Justia Civil Rights Opinion Summaries

Jason and Brandren Sims filed a lawsuit against the Dallas Independent School District (DISD) under 42 U.S.C. § 1983 after their mother, a special-education instructor, died following an assault by a student. They claimed that DISD was directly liable for her death due to an official policy or custom that led to a constitutional violation.The United States District Court for the Northern District of Texas dismissed the case for failure to state a claim. The plaintiffs appealed the decision, arguing that the district court erred in its dismissal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiffs failed to establish direct liability against DISD under § 1983. Specifically, the court noted that to prove such liability, plaintiffs must show an official policy or custom, knowledge of the policy by a policymaker, and a constitutional violation caused by that policy. The plaintiffs relied on the state-created danger theory of substantive due process to establish a constitutional violation. However, the Fifth Circuit reiterated that neither it nor the Supreme Court has ever adopted this theory. The court declined to recognize the state-created danger theory, citing the Supreme Court's caution against identifying unenumerated rights without a careful and deeply rooted historical basis. Consequently, the court affirmed the district court's dismissal of the case. View "Sims v. Dallas Independent School District" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

John Doe, a high school student with several psychological disabilities, repeated his freshman year at an out-of-state boarding school. Upon returning to Rhode Island, he sought a waiver from the Rhode Island Interscholastic League (the League) to extend his eligibility to play sports into his fifth year of high school, citing his disabilities as the reason for his request. The League denied the waiver, stating that his ineligibility was due to his voluntary decision to repeat the ninth grade, not his disabilities.Doe's parents appealed the League's decision to the Waiver Request Hearing Committee and the Principals' Committee, both of which upheld the denial. Subsequently, Doe filed a lawsuit in the District of Rhode Island, claiming that the League's refusal violated Titles II and III of the Americans with Disabilities Act (ADA). The district court granted a permanent injunction, allowing Doe to play sports in his fifth year, reasoning that the League's rule was not an essential aspect of its program and that Doe's disability was the but-for cause of his ineligibility.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's injunction. The appellate court concluded that Doe's disability was not the but-for cause of his ineligibility, as his decision to repeat the ninth grade was unrelated to his disability. Additionally, the court held that waiving the eight-semester rule would fundamentally alter the League's interscholastic athletics program, which aims to ensure competitive parity and maximize student participation. Thus, the requested accommodation was deemed unreasonable. View "Doe v. Rhode Island Interscholastic League" on Justia Law

The case involves the City of Myrtle Beach's response to a surge in violent crime in an area known as "the Superblock." Between 2015 and 2016, eleven people were shot, and dozens more were sexually assaulted, battered, or robbed in the Superblock, primarily around a small cluster of bars. The City increased police presence and investigated these establishments for compliance with safety regulations. Despite these measures, crime persisted, leading the City to shut down two bars for repeated legal violations, while a third bar closed due to lack of business. Years later, the bars and the landlord sued the City and the City Manager, alleging violations of the Takings Clause, Due Process Clause, Equal Protection Clause, and 42 U.S.C. § 1985, claiming the City unlawfully targeted them because their owners and clientele were predominantly racial minorities.The United States District Court for the District of South Carolina granted directed verdicts for the City on all claims during a jury trial. The court held that the appellants did not have a constitutionally protected property interest in the right to conduct their business. It found that the City's enforcement actions were within the legitimate bounds of state police power and rejected the § 1985 civil conspiracy claims based on the intra corporate conspiracy doctrine, which states that corporate and government agents cannot conspire with themselves.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the City acted within its lawful authority to address serious public safety threats and enforce compliance with state and local regulations. The appellants' claims were deemed speculative and unsupported by the evidence presented at trial. The court found no discriminatory intent or violation of due process, and it upheld the application of the intra corporate conspiracy doctrine, concluding that the City officials did not possess a personal stake independent of their relationship to the City. View "Brady v. City of Myrtle Beach" on Justia Law

Alisha Strife, a former U.S. Army service member with disabilities, requested that her employer, Aldine Independent School District (AISD), allow her service dog to accompany her at work. Strife's disabilities include PTSD and physical impairments, and her service dog, Inde, assists her with these conditions. Strife submitted her accommodation request on August 30, 2022, but AISD took six months to approve it, during which time Strife provided multiple medical documents supporting her need for the service dog.The United States District Court for the Southern District of Texas dismissed Strife's claims for failure to accommodate and hostile work environment. The court also granted AISD's motion for summary judgment on Strife's claims of disability discrimination, retaliation, and interference. The district court found that Strife did not suffer a physical injury during the six-month period and that she failed to allege a hostile work environment. The court also concluded that AISD had legitimate reasons for its actions and that Strife did not demonstrate that AISD's rationale was pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the hostile work environment claim, agreeing that Strife's allegations did not meet the standard for a hostile work environment. The court also affirmed the summary judgment on the disability discrimination, retaliation, and interference claims, finding that AISD had legitimate reasons for its actions and that Strife did not provide sufficient evidence of pretext.However, the Fifth Circuit reversed the dismissal of Strife's failure-to-accommodate claim. The court found that Strife had pled sufficient facts to suggest that AISD's six-month delay in granting her accommodation request could constitute a failure to accommodate her disability. The case was remanded to the district court for further proceedings on this claim. View "Strife v. Aldine Independent School District" on Justia Law

A group of innocent bystanders was injured when a fleeing suspect lost control of his car and crashed into them during a high-speed police chase. The plaintiffs, including the estate of a deceased individual and several injured parties, alleged that the police officers conducted the chase with the intent to harm the suspect and failed to provide or summon emergency services after the crash.The United States District Court for the Northern District of California denied the officers' motion for judgment on the pleadings based on qualified immunity. The officers appealed, arguing that they were entitled to qualified immunity because the plaintiffs did not state a claim for a violation of their constitutional rights.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the plaintiffs plausibly alleged a substantive due process claim by asserting that the officers conducted the high-speed chase with a purpose to harm the suspect, which exceeded any legitimate law enforcement purpose. The court also held that the law was clearly established that such conduct was unconstitutional, thus the officers were not entitled to qualified immunity.Additionally, the court addressed the plaintiffs' state-created danger claim, holding that the officers' failure to summon or render emergency services after the crash, despite witnessing the injuries, constituted deliberate indifference to a known danger. The court concluded that the plaintiffs plausibly alleged that the officers' actions violated clearly established law, and therefore, the officers were not entitled to qualified immunity on this claim either. The court emphasized that its decision was based on the unique facts of the case and did not preclude the possibility of qualified immunity being granted at a later stage. View "Estate of Soakai v. Abdelaziz" on Justia Law

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law

Sean Hart and Tiffany Guzman filed a lawsuit against the City of Grand Rapids and three police officers, alleging excessive force during a 2020 Black Lives Matter demonstration. Hart and Guzman claimed that the officers used excessive force and that the City ratified this conduct. The officers sought summary judgment based on qualified immunity, and the City argued that the plaintiffs failed to establish municipal liability.The United States District Court for the Western District of Michigan granted summary judgment in favor of the City and the officers, dismissing the federal claims with prejudice and declining jurisdiction over the state claims. The plaintiffs appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment based on qualified immunity for Officer Johnson and Sergeant Bush, finding that the plaintiffs did not show that the officers violated clearly established rights. However, the court reversed the grant of summary judgment for Officer Reinink, determining that a reasonable jury could find that he used excessive force when he fired a Spede-Heat canister at Hart at close range, which could be considered deadly force. The court remanded the case for further proceedings on this claim.The court also affirmed the grant of summary judgment in favor of the City, concluding that the plaintiffs did not provide sufficient evidence to support their claim of municipal liability based on ratification of unconstitutional conduct. The plaintiffs' evidence, a spreadsheet of excessive force complaints, lacked qualitative specifics to show a pattern of inadequate investigations by the City. View "Hart v. City of Grand Rapids, Mich." on Justia Law

In 1985, Douglas Carter was convicted and sentenced to death for the murder of Eva Olesen in Provo, Utah. There was no physical evidence linking Carter to the crime scene, but he signed a confession, and two witnesses, Epifanio and Lucia Tovar, provided testimony corroborating aspects of his confession. Decades later, the Tovars signed declarations stating that the police had threatened them, pressured them to make untrue statements, and instructed them to lie at Carter’s trial about financial support they had received from the police. Based on these revelations, Carter petitioned for postconviction relief.The Fourth Judicial District Court held an evidentiary hearing and found that Carter’s trial and sentencing were tainted by serious misconduct by the lead prosecutor, the lead investigator, and another police officer. The court found that the police had suborned perjury, threatened the Tovars with deportation and separation from their son, and provided them with financial assistance, which they were instructed to lie about. The prosecutor did not disclose this information to the defense or correct the false testimony at trial.The Utah Supreme Court reviewed the case and agreed with the lower court’s findings. The court concluded that the State had violated Carter’s constitutional right to due process by suppressing evidence favorable to Carter and by failing to correct false testimony. The court determined that these violations prejudiced Carter at both the guilt and sentencing stages of his trial. The court affirmed the lower court’s decision to grant Carter’s petition for postconviction relief, vacate his conviction and sentence, and order a new trial. View "Carter v. State" on Justia Law

Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law