Justia Civil Rights Opinion Summaries

Plaintiff is the former Vice President of Program and Community of the Eugene and Agnes E. Meyer Foundation. She received largely positive feedback during her tenure, but less than two years after she was hired, the CEO of the Foundation fired her for purported interpersonal and communication-related issues. Plaintiff, who is African-American, believes these stated reasons were pretext to mask discriminatory animus. Plaintiff and the Foundation signed a severance agreement, under which Plaintiff agreed to release employment-related claims against the Foundation and its employees, and which contained a mutual non-disparagement clause. But roughly a month after Plaintiff was fired, the CEO told another leader in the non-profit space that Plaintiff was let go because she was “toxic,” created a “negative environment.” Plaintiff sued the Foundation and its CEO for breaching the severance agreement, for doing so in a racially discriminatory manner in violation of 42 U.S.C. Section 1981, and for defaming her. The district court dismissed all three claims.   The DC Circuit held that the district court erred in dismissing all three claims. As to Plaintiff’s breach of contract claim, the non-disparagement clause could reasonably be interpreted to preclude the Foundation from disparaging Plaintiff, and dismissal under Federal Rule of Civil Procedure 12(b)(6) is therefore inappropriate. As to her Section 1981 claim, the court found that she has plausibly alleged a prima facie case that the Foundation, through the CEO, breached the severance agreement due to racial animus. And lastly, the CEO’s statements are not protected by the common interest privilege, which requires a showing of good faith on the part of the speaker. View "Terri Wright v. Eugene & Agnes E. Meyer Foundation" on Justia Law

Over a four-day stretch during his incarceration at Walker State Prison in Georgia, Plaintiff failed to receive his prescribed seizure medication. On the fourth night, Plaintiff had two seizures that he claimed caused permanent brain damage. Proceeding under 42 U.S.C. Section 1983, Plaintiff sued five prison employees, alleging that they were deliberately indifferent to his medical needs in violation of the Eighth Amendment. The district court granted summary judgment to all five defendants on the ground that they were entitled to qualified immunity. Shortly thereafter, Plaintiff died from causes unrelated to the seizures that he suffered while in prison. His sister pursued his claims on appeal as the personal representative of his estate.   The Eleventh Circuit affirmed. The court concluded that none of them was deliberately indifferent to Plaintiff’s medical needs and, accordingly, that none of them violated the Eighth Amendment—and, accordingly, that the district court was correct to grant all of them summary judgment. The court held that a deliberate-indifference plaintiff must prove (among other things) that the defendant acted with “more than gross negligence.” The court wrote that it echoes the district court’s lament that Defendants’ “careless actions and their systemic communication failures caused Plaintiff serious suffering” and “irreparably altered his life.” And the court reiterated that “while engaged in the business of prison medicine”—no less so than on the outside, so to speak—“the essential command of the Hippocratic Oath is ‘first, do no harm.’” Even so, the bar to proving an Eighth Amendment deliberate-indifference claim is appropriately high, and the court concluded that Plaintiff hasn’t met it. View "Betty Wade v. Georgia Correctional Health, LLC, et al" on Justia Law

In this § 1983 lawsuit, Plaintiff sought declaratory and injunctive relief to stop ongoing physician disciplinary proceedings in which the Iowa Board of Medicine (“the Board”), represented by the Attorney General of Iowa, charges Wassef with violating Iowa law by inappropriately accessing patient records during his residency at the University of Iowa Hospitals and Clinics (“UIHC”). The Board is responsible for regulating the practice of medicine in Iowa and is authorized to discipline doctors who do not meet minimum practice standards established by the Board and by the Iowa Legislature. Plaintiff alleged the ongoing proceedings violate federal law -- the Health Insurance Portability and Accountability Act (“HIPAA”). The district court dismissed the action, concluding that it must abstain pursuant to Younger v. Harris, 401 U.S. 37 (1971). The court also dismissed the due process claim because Plaintiff failed to exhaust state remedies and failed to plausibly allege a claim.   The Eighth Circuit modified the dismissal to be without prejudice, vacated the district court’s due process ruling, and granted Plaintiff’s unopposed Motion To Substitute Parties. The court concluded the district court properly abstained under Younger. However, as the state disciplinary proceedings are ongoing, the court should have declined to reach the merits of the due process claim, which Plaintiff can litigate in the state proceedings. Accordingly, the court modified the dismissal to be without prejudice, which is usually the proper disposition when a court abstains under Younger. View "Shafik Wassef v. Dennis Tibben" on Justia Law

Plaintiff brought an action against several police officers and the City of New York, asserting various claims under 42 U.S.C. Section 1983 and New York state law based on his allegation that police officers falsely claimed that they observed him selling drugs. After his criminal trial, Plaintiff was acquitted of a drug sale charge and convicted of a drug possession charge. Plaintiff subsequently filed this civil action, and the district court dismissed all of Plaintiff’s claims.   The Second Circuit affirmed in part and vacated in part the district court’s dismissal of Plaintiff’s claims and remanded. The court wrote that it agreed with the district court’s dismissal of all of the federal claims except for the dismissal of Plaintiff’s due process claim based on the use of fabricated evidence regarding the drug sale charge of which he was acquitted. Specifically, the district court erred in concluding that because Plaintiff was arrested, detained, prosecuted, and convicted for drug possession simultaneous to the drug sale proceedings, this precludes, as a matter of law, his ability to plead a deprivation of liberty caused by the drug sale prosecution. Because the prosecution of an individual based on fabricated evidence may itself constitute a deprivation of liberty, even in the absence of custody or a conviction, Plaintiff was not required to show that his drug sale prosecution resulted in additional custody or a conviction in order to sufficiently allege a claim at the pleading stage. View "Barnes v. City of New York" on Justia Law

This qualified immunity case arises from the death of a man who was shot and killed by officers of the Stratford Police Department when he attempted to evade arrest by fleeing in a stolen car. Plaintiffs, the man’s minor child and his estate appealed the district court’s grant of summary judgment to Defendants.   The Fifth Circuit affirmed in part, reversed in part, and remanded to the district court. The court explained that the officer would have been put on notice that his conduct violated the man’s constitutional rights. The court explained that Plaintiffs have not pointed to sufficient authority clearly establishing that the officer’s conduct violated the law under the specific circumstances he was facing, and thus he is entitled to qualified immunity. However, the court held that it is not convinced that the degree of force used was objectively reasonable. A jury could reasonably find that Defendants violated the man’s Fourth Amendment right to be free from excessive force. View "Baker v. Coburn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law

Plaintiff sued her former employer Xceed Financial Credit Union (Xceed) for wrongful termination and age discrimination in violation of the Fair Employment and Housing Act (FEHA). The case was submitted to binding arbitration pursuant to the stipulation of the parties. The arbitrator granted summary judgment in favor of Xceed on the ground Plaintiff’s claims were barred by a release in her separation agreement. The arbitrator rejected Plaintiff’s assertion that the release violated Civil Code section 1668, which prohibits pre-dispute releases of liability in some circumstances. Plaintiff moved to vacate the arbitration award, arguing the arbitrator exceeded his powers by enforcing an illegal release. The trial court denied the motion to vacate and entered judgment confirming the arbitration award.   The Second Appellate District affirmed. The court held that the arbitrator’s ruling for clear error. The arbitrator correctly ruled the release did not violate Civil Code section 1668. Plaintiff signed the separation agreement after she was informed of the decision to terminate her but before her last day on the job. At the time she signed, she already believed that the decision to terminate her was based on age discrimination and that she had a valid claim for wrongful termination. The alleged violation of FEHA had already occurred, even though the claim had not yet fully accrued. Accordingly, the release did not violate section 1668 because it was not a release of liability for future unknown claims. View "Castelo v. Xceed Financial Credit Union" on Justia Law

Plaintiffs were employees of VMSB’s restaurant. They argue that VMSB failed to meet its minimum wage and overtime pay obligations under the Fair Labor Standards Act and comparable Florida laws. Plaintiffs’ complaint alleged three counts, and both sides filed cross-motions for summary judgment. Plaintiffs moved the district court to approve the settlement and to “direct the clerk to dismiss Count III” with prejudice. The district court ultimately adopted the magistrate judge’s report and recommendation and entered judgment for VMSB on Counts I and II. Plaintiffs filed a notice of appeal regarding Counts I and II.   The Eleventh Circuit dismissed the appeal. The court explained that Federal Rule of Civil Procedure 41(a)(2) provides only for the dismissal of an entire action. Any attempt to use this rule to dismiss a single claim, or anything less than the entire action, will be invalid—just like it would be under Rule 41(a)(1). Because the parties here attempted to use Rule 41(a) to dismiss a single count and not an entire lawsuit, a final judgment was never rendered. Accordingly, the court found that it lacks jurisdiction to hear this appeal. View "Israel Rosell, et al. v. VMSB, LLC" on Justia Law

Plaintiff appealed the district court’s summary judgment in favor of William Marsh Rice University d/b/a Rice University (hereinafter, “Rice” or “the University”) dismissing his claims under Title IX of the Educational Amendments Act of 1972 (“Title IX”) as well as his state law breach-of-contract claims.   The Fifth Circuit affirmed the district court’s dismissal of Plaintiff’s breach-of-contract claim but reversed its summary judgment in favor of the University with respect to Plaintiff’s Title IX claims and remanded. The court explained that Plaintiff has not alleged any breaches of the University’s Code or associated policies. Moreover, as the district court accurately observed in evaluating Plaintiff’s breach-of-contract claim, the Code expressly provides that “[t]he procedures used . . . by SJP are not those used in court cases and are not intended to create contractual rights[.]” In the absence of contractual rights and the University’s intent to be bound, the court held that it is entitled to summary judgment as a matter of law with respect to Plaintiff’s breach-of-contract claim. Moreover, the court held that the district court erred in granting summary judgment in favor of the University on the grounds that the record clearly indicates that material fact issues remain in dispute as to whether Plaintiff has successfully advanced a Title IX claim against the University. View "Doe v. William Marsh" on Justia Law

In 2019, Susan Christie filed suit against Wayne State University, asserting age and disability discrimination under the Elliott-Larsen Civil Rights Act (the ELCRA); and the Persons with Disabilities Civil Rights Act (the PWDCRA). Christie took a medical leave of absence in February 2017 and returned to work on May 1, 2017. Plaintiff alleged that after her return to work, her supervisors questioned her about her age, asked her when she intended to retire, and had conversations with others in her presence regarding the ages of employees. Plaintiff received a negative job-performance review on September 22, 2017, allegedly the first negative review she had ever received, and defendant terminated her from her job on November 27, 2017. Defendant moved for summary judgment, arguing that MCL 600.6431(1) of the Court of Claims Act (the COCA), required plaintiff to file either a verified complaint with the Court of Claims or notice of intent to file suit with the Court of Claims within one year of the accrual of her claim; defendant maintained plaintiff’s claim was barred by governmental immunity because she failed to do either. The court denied the motion, concluding that MCL 600.6431(1) did not preclude plaintiff from filing her claim in the circuit court because the COCA notice requirements only applied to claims litigated in the Court of Claims. Defendant appealed that decision to the Court of Appeals. While the Court of Appeals ultimately concluded that it lacked jurisdiction to hear the appeal as a matter of right, it treated the appeal as though leave had been granted and affirmed the trial court’s order in an unpublished per curiam opinion. The Michigan Supreme Court reversed, finding the trial court erred by denying defendant’s motion for summary judgment. View "Christie v. Wayne State University" on Justia Law