S.C. Section 1983 for excessive force and state-created danger. The district court granted summary judgment to the officers.   The Eighth Circuit affirmed. The court explained that it is undisputed that Plaintiff had his hands up. And the court has no doubt that shooting into the car posed a substantial risk of serious bodily harm to him. But the driver had just led police on a reckless, high-speed chase, which involved swerving into oncoming traffic, hitting a police car, and resisting efforts to stop the car by other means. By the time officers started shooting, the car had run over one officer’s legs and was headed toward others. Here, the court wrote that all things considered, officers acted reasonably in using deadly force, and the district court didn’t err in granting summary judgment. View "Estate of De'Angelo Brown v. E.C. West" on Justia Law

After receiving a long suspension, Jacob Doe sued Virginia Polytechnic Institute and State University (“Virginia Tech”) and several university officials, alleging that Virginia Tech’s Title IX investigation, hearing, and appeal process denied him due process of law. The district court dismissed Doe’s complaint, holding that he hadn’t alleged a cognizable liberty or property interest in his continuing education.   The Fourth Circuit affirmed for a different reason. The court held that even assuming Doe has such an interest, he hasn’t alleged that he was deprived of it without sufficient process. The court wrote that Doe complains that his witnesses couldn’t appear in person at the hearing because it was held during the summer. But he doesn’t allege that the witnesses weren’t able to provide testimony by phone, video, or in writing. Nor does Doe claim he sought to continue the hearing until his witnesses were available. And Doe admits that the investigator interviewed his witnesses during her investigation into Roe, and the allegations against Roe were adjudicated at the same hearing. So these allegations too, don’t rise to the level of a due-process violation.   Moreover, the court explained that to find that Doe alleged a due-process violation on this sparse record, the court would have to hold that university students have a right—in effectively every disciplinary hearing—to advance notice of the evidence to be presented against them. The ask is even more striking here because Doe doesn’t allege that he sought a continuance or that Virginia Tech relied on the surprise testimony. Therefore, the court rejected Doe’s claim of error. View "Jacob Doe v. Virginia Polytechnic Institute and State Universit" on Justia Law

Plaintiff worked for Tug Hill Operating, LLC, for approximately a year and a half at rig sites in West Virginia. He commenced an action against Tug Hill under the Fair Labor Standards Act (“FLSA”), alleging that while Tug Hill formally classified him as an independent contractor, he actually qualified as an employee for purposes of the FLSA based on the degree of control that Tug Hill exercised over his work. He, therefore, claimed that Tug Hill was required to pay him overtime for those weeks in which he worked more than 40 hours. Tug Hill filed a motion to dismiss Plaintiff’s action on the ground that Plaintiff was contractually required to arbitrate his claim against it. In addition, RigUp itself filed a motion to intervene in order to seek the action’s dismissal in favor of arbitration. The district court granted both motions.   The Fourth Circuit reversed both rulings and remanded. The court explained that the numerous provisions in the Agreement preclude any conclusion that the Agreement was entered into solely or directly for the benefit of Tug Hill, such that Tug Hill could enforce it as a third-party beneficiary. Accordingly, the district court erred in granting Tug Hill’s motion to dismiss and compelling Plaintiff, under the arbitration agreement between him and RigUp, to proceed to arbitration with respect to his FLSA claim against Tug Hill. Moreover, the court explained that because RigUp’s agreement with Plaintiff expressly disclaimed any interest in any litigation, Plaintiff might have with a company in Tug Hill’s position RigUp cannot now opportunistically claim that intervention is necessary. View "Lastephen Rogers v. Tug Hill Operating, LLC" on Justia Law

A Virginia statute required the automatic suspension of residents’ driver’s licenses if they failed to pay certain court fines and fees. in 2016, a group of indigent Virginians who lost their licenses when they were unable to pay court debts initiated a putative class action against the Commissioner of the Virginia Department of Motor Vehicles (“Commissioner”), alleging that the Commonwealth’s license-suspension scheme was unconstitutional. The plaintiffs raised several claims under the Fourteenth Amendment: that the statute’s requirement of automatic suspension without notice or a hearing violated their procedural due process rights; and that the statute’s enforcement against those who were unable, not unwilling, to pay violated both their substantive due process rights and their equal protection rights. As relief, the plaintiffs sought preliminary and permanent injunctions preventing the statute’s enforcement and requiring license reinstatement to the “hundreds of thousands of Virginians” with suspended licenses. Plaintiffs then petitioned for attorney’s fees under 42 U.S.C. Section 1988(b), which provides that the district court, “in its discretion, may allow the prevailing party” in Section 1983 actions “a reasonable attorney’s fee as part of the costs.”   The Fourth Circuit vacated the district court’s denial of attorney’s fees and remanded. The court held that Plaintiffs here prevailed” in every sense needed to make them eligible for a fee award. The court explained that the named plaintiffs sought not only reinstatement of their own licenses but also class certification, a declaratory judgment that Section 46.2-395 was unconstitutional, and hence permanent license reinstatement for hundreds of thousands of Virginians. Those are precisely the kinds of considerations that bear on the “extent of a plaintiff’s success” – a critical factor in assessing a reasonable fee award in any fee litigation under Section 1988. View "Damian Stinnie v. Richard Holcomb" on Justia Law

High-level officials in the California prison system transferred 122 inmates from the California Institution for Men, where there was a widespread COVID-19 outbreak, to San Quentin State Prison, where there were no known cases of the virus. The transfer sparked an outbreak of COVID-19 at San Quentin that ultimately killed one prison guard and over twenty-five inmates. The guard’s family members sued the prison officials, claiming that the officials violated the guard’s due process rights. The officials moved to dismiss, arguing that they were entitled to qualified immunity. The district court denied the motion with respect to some of the officials, who then filed an interlocutory appeal.   The Ninth Circuit affirmed the district court’s denial of Defendants’ motion to dismiss. The panel held that based on the allegations in the complaint, Defendants were not entitled to qualified immunity. Plaintiffs sufficiently alleged a violation of the guard’s substantive due process right to be free from a state-created danger, under which state actors may be liable for their roles in creating or exposing individuals to danger they otherwise would not have faced. The panel held that the unlawfulness of defendants’ alleged actions was clearly established by the combination of two precedents: L.W. v. Grubbs, 974 F.2d 119 (9th Cir. 1992), which recognized a claim under the state-created danger doctrine arising out of a prison’s disregard for the safety of a female employee who was raped after being required to work alone with an inmate known to be likely to commit a violent crime if placed alone with a woman; and Pauluk v. Savage, 836 F.3d 1117 (9th Cir. 2016). View "PATRICIA POLANCO, ET AL V. RALPH DIAZ, ET AL" on Justia Law