Justia Civil Rights Opinion Summaries

A man was arrested for being part of a scheme to take a picture of Senator Thad Cochran’s late wife in the privacy of her nursing room home. One month later, the man was found dead in his home, seemingly from suicide. His widow, sons, and estate filed a complaint alleging 42 U.S.C. Section 1983 claims, as well as various tort claims against state and private actors involved in his arrest and prosecution. The complaint alleges that the man was subject to a politically motivated prosecution that deprived him of his constitutional rights, shut down his law practice, and humiliated him and his family, causing severe emotional distress—all of which directly led to his suicide. Defendants filed a motion to dismiss all claims. The district court granted summary judgment for the City of Madison and Mayor Hawkins-Butler. Plaintiffs appealed the dismissal of their claims, the summary judgment on their Lozman claim, and several orders regarding expert testimony and discovery.   The Fifth Circuit affirmed. The court explained that here, Plaintiffs’ best evidence merely establishes that the City of Madison was aggressively pursuing those who committed a potential invasion of the privacy of an incapacitated adult. The evidence doesn’t show that the City carried out the investigation, arrest, search, or prosecution because of the man’s political views. The same is true of the Mayor. Accordingly, the district court properly granted summary judgment for the City of Madison and its Mayor. View "Mayfield v. Butler Snow" on Justia Law

Plaintiffs, survivors and the administrator of a man shot and killed by Defendant police officers filed a lawsuit alleging claims of excessive force under the Fourth Amendment and battery and negligence under Georgia law. And it demanded monetary damages. Both officers moved for summary judgment. They argued that they are entitled to qualified immunity from the claim of excessive force. They also argued that they are entitled to official immunity under Georgia law from the claims of battery and negligence. The district court denied the officers’ motions.   The Eleventh Circuit dismissed Defendants’ appeal based on a lack of jurisdiction. The court explained that it lacks appellate jurisdiction over the denial of qualified or official immunity that turns on issues of evidentiary sufficiency. The court explained that in this case, the only issues in this appeal are issues of evidentiary sufficiency. In their motions for summary judgment, the officers argued that their use of force was reasonable under the circumstances because they encountered a suspect who had brandished a gun, discharged it at least once, and ignored their commands to show his hands. The officers argued that in the light of these facts when they saw the man move, they had actual and probable cause to use deadly force on him. View "Joshua Paul English, et al v. Officer Jonathan Fowler, et al" on Justia Law

Plaintiffs in this case are three sales representatives who alleged that their employer, a food-products distributor, did not pay them the overtime wages to which they were entitled under the Fair Labor Standards Act (“FLSA” or “Act”). Their employer defended on the ground that the plaintiffs fell within the Act’s “outside sales” exemption, which excuses overtime pay for employees who work outside the office and whose primary duty is making sales. The district court found that Plaintiffs were owed overtime pay because their employer had failed to prove, by clear and convincing evidence, that they came within the outside sales exemption. The court also awarded liquidated damages to Plaintiffs, finding that the employer had not shown objectively reasonable grounds for the challenged pay practices. The court concluded, the Plaintiffs had not shown that their employer willfully violated the Act. Both parties appealed: The employer challenged the district court’s liability finding and its award of liquidated damages, and Plaintiffs cross-appealed the court’s willfulness finding and attendant application of the two-year statute of limitations.   The Fourth Circuit affirmed. The court explained that there is ample evidence in the record to support the court’s finding that the defendants had only an “aspirational” and not a “concrete” sense of what their sales representatives did and, specifically, their ability to make sales at chain stores. Further, the court explained that the FLSA clearly contemplates as much, establishing as the default rule both the award of liquidated damages – predicated on the absence of objective reasonableness – and a two-year statute of limitations – predicated on a non-willful violation. View "Faustino Carrera v. E.M.D. Sales Inc." on Justia Law

Petitioners moved to quash trial subpoenas issued by the United States Bankruptcy Court for the Central District of California, requiring them to testify via contemporaneous video transmission from their home in the U.S. Virgin Islands. The bankruptcy court denied their motions, and the Petitioners sought mandamus relief from this court. Petitioners argued that Federal Rule of Civil Procedure 45(c)(1) prohibits the bankruptcy court from compelling them to testify, even remotely, where they reside out of state over 100 miles from the location of the trial.   The Ninth Circuit granted the petition. The panel held that the bankruptcy court erred in refusing to quash the trial subpoenas because, under the plain meaning of the text of the Rules, the geographic limitations of Rule 45(c) apply even when a witness is permitted to testify by contemporaneous video transmission. The panel concluded that Rule 45(c) governs the court’s power to require a witness to testify at trial and focuses on the location of the proceeding, while Rule 43(a) governs the mechanics of how trial testimony is presented. Weighing the Bauman factors to determine whether issuance of a writ of mandamus was appropriate, the panel concluded that the third factor, clear error, weighed in favor of granting mandamus relief. The panel concluded that the fifth Bauman factor also weighed in favor because the petition presented an important issue of first impression. The panel held that the third and fifth Bauman factors were sufficient on their own to warrant granting mandamus relief in this case. View "IN RE: JOHN KIRKLAND, ET AL V. USBC, LOS ANGELES" on Justia Law

Plaintiffs individually and as next friends of their minor daughter, I.B., appealed the district court’s dismissal of disability discrimination and civil rights deprivation claims, and denial of their motion to reconsider dismissing with prejudice a state law negligence claim against the Bentonville, Arkansas School District (“the District”).   The Eighth Circuit affirmed. The court explained that Arkansas law provides a direct cause of action against the liability insurer of a school district that is “not subject to suit for tort.” Plaintiffs’ Complaint named “John Doe” as an additional defendant, alleged on information and belief that the District maintained liability insurance, identified the insurer as John Doe, and stated that “the joinder of [John Doe] will be made upon verification of its identity.” Eleven months later, the district court ordered Plaintiffs to show good cause for an extension of the deadline to add parties, if they opposed dismissal of the John Doe defendant without prejudice. When Plaintiffs did not respond, the district court dismissed John Doe without prejudice, leaving the District, with its statutory immunity, the only negligence defendant. Plaintiffs were not deprived of a remedy for the alleged negligence of District employees and agents. View "Rodney Baker v. Bentonville School District" on Justia Law

Plaintiff sued Defendants L.A. Central Plaza LLC and Central Liquor & Market, Inc. for alleged violations of the Americans with Disabilities Act (“ADA”). After Plaintiff moved for summary judgment on the merits, the district court instead sua sponte dismissed the case on the ground that Plaintiff’s amended complaint had failed adequately to plead the elements of Article III standing. Plaintiff timely appealed the dismissal.   The Ninth Circuit vacated and remanded. The panel held that because Plaintiff had a full and fair opportunity to prove his case as to standing, the district court had discretion in resolving Plaintiff’s summary judgment motion, to also consider sua sponte whether to grant summary judgment against Jones on the issue of standing. The panel held, however, that when presented with the issue of standing in the context of Plaintiff’s fully briefed summary judgment motion, the district court could not ignore the factual evidence of standing presented at summary judgment and instead sua sponte examine the adequacy of the complaint’s allegations of standing. View "GEORGE JONES V. L.A. CENTRAL PLAZA, LLC, ET AL" on Justia Law

Plaintiff’s claim under the Americans with Disabilities Act (“ADA”) was dismissed for lack of standing. Thereafter, the district court considered and granted Malibu Road and Bungalow Lighting’s motion for attorneys’ fees under the ADA’s fee provision. Plaintiff did not appeal the dismissal of his ADA claim for lack of standing, but he appeals the award of attorneys’ fees, arguing that his lawsuit was not frivolous. However, the issue before the court was not whether Plaintiff’s claim was frivolous and therefore justified an award of fees, but rather whether there is a basis to award attorneys’ fees under the ADA’s fee provision after the underlying claim has been dismissed on jurisdictional grounds.   The Ninth Circuit reversed and vacated. The panel held that because the district court dismissed Plaintiff’s claim for lack of standing, it lacked jurisdiction to award fees under the Americans with Disabilities Act’s fee provision, 42 U.S.C. Section 12205 View "ANTONIO FERNANDEZ V. 23676-23726 MALIBU ROAD, LLC, ET AL" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this lawsuit against the Financial Oversight and Management Board for Puerto Rico (FOMB) and its executive director challenging the FOMB's alleged failure to review a sale agreement on untimeliness grounds, holding that the dismissal was proper, albeit on standing grounds.Appellants - several Puerto Rico corporations and individuals - brought this action claiming that the FOMB's alleged failure to review a $384 million loan sale agreement between the Economic Development Bank for Puerto Rico (BDE) and a private investment company violated their constitutional rights under the Fourteenth Amendment's Due Process and Equal Protection Clauses, and a statutory violation under the Puerto Rico Oversight, Management, and Economic Stability act . The district court granted the FOMB's motion to dismiss, concluding that the claims were time-barred. The First Circuit affirmed but on different grounds, holding that Appellants lacked standing because their complaint failed to allege that the FOMB's inaction caused their claimed injury. View "R&D Master Enterprises, Inc. v. Financial Oversight & Management Bd. for P.R." on Justia Law

Plaintiff filed this action in May 2018, alleging federal claims under Section 1981 and Section 1983 and state law claims against a building inspector Troy Seguirant, the City and County of Honolulu, and other defendants. Only Plaintiff’s Section 1981 claim against Seguirant is at issue in this appeal; the district court dismissed the Section 1983 claims against Seguirant with prejudice.   The Ninth Circuit vacated the district court’s order denying qualified immunity on a claim under Section 1981, and remanding, the en banc court held that Section 1981 does not provide an implied cause of action against state actors. Joining other circuits and overruling Federation of African American Contractors v. City of Oakland, 96 F.3d 1204 (9th Cir. 1996), the en banc court held that Section 1981, as amended in 1991, establishes substantive rights that a state actor may violate but does not itself contain a remedy against a state actor for such violations. Thus, a plaintiff seeking to enforce rights secured by Section 1981 against a state actor must bring a cause of action under 42 U.S.C. Section 1983. The en banc court remanded with instructions to allow the plaintiff to replead his Section 1981 claim as a Section 1983 claim. View "HITOSHI YOSHIKAWA V. TROY SEGUIRANT, ET AL" on Justia Law

Carrie Pueblo brought an action against her former domestic partner, Rachel Haas seeking joint custody and parenting time for a child whom Haas conceived through in vitro fertilization and gave birth to in 2008, during the parties’ relationship. Haas moved for summary judgment, arguing that because the parties had never married and Pueblo had no biological or adoptive relationship to the child, Pueblo lacked standing to sue and also failed to state a claim for which relief could be granted. The trial court granted the motion and dismissed the case without prejudice. After Haas moved for reconsideration, the trial court dismissed the action with prejudice. Pueblo then filed her own motion for reconsideration, arguing that she had standing as a natural parent, despite the lack of genetic connection, following the Court of Appeals decision in LeFever v. Matthews, 336 Mich App 651 (2021), which expanded the definition of “natural parent” to include unmarried women who gave birth as surrogates but shared no genetic connection with the children. Pueblo also argued the trial court order violated her Fourteenth Amendment rights to due process and equal protection, as well as those of the child. Furthermore, Pueblo argued that any dismissal should have been without prejudice. The trial court denied reconsideration, distinguishing LeFever on the ground that Pueblo had not given birth to the child. Pueblo appealed, reasserting her previous arguments and further asserting that the equitable-parent doctrine should extend to the parties’ relationship, which had been solemnized in a civil commitment ceremony when it was not yet legal in Michigan for same-sex partners to marry. The Court of Appeals rejected these arguments and affirmed the trial court. Because Michigan unconstitutionally prohibited same-sex couples from marrying before Obergefell v. Hodges, 576 US 644 (2015), the Michigan Supreme Court narrowly extended the equitable-parent doctrine as "a step toward righting the wrongs done by that unconstitutional prohibition. A person seeking custody who demonstrates by a preponderance of the evidence that the parties would have married before the child’s conception or birth but for Michigan’s unconstitutional marriage ban is entitled to make their case for equitable parenthood to seek custody." The trial court's judgment was reversed and the case remanded for that court to apply the threshold test for standing announced here. View "Pueblo v. Haas" on Justia Law