Justia Civil Rights Opinion Summaries

Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded for the district court to decide whether the right was clearly established.On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established. The officers appealed. The United States Court of Appeals for the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Thus, Coborn was not entitled to qualified immunity for the second round of shots. View "Baker v. Coborn" on Justia Law

An employee of the Falmouth Public Schools in Maine, enrolled in a health insurance plan administered by Anthem Health Plans of Maine, Inc., challenged the plan’s exclusion of coverage for weight-loss medications. After being diagnosed with obesity and prescribed FDA-approved weight-loss drugs, the employee’s requests for coverage were repeatedly denied. Her medical providers appealed to Anthem, supporting the necessity of the medication, but Anthem maintained its denial, citing the plan’s explicit exclusion of weight-loss medications regardless of obesity diagnosis.The employee, on behalf of herself and a proposed class, sued Anthem’s parent company, Elevance Health, Inc., in the United States District Court for the District of Maine. She alleged that the exclusion constituted disability discrimination under Section 1557 of the Patient Protection and Affordable Care Act, which incorporates the nondiscrimination requirements of Section 504 of the Rehabilitation Act. Elevance moved to dismiss, arguing the complaint failed to plausibly allege disability discrimination. The district court granted the motion, reasoning that the exclusion applied to all enrollees, regardless of disability status, and did not target disabled individuals for discriminatory treatment. The court found the allegations of discrimination to be conclusory and insufficient to support claims of intentional, proxy, or disparate impact discrimination.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff failed to plausibly allege that the exclusion of weight-loss medication coverage constituted discrimination under Section 1557. The court concluded that the exclusion was facially neutral, did not serve as a proxy for disability discrimination, and did not result in a lack of meaningful access to plan benefits for disabled individuals. Accordingly, the dismissal of the complaint was affirmed. View "Holland v. Elevance Health, Inc." on Justia Law

A woman who was pregnant while detained at the Tarrant County Jail gave birth in her cell two weeks before her due date. The infant was found stuck in her pants and was transported to the hospital, where the child died ten days later. The Medical Director at the jail, a physician who did not provide direct care to inmates in the female infirmary, had issued orders for the treatment of pregnant inmates but relied on other medical staff to carry out those orders. Days before the birth, the woman was seen by an OB/GYN, who noted her communication difficulties and recommended an elective induction of labor at 39–40 weeks, which the Medical Director approved. On the day of the birth, the woman was mentioned in the attachment to a nursing report email regarding abdominal cramps and refusal of breakfast, but not in the body of the email. The Medical Director stated he did not read the attachment before learning the birth had occurred.After the incident, the woman, through her guardian, filed suit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Texas, alleging the Medical Director denied her adequate medical care in violation of the Fourteenth Amendment. Following discovery, the Medical Director moved for summary judgment, asserting qualified immunity and arguing he lacked subjective knowledge of a substantial risk of serious harm. The district court granted summary judgment for the Medical Director and denied the plaintiff’s cross-motion.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court held that the Medical Director did not have subjective knowledge of a substantial risk of serious harm to the detainee and therefore did not act with deliberate indifference. The court affirmed the district court’s summary judgment in favor of the Medical Director. View "Congious v. Shaw" on Justia Law

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain.The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law

Several women incarcerated at a Michigan prison developed painful, persistent rashes between 2016 and 2019. Their complaints were largely ignored by prison staff, and medical providers initially misdiagnosed the condition, ruling out scabies, a highly contagious skin infestation. The prison’s contracted health care provider, Corizon Health, and its infectious disease coordinator were tasked with managing infectious diseases but failed to control the outbreak. Only after an outside dermatologist diagnosed scabies did prison officials begin widespread treatment and quarantine measures, though these efforts were not immediately effective. Four inmates who suffered from these conditions filed suit, seeking damages and injunctive relief against both the medical providers and high-level prison officials who had not directly treated them.The United States District Court for the Eastern District of Michigan denied motions for judgment on the pleadings by the Michigan Department of Corrections and Wayne State Officials. The district court held that the inmates had plausibly alleged that all defendants, including non-treating prison officials, committed clearly established Eighth Amendment violations and were not entitled to qualified immunity. The court also found that the gross negligence claims could proceed under Michigan law, as the complaint adequately alleged that the officials proximately caused the harms.On appeal, the United States Court of Appeals for the Sixth Circuit determined that, under existing precedent, non-treating prison officials’ reliance on contracted medical providers did not clearly constitute an Eighth Amendment violation. The court reversed the district court’s denial of qualified immunity on the inmates’ federal damages claims against these officials, finding no clearly established law requiring them to override medical judgments. However, the court affirmed the denial of state-law immunity, concluding that proximate cause under Michigan law could not be resolved at the pleading stage. The case was remanded for further proceedings consistent with these rulings. View "BLC Lexington SNF, LLC v. Townsend" on Justia Law

A video showing a Clark County School District police officer forcefully detaining a juvenile outside a Las Vegas high school prompted public concern. The American Civil Liberties Union of Nevada requested records related to the incident from the school district. In response, the district provided only limited information, citing statutory privileges and ongoing internal investigations as grounds for withholding additional documents. The ACLU reiterated its request, seeking a detailed privilege log and specific justifications for each withheld record.After the school district produced a privilege log and maintained that certain records were exempt due to their role in an ongoing employment investigation, the ACLU filed a petition for a writ of mandamus in the Eighth Judicial District Court of Clark County. Following briefing and a hearing, the district court ordered disclosure of certain records, such as body-worn camera footage, an incident report, and a dispatch log, with redactions. However, the court held that the internal affairs investigation report and the bulk of the investigative file were confidential under Nevada law and not subject to disclosure. The ACLU appealed this ruling.The Supreme Court of the State of Nevada reviewed the case. It interpreted the Nevada Public Records Act and NRS 289.080, concluding that an internal investigative file about a peace officer is confidential and exempt from public disclosure unless the investigating agency recommends punitive action against the officer. The Court reasoned that releasing records to the public when the subject officer does not have access would be illogical and inconsistent with legislative intent. The Supreme Court of Nevada affirmed the district court’s judgment, holding that such investigative files are exempt from disclosure to the same extent that their disclosure is barred under NRS 289.080. View "AM. CIVIL LIBERTIES UNION OF NEV. VS. CLARK CNTY. SCHOOL DIST." on Justia Law

A White police officer employed by the Atlanta Police Department alleged that he was denied a promotion to Captain in December 2014 and was later removed from a flexible work schedule after he reported alleged misconduct by superiors. The officer had previously reported in 2008 that Black supervisors were allegedly treating White officers less favorably, which resulted in tension but was not shown to have been communicated to the ultimate decisionmaker for promotions. In 2015, after reporting possible ticket-fixing by his superiors to internal and federal authorities, the officer was required to work a fixed schedule, which impacted his ability to work a second job and fulfill childcare obligations.The United States District Court for the Northern District of Georgia dismissed or granted summary judgment on most of the officer’s claims, including those under Title VII for racial discrimination and retaliation, and under the Georgia Whistleblower Act. The court found no evidence that the Police Chief, who was the sole decisionmaker for promotions, was aware of the officer’s 2008 discrimination complaint, and further held that the officer had not experienced an adverse employment action as required by the statutes. At trial, the jury found for the City on the Title VII discrimination claim, concluding the officer had not been denied a promotion.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed most of the district court’s rulings, including summary judgment for the City on the Title VII and Whistleblower Act claims and the jury verdict on the discrimination claim. However, the Eleventh Circuit reversed the grant of summary judgment for the Chief and another supervisor on the First Amendment retaliation claim, holding that revoking the officer’s flexible schedule constituted a material adverse action sufficient to support such a claim. The case was remanded for further proceedings on this First Amendment issue. View "Joyner v. City of Atlanta" on Justia Law

Law enforcement officers executed a search warrant for methamphetamine at a rural Wisconsin property, where they believed Ryan Steinhoff, suspected of violent criminal activity, was present. During the early morning search, Steinhoff was found in a camper and, after initially appearing to comply with police orders, was tackled by an officer. In the course of his restraint, Steinhoff sustained a head injury from a rifle barrel, which required stitches. Body-camera footage captured the incident, but it was unclear whether the head injury was caused intentionally or accidentally.Steinhoff filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Wisconsin, alleging that Detective Kowalczyk and Investigator Malovrh used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to Captain Ramberg, as Steinhoff conceded no excessive force was used by him. The court denied summary judgment to Investigator Malovrh on the claim regarding kneeling during handcuffing, and a jury later found in Malovrh’s favor on that issue. The district court granted summary judgment and qualified immunity to Detective Kowalczyk regarding the tackle, finding no clearly established law prohibiting his actions. The court also granted summary judgment to Investigator Malovrh on the rifle strike, concluding no reasonable jury could find the strike intentional.The United States Court of Appeals for the Seventh Circuit affirmed qualified immunity for Detective Kowalczyk, holding that his actions during a high-risk drug raid did not violate clearly established law. However, the appellate court reversed summary judgment for Investigator Malovrh, finding factual disputes about whether the rifle strike was intentional. The court remanded for a jury to resolve those disputes, as a blow to the head with a rifle could constitute excessive force if intentional. View "Steinhoff v Malovrh" on Justia Law

Two married tenured professors at California State University, Chico alleged that they were subjected to harassment and discrimination by their department chair, with one professor experiencing conduct targeted at her gender and Korean ancestry. Despite their reports to university administration, the university did not intervene. As a result, one professor suffered serious mental health consequences, leading their doctor to recommend that she not work in the same environment as the chair. The university’s lack of response allegedly forced both professors to resign and accept positions at another university. After their resignation, the university initiated an investigation into one professor for an alleged violation of student privacy laws and communicated these allegations to the new employer, which the professors claimed was intended to sabotage their new employment. There were also alleged delays in transferring their lab equipment.The professors filed suit in the Superior Court of Butte County, asserting, among other claims, retaliation and whistleblower retaliation under California law. The university filed a special motion to strike these two causes of action under California’s anti-SLAPP statute, arguing that the claims were based in part on communications protected by the statute. The trial court denied the motion, finding the university’s actions involved an official proceeding but also concluding that the professors demonstrated a likelihood of prevailing on their claims.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s denial of the anti-SLAPP motion. The appellate court held that the university failed to carry its burden to show that all actions underlying the challenged causes of action were protected activity. The court clarified that the presence of some protected communications within the allegations does not mean the entire cause of action arises from protected activity. The judgment denying the anti-SLAPP motion was therefore affirmed. View "Pechkis v. Trustees of the Cal. State University" on Justia Law

During the inauguration of Vermont’s governor, a group of protesters, including Shela Linton, staged a sit-in at the state capitol to advocate for universal healthcare. When the building closed, police instructed the protesters to leave or face arrest for trespassing. Some complied, while others, including Linton, refused. Sergeant Jacob Zorn approached Linton, who remained seated and passively resisted. After multiple warnings, Zorn used a rear wristlock to lift Linton to her feet, causing her to exclaim in pain. Linton alleged that this action resulted in physical and psychological injuries.Linton filed a lawsuit under 42 U.S.C. §1983, claiming Zorn’s use of force violated her Fourth Amendment rights. The United States District Court for the District of Vermont granted summary judgment to Zorn, holding he was entitled to qualified immunity because it was not clearly established that his actions constituted excessive force in these circumstances. The United States Court of Appeals for the Second Circuit reversed, relying on its earlier decision in Amnesty America v. West Hartford, reasoning that the use of a rear wristlock on a passively resisting protester was clearly established as excessive force. The Second Circuit remanded the case for a jury trial.The Supreme Court of the United States reviewed the case and held that Zorn was entitled to qualified immunity. The Court determined that Amnesty America did not clearly establish, with the requisite specificity, that Zorn’s conduct—using a wristlock after repeated warnings—violated the Fourth Amendment. The Court emphasized that qualified immunity protects officials unless prior precedent places the constitutional question beyond debate and found that no case had clearly held such conduct unlawful in similar circumstances. Accordingly, the Supreme Court granted certiorari and reversed the judgment of the Second Circuit. View "Zorn v. Linton" on Justia Law