Justia Civil Rights Opinion Summaries

In 1996, the defendant broke into a home, raped a woman at knifepoint, and carried a child at knifepoint while stealing a firearm and ammunition. He was charged with multiple offenses, including kidnapping to commit robbery and, later, a one-strike rape allegation. After a mistrial due to a deadlocked jury and the emergence of DNA evidence linking him to the crime, the defendant pled guilty in 1998 to several charges under a plea agreement. The plea resulted in the dismissal of the rape charge and the one-strike allegation, and the kidnapping charge was amended. He was sentenced to a determinate prison term, which was later reduced.In 2024, the defendant, who is ethnically Samoan, filed a motion in the Superior Court of Riverside County seeking discovery under the Racial Justice Act (RJA). He argued that the addition of the one-strike allegation before trial was racially motivated, citing a different case involving a white defendant who was not similarly charged. He requested records of comparable cases, including defendants’ races and charges. The People opposed, arguing that the plea negotiations were driven by DNA evidence, not the added charge, and that the comparison case was not analogous. The trial court granted the discovery motion but limited the scope of the records to be produced.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a petition for writ of mandate. The appellate court held that the defendant failed to establish good cause for discovery under the RJA because his factual scenario was not plausible in light of the record, the comparison case did not support an inference of racial disparity, and statewide incarceration statistics did not provide specific facts of misconduct in his case. The court granted the writ, directing the trial court to vacate its order granting discovery and to deny the motion. View "People v. Superior Ct. (Lalo)" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

A woman alleged that a sheriff’s deputy in Okanogan County, Washington, coerced her into sexual encounters over several years, exploiting her drug addiction and involvement in criminal activity. She claimed that the deputy’s misconduct began in 2014 and continued through 2021, with the deputy using his position to pressure her into unwanted sexual acts in exchange for not pursuing criminal charges against her. The woman also alleged that the sheriff’s office was aware of the deputy’s behavior but failed to take effective action, and that similar misconduct occurred with other deputies and vulnerable women.After the woman filed suit in the United States District Court for the Eastern District of Washington, the defendants moved to dismiss, arguing that her claims were barred by Washington’s three-year statute of limitations. The district court agreed, holding that her claims were untimely and that her allegations did not sufficiently support municipal liability under Monell v. New York City Department of Social Services. The court dismissed her claims with prejudice and denied her request to amend her complaint.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that each alleged act of sexual misconduct constituted a discrete, independently wrongful act for statute of limitations purposes, so claims based on acts within three years of the complaint were timely. For earlier acts, the court found that the plaintiff plausibly alleged a delayed accrual theory, given the power imbalance and her delayed realization of harm. The court also held that the district court abused its discretion by denying leave to amend the Monell claim, as the plaintiff alleged facts supporting a pattern of deliberate indifference. The Ninth Circuit reversed the dismissal of both federal and state law claims and remanded for further proceedings. View "ST. CLAIR V. COUNTY OF OKANOGAN" on Justia Law

A hospital employee in Oregon, who identified as a practicing Christian, requested a religious exemption from her employer’s COVID-19 vaccine mandate, citing her belief that her body is a temple of the Holy Spirit and that she must avoid substances that could harm her body. The employer granted her exemption from vaccination but required her to wear personal protective equipment and undergo weekly antigen testing using a nasal swab treated with ethylene oxide. The employee objected to the testing, claiming her research showed the swab was carcinogenic and that using it would violate her religious duty to protect her body. She requested alternative accommodations, such as saliva testing or full-time remote work, but the employer denied these requests and ultimately terminated her employment when she refused to comply.The United States District Court for the District of Oregon dismissed her complaint for failure to state a claim, finding that her objection to the testing was based on secular, medical concerns rather than a bona fide religious belief. The court concluded that while her general belief in protecting her body as a temple was religious, her specific objection to the nasal swab was rooted in her personal interpretation of medical research.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that to state a claim for religious discrimination under Title VII and Oregon law, a plaintiff must plausibly allege that the specific accommodation request is rooted in a bona fide religious belief, not merely a secular or personal preference. The court found that the employee’s complaint did not sufficiently connect her religious beliefs to her objection to antigen testing, as her concerns were based on her own medical judgment rather than religious doctrine. The court declined to adopt a more lenient pleading standard and affirmed the dismissal with prejudice. View "DETWILER V. MID-COLUMBIA MEDICAL CENTER" on Justia Law

A North Carolina police officer, Clarence Belton, was shot multiple times by fellow officer Heather Loveridge during the execution of a search warrant. The incident, which resulted in serious injuries to Belton and ended his law enforcement career, was captured on video and body camera footage. Belton sued Loveridge and the City of Charlotte, alleging excessive force and other claims. During the litigation, both parties moved to seal the video exhibits related to the shooting, and the district court granted these motions, placing the footage under seal.After the district court denied Loveridge’s motion for summary judgment, which was later vacated and remanded by the United States Court of Appeals for the Fourth Circuit, a local television station, WBTV, sought to intervene in the case to unseal the video footage. Belton supported WBTV’s motion, but Loveridge opposed it, arguing that unsealing would jeopardize her right to a fair trial. The United States District Court for the Western District of North Carolina denied WBTV’s motion to intervene, citing lack of jurisdiction due to the pending appeal, and also denied the motion to unseal, finding no right of access under the common law or the First Amendment and concluding that Loveridge’s fair trial rights outweighed any public interest.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of WBTV’s motion to intervene, agreeing that the district court lacked jurisdiction at that stage. However, the appellate court treated WBTV’s appeal regarding the sealing order as a petition for a writ of mandamus. The Fourth Circuit held that the district court’s order sealing the video exhibits violated the First Amendment right of access to judicial records. The court vacated the sealing order and remanded with instructions to unseal the video footage, finding that Loveridge had not met her burden to justify continued sealing. View "Gray Media Group, Inc. v. Loveridge" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law

A sheriff’s deputy responded to a 911 call reporting a domestic dispute at a residence, with allegations that the homeowner had threatened a woman with a gun and grabbed her by the neck. Upon arrival, the deputy encountered three women and a small child outside or in the garage; none appeared injured or in distress. The homeowner stood in the garage doorway, raised his hands when ordered, and denied wrongdoing. When the deputy attempted to handcuff him, the homeowner retreated into his house, resisted being handcuffed, and a physical altercation ensued, during which the deputy punched the homeowner. The deputy ceased his efforts after being told that no gun threat had occurred.The homeowner filed suit under 42 U.S.C. § 1983 in the United States District Court for the Middle District of Tennessee, alleging unlawful entry and excessive force in violation of the Fourth Amendment. Both parties moved for summary judgment. The district court denied summary judgment to the deputy on the unlawful entry and excessive force claims, finding that material factual disputes existed as to whether exigent circumstances justified the warrantless entry and whether the force used was reasonable. The deputy appealed, asserting entitlement to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, viewing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the deputy lacked an objectively reasonable basis for believing exigent circumstances existed to justify a warrantless entry. The court further held that the right to be free from such entry and from force used to effectuate it was clearly established. Because the deputy failed to argue that his use of force was reasonable even if the entry was unlawful, the court affirmed the district court’s denial of summary judgment on both claims. View "Hoover v. Due" on Justia Law

Raymond Thompson purchased a custom Harley Davidson motorcycle and paid off all liens, but after the sale, the seller, Nathan Rench, fraudulently obtained a duplicate title, preventing Thompson from registering the motorcycle. Later, two individuals claiming to act for Rench arrived at Thompson’s home with Manchester, Missouri police officers, seeking to recover the motorcycle. The officers, after verifying the duplicate title and registration in Rench’s name, allowed the individuals to take the motorcycle from Thompson’s fenced backyard. Thompson was not home at the time. The next day, after Thompson reported the motorcycle stolen and provided evidence of his ownership, the officers instructed Rench to return the motorcycle, but Rench refused. The motorcycle was eventually recovered after Rench’s arrest.Thompson filed a lawsuit in the United States District Court for the Eastern District of Missouri, alleging that the officers violated his Fourth Amendment rights by entering his property and allowing the removal of his motorcycle, and his Fourteenth Amendment due process rights. He also sought sanctions for the police department’s failure to preserve body and dash camera footage. The district court granted summary judgment to the officers on the basis of qualified immunity, denied Thompson’s motion for sanctions, and denied his motion for partial summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the officers did not violate a clearly established constitutional right by entering Thompson’s backyard or by allowing the motorcycle’s removal, as their actions were consistent with existing Eighth Circuit precedent regarding limited warrantless entries and peacekeeping roles. The court also found no evidence of joint action or coercion by the officers sufficient to establish state action for a due process claim. Finally, the court concluded that the district court did not abuse its discretion in denying sanctions, as Thompson failed to show prejudice from the loss of the recordings. View "Thompson v. Cockrell" on Justia Law

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law