Justia Civil Rights Opinion Summaries

Plaintiffs Moses Lugo and Cheryl Seaton, who use motorized wheelchairs, sued the City of Troy, New York, under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 (RA). They alleged that the city failed to maintain accessible pedestrian pathways. After discovery, Plaintiffs moved for summary judgment, while the City of Troy moved to dismiss the complaint for lack of standing or, alternatively, for summary judgment. The district court dismissed the complaint, finding the factual allegations insufficient to establish standing, without considering the full summary-judgment record.The United States District Court for the Northern District of New York dismissed the complaint based on the pleadings, concluding that the allegations were too generic to establish standing for city-wide remedies and that the specific obstacles mentioned had been remedied, thus mooting those claims. The court did not evaluate whether the evidence from discovery could establish standing.The United States Court of Appeals for the Second Circuit reviewed the case. The appellate court found that the district court erred by resolving the standing issue based solely on the pleadings rather than the full summary-judgment record. The appellate court held that the district court should have considered the evidence developed during discovery to determine whether Plaintiffs had standing. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the lower court to evaluate the standing issue based on the complete evidentiary record and to determine if summary judgment is warranted or if Plaintiffs should be allowed to amend their complaint. View "Lugo v. The City of Troy, New York" on Justia Law

Tesla, Inc. and its affiliates challenged a Louisiana law that prohibits automobile manufacturers from selling directly to consumers and performing warranty services for cars they do not own. Tesla alleged that the law violated federal antitrust law, due process rights, and equal protection rights. The defendants included the Louisiana Motor Vehicle Commission, its commissioners, the Louisiana Automobile Dealers Association (LADA), and various dealerships.The United States District Court for the Eastern District of Louisiana dismissed Tesla's claims. The court found that the private defendants were immune from antitrust liability, Tesla had not plausibly pleaded a Sherman Act violation against the governmental defendants, there was insufficient probability of actual bias to support the due process claim, and the regulations passed rational-basis review for the equal protection claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the dismissal of Tesla's due process claim, finding that Tesla had plausibly alleged that the Commission's composition and actions created a possible bias against Tesla, violating due process. The court vacated and remanded the dismissal of the antitrust claim, noting that the due process ruling fundamentally altered the grounds for Tesla's alleged antitrust injury. The court affirmed the dismissal of the equal protection claim, holding that the regulations had a rational basis in preventing vertical integration and controlling the automobile retail market.In summary, the Fifth Circuit reversed the due process claim dismissal, vacated and remanded the antitrust claim dismissal, and affirmed the equal protection claim dismissal. The case was remanded for further proceedings consistent with the court's opinion. View "Tesla v. Louisiana Automobile Dealers" on Justia Law

The case involves a long-standing litigation concerning the Orleans Parish Sheriff’s Office and the conditions at Orleans Parish Prison. Plaintiffs, including detainees and the United States, argued that the jail provided constitutionally inadequate housing and medical care. In 2013, a district court approved a consent decree to address these issues, which included a plan to construct a mental health annex, known as Phase III. Despite years of delays, the district court ordered the construction to proceed. No party appealed these orders at the time.The United States District Court for the Eastern District of Louisiana oversaw the case initially. In 2016, the parties entered a stipulated order to develop a plan for appropriate housing for prisoners with mental health issues. The Compliance Director later proposed the construction of Phase III, which was agreed upon by the former Sheriff and the City. However, the City later sought to explore alternatives, leading to further court orders in 2019 to proceed with Phase III. The City’s subsequent motion to halt the project was denied, and this decision was affirmed by the United States Court of Appeals for the Fifth Circuit in Anderson v. City of New Orleans.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The new Sheriff, Susan Hutson, moved to terminate all orders concerning Phase III, arguing that the Prison Litigation Reform Act (PLRA) prohibits the construction of a new jail facility. The district court denied this motion, and the Fifth Circuit dismissed the appeal for lack of jurisdiction. The court held that it could review the denial of the motion but not the underlying orders, as the Sheriff’s motion was not a proper procedural mechanism under the PLRA to challenge the 2019 Orders and Stipulated Order. The appeal was dismissed, and the construction of Phase III continues. View "Anderson v. Hutson" on Justia Law

Alexis Guerrero, a Black Dominican-American, sued Ollie’s Bargain Outlet under 42 U.S.C. § 1981 for race discrimination. Guerrero alleged that while shopping for flowerpots at an Ollie’s store in Salisbury, Maryland, an employee named Richard Murray threatened him with a knife and shouted racial slurs, preventing him from purchasing the items. Guerrero claimed that this discriminatory conduct interfered with his right to make and enforce contracts.The United States District Court for the District of Maryland granted Ollie’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The court reasoned that Guerrero failed to sufficiently allege that he was denied the opportunity to contract for goods or services that was otherwise afforded to white customers. Specifically, the court found that Guerrero did not claim that Ollie’s actually prevented him from purchasing a flowerpot and noted that he voluntarily left the store without attempting to make a purchase.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Guerrero sufficiently alleged a contractual interest by demonstrating his intent to purchase the flowerpots and that Murray’s actions, including wielding a knife and shouting racial slurs, interfered with this interest. The court found that Guerrero’s allegations were enough to show that he was denied the opportunity to contract based on his race. Consequently, the Fourth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Guerrero v. Ollie's Bargain Outlet, Inc." on Justia Law

Victor Raul Tellez was charged with three counts of lewd or lascivious acts upon a child and faced a maximum prison term of 12 years. On the advice of his attorney, he accepted a plea deal, pleading guilty to one count and receiving a three-year prison sentence. Tellez was not informed that his conviction would make him eligible for civil commitment as a sexually violent predator (SVP) under the Sexually Violent Predator Act (SVPA). After completing his prison term, the District Attorney initiated SVPA proceedings for his involuntary commitment to a state hospital.Tellez filed a petition for writ of habeas corpus in the San Diego County Superior Court, claiming ineffective assistance of counsel for not being advised of the SVPA consequences. The superior court denied his petition, and the Court of Appeal also denied it, stating that prevailing norms did not require such advisement and that Tellez had not demonstrated prejudice. Tellez then petitioned the California Supreme Court for review.The California Supreme Court held that Tellez did not sufficiently demonstrate he was prejudiced by his counsel’s failure to advise him of the SVPA consequences. The court noted that Tellez provided insufficient evidence that he would not have accepted the plea deal had he been informed of the SVPA consequences. Therefore, the court did not address whether his counsel’s performance was constitutionally deficient. However, recognizing the significant liberty deprivation involved in SVPA commitments, the court exercised its supervisory powers to require trial courts to inform defendants of potential SVPA consequences when pleading guilty or no contest to a qualifying offense. The judgment of the Court of Appeal was affirmed on the ground that Tellez had not demonstrated prejudice. View "In re Tellez" on Justia Law

Christopher Lockhart, a licensed Arkansas bail bondsman and private investigator, was stopped by Siloam Springs police officer Zachary Ware around 3:30 AM on March 11, 2019, for alleged traffic violations. Lockhart was arrested and charged with DWI, careless driving, and driving left of center. After refusing a plea deal, Lockhart was tried for DWI but was found not guilty. Subsequently, Lockhart filed a § 1983 action against multiple defendants, including claims of unreasonable stop, unlawful arrest, and malicious prosecution.The United States District Court for the Western District of Arkansas granted summary judgment to the defendants on most claims but allowed Lockhart’s illegal stop and false arrest claims against Officer Ware and the malicious prosecution claim against Siloam Springs to proceed. The court found genuine disputes of material fact regarding whether Officer Ware had probable cause to stop Lockhart, as the dashcam video did not conclusively support Ware’s testimony. The court also denied summary judgment on the malicious prosecution claim, finding a material fact dispute about whether the prosecutor had probable cause to try Lockhart for DWI.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that Officer Ware had probable cause to stop Lockhart for careless driving, as Lockhart’s tires touched the centerline, which under Arkansas law constitutes a traffic violation. The court reversed the district court’s decision regarding the initial stop and remanded the case for further proceedings on the remaining issues. The court also affirmed the district court’s denial of summary judgment on the malicious prosecution claim, agreeing that Arkansas statutory immunity does not apply to intentional torts like malicious prosecution. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

In 2001, the Commonwealth charged Robert Gene Rega with first-degree murder and other crimes for shooting a security guard, Christopher Lauth, during a robbery at the Gateway Lodge in Jefferson County, Pennsylvania. Rega, along with Shawn Bair, Raymond Fishel, and Stanford Jones, planned the robbery, while Jones’s wife, Susan, stayed at Rega’s home. During the robbery, Lauth was killed. The prosecution's case relied heavily on the testimonies of Bair, Fishel, and the Joneses, who identified Rega as the shooter. Additional evidence included a video of Rega purchasing ammunition and testimony from a friend that Rega asked for a false alibi.The Pennsylvania state court convicted Rega of first-degree murder and sentenced him to death. Rega's conviction and sentence were upheld on direct appeal and in a Post-Conviction Relief Act (PCRA) proceeding. Rega then filed a federal habeas petition. The United States District Court for the Western District of Pennsylvania denied his guilt-phase claims but granted relief from his death sentence, ordering a new sentencing hearing or life imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. Rega raised claims that the prosecutor withheld evidence in violation of Brady v. Maryland and presented false testimony in violation of Giglio v. United States and Napue v. Illinois. The Third Circuit affirmed the denial of relief on these claims, concluding that the evidence and testimony in question were not material to Rega’s murder conviction. The court found that the prosecutor’s noncommittal statements to witnesses about considering their cooperation in future plea deals did not significantly undermine their credibility, as the jury was already aware of their potential motives. Additionally, evidence of Susan Jones’s memory problems was deemed not material, as it did not sufficiently undermine her testimony or the overall case against Rega. View "Rega v. Secretary Pennsylvania Department of Corrections" on Justia Law

In the early days of the COVID-19 pandemic, Governor Roy Cooper of North Carolina issued an executive order limiting attendance at outdoor venues to twenty-five people. Robert Turner, who operated Ace Speedway in Alamance County, publicly opposed these restrictions and kept the racetrack open. This led to a series of events where Governor Cooper allegedly pressured local officials to enforce the order against Ace Speedway, culminating in the North Carolina Department of Health and Human Services (DHHS) issuing an abatement order to shut down the racetrack as a health hazard.The Superior Court of Alamance County initially issued a preliminary injunction against Ace Speedway, prohibiting it from holding events until it complied with the abatement order. Ace Speedway and its operators counterclaimed, alleging constitutional violations, including the right to earn a living and selective enforcement. The trial court denied the State’s motion to dismiss these counterclaims, and the State appealed. The North Carolina Court of Appeals affirmed the trial court’s decision, allowing the case to proceed.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decision. The Court held that Ace Speedway sufficiently alleged colorable claims under the North Carolina Constitution. The allegations suggested that the State's actions were not for a proper governmental purpose but to retaliate against Turner for his public criticism, thus violating the right to earn a living. Additionally, the selective enforcement claim was deemed colorable because Ace Speedway alleged it was targeted while other similar venues were not, based on Turner’s exercise of his First Amendment rights. The Court concluded that these claims were sufficient to overcome the State’s sovereign immunity at this stage. View "Kinsley v. Ace Speedway Racing, Ltd" on Justia Law

Bobby Stevenson, a prisoner at the Louisiana State Penitentiary, claims he was forced to labor in the prison’s agricultural fields despite severe ankle pain caused by two broken surgical screws. He alleges that two prison physicians, Dr. Randy Lavespere and Dr. Paul M. Tocé, refused to fix the screws or relieve him from field labor. Stevenson asserts that the broken screws caused him tremendous pain and secondary injuries, and that the physicians ignored his complaints and medical recommendations for surgery.The United States District Court for the Middle District of Louisiana reviewed the case. The magistrate judge allowed Stevenson to file an amended complaint and recommended denying the defendants' motion to dismiss, which argued for qualified immunity. The district court accepted this recommendation and denied the motion, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Stevenson sufficiently alleged that the defendants violated his Eighth Amendment rights by ignoring his severe medical needs and forcing him to work despite his condition. The court also determined that the defendants had fair warning from existing case law that their actions were unconstitutional. Consequently, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss, rejecting the defendants' claim of qualified immunity. View "Stevenson v. Toce" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law