Justia Civil Rights Opinion Summaries

Two long-time residents of Nashua, New Hampshire, sought to fly various flags on a designated "Citizen Flag Pole" located at City Hall Plaza. The City had previously allowed private citizens and groups to fly flags representing diverse causes and cultural events on this pole, with minimal oversight and no substantive review of flag content. After one of the plaintiffs flew a "Save Women's Sports" flag, the City received complaints, revoked permission, and removed the flag, stating that it was discriminatory toward the transgender community. Subsequently, the City adopted a written policy in 2022 asserting that the flagpole’s use constituted government speech and reserving the right to deny flags not aligned with City policies.The plaintiffs filed suit in the United States District Court for the District of New Hampshire, alleging violations of the First and Fourteenth Amendments and seeking a preliminary injunction to prevent viewpoint-based denials of flag applications. Before the City filed its opposition, it enacted a new policy to exercise exclusive government control over the flagpoles. The magistrate judge recommended denying the injunction, finding the flag program to be government speech, and the district court adopted that recommendation and denied relief. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court’s denial for abuse of discretion and legal conclusions de novo. Applying the government speech test from Shurtleff v. City of Boston, the court held that Nashua’s Citizen Flag Pole program was not government speech, but rather operated as a forum for private expression. Because Nashua conceded that, absent a government speech determination, its actions constituted impermissible viewpoint discrimination, the First Circuit reversed the district court. The case was remanded with instructions to enter interim declaratory relief in favor of the plaintiffs. View "Scaer v. City of Nashua" on Justia Law

Karl Rabenhorst, a former Navy officer employed by FEMA, alleged that he was subjected to age and sex discrimination, a hostile work environment, and retaliation after being removed from a Puerto Rico disaster relief operation and later suspended without pay. The incidents leading to these adverse actions included reprimands for inappropriate interactions with state officials and insubordination, such as sending unauthorized emails and making disrespectful remarks. During the Puerto Rico deployment, Rabenhorst used derogatory language toward younger female coworkers, which prompted his removal from the operation.After his removal, Rabenhorst filed internal complaints, including a grievance with the DHS Office of Equal Rights, alleging discrimination and retaliation. FEMA investigated and ultimately denied his claims, issuing a final agency decision in 2021. Rabenhorst then brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, asserting violations of Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment for the Secretary of Homeland Security, finding that Rabenhorst failed to establish a prima facie case of discrimination, as he did not meet his employer’s legitimate expectations and could not show that similarly situated employees outside his protected classes were treated more favorably. The court also concluded that Rabenhorst provided no evidence of an objectively hostile work environment or that any adverse conduct was based on his age or sex. Regarding retaliation, the court found no causal link between his protected activity and the suspension decision. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo and affirmed, holding that Rabenhorst did not provide sufficient evidence to support claims of discrimination, hostile work environment, or retaliation. View "Rabenhorst v. Noem" on Justia Law

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law

HRT Enterprises pursued a takings claim against the City of Detroit after losing a jury verdict in state court in 2005. Subsequently, HRT filed suit in federal court in 2008, alleging a post-2005 violation under 42 U.S.C. § 1983. The United States District Court for the Eastern District of Michigan dismissed the federal action, citing the requirement from Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), to exhaust state remedies first. HRT then returned to state court, where its claim was dismissed on claim preclusion grounds, a decision affirmed by the Michigan Court of Appeals. After the state court denied compensation, HRT initiated a federal § 1983 action in 2012. The case was stayed when the City filed for bankruptcy, prompting HRT to participate in bankruptcy proceedings to protect its compensation rights. Ultimately, the bankruptcy court excepted HRT’s takings claim from discharge, allowing the federal case to proceed. After two jury trials, the district court entered judgment for HRT in September 2023.Following its success, HRT moved for attorney fees under 42 U.S.C. § 1988, presenting billing records that included work from related state and bankruptcy proceedings. The district court applied a 33% discount to the claimed hours due to commingled and poorly described entries, set an average hourly rate, and awarded $720,486.25, which included expert witness fees. Both parties appealed aspects of the fee award to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit held that the district court erred by concluding it had no discretion to award fees for work performed in the related state-court and bankruptcy proceedings, as such fees are recoverable when the work is necessary to advance the federal litigation. The court also found the district court erred in awarding expert witness fees under § 1988(c) in a § 1983 action, as the statute does not authorize such fees for § 1983 claims. The appellate court vacated the fee award and remanded for recalculation consistent with its opinion. View "HRT Enterprises v. City of Detroit" on Justia Law

Ryan O’Donnell and Michael Goree each had their vehicles disposed of by the City of Chicago after failing to pay multiple traffic tickets. The City acted under a municipal code provision that allows for immobilization, towing, and eventual disposition of vehicles registered to owners with outstanding violations. O’Donnell’s vehicle was sold to a towing company at scrap value; Goree’s vehicle was relinquished to a lienholder. Neither was compensated or had proceeds offset against their ticket debt.After these events, O’Donnell and Goree filed a putative class action in the United States District Court for the Northern District of Illinois, Eastern Division. Their complaint alleged that the City’s forfeiture scheme was facially unconstitutional under the Fifth Amendment’s Takings Clause and the Illinois constitution, and included a state-law unjust enrichment claim. They also asserted a Monell claim against the towing company, URT United Road Towing, Inc. The district court dismissed all claims for failure to state a claim, finding that the vehicle forfeiture under the traffic code was not a taking.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that the City’s graduated forfeiture scheme is an exercise of its police power to enforce traffic laws rather than a taking for public use. The court reasoned that this type of law enforcement forfeiture does not trigger the Takings Clause of either the federal or Illinois constitutions. The court further found that because there was no constitutional violation, the plaintiffs’ Monell and unjust enrichment claims also failed. The Seventh Circuit affirmed the district court’s dismissal of all claims. View "O'Donnell v City of Chicago" on Justia Law

Three business entities and individuals associated with the operation of a retail store in Cedar Park, Texas, were subject to enforcement under a city ordinance banning “head shops”—stores selling items commonly used to ingest or inhale illegal substances. After receiving notices from the City, two of the appellants were charged in municipal court and fined for violating the ordinance, while the third appellant, a related business entity, was not charged. Following the municipal court’s judgment, the two charged parties appealed for a trial de novo in the county court, which annulled the municipal court’s judgment and began new criminal proceedings. They also pursued state habeas relief, which was still ongoing at the time of this appeal.Separately, the appellants filed a lawsuit in the United States District Court for the Western District of Texas, challenging the ordinance’s validity and constitutionality under federal and state law, and seeking declaratory and injunctive relief. The district court dismissed all claims as barred by the doctrine announced in Heck v. Humphrey, which precludes certain civil claims that would imply the invalidity of existing criminal convictions. The district court also dismissed a distinct claim related to termination of utility services.On appeal, the United States Court of Appeals for the Fifth Circuit held that because the municipal court’s judgments were annulled by the trial de novo and criminal proceedings were still pending under Texas law, there were no outstanding convictions to trigger the Heck bar. Thus, the Fifth Circuit reversed the district court’s dismissal of the claims challenging the ordinance and remanded for further proceedings. The court affirmed the district court’s dismissal of the standalone water termination claim, as the appellants had disclaimed any intent to pursue it. View "Kleinman v. City of Cedar Park" on Justia Law

The plaintiff was incarcerated in Tennessee on sentences from multiple convictions. After being granted parole by the Tennessee Board of Parole, he was not released on his effective parole date because county officials filed a detainer warrant, claiming he had not completed his sentence and was required to serve additional time in county jail. The plaintiff remained in custody for over four months beyond his scheduled release date. He and his family attempted to resolve the situation, and he eventually retained counsel, after which the detainer was lifted and he was released.The plaintiff brought suit in the United States District Court for the Western District of Tennessee against the county, several county officials, state officials, and unnamed defendants under 42 U.S.C. § 1983, alleging violations of his rights under the Fourth and Fourteenth Amendments, as well as state law. The county defendants moved to dismiss for failure to state a claim and asserted qualified immunity. The plaintiff voluntarily dismissed his claims against the state defendants. The district court granted the county defendants’ motion to dismiss, holding that there was no liberty interest in release on parole under Tennessee law, that the individual defendants were entitled to qualified immunity, and that no plausible claim was stated against the county under Monell v. Department of Social Services. The court declined to exercise supplemental jurisdiction over the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that Tennessee’s statutory scheme does not create a protected liberty interest in parole or in release following a grant of parole. Without such a liberty interest, the plaintiff’s due process claim failed, and the individual defendants were entitled to qualified immunity. The Monell claim against the county also failed in the absence of an underlying constitutional violation. The appellate court affirmed the district court’s refusal to exercise supplemental jurisdiction over the state law claims. The judgment of the district court was affirmed. View "Hester v. Chester County" on Justia Law

A prison inmate with a documented history of mobility impairments and medical accommodations, including the use of a wheelchair and a transportation code requiring wheelchair-accessible vehicles, was scheduled for transfer between two facilities. On the day of the transport, he arrived in his wheelchair but was not provided with an accessible van. Instead, prison officials attempted to move him onto a standard bus. The inmate protested, stating he could not board without proper accommodations, but officials treated his protest as a refusal. After a crisis negotiator was called and negotiations failed, prison staff physically moved him onto the bus, allegedly causing him injury.A magistrate judge in the United States District Court for the Western District of Washington found that there were genuine disputes of material fact regarding the officials’ awareness of the inmate’s needs, the transportation code in effect, the extent of force used, and the resulting injuries. The magistrate recommended denying summary judgment and qualified immunity for most defendants. However, the district court rejected these recommendations, granted summary judgment for the State of Washington and the individual prison officials, and found that qualified immunity shielded the officials, reasoning that the mistaken transportation code did not amount to deliberate indifference.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the district court erred in granting summary judgment because material factual disputes remained regarding whether officials had notice of the inmate’s need for accommodation and the extent of their investigation into those needs. The Ninth Circuit also found that these disputes precluded summary judgment on Eighth Amendment claims alleging deliberate indifference and excessive force, and that qualified immunity was improperly granted at this stage. The court reversed the district court’s judgment and remanded for further proceedings. View "WELDEYOHANNES V. STATE OF WASHINGTON" on Justia Law

A computer science teaching professor at a public university included a statement in his course syllabus that parodied the university’s recommended indigenous land acknowledgment. This statement, which challenged the university’s view regarding the ownership of campus land, drew complaints from students and staff, particularly those involved in diversity and indigenous advocacy. The professor refused to remove the statement when asked, prompting university administrators to replace his syllabus, publicly condemn his remarks, and encourage official complaints from students. The university then initiated a lengthy disciplinary investigation, withheld a merit pay increase during this period, issued a reprimand, and warned of potential future discipline if the professor continued similar conduct. The university’s actions were based on the disruption and distress reported by students and concerns about creating an unwelcome environment.The United States District Court for the Western District of Washington found that the professor’s speech was protected and addressed a matter of public concern. However, applying the balancing test from Pickering v. Board of Education, it granted summary judgment to the university, finding that the institution’s interest in preventing disruption and maintaining an inclusive learning environment outweighed the professor’s First Amendment rights. The district court also dismissed the professor’s facial challenges to the university’s nondiscrimination policy, interpreting it narrowly to apply only to conduct resembling unlawful discrimination, harassment, or retaliation.The United States Court of Appeals for the Ninth Circuit reversed the district court’s grant of summary judgment for the university and directed that summary judgment be entered for the professor on his First Amendment retaliation and viewpoint discrimination claims. The appellate court held that the professor’s syllabus statement was protected academic speech on a matter of public concern, and that student or community offense or discomfort could not justify university retaliation or discipline under the First Amendment. The panel also ruled that the district court improperly construed the university’s nondiscrimination policy and remanded for further proceedings on the policy’s facial constitutionality. View "REGES V. CAUCE" on Justia Law

A thirteen-year-old student in Brewer, Maine, developed a relationship with a twenty-year-old man, who was a coach associated with her school. Over two years, the man sexually assaulted the student multiple times. During that period, rumors circulated at the local high school about their inappropriate relationship. The student reported these rumors to the principal, denied any truth to them, and the principal took limited follow-up action. Other school staff and a police officer had some interactions with the student and the perpetrator, but no one reported or investigated the abuse at the time. The student, now an adult, later sued various school officials, the school department, a police officer, and others, alleging they failed to protect her from abuse despite being aware of warning signs, and sought relief under federal and Maine law.At the United States District Court for the District of Maine, most claims were dismissed at the pleading stage for failing to state a claim. The remaining claims, including those brought under Title IX and 42 U.S.C. § 1983, were resolved in favor of defendants at summary judgment. The court also dismissed the claims against the unidentified police officer for lack of personal jurisdiction, denied the plaintiff’s request for more time to serve that officer, and later denied leave to amend the complaint to add the officer once identified.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s decisions in all respects. The First Circuit held that the plaintiff’s allegations did not plausibly establish municipal liability under § 1983, nor did they show actual knowledge by school officials sufficient to support a Title IX claim. The appellate court also found no abuse of discretion in the district court’s procedural rulings regarding service of process and amendment of the complaint. View "Hewes v. Gardiner" on Justia Law