Justia Civil Rights Opinion Summaries

The case involves Sharon Lewis, an African-American woman who worked as an assistant athletic director for Louisiana State University’s (LSU) football team. Lewis alleges that she experienced and witnessed numerous instances of racist and sexist misconduct from former head football coach Les Miles and that she received complaints of sexual harassment from student workers that she oversaw. In 2013, LSU retained Vicki Crochet and Robert Barton, partners of the law firm Taylor, Porter, Brooks & Phillips LLP, to conduct a Title IX investigation of sexual harassment allegations made against Miles. The report and its contents were kept confidential, and allegations brought by the student complainants were privately settled.The district court dismissed Lewis's Racketeer Influenced and Corrupt Organization Act (RICO) claims against Crochet and Barton because Lewis’s claims were time-barred and she failed to establish proximate causation. On appeal of the dismissal order, a panel of this court affirmed the district court on the grounds that Lewis knew of her injuries from alleged racketeering as early as 2013, and thus the four-year statute of limitations had expired before she filed suit in 2021.The district court ordered Lewis to file a motion to compel addressing the lingering “issues of discoverability and the application of [its Crime-Fraud Exception Order].” The district court denied Crochet and Barton’s motion for a protective order and compelled the depositions of Crochet and Barton and the disclosure of documents drafted during the 2013 investigation. Crochet and Barton timely appealed.The United States Court of Appeals for the Fifth Circuit reversed the district court’s Crime-Fraud Exception Order and remanded for proceedings consistent with this opinion. The court concluded that the district court clearly erred in holding that Lewis established a prima facie case that the Board violated La. R.S. 14:132(B) and that the alleged privileged communications were made in furtherance of the crime and reasonably related to the alleged violation. View "Lewis v. Crochet" on Justia Law

The case involves Jeremy and Kristy Morris, who sued the West Hayden Estates First Addition Homeowners Association (HOA) under the Fair Housing Act. The Morrises alleged that the HOA discriminated against them based on religion by attempting to prevent them from conducting a Christmas program. The jury ruled in favor of the Morrises, awarding them compensatory and punitive damages. However, the district court granted judgment as a matter of law to the HOA, alternatively granted a new trial, and issued a permanent injunction against future productions of the Christmas program that violate the HOA’s covenants, conditions, restrictions, and easements.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s judgment. The appellate court held that the district court properly granted judgment as a matter of law to the HOA as to the Morrises’ disparate treatment claim under 42 U.S.C. § 3604(b) because they did not show that they were adversely affected by the HOA’s actions. However, the court reversed the district court's judgment as a matter of law on the Morrises’ claim that the HOA interfered with their right to purchase and enjoy their home free from discrimination, in violation of 42 U.S.C. § 3617. The court affirmed the district court’s grant of a new trial to the HOA as to the § 3617 claim and vacated the district court’s grant of an injunction to the HOA. The case was remanded for further proceedings. View "MORRIS V. WEST HAYDEN ESTATES FIRST ADDITION HOMEOWNERS ASSOCIATION, INC." on Justia Law

The case revolves around Erin Bulfin, who sued St. Louis County and several employees of St. Louis County Animal Care & Control (ACC) after her pet dog, Daisy, was euthanized at ACC. Bulfin's dog had bitten her daughter, requiring hospitalization. Following the incident, Bulfin's husband, Edward Nea, took Daisy to ACC. The details of the conversation between Nea and ACC employees are disputed, but it is undisputed that Nea signed a form authorizing the euthanasia of Daisy. The next day, Bulfin went to ACC to pick up Daisy for home quarantine and was informed that Daisy had been euthanized.The district court granted summary judgment to the individual defendants, concluding that Bulfin's Fourth Amendment rights were not violated because the defendants reasonably relied on the apparent consent of Bulfin's husband to euthanize Daisy. The court also granted summary judgment in favor of the County on Bulfin's federal municipal liability claims and declined to exercise supplemental jurisdiction over Bulfin's state law claims.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that when ACC accepted custody of Daisy, that was not a seizure because it is undisputed Bulfin approved of Daisy being quarantined in ACC custody after biting her daughter. The court also held that the individual defendants were entitled to qualified immunity unless the evidence established a violation of her Fourth Amendment rights that was clearly established at the time of the violation. The court concluded that no Fourth Amendment violation occurred and that the individual defendants are entitled to qualified immunity because there is no clearly established authority holding that government officials violate the Fourth Amendment by seizing and destroying an effect with the consent of a person who reasonably has actual or apparent authority. View "Bulfin v. Rainwater" on Justia Law

Michael Jones, a pretrial detainee, filed a lawsuit against the City of St. Louis and four city employees, alleging that they held him in custody for eight months after his criminal charges were dismissed and failed to inform him of his right to be released. Jones's lawsuit, filed under 42 U.S.C. § 1983, included claims under both state and federal law. The defendants moved to dismiss all fourteen counts of the lawsuit. The district court dismissed seven counts, leaving no federal due process claims against the individual defendants at issue on appeal. The defendants appealed the denial of their motion to dismiss the remaining counts, arguing that Jones failed to allege plausible constitutional violations and that they were entitled to qualified immunity from damage claims.The United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo, accepting the factual allegations in Jones's First Amended Complaint as true. The court found that Jones failed to allege specific facts of personal involvement in, or direct responsibility for, a deprivation of his constitutional rights by the individual defendants. The court also found that Jones's allegations that the defendants "should have known" that he was incarcerated despite his charges being dismissed failed to state a claim under either the Fourth Amendment or the Due Process Clause.The court reversed the denial of qualified immunity and directed that the remaining counts be dismissed with prejudice. The case was remanded for further proceedings consistent with the court's opinion. The court did not rule on the state law claims of false imprisonment, leaving that for the district court to resolve on remand. View "Jones v. City of St. Louis" on Justia Law

The case involves Earl Johnson, a former inmate of the Maryland Correctional Training Center, who alleged that corrections officer Chad Zimmerman sexually harassed and abused him during strip searches, in violation of his Fourth and Eighth Amendment rights. Johnson also sued Zimmerman’s supervisor, Lt. Richard Robinette, alleging supervisory and bystander liability. The district court dismissed Johnson’s claims against Robinette due to failure to exhaust administrative remedies but held that Johnson’s claims against Zimmerman were exempt from this requirement. The court also granted summary judgment to Zimmerman and Robinette on the merits of Johnson’s claims.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding that Johnson’s claims against Robinette were subject to exhaustion requirements. However, the court affirmed the district court’s decision to grant summary judgment to both defendants. The court found that the strip searches, including those involving momentary touchings of Johnson’s genitalia or buttocks, did not rise to the level of an unreasonable search under the Fourth Amendment. The court also found that Johnson failed to present sufficient evidence to prove that Zimmerman had the requisite malicious intent to sexually abuse him, sexually arouse him or himself, or otherwise gratify sexual desire. Furthermore, the court found that Johnson’s evidence fell short of establishing supervisory or bystander liability against Robinette. View "Johnson v. Robinette" on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

The case revolves around an incident involving Michael Miller, a white Correctional Security Operations Supervisor at Chittenden Regional Correctional Facility (CRCF), and a black coworker. Miller asked the coworker if the food he was heating in the microwave was fried chicken, a comment the coworker perceived as racially discriminatory. Following an investigation, the State of Vermont terminated Miller's employment, citing violations of several personnel policies and work rules, including allegations of racial discrimination and harassment.The Vermont Labor Relations Board, however, reversed the State's decision. It found that while Miller's comments were inappropriate and unprofessional, they did not constitute racial discrimination or harassment as defined by the applicable personnel policies. The Board also found that the State failed to prove that Miller was untruthful during the investigation. Consequently, the Board reduced Miller's penalty to a twenty-day suspension.The State appealed the Board's decision to the Vermont Supreme Court, arguing that the Board misinterpreted the meaning of racial discrimination and harassment in the personnel policies. The Supreme Court affirmed the Board's decision, stating that the Board's interpretation of the policies was within its discretion and was supported by analogous definitions under Title VII of the Civil Rights Act of 1964. The Court also noted that the State could amend the language of the policies to more clearly define what constitutes racial discrimination or harassment. View "In re Grievance of Miller" on Justia Law

The case revolves around Christopher Smith, who was convicted of first-degree murder for the death of Nakisa Benson. Smith was initially deemed incompetent to stand trial but was later found competent. During the jury selection process, Smith's counsel exercised ten peremptory strikes on potential jurors, nine of whom were white. The State raised a reverse-Batson challenge, arguing that the strikes were racially motivated. The circuit judge conducted a Batson hearing and disallowed several of Smith's strikes, finding that the reasons provided were not race-neutral.Smith appealed his conviction to the Court of Appeals, arguing that the trial court erred by admitting certain autopsy photographs and by overruling five of his peremptory strikes. The Court of Appeals found no error and affirmed the conviction. Smith then filed a petition for writ of certiorari, contending that the Court of Appeals erred in its Batson analysis with respect to two jurors. He requested that the case be remanded for a proper Batson hearing.The Supreme Court of Mississippi reviewed the case and the Batson challenge. The Court gave great deference to the trial court's findings, stating that it would not overrule a trial court on a Batson ruling unless the record indicated that the ruling was clearly erroneous or against the overwhelming weight of the evidence. The Court found that Smith's counsel had shown a clear pattern of striking jurors because of their race, which was evident from his choice of words during the trial court’s Batson hearing. The Court affirmed the judgments of the Court of Appeals and of the Copiah County Circuit Court, denying Smith's request for a Batson hearing on the two jurors. View "Smith v. State" on Justia Law

Leroy Johnson, a supervisor at Westinghouse Air Brake Technologies Corporation (Wabtec), was terminated after failing to fully disclose his contact with a COVID-19 positive individual, violating the company's COVID-19 protocols and a Last Chance Agreement he had signed. Johnson, the only salaried black employee at the plant, sued Wabtec for wrongful termination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act of 1965, and the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment in favor of Wabtec.The district court's decision was based on the conclusion that Johnson had not established a prima facie case of discrimination. Johnson had argued that he was treated less favorably than similarly situated white employees, but the court found that the employees he cited were not similarly situated as they were not terminated for misconduct. The court also found that Johnson's failure to fully disclose his potential COVID-19 exposure constituted a safety concern and misconduct, which was grounds for termination under the Last Chance Agreement.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Johnson had not established a prima facie case of discrimination and that his termination was due to his misconduct, not his race or age. The court also noted that Johnson had waived his ADEA claim by failing to address its merits in his opening brief. View "Johnson v. Westinghouse Air Brake Technologies Corporation" on Justia Law