Justia Civil Rights Opinion Summaries

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

A group of nine individuals, representing a putative class, alleged that a credit union systematically discriminated against racial minorities in its residential mortgage lending practices. The plaintiffs varied in racial background (eight Black, one Latino), state of residence, type of loan product sought, and financial circumstances. Despite these differences, they claimed the credit union used a single, semi-automated underwriting process for all applicants, which, through its proprietary algorithm, resulted in discriminatory outcomes against minority applicants. The complaint sought both damages and injunctive relief, and proposed a class consisting of all minority applicants for mortgage-related products from 2018 to the present who faced adverse actions compared to similarly situated non-minority applicants.The United States District Court for the Eastern District of Virginia partially granted the defendant’s motion to dismiss and struck the class allegations, relying on Federal Rules of Civil Procedure 12(f) and 23(d)(1)(D). The district court focused on the diversity of the plaintiffs’ circumstances, suggesting that the variations in loan types and applicant characteristics defeated the possibility of class certification, particularly under Rule 23(b)(3).On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit addressed the standards governing class certification denials at the pleading stage before discovery. The Fourth Circuit held that district courts should only deny class certification at this stage if, on the face of the complaint, the Rule 23 requirements are not met as a matter of law. The appellate court affirmed the district court’s denial of class certification under Rule 23(b)(3), finding the lack of predominance and superiority apparent from the complaint due to the differences among the plaintiffs. However, the Fourth Circuit vacated the district court’s order as to Rule 23(b)(2), concluding that the complaint sufficiently alleged commonality for classwide declaratory and injunctive relief, and that the district court acted prematurely in denying certification under that provision. View "Oliver v. Navy Federal Credit Union" on Justia Law

A young man, after displaying erratic behavior in his Florida apartment, was tied up by his family who feared for his safety. Family members called 911, expressing concern but clarifying he was not violent. When police officers arrived, they found the man tied up, wet, and partially undressed. The officers attempted to detain him under Florida’s Baker Act, which allows for involuntary mental health evaluations under specific criteria. A struggle ensued, during which officers used force, including repeated taser deployments, physical strikes, and dragging the man outside, resulting in injuries. The man was taken to the hospital but not criminally charged.In the United States District Court for the Southern District of Florida, the man sued the responding officers and the city under federal and state law, alleging false arrest, excessive force, and assault and battery, among other claims. The officers moved for summary judgment, arguing qualified immunity and state agent immunity. The district court granted summary judgment for some claims but allowed others—including false arrest and excessive force under 42 U.S.C. § 1983, and state-law claims of assault and battery—to proceed to trial against certain officers.The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. The court reversed the district court’s denial of qualified immunity to two officers on the false arrest claim, finding they had arguable probable cause to detain the man under the Baker Act. However, the court affirmed the denial of qualified immunity to two other officers on excessive force claims, concluding that a reasonable jury could find their use of force grossly disproportionate and in violation of clearly established law. The court also affirmed denial of state agent immunity on the assault and battery claims. The case was remanded for further proceedings. View "Castro-Reyes v. Bosque" on Justia Law

A Black man worked as a truck salesman at a Florida business where he was the only nonwhite employee. He observed that his supervisors and colleagues frequently made derogatory, racially charged comments about nonwhite customers, including the use of slurs for various ethnic groups and stereotypes about Black customers. These comments occurred nearly every time a nonwhite customer entered the business, which happened often. The employee was also the subject of racial slurs behind his back and was sometimes called “boy” in a heated workplace dispute. He reported these incidents to his supervisor, but no corrective action was taken. Over time, his managers began documenting performance and attendance issues, and he was ultimately terminated and replaced by a white employee.The United States District Court for the Northern District of Florida granted summary judgment to the employer on all claims, finding the employee did not provide sufficient evidence of discriminatory or retaliatory termination or a racially hostile work environment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court affirmed summary judgment in favor of the employer on the claims of discriminatory and retaliatory termination. It held the employee failed to present substantial evidence that his termination was motivated by racial animus or retaliation for protected complaints, and the employer articulated legitimate, nondiscriminatory reasons for its actions.However, the Eleventh Circuit vacated the summary judgment on the hostile work environment claim and remanded for further proceedings. The court held that the employee presented substantial evidence that he was subjected to a racially hostile work environment, including pervasive use of racial slurs and discriminatory conduct towards nonwhite individuals, sufficient for a reasonable jury to find in his favor on that claim. View "Melton v. I-10 Truck Center, Inc." on Justia Law

A.B., a 42-year-old individual with a longstanding diagnosis of schizoaffective disorder, had been receiving mental health services in San Francisco since 2008, including numerous psychiatric hospitalizations and crisis interventions. He was previously under conservatorship, which ensured compliance with medication, but historically disengaged from treatment and decompensated when conservatorship ended. In October 2023, following a psychiatric incident at home involving paranoia and disruptive behavior, A.B. was hospitalized. His mother, who provided housing, testified to his history of aggression and repeated decompensation when not medicated, stating she would not allow him to live with her absent a conservatorship and mandatory medication order.The San Francisco County Superior Court initially appointed the public conservator and imposed an involuntary medication order. After a mistrial in April 2023, the parties resolved the matter by conservatorship without a medication order, but following further decompensation, the conservator sought renewal with an involuntary medication order. At the 2025 court trial, testimony from A.B.’s mother and treating psychiatrist indicated that A.B. lacked insight into his illness, would not reliably take medication without a legal mandate, and was unable to maintain shelter independently. Although A.B. testified that he now recognized his diagnosis and would comply with medication, the court credited the testimony of his mother and psychiatrist over his own.The California Court of Appeal, First Appellate District, Division Two, held that substantial evidence supported the trial court’s findings that A.B. was presently gravely disabled due to his mental disorder and unable to provide for his own shelter without medication, which he would not take absent a court order. The appellate court also affirmed the finding that A.B. was incompetent to give or withhold informed consent for psychotropic medication. The orders renewing the conservatorship and involuntary medication were affirmed. View "Conservatorship of A.B." on Justia Law

Marquis Kennedy sought employment as a police officer with the City of Arlington, Texas, and enrolled in the Arlington Police Academy after passing a physical exam. During a mandatory training exercise known as Gracie Survival Tactics, which involved intense self-defense scenarios, Marquis reportedly complained of fatigue, thirst, and lightheadedness, but was not permitted breaks or water. He continued participating, allegedly due to fear of failing and repeating the training. During the final scenario, Marquis signaled distress, but the instructors continued the exercise until he could not proceed. After the simulation ended, Marquis requested an ambulance, was assisted to a break room, and subsequently suffered cardiac arrest. Emergency services were called, and Marquis was taken to a hospital, where he died two days later. The autopsy listed cardiac arrest as the cause of death, likely due to atherosclerotic cardiovascular disease.Kennedy, Marquis’s widow, brought suit in the United States District Court for the Northern District of Texas against the City and several officers, asserting Fourth and Fourteenth Amendment violations under 42 U.S.C. § 1983, including claims for excessive force, deliberate indifference to medical needs, bystander liability, and municipal liability for failure to train officers. The City moved to dismiss and submitted video evidence of the training, which Kennedy referenced in her claims. The magistrate judge recommended dismissal of all claims, finding no plausible constitutional violation, no constitutional seizure, and no duty of medical care in an employment setting. The district court adopted these findings and dismissed the case.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Kennedy failed to plausibly allege a Fourth Amendment seizure or substantive due process violation, and that no constitutional duty of medical care existed in this employment context. The court also found no basis for bystander or municipal liability. View "Kennedy v. City of Arlington, Texas" on Justia Law

A California state prisoner, Maurice Lydell Harris, is a practicing Nichiren Buddhist who believes his faith requires him to eat “clean” food, including meat as close to its natural state as possible. Because the prison system did not offer a diet specifically aligned with his religious practice, Harris enrolled in the halal meat program (RMAP), based on advice from a prison chaplain that it most closely matched his requirements. Prison regulations require RMAP participants to refrain from buying non-halal foods from the commissary, but Harris purchased such items, including ramen and processed meats, citing health needs and cultural practices, which led to multiple violations and ultimately his removal from the program.Harris filed suit in the United States District Court for the Northern District of California, alleging that his removal from RMAP violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought preliminary injunctive relief to continue receiving the RMAP diet while supplementing with non-halal foods. The district court denied Harris’s requests twice, concluding that the RMAP diet was not required by Harris’s religion and that expulsion would not affect his ability to observe his faith.On appeal, the United States Court of Appeals for the Ninth Circuit found that the district court erred by evaluating the centrality of the halal diet to Harris’s beliefs, rather than whether Harris sincerely believed the diet best suited his religious needs. The Ninth Circuit held that Harris could demonstrate a substantial burden on his religious exercise and that, if so, the government must show its regulation is the least restrictive means of advancing a compelling interest. The court vacated the district court’s denial of a preliminary injunction and remanded for further proceedings to reassess whether Harris’s religious exercise was substantially burdened. View "Harris v. Muhammad" on Justia Law

Four juveniles conspired to rob a victim of vaping products in Colorado in 2019. During the incident, one of the juveniles, who is Black, shot and killed the victim. All four were initially charged with felony murder, aggravated robbery, and conspiracy to commit aggravated robbery. Subsequent investigation revealed that the shooter acted alone in confronting and shooting the victim, while the other three, including two non-Black juveniles, had more limited roles and cooperated with law enforcement. The two non-Black juveniles received plea deals allowing them to be tried in juvenile court and were sentenced to two years in the Division of Youth Services, while the two Black defendants, including the shooter, were prosecuted in district court and faced substantially harsher potential sentences.The District Court for Arapahoe County denied the shooter's motion to dismiss for selective prosecution, finding that he was not similarly situated to his non-Black codefendants due to his greater culpability as the shooter. The court also found that statistical evidence provided did not establish discriminatory purpose by the prosecution. The case proceeded to trial, and a jury convicted the shooter, who was sentenced to life in prison with the possibility of parole after forty years. On appeal, the Colorado Court of Appeals affirmed the trial court’s denial of the motion to dismiss, agreeing that the shooter was not similarly situated to the other defendants. The appellate division did not address whether the statistical evidence sufficed to show discriminatory purpose.The Supreme Court of Colorado affirmed the judgment of the Court of Appeals. It held that the defendant failed to establish a claim of selective prosecution because he did not show a discriminatory effect or purpose. Specifically, he was not similarly situated to his non-Black codefendants, and his statistical evidence did not demonstrate that similarly situated non-Black individuals were treated differently. View "Mitchell v. People" on Justia Law

The case centers on Orlando González Tomasini, who filed civil rights and tort claims against the United States Postal Service, his former employer, alleging that psychological and medical conditions prevented him from working. His then-wife, Juliette Irizarry-Miranda, was initially a co-plaintiff but eventually became a defense witness after a contentious divorce and ongoing custody dispute over their son. On the eve of trial, the Postal Service accused González of witness tampering, specifically of seeking to dissuade Irizarry from testifying by conditioning custody concessions on her refusal to take the stand. Irizarry recorded part of a phone call between them, and the Postal Service submitted this as evidence.Prior to the current appeal, the case was heard in the United States District Court for the District of Puerto Rico, where a magistrate judge presided by consent of the parties. The magistrate judge held a three-day evidentiary hearing to address the witness tampering allegations. After hearing testimony from González, Irizarry, and a social worker, the court found by clear and convincing evidence that González had engaged in witness tampering. As a sanction for this fraud on the court, the magistrate judge dismissed González’s case.The United States Court of Appeals for the First Circuit reviewed the district court's decisions. The First Circuit affirmed the district court in all respects, holding that the evidentiary hearing was appropriately ordered, the finding of witness tampering was not clearly erroneous, and the sanction of dismissal was within the court’s discretion. The appellate court found that González’s conduct constituted a fraud on the court, justifying dismissal, especially given the egregiousness of the witness tampering and its potential impact on the integrity of judicial proceedings. Judgment was affirmed for the Postal Service. View "Gonzalez Tomasini v. Steiner" on Justia Law

Three parents of students in Philadelphia challenged the School District’s 2022 Admissions Policy for four selective public high schools. Prior to 2022, admissions decisions were made by individual schools using academic criteria, attendance, and sometimes additional requirements such as interviews and writing samples. After a report identified geographic disparities in school representation, and following the School District’s public commitments to anti-racism and equity, a new centralized policy was adopted. This policy introduced revised academic standards, eliminated certain prior requirements, and implemented a zip code preference favoring applicants from six areas with high Black and Hispanic populations. Qualified applicants from these zip codes received automatic admission, while others had to enter a lottery for remaining seats.The parents, whose children lived outside the preferred zip codes and met the new criteria but were not admitted to their first-choice schools, filed suit in the United States District Court for the Eastern District of Pennsylvania. They alleged violations of Title VI, the Equal Protection Clause, and related state constitutional provisions, arguing that the new process was racially discriminatory. The District Court granted summary judgment for the School District, finding that no reasonable factfinder could conclude the policy had a racially discriminatory purpose or impact. The court applied rational basis review, holding the policy was rationally related to legitimate interests such as increasing access for underrepresented geographic areas.On appeal, the United States Court of Appeals for the Third Circuit held that, viewing the evidence in the light most favorable to the parents, a reasonable factfinder could conclude the Admissions Policy had both discriminatory purpose and impact. The Third Circuit vacated the District Court’s judgment and remanded for further proceedings, directing that strict scrutiny must be applied if a discriminatory purpose and impact are found. View "Sargent v. School District of Philadelphia" on Justia Law