Justia Civil Rights Opinion Summaries

Universal Life Church Monastery permits anyone who feels called to become ordained as a minister—over the Internet, free of charge, in a matter of minutes. Tennessee law permits only those “regular” ministers—ministers whose ordination occurred “by a considered, deliberate, and responsible act”—“to solemnize the rite of matrimony.” Tenn. Code 36-3-301(a)(1)–(2). Since 2019, the law has explicitly clarified that “[p]ersons receiving online ordinations may not solemnize the rite.”Asserting that those restrictions violate the federal and Tennessee constitutions, ULC and its members sued several Tennessee officials, seeking an injunction and declaratory judgment. The officials claimed sovereign immunity and that the plaintiffs lacked standing to sue. The district court entered a preliminary injunction against several defendants. The Sixth Circuit reversed in part. No plaintiff has standing to seek relief against Governor Lee, Attorney General Slatery, District Attorney General Helper, or County Clerks Crowell, Anderson, and Knowles. The plaintiffs have standing to sue District Attorneys General Dunaway, Pinkston, and Jones, and County Clerk Nabors. The court noted that county clerks have no discretion to inspect officiants’ credentials or to deny licenses on that basis; state law deems issuance of the licenses a ministerial duty. View "Universal Life Church Monastery Storehouse v. Nabors" on Justia Law

Under the 2020 Racial Justice Act, “[t]he state shall not seek or obtain a criminal conviction or seek, obtain, or impose a sentence on the basis of race, ethnicity, or national origin” (Pen. Code 745 (a)). The Act's discovery provision allows a defendant, “[u]pon a showing of good cause,” to obtain evidence from the prosecution relevant to a potential violation. Based on evidence presented at his preliminary hearing, Young argued that racial profiling in a traffic stop led to his arrest for possession of Ecstasy for sale. He cited statistics showing that, statewide, blacks are more likely to be searched during traffic stops than others. He sought discovery relating to charging decisions for the past five years concerning others who were charged with or could have been charged with possession of Ecstasy for sale and related drug offenses. The trial court denied the motion.The court of appeal vacated. Borrowing from the minimal threshold showing that is required to trigger an obligation to provide “Pitchess” discovery (Evid. Code 1043(b), Young may claim entitlement to discovery under the Act if he makes a plausible case, based on specific facts, that any of the enumerated violations of section 745(a) could or might have occurred. The court must engage in a discretionary weighing of the strength of Young’s factual showing, the potential probative value of the information he seeks, and the burdens of gathering the requested information. View "Young v. Superior Court of Solano County" on Justia Law

Plaintiff sued her employer under the Age Discrimination in Employment Act (“ADEA”), claiming that Defendant engaged in unlawful age discrimination and retaliation. Plaintiff filed a motion with the district court requesting additional time so that Defendant could respond to her requests for production. The court denied the motion and Plaintiff later filed a supplement to her Rule 56(d) motion, again asking the court to defer consideration of Defendant’s summary-judgment motion and allow Plaintiff to conduct discovery, or alternatively, deny Defendant’s motion. The district court granted Defendant’s motion and entered final judgment in their favor.   The Fifth Circuit reversed the district court’s order and held that a district court cannot deny discovery rights protected by the Federal Rules of Civil Procedure. The court explained that a Rule 56(d) movant first must demonstrate that additional discovery will create a genuine issue of material fact. Here, Plaintiff identified such evidence for (1) her age-discrimination claim, and (2) her retaliation claim. The court reasoned it was an abuse of discretion for the district court to deny Plaintiff the opportunity to conduct discovery on the relevant issues in question and then fault her for having “no evidence of a causal connection” between her protected activity and the adverse employment actions. Further, the fact that Plaintiffs requests for discovery were repeatedly denied does not reveal a lack of diligence on her part. View "Bailey v. KS Mgmt Services" on Justia Law

In 2014, Tomas Beauford suffered a fatal epileptic seizure in his cell while in pretrial custody at the Mesa County Detention Facility (“MCDF”). The administrator of Beauford’s estate sued various Mesa County and medical defendants in federal district court in Colorado under 42 U.S.C. 1983, alleging they were deliberately indifferent to Beauford’s serious medical needs in violation of the Fourteenth Amendment. The district court granted summary judgment to all defendants. The Tenth Circuit reversed the district court’s grant of summary judgment as to Deputy Dalrymple, finding that whether the deputy was aware that Beauford was not breathing was a material fact in genuine dispute: “We cannot imagine a more material fact in the context of the Estate’s deliberate indifference claim than whether Deputy Dalrymple knew of the risk that Mr. Beauford was not breathing. The district court failed to account for this dispute, which a reasonable jury could resolve in favor of the Estate.” The Court affirmed summary judgment in all other respects, and remanded the case for further proceedings. View "Estate of Tomas Beauford, et al. v. Correct Care Solutions, et al." on Justia Law

In 2018, the Indiana Supreme Court held that the state holds exclusive title to Lake Michigan and its shores up to the lake’s ordinary high-water mark. The plaintiffs, who own beachfront property on Lake Michigan’s Indiana shores, believed that their property extended to the low-water mark, and filed suit, alleging that the ruling amounted to a taking of their property in violation of the Fifth Amendment–a “judicial taking.” The defendants were Indiana officeholders in their official capacities: the Governor, the Attorney General, the Department of Natural Resources Director, and the State Land Office Director.The Seventh Circuit affirmed the dismissal of the suit. None of the named officials caused the plaintiffs’ asserted injury or is capable of redressing it, so the plaintiffs lack Article III standing. View "Pavlock v. Holcomb" on Justia Law

In January 2019, Ali brought this civil rights action against Chicago and several police officers, alleging that the officers followed a city policy “of refusing to release on bond an arrestee taken into custody on an arrest warrant issued by an Illinois state court outside of Cook County.” Days before the deadline for completing fact discovery, Ali moved to certify a class. The district court granted the city’s motion to strike, noting that Ali had not added class allegations to his complaint. Ali sought leave to amend his complaint to include class allegations, arguing that he did not have evidentiary support for the existence of the city policy until a November 2019 deposition. The city replied that it had acknowledged the policy months earlier. The district court denied Ali's motion. Weeks later, Ali settled his case.On January 25, the district court dismissed the case without prejudice. Also on January 25, Miller moved to intervene under Rule 24, asserting that he was a member of Ali’s proposed class. With his motion to intervene pending, Miller filed a notice of appeal from the January 25 order. On March 24, with that appeal pending, the district court denied Miller’s motion to intervene as untimely. The Seventh Circuit affirmed. There was no operative class action complaint. Miller’s motion to intervene was untimely; he is not a party to the lawsuit and cannot pursue other challenges. View "Miller v. City of Chicago" on Justia Law

Plaintiffs, several organizations and an individual, sued the City of Pensacola (“City”) and the Secretary of State of Florida (“Secretary”) in state court because the Pensacola City Council voted to remove a Confederate cenotaph from one of the City’s parks. The complaint included both federal and state constitutional claims, a claim under 42 U.S.C. Section 1983, and state statutory and common-law claims.   Plaintiffs appealed 1) the denial of leave to file a proposed amended complaint; 2) the District Court’s grant of the City’s and the Secretary’s motions to dismiss; 3) the District Court’s denial of the motion for reconsideration of remand back to state court.   The Eleventh Circuit reversed the district court’s dismissal of Plaintiffs’ complaints against Defendants in state court with instructions for the District Court to remand this case back to state court. The court held that Plaintiffs do not have standing because their allegations do not amount to an injury under Article III. The court reasoned that standing requires Plaintiffs to allege enough facts to establish injury-in-fact, causation, and redressability. Here, most of Plaintiffs’ allegations of harm go only to the general disagreement with taking down the cenotaph and a general notion that such action by the government would violate their constitutional rights, both of which fall short of the concreteness standard under Gardner v. Mutz, 962 F.3d 1329 (11th Cir. 2020) and Diamond v. Charles, 476 U.S. 54 (1986) respectively. View "Ladies Memorial Association, Inc., et al. v. City of Pensacola, Florida, et al." on Justia Law

The Southern District of Indiana imposed a filing bar against Martin for submitting false information in an application to proceed in forma pauperis. Martin subsequently filed suit in the Northern District of Indiana under 42 U.S.C. 1983, alleging that an Indiana State Prison guard sexually assaulted him. The defendants argued that Martin had forged the signature, date, and checkmark on a grievance form to avoid summary judgment for failure to exhaust administrative remedies. Martin unsuccessfully moved to remove the allegedly falsified documents from the record and asked the court to appoint handwriting and computer experts; he alleged the defendants had tampered with the forms.The district court found that Martin had knowingly submitted an altered form and, under FRCP 56(h), barred him for two years “from filing any document in any civil case in this court until he pays all fines and filing fees due in any federal court.” The bar does not apply to appeals or to habeas corpus petitions. The court dismissed all of Martin’s pending civil cases. The Seventh Circuit affirmed. The evidence of Martin’s fraud was plain, and the court did not abuse its discretion in deciding that it did not need an expert to understand the evidence. The court reasonably concluded that a hearing would not aid its decision. “Martin’s conduct in this case and others cannot be tolerated.” View "Martin v. Redden" on Justia Law

Plaintiff Angela Gates appealed a trial court’s decision granting summary judgment to defendant, her former employer, on plaintiff’s claims for disability discrimination under the Vermont Fair Employment Practices Act (FEPA) and retaliation under both the Vermont Parental Family Leave Act (PFLA) and Vermont’s workers’ compensation law. Defendant hired plaintiff as a “molder” in 1996. In May 2015, plaintiff reported to defendant that she injured her left knee outside of work. She subsequently took approximately twelve weeks of leave under the federal Family and Medical Leave Act (FMLA) and the PFLA, which ran concurrently. Plaintiff returned to work full-time as a "molder" in August 2015 after exhausting her FMLA/PFLA leave. She returned to molder work, but it caused pain in her knee. Plaintiff was reassigned to work as a "finisher," which again aggravated her knee. After a third period of recovery and return to work, plaintiff testified that when she returned, she was told there was no work she could do that was a light-duty task. "Ultimately, plaintiff had the burden to present some admissible material by which a reasonable jury could infer that defendant’s stated legitimate, nondiscriminatory reason for terminating her - that she was indefinitely incapable of performing the essential functions of her job - was a lie. She failed to do so." The trial court correctly granted summary judgment to defendant on plaintiff’s retaliation claims. View "Gates v. Mack Molding Company, Inc." on Justia Law

After nine years of litigation and in their third set of appeals, the parties asked the Ninth Circuit to decide whether California’s sales ban is preempted by the Poultry Products Inspection Act (“PPIA”) or violates the dormant Commerce Clause. The Ninth Circuit affirmed the district court’s dismissal of Plaintiffs’ preemption and Dormant Commerce Clause claims and its summary judgment in favor of Plaintiffs on a declaratory judgment claim in an action brought by various foie gras sellers challenging California’s ban on the in-state sale of products that are “the result of force-feeding a bird for the purpose of enlarging the bird’s liver beyond normal size.” Cal. Health & Safety Code Sec. 25982.   The court held that the sales ban was neither preempted nor unconstitutional and that certain out-of-state sales were permitted by California law. that the sales ban was neither preempted nor unconstitutional and that certain out-of-state sales were permitted by California law and the federal Poultry Products Inspection Act. The court held that the district court did not abuse its discretion by denying Plaintiffs leave to amend to add a new express ingredient preemption claim alleging that the sales ban operates as an “ingredient requirement” by prohibiting foie gras as an ingredient in other poultry products.  Further, rejecting Plaintiffs’ Dormant Commerce Clause claim, the court held that California’s sales ban prohibits only instate sales of foie gras, so it was not impermissibly extraterritorial. View "ASSOCIATION DES ELEVEURS V. ROB BONTA" on Justia Law