Justia Civil Rights Opinion Summaries

The plaintiff, Lupe Stratton, worked at Bentley University from August 2016 to July 2018. She alleged that her supervisors discriminated against her based on her gender, race, disability, and Guatemalan origin. After she complained to Bentley's human resources department, she was placed on a performance improvement plan, which she claimed was retaliatory. Stratton also contended that Bentley interfered with her right to medical leave and failed to provide reasonable accommodations for her disability. She resigned, claiming her workplace had become intolerable.The United States District Court for the District of Massachusetts granted summary judgment in favor of Bentley University on all of Stratton's claims. The court found that Stratton did not suffer an adverse employment action that could support her discrimination claims and that her retaliation claims failed because she could not establish a causal connection between her complaints and the adverse actions. The court also held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that Stratton did not experience an adverse employment action that could support her discrimination claims, as her working conditions were not so intolerable as to constitute a constructive discharge. The court also found that Stratton's retaliation claims failed because she could not show that her complaints were the but-for cause of the adverse actions. Additionally, the court held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights. The court clarified the relevant law governing Title VII retaliation claims in the circuit. View "Stratton v. Bentley University" on Justia Law

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

Ryan Haygood, a dentist in Louisiana, faced an investigation by the Louisiana State Board of Dentistry, which led to the revocation of his dental license in 2010. Haygood alleged that competing dentists conspired with Board members to drive him out of business by fabricating complaints and manipulating the Board's proceedings. In 2012, a Louisiana appellate court vacated the Board's revocation of Haygood's license, citing due process violations. Haygood then entered a consent decree with the Board, allowing him to keep his license.Haygood filed a civil action in state court in 2011, alleging due process violations and unfair competition. In 2013, he filed a similar federal lawsuit, claiming violations under 42 U.S.C. § 1983 and the Louisiana Unfair Trade Practices Act (LUTPA). The federal district court dismissed the federal complaint, ruling that the § 1983 claim was time-barred and the LUTPA claim was not plausible. The court also awarded attorney’s fees to the defendants, deeming both claims frivolous.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to award attorney’s fees for the frivolous § 1983 claim, agreeing that it was clearly time-barred. However, the appellate court found that the district court erred in calculating the fee amount. The district court had properly calculated $98,666.50 for the defendants' private attorneys but improperly awarded $11,594.66 for the Louisiana Attorney General’s office without using the lodestar method. Consequently, the Fifth Circuit remitted the fee award to $98,666.50 while affirming the decision to award fees. View "Haygood v. Morrison" on Justia Law

Tony Fisher, a federal inmate, filed a lawsuit against several prison officials, alleging they were deliberately indifferent to the risk of sexual assault by another inmate, resulting in his rape. Fisher entered federal prison in 2013 and was transferred to Fort Dix, where he reported past sexual assault and harassment by other inmates. Despite these reports, prison staff did not classify him as at high risk for sexual assault. Shortly after, Fisher was raped by another inmate. Fisher claimed that a prison official, Captain Fitzgerald, discouraged him from reporting the assaults and seeking legal help, warning him of potential retaliation.The United States District Court for the District of New Jersey dismissed Fisher’s complaint, ruling it was time-barred under New Jersey’s two-year statute of limitations for personal injury actions. Fisher appealed, arguing that the statute of limitations should be tolled due to the prison official’s threats and his mental health issues.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The court held that no Bivens cause of action exists for failure to protect an inmate from another inmate’s violence, following the Supreme Court’s decision in Egbert v. Boule. The court also ruled that even if such a claim were cognizable, Fisher’s complaint was untimely. The court found that Fisher did not qualify for equitable tolling because he was transferred away from the influence of the threatening official shortly after the assaults and did not exercise due diligence in pursuing his claims. Additionally, the court held that New Jersey’s revival statute for sexual assault claims did not apply to Bivens actions. View "Fisher v. Hollingsworth" on Justia Law

Two high school brothers, Kameron and Noah Evans, were arrested for disorderly conduct after wearing tactical vests to school. The brothers, who had faced racial bullying, wore the vests on a day when the school was screening an active-shooter video. They were searched by school resource officers, who found no weapons. The principal decided to have them arrested, and they were charged with disorderly conduct. The state court later acquitted them, and the brothers filed a lawsuit under § 1983 and state tort claims against the officers, alleging lack of probable cause and excessive force.The United States District Court for the Eastern District of Arkansas denied the officers' motion for summary judgment based on qualified immunity. The officers appealed, arguing they had probable cause or at least arguable probable cause to arrest the brothers for disorderly conduct under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the officers lacked probable cause to arrest the brothers, as their actions did not disrupt a lawful assembly or constitute threatening behavior. The court also determined that the officers did not have arguable probable cause, as the brothers were cooperative and their attire did not violate the school dress code. The court affirmed the district court's denial of qualified immunity on the unlawful arrest, malicious prosecution, and false imprisonment claims. However, the court reversed the denial of qualified immunity on the excessive force and abuse of process claims, as the plaintiffs failed to respond to these arguments on appeal. The case was remanded for further proceedings. View "Evans v. Dodd" on Justia Law

The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law

In 2018, Officer Patrick Kaine of the City of Wauwatosa Police Department stopped a vehicle based on a citizen's tip about a potential robbery. The vehicle contained Akil Carter, Paulette Barr, and Sandra Adams. Officer Kaine handcuffed Carter and placed him in the back of his squad car while he investigated. He soon realized the tip was mistaken, uncuffed Carter, and allowed the group to leave. Carter, Barr, and Adams subsequently sued Officer Kaine, other officers, and the City of Wauwatosa, alleging violations of their Fourth Amendment rights.The case was initially heard in the United States District Court for the Eastern District of Wisconsin, where the jury found in favor of the defendants. The plaintiffs appealed, challenging several pretrial and trial decisions, including the bifurcation of the trial, jury instructions, exclusion of their police-practices expert, and the judge's failure to recuse himself. They also contested the district judge's denial of their Batson challenge to a peremptory strike.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found no error in the district judge's decisions regarding bifurcation, jury instructions, exclusion of the expert, or recusal. However, the court determined that the district judge did not properly conduct the third step of the Batson inquiry, which requires assessing whether the race-neutral reasons for the peremptory strike were pretextual. The court remanded the case for further findings on the Batson challenge to Juror 10, instructing the district judge to complete the three-step Batson process and make the necessary credibility determinations on the record. The court affirmed the district court's decisions in all other respects. View "Carter v. City of Wauwatosa" on Justia Law

The case involves a challenge to the Parental Consent for Abortion Act of 2013 (Consent Act) in Montana, which requires minors to obtain parental consent or a judicial waiver to have an abortion. The plaintiffs, Planned Parenthood of Montana and Dr. Samuel Dickman, argue that the Act violates the Montana Constitution by infringing on minors' fundamental rights to privacy and equal protection.The First Judicial District Court in Lewis and Clark County initially issued a preliminary injunction against the Consent Act, keeping the Parental Notice of Abortion Act of 2011 (Notice Act) in effect. The District Court later granted summary judgment in favor of Planned Parenthood, ruling that the Consent Act violated the Montana Constitution. The court found that the Act was not narrowly tailored to achieve the State's compelling interests, such as protecting minors from sexual offenses, ensuring informed decision-making, and promoting parental rights. The court did not address the equal protection challenge but noted that the Notice Act, while serving similar ends, was less onerous.The Montana Supreme Court reviewed the case de novo. The Court held that the Consent Act violates minors' fundamental rights to privacy and equal protection under the Montana Constitution. The Court found that the Act's classification between minors seeking abortions and those carrying pregnancies to term was unjustified. The State failed to demonstrate that the Act was narrowly tailored to serve compelling state interests, such as protecting minors from sexual victimization, psychological and physical harm, and immaturity, or promoting parental rights. The Court also found that the judicial waiver provision did not save the Act, as it introduced unnecessary delays and burdens on minors seeking abortions.The Montana Supreme Court concluded that the Consent Act infringes on minors' fundamental rights without adequate justification and does not enhance their protection. Therefore, the Court held that the Consent Act is unconstitutional. View "Planned Parenthood v. State" on Justia Law

Trevor Davis filed a lawsuit against Deputy Christopher Allen under 42 U.S.C. § 1983, claiming that Allen violated his Fourth Amendment rights by using excessive force during his arrest. Davis had several outstanding warrants for violent felonies, and when officers arrived to arrest him, he fled into a trailer. Deputy Allen used his police dog, Koda, to locate Davis inside the trailer. Despite Davis lying face-down with his hands over his head, Koda bit him, causing severe injury. Davis alleged that Allen failed to recall Koda after Davis had surrendered.The United States District Court for the Western District of Wisconsin denied Deputy Allen’s motion for summary judgment. The court found that there were material disputes of fact regarding the circumstances and timing of the use of the police dog, which precluded a finding of qualified immunity at this stage. Specifically, the court noted that a jury could find that a reasonable officer would have known that Davis had surrendered and that continuing to allow Koda to bite him constituted excessive force.The United States Court of Appeals for the Seventh Circuit reviewed the case and dismissed the appeal for lack of appellate jurisdiction. The court noted that the district court’s denial of qualified immunity was based on disputed facts, which are not subject to interlocutory appeal. The Seventh Circuit emphasized that the reasonableness of Deputy Allen’s actions depended on resolving these factual disputes, such as whether Davis was visibly unarmed and compliant. The court concluded that it could not address the merits of the qualified immunity claim without first resolving these factual issues, which must be done by a jury. View "Davis v. Allen" on Justia Law

Hasmik Chinaryan was driving home with her daughter and a friend when Los Angeles Police Department (LAPD) officers mistakenly suspected her vehicle was stolen due to a DMV error with the license plates. Despite driving normally, officers conducted a high-risk felony stop, ordering Chinaryan and her passengers out of the vehicle at gunpoint, handcuffing them, and making them lie on the street while they investigated.The plaintiffs sued the officers, the LAPD, and the City of Los Angeles under 42 U.S.C. § 1983 and California’s Bane Act, alleging illegal seizures, excessive force, and failure to properly train the officers. The United States District Court for the Central District of California granted partial summary judgment in favor of the officers, ruling they were entitled to qualified immunity on the § 1983 claims and that there was no evidence of specific intent to violate plaintiffs’ rights under the Bane Act. A jury later found in favor of the City and the LAPD on the Monell claims.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment in favor of the individual officers on the Fourth Amendment and Bane Act claims. The appellate court held that it was clearly established in Washington v. Lambert and Green v. City & County of San Francisco that officers cannot conduct a high-risk vehicle stop based solely on reasonable suspicion that a vehicle is stolen. The court found that the officers were not entitled to qualified immunity and that there was sufficient evidence for a jury to find that the officers acted with reckless disregard for plaintiffs’ rights. The court affirmed the judgment in favor of the City and the LAPD, ruling that the district court did not abuse its discretion in declining plaintiffs’ requested jury instructions. The case was remanded for a new trial on all claims against the individual officers. View "Chinaryan v. City of Los Angeles" on Justia Law