Justia Civil Rights Opinion Summaries

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

Roy Lee Williams, a death-row inmate with a history of mental illness, was held in solitary confinement for twenty-six years. Williams filed a lawsuit claiming that his prolonged solitary confinement without penological justification violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Americans with Disabilities Act (ADA). The District Court granted summary judgment in favor of the defendants, ruling that the former Secretary of the Pennsylvania Department of Corrections (DOC) was entitled to qualified immunity on the Eighth Amendment claim and that Williams could not prove deliberate indifference under the ADA.Before the summary judgment, the District Court dismissed Williams' Fourteenth Amendment claim for failure to state a claim. Williams appealed both the summary judgment and the dismissal of his Fourteenth Amendment claim.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the Secretary had "fair and clear warning" that keeping Williams in solitary confinement without penological justification was unconstitutional, thus rejecting the qualified immunity defense. The court held that it was clearly established that someone with a known preexisting serious mental illness has a constitutional right not to be held in prolonged solitary confinement without penological justification.Regarding the ADA claim, the court found that the District Court erred in concluding that a trier of fact could not find the DOC deliberately indifferent to the risk of harm caused by placing and keeping Williams in solitary confinement despite his mental illness. The court vacated the District Court's grant of summary judgment on both the Eighth Amendment and ADA claims and remanded for further proceedings. However, the court affirmed the dismissal of Williams' Fourteenth Amendment claim. View "Williams v. Secretary Pennsylvania Department of Corrections" on Justia Law

The case involves an encounter between the Hawai'i Police Department (HPD) and Steven Hyer, which resulted in Hyer's death. On June 22, 2018, HPD officers responded to calls about Hyer's erratic behavior. Hyer, who had a history of mental illness, barricaded himself in his apartment. After several hours of failed negotiations and attempts to subdue him, including the use of a Taser and chemical munitions, HPD officers deployed a police dog. When Hyer allegedly threatened the officers with a compound bow, Corporal Torres shot and killed him.The United States District Court for the District of Hawaii granted summary judgment in favor of the defendants, the City and County of Honolulu, and several HPD officers. The court excluded the plaintiffs' expert reports, finding them speculative, unreliable, and containing legal conclusions. The court ruled that the use of force was objectively reasonable and that the officers were entitled to qualified immunity. The court also dismissed the plaintiffs' claims under the Americans with Disabilities Act (ADA) and various state law claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the district court erred in excluding the entirety of the plaintiffs' expert reports, as the reports were based on sufficient facts and data. The Ninth Circuit found that the exclusion of these reports was prejudicial because they created genuine disputes of material fact regarding the reasonableness of the use of deadly force and chemical munitions, as well as potential ADA violations. The court reversed the district court's summary judgment on these claims but affirmed the grant of qualified immunity regarding the use of the police dog, as the law was not clearly established. The case was remanded for further proceedings. View "HYER V. CITY AND COUNTY OF HONOLULU" on Justia Law

The plaintiff pleaded guilty to obstructing a peace officer under California Penal Code § 148(a)(1) after an incident where San Diego County Deputy Sheriffs came to his home to investigate a report of domestic violence. During the encounter, the plaintiff did not comply with the deputies' orders, leading to his being pushed to the floor, which he claims resulted in a dislocated shoulder and rotator cuff tear. He later filed a 42 U.S.C. § 1983 action alleging that the deputies used excessive force.The United States District Court for the Southern District of California dismissed the plaintiff's complaint, citing Heck v. Humphrey, which bars § 1983 actions if a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction. The district court concluded that the plaintiff's resistance and the force used by the deputies were part of the same factual context and could not be separated into isolated events. Therefore, the court held that the § 1983 action was barred by Heck and denied the plaintiff's request to amend his complaint.The United States Court of Appeals for the Ninth Circuit reversed the district court's dismissal. The appellate court held that Heck did not bar the plaintiff's suit because he engaged in multiple acts of resistance or obstruction that could serve as the factual basis for his conviction, both before and after the use of force he claimed was excessive. Since the plaintiff's guilty plea did not specify which act was the basis of his conviction, success in his § 1983 action would not necessarily undermine his conviction. The court emphasized that a § 1983 action is barred by Heck only if success in the action would necessarily imply the invalidity of the plaintiff's conviction. The case was remanded for further proceedings. View "MARTELL V. COLE" on Justia Law

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Angela Richardson, an inmate in Arkansas, filed a lawsuit against Krystle Reed Duncan, a former prison security officer, under 42 U.S.C. § 1983, alleging sexual harassment and assault in violation of the Eighth Amendment. Richardson claimed that between November 2018 and January 2019, she and Duncan engaged in a consensual sexual relationship, which included kissing and digital penetration. Richardson did not report the relationship to prison officials until late 2020, after learning that Duncan had been involved with other inmates, which caused her emotional distress.The United States District Court for the Eastern District of Arkansas reviewed the case. Duncan did not respond to the complaint, leading to a default entry. A magistrate judge held a hearing and recommended vacating the default and dismissing the complaint for failure to state a claim. The magistrate judge found that Richardson's allegations described consensual sexual activity and did not support a claim of coercion or non-consensual conduct. The district court adopted this recommendation and dismissed the complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Richardson failed to state a claim under the Eighth Amendment. The court applied its precedent from Freitas v. Ault, which held that consensual sexual interactions, even if inappropriate, do not constitute "pain" under the Eighth Amendment. The court found that Richardson's complaint and testimony did not allege any coercion, force, or threats by Duncan, and thus did not meet the objective component of an Eighth Amendment violation. The judgment of the district court was affirmed. View "Richardson v. Duncan" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law

In the early morning of July 8, 2022, Officer Luke Thorp of the Mills Police Department responded to a report of an unconscious male in a truck with syringes on the ground nearby. Upon arrival, Officer Thorp found Travis Dean Schaub in the vehicle, appearing disoriented and exhibiting signs of intoxication. After a slow and difficult exit from the vehicle, Schaub refused consent to a search, but Officer Thorp proceeded to search him, finding methamphetamine. Schaub was then handcuffed, placed in the patrol vehicle, and read his Miranda rights.The District Court of Natrona County reviewed Schaub’s motion to suppress the evidence obtained during the search, arguing it exceeded the scope of an investigatory stop and lacked a warrant. The State contended that the search was justified as incident to a lawful arrest for public intoxication. The district court agreed with the State, finding that Officer Thorp had probable cause to arrest Schaub for public intoxication under the Mills Municipal Code, and thus the search was lawful.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that Officer Thorp had probable cause to arrest Schaub based on his observed intoxication and the presence of syringes. The court further held that the search was valid as incident to a lawful arrest, even though it preceded the formal arrest by a few minutes. The court emphasized that the Fourth Amendment does not require the arrest to precede the search, as long as the arrest follows quickly and there is probable cause. Therefore, the denial of Schaub’s motion to suppress was upheld. View "Schaub v. The State of Wyoming" on Justia Law

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law