Justia Civil Rights Opinion Summaries

This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

In 2011, Veronica-May Clark, an incarcerated transgender woman, was repeatedly sexually assaulted by corrections officer Thomas Hanley. More than seven years after the abuse, Clark filed a lawsuit against Hanley and other officers, alleging violations of her Eighth Amendment rights and seeking equitable tolling of the statute of limitations due to the traumatic effects of the abuse. After holding an evidentiary hearing on the issue of equitable tolling, the United States District Court for the District of Connecticut (Meyer, J.) denied Clark's claim for equitable tolling and dismissed her case as untimely. Clark appealed, claiming that the court improperly conducted factfinding at the pleading stage and violated her Seventh Amendment rights. The United States Court of Appeals for the Second Circuit affirmed the district court's ruling, finding that the court properly resolved Clark's equitable tolling claim and did not infringe her Seventh Amendment rights. View "Clark v. Hanley" on Justia Law

The Supreme Court of Pennsylvania held that the Pennsylvania Department of Corrections (DOC) had violated the procedural due process rights of an inmate, Thomas Washington. The DOC had increased the rate at which it garnished Washington’s prison account to pay for his court-ordered financial obligations, without giving him prior notice or an opportunity to challenge this increase. The court rejected the DOC's argument that the increase was mandated by a legislative amendment and that no discretion was available for the DOC to alter the rate. The court held that the amendment to the law did not remove the obligation for the DOC to follow due process requirements before increasing the rate of deductions from inmates' accounts. The court reversed the lower court's decision, which had dismissed Washington's complaint, and remanded the case for further proceedings. The court noted that even if Washington was not ultimately entitled to a return of the additional funds, he had a right to make his case before the increased deductions occurred. View "Washington v. PA Dept. of Corrections" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit examined the constitutionality of Cook County, Illinois's use of cameras to record holding cell toilets in courthouses throughout the county. The plaintiffs, pretrial detainees, claimed that the cameras infringed upon their Fourth Amendment privacy interests and also constituted an intrusion upon seclusion under Illinois law. The district court granted summary judgment in favor of the defendants, Cook County and Sheriff Thomas J. Dart, and the plaintiffs appealed.The Court of Appeals held that the plaintiffs did not have a reasonable expectation of privacy when using the toilets in courthouse holding cells. While it acknowledged that there are questions around the extent to which detainees have a reasonable expectation of privacy in their bodies while in a holding cell, it found that any privacy rights are substantially diminished. The court further held that Cook County's use of cameras in courthouse holding cells was reasonable due to the security risks inherent in the setting. The court also determined that one of the plaintiffs, Alicea, had standing to sue, but the other plaintiffs did not.Furthermore, the court affirmed the district court's decision to grant summary judgment on the plaintiffs' claim for intrusion upon seclusion. It held that the plaintiff had not met his burden on the fourth element of the claim, anguish and suffering.Lastly, the court affirmed the district court's decisions related to discovery and attorneys' fees. The court held that the district court did not abuse its discretion in these decisions. Thus, the judgment of the district court was affirmed. View "Alicea v. County of Cook" on Justia Law

This case involves Delta Charter Group, Inc. (Delta), a public charter school operating within Concordia Parish in Louisiana. The case has its roots in a 1965 lawsuit against the Concordia Parish School Board for operating segregated schools in violation of the Fourteenth Amendment. The district court approved a desegregation plan, but the Board has yet to achieve unitary status, and Delta, which had intervened in the ongoing desegregation case, was required by a 2013 consent order to comply with the Board's desegregation decree. A second consent order in 2018 outlined a race-based enrollment process for Delta, giving the highest enrollment preference to black students.Four years later, Delta moved to discontinue the race-based enrollment process, arguing that it was unconstitutional. The district court declined to modify the order under Federal Rule of Civil Procedure 60(b)(5), which allows courts to modify or dissolve a consent decree if applying it prospectively is no longer equitable. Delta failed to show a significant change in factual conditions or in law that would justify modification. The United States Court of Appeals for the Fifth Circuit affirmed the judgment of the district court, stating that Delta had forfeited any argument that the district court had abused its discretion by failing to adequately brief the argument on appeal. The court did not offer any opinion on the underlying constitutional merits, as Delta had forfeited any available argument that the district court should have applied Rule 54(b) and that it had abused its discretion in denying relief under Rule 60(b)(5). View "Delta Charter v. Sch Bd Concordia Prsh" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit ruled on a motion to intervene in an appeal filed by a coalition of civil rights organizations. The original lawsuit was brought by the Association for Education Fairness against the Montgomery County Board of Education and its superintendent, alleging that a new admissions policy for magnet schools in the county was discriminatory against Asian American students. The district court dismissed the case, ruling that the admissions policy was not enacted with discriminatory intent and did not have a disparate impact on Asian American students.After the Association appealed the district court's decision, the civil rights organizations moved to intervene in the appeal. They argued that the Board may not adequately defend the district court's disparate impact holding on appeal. However, the Board assured the court that it intended to defend this holding.The Court of Appeals denied the motion to intervene without prejudice, stating that it trusted the Board's representation that it would defend the disparate impact holding. The court also noted that if the organizations were granted intervention, their rights would be largely the same as those of amici, or friends of the court. They would be able to file a separate brief and attempt to participate in oral argument, both of which they could also do as amici. The court also found that the organizations' argument that they needed to be parties in order to participate in potential future Supreme Court proceedings was speculative and contingent on unknown factors. As a result, the court found no need to grant the motion to intervene. View "Association for Education Fairness v. Montgomery County Board of Education" on Justia Law

In the case before the United States Court of Appeals for the Second Circuit, Ateres Bais Yaakov Academy of Rockland (ABY) sued the Town of Clarkstown, George Hoehmann, CUPON Inc., and Citizens United to Protect Our Neighborhoods of Greater Nanuet Inc. ABY, a religious educational institution, planned to purchase property in Clarkstown, New York, to establish an Orthodox Jewish school. It alleged that the Defendants manipulated an ostensibly neutral building permit application and zoning appeals process to block this construction. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that ABY's religious discrimination and civil rights claims were not ripe as it had not received a final decision from the town’s Zoning Board of Appeals (ZBA) and that the lost-contract injury underpinning ABY’s tortious interference claim was not traceable to the Town Defendants.In this appeal, the Second Circuit disagreed with the district court. The Second Circuit found that the ZBA's refusal to adjudicate ABY's appeal of its permit application constituted a final decision for ripeness purposes. The court also determined that ABY had plausibly alleged a causal connection between the Town Defendants’ actions and the injuries resulting from ABY's lost contract with Grace Church. Therefore, the Second Circuit reversed the district court's judgment and remanded the case for further proceedings. View "Ateres Bais Yaakov Academy of Rockland v. Town of Clarkstoawn" on Justia Law

In a class action suit brought by George Mandala and Charles Barnett against NTT Data, Inc., the plaintiffs argued that NTT's policy of not hiring individuals with a felony conviction disproportionately impacted Black applicants, constituting disparate impact discrimination under Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed the plaintiffs' complaint, and that decision was affirmed by the United States Court of Appeals for the Second Circuit. The plaintiffs then filed a motion to vacate the dismissal judgment and sought leave to file a first amended complaint, which the district court denied as untimely under Federal Rule of Civil Procedure 60(b)(1).On appeal, the Second Circuit reversed the district court's decision, holding that the plaintiffs' motion should have been evaluated under Rule 60(b)(6) rather than Rule 60(b)(1). Rule 60(b)(6) allows for relief from a judgment under "extraordinary circumstances," which the court found to be present in this case. The court reasoned that the plaintiffs had not previously had a chance to amend their complaint, and that their decision to stand by their initial complaint was not unreasonable given that its sufficiency had been a point of dispute. Additionally, the court found that the proposed amendments to the complaint were not futile. Consequently, the Second Circuit ordered the case to be remanded to the district court for further proceedings consistent with its opinion. View "Mandala v. NTT Data, Inc." on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Rudolph Betancourt, a disabled individual, filed a lawsuit against Indian Hills Plaza LLC, the owner of a shopping plaza, citing violations of the Americans with Disabilities Act (ADA). The plaintiff experienced difficulties accessing the shopping plaza due to his disability. The parties agreed that the defendant had violated the ADA in 17 aspects, and Indian Hills Plaza LLC undertook remediation measures. The district court awarded Betancourt $12,000 in attorney's fees and costs. However, Betancourt appealed this decision, believing he was entitled to more.The main issue on appeal was the challenge to the district court's award of attorney’s fees and costs. The Court of Appeals affirmed the District Court's decision, finding no abuse of discretion. The court explained that the district court properly calculated the lodestar amount (reasonable hourly rate multiplied by the reasonable number of hours worked), which serves as a baseline for attorney's fees. It reduced the hourly rate considering the quality of the performance of Betancourt’s attorney and reduced the number of hours billed by 20% due to excessive billing. The court further reduced the attorney’s fees award based on deficiencies in the actions by Betancourt’s counsel during the litigation. The district court also deemed the requested expert costs as unreasonable and reduced them.Therefore, the holding of the case is that the district court did not abuse its discretion in awarding $12,000 in attorney’s fees and costs to the plaintiff, and that the court properly calculated the lodestar amount and adjusted it based on relevant considerations. The court also held that the plaintiff's attorney's premature fee motions, not the defendant's opposition to those motions, caused the excessive fees. View "Betancourt v. Indian Hills Plaza LLC" on Justia Law

The U.S. Court of Appeals for the District of Columbia Circuit ruled on an appeal by former President Donald J. Trump regarding his claim of presidential immunity from civil damages liability related to the January 6, 2021, Capitol riot. Plaintiffs included Capitol Police officers and members of Congress who alleged that Trump, through his actions and speech, incited the riot that resulted in physical injuries and emotional distress.The court determined that, at this stage in the proceedings, Trump has not demonstrated an entitlement to presidential immunity. It distinguished between actions carried out in a president’s official capacity, which are protected by immunity, and those carried out in a private or unofficial capacity, which are not. The court rejected Trump's argument that presidential speech on matters of public concern is always an official function, stating that such speech can be either official or unofficial depending on context.The court also rejected Trump's claim that his actions leading up to and on January 6 were official because they were under his Article II duty to "take Care that the Laws be faithfully executed," stating that this claim is not independent of his ability to show that he engaged in the relevant actions in his official capacity as President rather than his unofficial capacity as a presidential candidate.The court held that Trump's actions as alleged in the complaints, if proven to be true, were carried out in his capacity as a presidential candidate, not as the sitting President. Therefore, he is subject to civil suits like any private citizen. However, the court specified that Trump must be allowed to present facts and make arguments in the district court that his actions were taken in his official capacity. View "Blassingame v. Trump" on Justia Law