Justia Civil Rights Opinion Summaries

Christine Bube and Connie Hedrington, both registered nurses, worked for Aspirus, Inc., a non-profit hospital system. In response to the COVID-19 pandemic, Aspirus mandated that all employees receive the COVID vaccine, allowing exemptions for religious reasons. Bube and Hedrington applied for religious exemptions, citing their Catholic faith and beliefs about bodily integrity and health. Aspirus denied their requests and terminated their employment in December 2021.The United States District Court for the Western District of Wisconsin dismissed Bube and Hedrington’s Title VII claim, reasoning that their accommodation requests did not sufficiently tie their objections to specific religious beliefs or practices. The court concluded that their objections were primarily about personal autonomy and vaccine safety, rather than religious beliefs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that an employee seeks accommodation because of their religion when their request is plausibly based at least in part on some aspect of their religious belief or practice. Applying this standard, the court found that Bube’s and Hedrington’s requests were indeed based in part on their religious beliefs. The court emphasized that Title VII’s broad definition of religion requires a hands-off approach to defining religious exercise. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Bube v. Aspirus Hospital, Inc" on Justia Law

Two healthcare workers, Megan Passarella and Sandra Dottenwhy, employed by Aspirus Health in Wisconsin, sought religious exemptions from the company's COVID-19 vaccination mandate. Passarella cited her Christian belief that her body is a temple of the Holy Spirit and expressed concerns about the vaccine's safety. Dottenwhy also referenced her Christian faith, stating that her body is a temple and expressing distrust in the vaccine's development and long-term effects. Both were denied exemptions and subsequently terminated.The United States District Court for the Western District of Wisconsin dismissed their Title VII claims, ruling that their objections were based on medical judgment rather than religious conviction. The court found that the plaintiffs did not articulate any religious belief that would prevent them from taking the vaccine if they believed it was safe.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that an employee's request for accommodation is based on religion if it is plausibly connected to their religious beliefs or practices, even if it also includes non-religious reasons. The court emphasized that Title VII's definition of religion is broad and includes all aspects of religious observance and practice. The court found that both Passarella's and Dottenwhy's exemption requests were at least partially based on their religious beliefs, making them sufficient to survive a motion to dismiss. The case was remanded for further proceedings to determine the sincerity of the plaintiffs' beliefs and whether Aspirus could reasonably accommodate them without undue hardship. View "Dottenwhy v. Aspirus, Inc." on Justia Law

A civilian, Clarissa Gilmore, was strip-searched while visiting her incarcerated husband at Smith State Prison in Georgia. During the search, officers manipulated her breasts, ordered her to bend over, and felt between her buttocks with a gloved hand. The officers did not inform her of the reasons for the search, and no contraband was found. Gilmore sued the officers and the Georgia Department of Corrections, claiming the search violated her Fourth Amendment rights.The United States District Court for the Southern District of Georgia granted summary judgment to the officers, finding that the search did not violate clearly established law and that the officers were entitled to qualified immunity. The court concluded that the officers acted within the scope of their discretionary authority and that there was no clearly established requirement for reasonable suspicion to conduct a strip search of a prison visitor.The United States Court of Appeals for the Eleventh Circuit reviewed the case and agreed that the strip search violated Gilmore’s Fourth Amendment rights. The court held that correctional officers must have at least reasonable suspicion that a visitor is concealing contraband before conducting a strip search. However, the court also found that no Supreme Court or Eleventh Circuit precedent expressly prohibited suspicionless strip searches of prison visitors at the time of the search. As a result, the law was not clearly established, and the officers were entitled to qualified immunity. The Eleventh Circuit affirmed the district court’s grant of summary judgment. View "Gilmore v. Georgia Department of Corrections" on Justia Law

Jamal L. Smith was convicted of first-degree intentional murder while committing a drive-by shooting, among other charges, for the fatal shooting of Jay Boughton during a road rage incident. Smith was driving a rented Chevrolet Suburban with two passengers from Chicago to Minnesota. During the trip, Smith brandished a pistol in a video, and later, the Suburban was involved in a road rage incident where Smith allegedly pointed a gun at another driver. On the night of the murder, Smith's Suburban paced Boughton's truck on the highway before a single .45-caliber bullet was fired from the Suburban, striking Boughton in the neck and causing his death.The Hennepin County District Court denied Smith's motion to dismiss the indictment based on the racial composition of the grand jury and admitted evidence of Smith's prior bad acts under the immediate episode exception. A jury found Smith guilty, and he was sentenced to life with the possibility of release for the murder charge and a concurrent sentence for possession of ammunition or a firearm after being convicted of a crime of violence. Smith appealed, arguing judicial bias, ineffective assistance of counsel, improper jury pool composition, erroneous admission of prior bad acts, and insufficient evidence to prove he fired the fatal shot.The Minnesota Supreme Court reviewed the case and found that Smith failed to demonstrate judicial bias or ineffective assistance of counsel. The court also held that Smith did not show that Black persons were underrepresented in the jury pool or that any underrepresentation resulted from systematic exclusion. The court ruled that the district court did not abuse its discretion in admitting evidence of Smith's prior bad acts, as it was admissible under the Spreigl exception or as direct or corroborative evidence of a charged crime. Finally, the court concluded that the only reasonable inference from the circumstances proved was that Smith fired the fatal shot. The court affirmed the judgment of convictions. View "State v. Smith" on Justia Law

Kathleen Saurman, who had mobility impairments, fell on a small stairway at a restaurant while celebrating her 60th birthday. She subsequently died from an infection following surgery for a broken hip. Her husband, Robert, filed a wrongful death lawsuit against the restaurant's former owner and later sued the current owner, Peter’s Landing Property Owner LLC, alleging violations of the Americans with Disabilities Act (ADA), the Unruh Civil Rights Act, and the Disabled Persons Act (DPA).The Superior Court of Orange County granted summary judgment in favor of the current owner, finding that Robert lacked standing to bring an ADA claim for injunctive relief and had not provided evidence of any act or omission by the current owner. The court also imposed nearly $100,000 in sanctions against Robert’s attorney for pursuing what it deemed a frivolous lawsuit.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that under California law, a successor in interest has standing to bring an ADA claim for injunctive relief in state court, even if federal standing requirements are not met. The court also found that there was a triable issue of fact regarding the current owner’s compliance with the Unruh Act and the DPA, as the property remained in the same condition as when Kathleen fell. Consequently, the court reversed the summary judgment on the ADA, Unruh Act, and DPA claims but affirmed the summary judgment on the claims for injunctive and declaratory relief. The court also reversed the sanctions against Robert’s attorney and denied the current owner’s motion for sanctions for a frivolous appeal. View "Saurman v. Peter's Landing Property Owner, LLC" on Justia Law

Harry Malbry, who was convicted in 1991 for committing lewd acts on a child, sought to terminate his obligation to register as a sex offender. His offenses involved daily sexual abuse of a five-year-old girl over three years. After serving a six-year prison term, he was released and required to register annually as a sex offender. In 2022, Malbry petitioned the trial court to end his registration duty, citing his crime-free record since 1991 as evidence that he no longer posed a danger to the community.The Superior Court of Los Angeles County denied Malbry’s petition, emphasizing that community safety would be significantly enhanced by his continued registration. The court highlighted the persistence and severity of his offenses, his lack of insight into his actions, and his exploitation of a trusting child. The court also noted that Malbry had not sought any professional help or therapy to address his behavior.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case and affirmed the lower court’s decision. The appellate court considered several factors, including the nature and facts of the offense, the age of the victim, and Malbry’s lack of participation in a certified sex offender treatment program. The court also noted that legislative changes, such as the enactment of section 288.7, which mandates lifetime registration for similar offenses, underscored the heightened danger posed by Malbry’s conduct. The court concluded that continuing Malbry’s registration as a sex offender significantly enhances community safety, given the severity and persistence of his past offenses and his lack of demonstrated rehabilitation. View "People v. Malbry" on Justia Law

Rashad Matthew Riddick, an involuntarily committed patient at Central State Hospital in Virginia, alleged that he was subjected to extreme conditions of confinement. He claimed he was immobilized in four-point restraints for two weeks and then placed in seclusion for a year and a half. Riddick filed a civil rights lawsuit against the hospital’s director and the interim commissioner of the Virginia Department of Behavioral Health and Developmental Services, arguing that these conditions violated his Fourteenth Amendment rights.The United States District Court for the Eastern District of Virginia dismissed Riddick’s complaint. The court reasoned that Riddick failed to adequately plead the professional standard of care from which his treatment allegedly departed and did not sufficiently allege the interim commissioner’s personal involvement in his conditions of confinement. The court also denied Riddick’s requests for appointed counsel, finding that his claims were not complex enough to warrant such an appointment and that he had demonstrated an ability to represent himself.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s dismissal. The Fourth Circuit held that plaintiffs like Riddick are not required to identify an accepted professional standard at the pleading stage. Instead, a substantial departure from professional judgment can be inferred from specific factual allegations. The court found that Riddick’s allegations of prolonged restraint and seclusion, along with the adverse effects on his mental health, were sufficient to suggest a substantial departure from professional judgment. The court also concluded that Riddick had adequately alleged the interim commissioner’s personal involvement by claiming that the commissioner approved the conditions of his confinement. The Fourth Circuit recommended that the district court appoint counsel for Riddick as the case proceeds. View "Riddick v. Barber" on Justia Law

A retired Navy chaplain, Allen Lancaster, sued several Navy officials in their official capacities, alleging discrimination in the Navy’s promotion practices. Lancaster claimed he was not promoted due to retaliation based on personal hostility and denominational prejudice. He sought declaratory and injunctive relief, including orders to remedy the harm to his career and to hold new promotion boards. Lancaster also challenged the six-year statute of limitations for civil actions against the United States and the constitutionality of a statutory privilege for selection board proceedings.The United States District Court for the Eastern District of Virginia dismissed Lancaster’s amended complaint with prejudice on res judicata grounds, referring to several prior decisions in the longstanding dispute over the Navy’s promotion procedures for chaplains. After Lancaster’s death, his widow, Darlene Lancaster, sought to reopen the case, substitute herself as the plaintiff, and amend the dismissed complaint. The district court denied these requests, leading to the current appeal.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that Lancaster’s death mooted his claims for prospective relief, as he could no longer benefit from the requested declarations and orders. The court also found that any potential claims for retrospective relief were barred by sovereign immunity, as the Lancasters failed to demonstrate an unequivocal waiver of this immunity. Consequently, the district court lacked subject matter jurisdiction to dismiss the case on res judicata grounds or to rule on the widow’s post-dismissal motion. The Fourth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it without prejudice for lack of subject matter jurisdiction. View "Lancaster v. Secretary of the Navy" on Justia Law

Aly Abdellatif, an Egyptian citizen, suspected he was placed on government watchlists after experiencing unwarranted airport security screenings. He sought correction through the Transportation Security Administration's (TSA) redress program, which responded without confirming or denying his watchlist status. Abdellatif and his wife, Nina Araujo, petitioned for review, challenging the administration of the traveler redress program and their treatment during travel.The petitioners initially filed their case in the United States Court of Appeals for the District of Columbia Circuit. They named multiple federal agencies and officials as respondents, alleging that Abdellatif's inclusion on the Selectee List and TSA watchlists led to enhanced security screenings and secondary inspections. They argued that TSA's redress process failed to correct erroneous information, violating statutory obligations and due process rights. The court dismissed the petition against all respondents except TSA, citing jurisdictional limitations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed the petition in part for lack of standing, as TSA cannot remove names from the Selectee List, which is maintained by the Terrorist Screening Center (TSC). The court found that petitioners' injuries related to the Selectee List were not redressable in this lawsuit. However, the court denied the remaining claims on the merits, concluding that TSA's redress process complies with statutory requirements and does not violate due process. The court also rejected the Fourth Amendment claims, finding that the enhanced security screenings and secondary inspections described were reasonable and did not constitute unreasonable searches or seizures. The petition was dismissed in part and otherwise denied. View "Abdellatif v. DHS" on Justia Law

Joshua Francisco, an inmate at Farmington Correctional Center (FCC), suffered from mental illness and was placed on suicide watch multiple times during his incarceration. Despite receiving treatment and being evaluated by mental health professionals, Francisco was found hanging in his cell on October 22, 2014, after his cellmate reported he was suicidal. Francisco had denied being suicidal to correctional officers and mental health staff earlier that day.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the correctional officers and the warden, finding no deliberate indifference to Francisco's medical needs. The court determined that the officers' actions did not rise to the level of criminal recklessness required to establish a violation of the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the correctional officers and the warden were entitled to qualified immunity. The court found that the officers had conducted reasonable investigations and searches based on the information available to them and that Francisco's repeated denials of suicidal intent, along with the absence of a noose, did not indicate a strong likelihood of self-harm. The court also concluded that the warden was not personally involved in any unconstitutional custom or practice and that the claim of an unconstitutional policy requiring inmates to explicitly state they were suicidal was not supported by the evidence. View "Francisco v. Villmer" on Justia Law