Justia Civil Rights Opinion Summaries

A physician assistant employed by a Michigan hospital, later affiliated with the University of Michigan Health System, was terminated after she refused, on religious and medical grounds, to use gender identity-based pronouns or refer patients for gender reassignment procedures. The hospital had required her to complete training on serving LGBTQ+ patients, which she believed conflicted with her Christian faith and medical judgment. After seeking a religious accommodation and participating in meetings with hospital administrators, she was fired for her refusal to comply with the hospital’s requirements.She filed suit in the United States District Court for the Western District of Michigan against the hospital and several administrators, alleging violations of federal constitutional rights under 42 U.S.C. § 1983, Title VII, and Michigan law. The hospital and its administrators moved to dismiss all claims on the merits, and the district court granted the motion in part and denied it in part, allowing several of her claims to proceed. Only after this partial denial, and more than a year into the litigation, did the hospital invoke an arbitration clause from her employment agreement and move to compel arbitration. The district court granted this motion, found the arbitration clause enforceable, and dismissed the case in favor of arbitration.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the hospital had forfeited its right to arbitrate by substantially litigating the case before seeking arbitration. The Sixth Circuit held that the hospital’s conduct—seeking a complete judicial victory on the merits before invoking arbitration—was inconsistent with the right to arbitrate and constituted “default” under the Federal Arbitration Act. The court reversed the district court’s order compelling arbitration and remanded the case for further proceedings. View "Kloosterman v. Metropolitan Hospital" on Justia Law

In this case, the defendant was shot five times in his apartment parking lot and, in the chaos, dropped his black iPhone and a satchel. His girlfriend took the satchel but left the phone, which was later recovered by police near some shrubs. The police also seized a different (white) iPhone from the defendant at the hospital. The black iPhone remained in police evidence for over two years, until it became relevant in a separate federal drug investigation. The government ultimately used data from the black iPhone, along with other evidence, to charge the defendant with drug trafficking, firearm offenses, and money laundering.The United States District Court for the District of Oregon presided over the trial. Before trial, the defendant moved to suppress evidence from the black iPhone, arguing that he retained a privacy interest in the device and its data, and also sought recusal of the district judge due to her prior service as U.S. Attorney when he was prosecuted for unrelated charges over fifteen years earlier. The district court denied both motions, finding that the defendant had abandoned the black iPhone and thus lacked standing to challenge its search, and that recusal was not warranted.The United States Court of Appeals for the Ninth Circuit reviewed the case. The Ninth Circuit disagreed with the district court’s finding that the defendant had abandoned his privacy interest in the black iPhone, holding that the circumstances—dropping the phone while fleeing after being shot—did not show intent to abandon the device or its data. However, the Ninth Circuit affirmed the denial of the suppression motion because federal agents obtained a warrant and searched the phone within a reasonable period. The court also affirmed the denial of the recusal motion, concluding that a reasonable person would not question the judge’s impartiality under these facts. The conviction and sentence were affirmed. View "USA V. HUNT" on Justia Law

A New York State Police trooper stopped Daniel Delgado for erratic driving and discovered that his license was suspended. During an inventory search of his vehicle, the trooper found a loaded “ghost gun” and ammunition, which Delgado admitted belonged to him. Delgado had several prior convictions, including a felony conviction for attempted second-degree murder in Florida, where he had shot a man in the back. Delgado was indicted for possessing ammunition after a felony conviction, in violation of 18 U.S.C. § 922(g)(1), and pleaded guilty without a plea agreement.The United States District Court for the Southern District of New York denied Delgado’s motion to withdraw his guilty plea and to dismiss the indictment, finding that § 922(g)(1) did not violate the Second Amendment. At sentencing, the court determined that Delgado’s prior Florida conviction for attempted second-degree murder was a “crime of violence” under U.S.S.G. § 2K2.1(a), resulting in a higher base offense level. Delgado was sentenced to thirty months’ imprisonment and three years of supervised release. He timely appealed, challenging both the constitutionality of § 922(g)(1) and the classification of his prior conviction.The United States Court of Appeals for the Second Circuit reviewed the case. It held that Delgado’s constitutional challenge to § 922(g)(1) was foreclosed by its recent decision in Zherka v. Bondi, which reaffirmed the statute’s constitutionality after New York State Rifle & Pistol Ass’n v. Bruen. The court also held that Florida’s offense of attempted second-degree murder is categorically a crime of violence under the Sentencing Guidelines, as it requires an intentional act imminently dangerous to another and demonstrating a depraved mind. The Second Circuit affirmed the judgment of the district court. View "United States v. Delgado" on Justia Law

Chicago police officers responded to an anonymous tip alleging animal abuse at a property where Vaughn Neita kept his dog, Macy. Upon arrival, the officers found Macy tethered outside in cold weather, inside a plywood doghouse with a heater and bowls. The officers observed Macy for about twenty minutes, noting she appeared healthy and playful, but claimed her bowls were empty or contained frozen water. Neita arrived during the investigation, identified himself as Macy’s owner, and explained he had left Macy outside briefly. The officers arrested Neita for animal abuse and impounded Macy. Neita was charged in the Circuit Court of Cook County with violating two provisions of the Illinois Humane Care for Animals Act, but after a bench trial, the court found no evidence of neglect or abuse and entered a directed finding in Neita’s favor.Neita then filed a civil suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the City of Chicago and the officers, alleging false arrest, illegal search and seizure, malicious prosecution, and related claims under federal and state law. The district court dismissed some claims, including federal malicious prosecution, and later granted summary judgment to the defendants on the remaining federal claims, finding the officers had at least arguable probable cause and were entitled to qualified immunity. The court also declined to sanction the defendants for discovery delays and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s discovery rulings and dismissal of the federal malicious prosecution claim. However, it reversed the grant of summary judgment on qualified immunity, holding that genuine issues of material fact remained as to whether the officers had even arguable probable cause to arrest Neita and seize Macy. The case was remanded for further proceedings on Neita’s revived federal and state claims. View "Neita v. City of Chicago" on Justia Law

A man was accused of picking up a woman in El Paso, Texas, under the pretense of giving her a ride, then driving her across state lines to his home in Anthony, New Mexico, where he violently sexually assaulted her. The woman testified that she was handcuffed, physically assaulted, and raped multiple times before escaping at a stoplight in El Paso and seeking help. The defendant’s adopted daughter also testified that he had sexually assaulted her repeatedly when she was a minor and again as an adult.A federal grand jury in the United States District Court for the District of New Mexico indicted the defendant for kidnapping and transporting an individual across state lines with intent to engage in illegal sexual activity. At trial, the defendant argued that the encounter with the woman was consensual and related to commercial sex, and he sought to introduce evidence of her prior prostitution to support his consent defense. The district court excluded this evidence under Federal Rule of Evidence 412, finding it irrelevant to consent. The court also allowed the adopted daughter’s testimony under Rule 413, concluding that her allegations of prior sexual assault by the defendant were admissible and not unduly prejudicial under Rule 403. The jury convicted the defendant on both counts.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s evidentiary rulings. The court held that excluding evidence of the victim’s prior prostitution did not violate the defendant’s constitutional rights, as such evidence is not probative of consent under established precedent. The court also affirmed the admission of the adopted daughter’s testimony, holding that Rule 413 applies based on the conduct underlying the charges, not the statutory elements, and that the district court did not abuse its discretion under Rule 403. The court further found that the defendant had waived arguments regarding limitations on cross-examination of the adopted daughter. The convictions were affirmed. View "United States v. Clay" on Justia Law

A long-serving principal at a public middle school implemented an “inclusion project” that included a display of various flags, among them a Pride flag, using school funds. She informed staff that this project was part of her professional goals and later helped establish a Gay-Straight Alliance (GSA) student group. The inclusion of the Pride flag and her advocacy for LGBTQ+ students generated controversy among staff and community members, leading to complaints about her leadership style and claims that she was creating a divisive work environment. After an outside investigation substantiated concerns about her management, she was removed as principal and reassigned to a different administrative role.The United States District Court for the District of Minnesota granted summary judgment in favor of the school district and its officials on her federal claims, finding that her speech and actions were made pursuant to her official duties as principal and thus not protected by the First Amendment. The court also found insufficient evidence that any private speech or advocacy outside her official role was a motivating factor in the adverse employment actions. The district court dismissed her federal claims with prejudice and declined to exercise supplemental jurisdiction over her state law claims, dismissing them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the principal’s actions regarding the flag display and GSA were undertaken as part of her official duties and therefore constituted government speech, not protected by the First Amendment. The court also found no evidence that any private speech was a substantial or motivating factor in the employment decisions. The court further held that the district court did not abuse its discretion in declining supplemental jurisdiction over the state law claims. View "Thomas v. Marshall Public Schools" on Justia Law

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal.After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

The plaintiff, an Illinois prisoner, was involved in a physical altercation with several correctional officers at Stateville Correctional Center. Following the incident, he was transferred to Pontiac Correctional Center, where he received medical treatment. He was issued a disciplinary ticket for a major infraction, which led to an adjustment committee hearing at Pontiac. At the hearing, he was allowed to present his side but was not permitted to call witnesses or view video evidence. The committee recommended several disciplinary measures, including three months of solitary confinement in conditions the plaintiff later described as appalling, with unsanitary and unsafe features.The plaintiff filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the disciplinary committee members and the warden violated his Fourteenth Amendment rights by imposing solitary confinement without sufficient procedural protections. The defendants moved for summary judgment, arguing that the plaintiff had not established a protected liberty interest, had not shown inadequate procedures, and that they were entitled to qualified immunity. The district court granted summary judgment for the defendants, finding that three months in segregation, even with harsh conditions, did not amount to a deprivation of a liberty interest protected by due process.On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s conclusion regarding the liberty interest, holding that the plaintiff’s evidence of three months in unusually harsh and unsanitary solitary confinement raised a genuine issue of material fact about deprivation of a protected liberty interest. However, the Seventh Circuit affirmed the judgment for the defendants, holding that they were entitled to qualified immunity because the law was not clearly established at the time of the plaintiff’s confinement. The court clarified that, going forward, short terms of solitary confinement combined with comparably harsh conditions will suffice to show a protected liberty interest requiring procedural protections. View "Jackson v. Anastacio" on Justia Law

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.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 the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

A woman who had been living with a couple in Tennessee returned to their home to collect her belongings after being told she could no longer stay there. A dispute arose over the ownership of a car parked at the residence. The woman alleged that one of the residents, Matthew Howell, pointed a gun at her and refused to let her retrieve the car. She called 911, reporting the incident and stating that Howell was intoxicated and had threatened her. When police arrived, they spoke with the woman, who reiterated her allegations. Officers knocked on the door, and upon Howell opening it, they detected the smell of marijuana. The officers entered the home, arrested Howell for aggravated assault and resisting a frisk, and temporarily handcuffed his girlfriend, Alisha Brown, while conducting a protective sweep. The officers also allowed the woman to access the disputed car.Howell was indicted by a Tennessee grand jury for aggravated assault and resisting arrest. At trial, the jury convicted him of reckless aggravated assault, but the conviction was later amended to simple assault and ultimately reversed on double jeopardy grounds by an appellate court. Meanwhile, Howell and Brown filed a civil suit in the United States District Court for the Middle District of Tennessee, alleging Fourth Amendment violations and state tort claims against the officers and the Metropolitan Government of Nashville and Davidson County. The district court granted summary judgment to the defendants on the federal claims and declined to exercise jurisdiction over the state claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the officers were entitled to qualified immunity on all federal claims. It found that the officers’ warrantless entry was not clearly established as unconstitutional under existing precedent, that probable cause supported Howell’s arrest, and that Brown’s temporary detention did not violate clearly established law. The court also found no clearly established law prohibiting the officers’ actions regarding the disputed car and rejected the malicious prosecution claim. The court affirmed summary judgment for the officers and municipality. View "Howell v. McCormick" on Justia Law