Justia Civil Rights Opinion Summaries

The plaintiff, Jane Doe, challenged the Manchester School District's policy regarding transgender and gender non-conforming students. The policy allowed students to keep their transgender status private and required school personnel to use a student's preferred name and pronouns, without disclosing this information to parents unless legally required or authorized by the student. Jane Doe, the parent of a minor child (M.C.) in the district, discovered that M.C. had asked to be called by a different name and pronouns. She requested the school to use M.C.'s birth name and pronouns, but the school adhered to the district policy.The Superior Court dismissed Jane Doe's claims, finding that the policy did not infringe upon a fundamental right and thus did not warrant strict scrutiny. The court applied the rational basis test and concluded that the policy was constitutional. The court also found that the policy was not ultra vires and did not violate federal laws such as the Family Educational Rights and Privacy Act (FERPA) or the Protection of Pupil Rights Act (PPRA).The Supreme Court of New Hampshire reviewed the case and affirmed the lower court's decision. The court held that the policy did not directly interfere with the fundamental right to parent, as it did not prevent parents from obtaining information from other sources or restrict their ability to parent their child. The court agreed that the policy did not infringe on a fundamental right and thus was subject to rational basis review, which it survived. The court did not find it necessary to address the plaintiff's facial and as-applied challenges separately, as the policy was found to be constitutional under the rational basis test. View "Doe v. Manchester School District" on Justia Law

In 1987, Michael Hill was convicted of two murders and sentenced to death. Hill maintained that the murders were committed by Michael McCray, whose statements to the police incriminated both himself and Hill. McCray did not testify at trial, invoking his privilege against self-incrimination, but his statements were admitted under the hearsay rule. Decades later, Hill discovered that the prosecution had failed to disclose a promise not to prosecute McCray for his involvement in the case. Hill filed a habeas corpus petition alleging violations of Brady v. Maryland and Napue v. Illinois.The trial court dismissed Hill’s claims, finding he failed to establish a prima facie case. The court concluded that the evidence against Hill was overwhelming and that the failure to disclose the non-prosecution agreement did not undermine confidence in the verdict. The court also found that Hill did not plead that false evidence was presented to the jury, as required under Napue.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that Hill established a prima facie case for both Brady and Napue violations. The court noted that McCray’s testimony at the preliminary hearing was misleading and that the prosecution’s suppression of the non-prosecution agreement allowed McCray to assert his privilege against self-incrimination, leading to the admission of his statements without cross-examination. The court concluded that the suppressed evidence was material and could have affected the jury’s verdict. The court reversed the trial court’s order and remanded the case for further proceedings, directing the trial court to issue an order to show cause. View "In re Hill" on Justia Law

Michael Harvel, a county official, was convicted by a jury for sexually assaulting seven women he supervised, violating their constitutional rights under 18 U.S.C. § 242. Harvel appealed, raising issues about the timeliness of the charges, the indictment's sufficiency, and the admission of certain evidence.The United States District Court for the Middle District of Tennessee initially handled the case. Harvel argued that the most serious charges were not brought within the five-year statute of limitations under 18 U.S.C. § 3282(a). However, the court found that these charges were "punishable by death" under 18 U.S.C. § 3281, thus not subject to the five-year limit. Harvel also claimed that the introduction of "other crimes" evidence violated the Due Process Clause and Federal Rule of Evidence 403. The district court allowed this evidence, finding it relevant and not overly prejudicial.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's rulings, holding that the charges were timely under § 3281 because the crimes included kidnapping and aggravated sexual abuse, which are punishable by death under § 242. The court also rejected Harvel's due process challenge to Rule 413, which allows the admission of other sexual assaults to show propensity, and found no abuse of discretion in the district court's Rule 403 balancing. Additionally, the court upheld the denial of Harvel's motion for a mistrial, concluding that the district court's limiting instructions were sufficient to mitigate any potential prejudice from the inadmissible testimony.In conclusion, the Sixth Circuit affirmed Harvel's convictions and the 204-month sentence, finding no merit in his arguments regarding the statute of limitations, the indictment's sufficiency, or the evidentiary rulings. View "United States v. Harvel" on Justia Law

Thad Brockett, a former employee of the Effingham County Sheriff’s Department, alleged he was terminated for supporting the former sheriff in disputes with the county chair and for reporting misconduct by two correctional officers. Brockett claimed that after he reported the officers for violating inmate safety and sexually harassing female inmates, the county chair and board shielded the officers from discipline. Subsequently, the newly elected sheriff terminated Brockett, allegedly due to budget cuts, which Brockett argued was a pretext for retaliation.The United States District Court for the Southern District of Illinois dismissed Brockett’s claim under 42 U.S.C. § 1983 for First Amendment retaliation. The court found that Brockett’s speech was not protected by the First Amendment because it pertained to personal matters and was made pursuant to his official duties, not as a private citizen. Brockett appealed the dismissal, arguing that his speech addressed matters of public concern and was protected political activity.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court noted that Brockett failed to provide sufficient arguments or legal analysis to support his claim that his speech was a matter of public concern and that he spoke as a private citizen. The court emphasized that public employees must demonstrate that their speech addresses matters of public concern and is made as private citizens to claim First Amendment protection. Brockett’s failure to adequately argue these points resulted in the waiver of his claims, leading to the affirmation of the district court’s decision. View "Brockett v. Effingham County, Illinois" on Justia Law

Judith Maureen Henry was mistakenly arrested on a warrant intended for another woman with the same name who had skipped parole in Pennsylvania. The warrant included Henry's home address and driver’s license photo. Henry was detained for over two weeks, despite her repeated claims of innocence and requests for fingerprint comparison. She was eventually released after Pennsylvania officials confirmed her fingerprints did not match those of the actual parole violator.The United States District Court for the District of New Jersey reviewed the case and denied a motion to dismiss filed by six deputy United States Marshals. The Marshals argued for qualified immunity, claimed that Henry could not pursue her claims under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, and contended that her complaint failed to state a claim. The District Court rejected these arguments, citing a need for further factual development.The United States Court of Appeals for the Third Circuit reviewed the case and reversed the District Court’s decision. The Third Circuit held that Henry’s claims presented a new context under Bivens, as her arrest was based on a valid warrant and her mistaken-identity arrest was constitutionally valid. The court found that the Marshals’ actions did not violate the Fourth Amendment and that Henry’s other claims, including those for failure to investigate her innocence and failure to present her to a magistrate, also presented a new context. The court concluded that separation of powers concerns precluded extending Bivens to this new context. Additionally, Henry’s claims under 42 U.S.C. § 1985(3) and the New Jersey Civil Rights Act were dismissed, as she failed to provide sufficient factual allegations of discriminatory animus and the Westfall Act barred her NJCRA claim. The Third Circuit remanded the case for dismissal of Henry’s claims against the Marshals. View "Henry v. Essex County" on Justia Law

Brian Jones, a Wisconsin prisoner, sued several correctional officers under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights. The claims arose from an incident where Jones caused a disturbance in the prison dayroom, refused to return to his cell, and was subsequently placed in a restraint chair and transported to a restrictive-housing cell. Jones alleged that the officers used excessive force, conducted an unlawful strip search, and confined him in a dirty cell.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the officers on all claims. Jones, who represented himself during the lower court proceedings, argued on appeal that the magistrate judge should have granted his request for pro bono counsel under 28 U.S.C. § 1915(e)(1). The magistrate judge had denied this request, concluding that Jones was competent to litigate the straightforward case on his own.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the magistrate judge applied the correct legal standard and reasonably concluded that Jones was capable of handling the case himself. The court also determined that the video evidence conclusively showed that Jones's claims lacked merit. The video demonstrated that the officers used only minimal force, conducted the strip search in a professional manner, and that Jones's cell conditions did not amount to a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's judgment, holding that the denial of pro bono counsel was appropriate and that the officers did not violate Jones's Eighth Amendment rights. View "Jones v. Anderson" on Justia Law

A 28-year-old man, Steven Mitchell Qualls, died in police custody from a methamphetamine overdose. Qualls had been taken to a hospital for chest pains and agitation but was arrested for public intoxication after refusing to leave. He was booked into the Jasper City Jail, where his condition worsened. Despite showing signs of severe distress, including vomiting black liquid and screaming in pain, officers did not seek medical help. Qualls died approximately 33 hours after being booked.Qualls’s mother, Frances E. Sims, sued the City of Jasper and several police officers under 42 U.S.C. § 1983, alleging deliberate indifference to Qualls’s serious medical needs in violation of the 14th Amendment. The district court dismissed claims against one officer and the city but denied summary judgment on qualified immunity grounds for the remaining officers. Sims then moved to bifurcate the trial into separate liability and damages phases, arguing that evidence of Qualls’s past behavior would unfairly prejudice the jury. The district court denied the motion, and the jury found for the defendants. Sims’s motion for a new trial was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in refusing to bifurcate the trial. The court reasoned that the evidence of Qualls’s past behavior was relevant to the officers’ defense, as it could show they did not recognize the severity of his condition. The court also found that standard trial practices, such as objections and limiting instructions, could mitigate any potential prejudice. The court affirmed the district court’s judgment and the denial of a new trial. View "Sims v. City of Jasper" on Justia Law

In 2017, a minor admitted to two counts of assault with intent to commit rape and was initially placed in a Level B program. Due to multiple probation violations, the juvenile court later committed him to the Division of Juvenile Justice (DJJ) in 2019. After being discharged from DJJ in April 2023, the juvenile court imposed a probation condition requiring the minor to register as a sex offender under Penal Code section 290.008. The minor appealed, arguing that this requirement violated his equal protection rights because it treated him differently from minors who committed similar offenses after the juvenile justice realignment, which closed DJJ and transferred responsibilities to county facilities.The Superior Court of Sacramento County upheld the probation condition, rejecting the minor's equal protection argument. The court found that the sex offender registration requirement did not involve a loss of liberty and thus did not implicate a fundamental right, applying the rational basis standard of review. The court reasoned that the Legislature could have determined that minors in county facilities have a lower risk of recidivism due to more effective treatment, justifying the differential treatment.The California Court of Appeal, Third Appellate District, reviewed the case de novo and affirmed the lower court's decision. The court held that the rational basis standard applied because the sex offender registration requirement did not involve a fundamental right or suspect classification. The court found that a rational basis existed for the differential treatment, as the Legislature could have reasonably concluded that minors already in DJJ custody posed a higher risk of recidivism and required continued registration to protect public safety. Thus, the court found no equal protection violation and affirmed the dispositional order. View "People v. I.B." on Justia Law

A high-school administrator, Justin Schimandle, forcibly restrained a student, C.G., at school. Following an investigation, Detective Josh Duehning of the Dekalb County Sheriff’s Office submitted affidavits to support an arrest warrant for Schimandle on battery charges. An Illinois state magistrate judge issued the warrant, and Schimandle turned himself in. The criminal case proceeded to a bench trial, where Schimandle was found not guilty after the prosecution rested.Schimandle then sued the Dekalb County Sheriff’s Office and Duehning, alleging false arrest. The defendants moved for judgment on the pleadings, and the United States District Court for the Northern District of Illinois granted the motion, dismissing Schimandle’s claims. The court found that there was probable cause to arrest Schimandle and that Duehning was entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that arguable probable cause supported Schimandle’s arrest, meaning a reasonable officer could have believed probable cause existed based on the circumstances. The court also found that Duehning was entitled to qualified immunity, protecting him from liability for the false arrest claim. Additionally, the court noted that the magistrate judge’s issuance of the arrest warrant further supported the reasonableness of Duehning’s actions. Consequently, the court affirmed the dismissal of Schimandle’s complaint. View "Schimandle v. DeKalb County Sheriff's Office" on Justia Law

Meng Huang, a former Ph.D. student at The Ohio State University (OSU), alleged that her advisor, Professor Giorgio Rizzoni, sexually harassed and assaulted her during her studies. Huang filed a lawsuit against OSU and Rizzoni, claiming Title VII quid pro quo sexual harassment and retaliation against OSU, and a due process violation against Rizzoni under 42 U.S.C. § 1983.The United States District Court for the Southern District of Ohio granted summary judgment to OSU on Huang’s Title VII claims, concluding she was not an "employee" under Title VII until August 2017. The court also ruled that Huang’s retaliation claim failed because her first protected activity occurred after the alleged adverse actions. Huang’s § 1983 claim against Rizzoni proceeded to trial, where the court trifurcated the trial and excluded evidence of Rizzoni’s alleged manipulation and coercion. The jury found in favor of Rizzoni.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in determining Huang was not an employee under Title VII before August 2017, as her research work and the control Rizzoni exerted over her indicated an employment relationship. The court also held that Huang’s resistance to Rizzoni’s advances constituted protected activity under Title VII, and she presented sufficient evidence of adverse employment actions linked to her resistance.The Sixth Circuit reversed the district court’s summary judgment on Huang’s Title VII claims, vacated the trial verdict in favor of Rizzoni on the § 1983 claim, and remanded for a new trial. The court emphasized that the district court’s exclusion of relevant evidence regarding Rizzoni’s power and manipulation was an abuse of discretion, which prejudiced Huang’s ability to present her case. View "Huang v. Ohio State University" on Justia Law