Justia Civil Rights Opinion Summaries

Over 20 years ago, taxpayers sued Kentucky and Sunrise, a religiously affiliated organization, for alleged violations of the Establishment Clause by paying for religious services that Sunrise allegedly imposed on children in state custody. The Sixth Circuit remanded the approval of a 2013 settlement. In 2015, the parties replaced monitoring provisions that mentioned Sunrise with general language about “any Agency.” The Third Circuit held, for the third time, that the plaintiffs had standing to bring their Establishment Clause claim but that the 2015 Amendment required new regulations or modifications to existing regulations for implementation, which meant the Amendment violated Kentucky law. In 2021 Kentucky and the plaintiffs jointly moved to dismiss the case with prejudice. Kentucky agreed to pursue new regulations in good faith; certain provisions of the Agreement would not take effect unless those regulations were adopted. The Settling Parties did “not” seek to have the court retain jurisdiction for enforcement, nor to incorporate the Agreement in the order of dismissal.Noting that the motion was filed by “the parties to the sole remaining claim,” the Establishment Clause claim against Kentucky, the district court dismissed the case. The court refused to address the terms of the 2021 Agreement, which was not properly before it. The Sixth Circuit affirmed. “Sunrise no doubt is frustrated to find itself unable to vindicate the legality of its program” but federal courts do not decide constitutional issues in the abstract. View "Pedreira v. Sunrise Children's Services, Inc." on Justia Law

Plaintiff alleged that Defendant falsely arrested him, used excessive force in doing that, and then was deliberately indifferent to Plaintiff’s alleged medical needs. The district court granted Officer Miller’s motion for summary judgment and dismissed Plaintiff’s case for failure to state a claim.   The Eleventh Circuit affirmed the district court’s entry of summary judgment in part and reversed in part. The court explained that the dash-cam recording from Plaintiff’s interaction with Defendant proves definitively that Defendant did not falsely arrest Plaintiff. And though the dash-cam recording does not resolve Plaintiff’s deliberate indifference claim, Plaintiff hasn’t shown that any violation Defendant may have committed was clearly established. So Defendant is entitled to qualified immunity on that claim as well. As for Plaintiff’s excessive-force claim, the recording did not capture Defendant’s physical arrest of Plaintiff. Accordingly, the court wrote that it must rely on the default summary-judgment rule and assume the truth of Plaintiff’s attestations that Defendant used excessive force in arresting him. Thus the court concluded that the excessive-force claim survives summary judgment. View "Eric K. Brooks v. D Miller" on Justia Law

After being passed over for a superintendent role, Plaintiff sued her employer, Pulaski County Special School District (“PCSSD”), and its board members for discrimination and retaliation in violation of Title VII and 42 U.S.C. Section 1981. A jury found in her favor on her Title VII and Section 1981 retaliation claims and awarded damages, including punitive damages. Defendants appealed the district court’s denial of their motion for judgment as a matter of law and the punitive damages award. Plaintiff cross-appeals the district court’s denial of her request for front pay, additional back pay, and equitable relief.   The Eighth Circuit vacated the judgment. The court explained that, as a whole, the evidence demonstrates that she believed she reported the disparity in the facilities as part of her duty to oversee compliance with Plan 2000, which sought to rectify discrimination against students in public education. The court explained that it does not rule out that the disparity in the facilities could affect employees too, there is simply no evidence here that Plaintiff believed she was complaining about a discriminatory employment practice. Thus, a jury could not conclude that Plaintiff had a good faith belief that she was reporting a discriminatory employment practice. View "Janice Warren v. Mike Kemp" on Justia Law

Cichocki called the police to report that her 15-year-old daughter, G.C., had been sexually assaulted by Garcia days earlier at a resort where the families were vacationing. Cichocki told Detective Posewitz that G.C. had reported that, while G.C. and the other children were in the pool, Garcia purposely touched her breasts and “down there.” Both families stayed at the resort until the next afternoon. Cichocki suggested that G.C. could not remember all the details of the incident and had expressed fear that the video would contradict her report. Posewitz interviewed G.C., who described the incidents. Surveillance footage of the pool area was poor quality and inconclusive. Although the area was crowded, there were apparently no witnesses. ADA Spoentgen drafted a criminal complaint, which ADA Hoffman reviewed. It did not refer to the surveillance footage or Cichoki's statements. The Court Commissioner found probable cause for Garcia’s arrest. The court found probable cause to proceed to trial. After Hoffman’s opening statement, the judge declared a mistrial because Hoffman mentioned that G.C. had a learning disability, which had not been disclosed to the defense.Garcia sued Posewitz, Hoffman, and Spoentgen under 42 U.S.C. 1983. The Seventh Circuit affirmed summary judgment for the defendants, citing qualified immunity. No reasonable jury could find that it would have been clear to a reasonable officer that the information omitted from the complaint would have negated probable cause. G.C.’s and Cichocki’s accounts were largely consistent; the defendants lacked any indication that either had a motive to lie. View "Garcia v. Posewitz" on Justia Law

Plaintiff-Appellant appealed from a district court order granting summary judgment to Defendants-Appellees on his claim under the Racketeer Influenced and Corrupt Organizations Act (“RICO”). On appeal, Appellant argued that the district court erroneously held that he lacks RICO standing to sue for his lost earnings because those losses flowed from, or were derivative of, an antecedent personal injury.   The Second Circuit vacated and remanded. The court explained that RICO’s civil-action provision, 18 U.S.C. Section 1964(c), authorizes a plaintiff to sue for injuries to “business or property.” While that language implies that a plaintiff cannot sue for personal injuries, that negative implication does not bar a plaintiff from suing for injuries to business or property simply because a personal injury was antecedent to those injuries. The court explained that it is simply wrong to suggest that the antecedent-personal-injury bar is necessary to ensure “genuine limitations” in Section 1964(c), or to give restrictive significance to Congress’s implicit intent to exclude some class of injuries by the phrase “business or property”’ when it enacted RICO. View "Horn v. Medical Marijuana, Inc." on Justia Law

Defendants, game wardens with the Texas Parks and Wildlife Department, appealed the district court’s denial of qualified immunity as to Plaintiff’s Section 1983 claims against them.   The Fifth Circuit reversed and rendered judgment for Defendants. The court concluded that Plaintiff has not plausibly alleged that Defendant violated his constitutional rights. The court explained that because Plaintiff does not allege that Defendants knowingly withheld relevant, material information from the grand jury, he has not shown that the independent intermediary’s deliberations or decisions were tainted. Accordingly, the independent-intermediary doctrine defeats Plaintiff’s allegations that there was no probable cause to prosecute him and insulates Defendants from liability. The court wrote that this conclusion applies with equal force to Plaintiff’s claims for both retaliatory prosecution and prosecution without probable cause. View "Trevino v. Iden" on Justia Law

The property owners (doing business as Re-Mart Investment), and St. Maron Properties— brought Section 1983 claims against the City under the Takings Clause, the Due Process Clause, and the Equal Protection Clause, as well as state law tort and statutory claims. The district court dismissed the state law claims as barred by sovereign immunity. It also dismissed the Section 1983 claims under Rule 12(b)(6) for failure to satisfy the requirements for municipal liability under Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978).   The Fifth Circuit affirmed the dismissal of the state law claims. But reversed the dismissal of the Section 1983 claims. The court explained that under Monell, a Section 1983 plaintiff may not proceed against a municipality unless the injury was caused by an official policy of the municipality. But here, the property owners allege that city officials violated their rights at the specific direction of the Mayor and the City Council. That is enough to establish liability under Monell. Accordingly, the court held that the property owners are entitled to proceed against the City on their federal claims. View "St. Maron v. City of Houston" on Justia Law

The First Circuit granted in part Petitioner's petition for review of an order of the Board of Immigration Appeals (BIA) affirming the denial of Petitioner's application for deferral of removal under the Convention Against Torture (CAT) and vacated the BIA's order denying Petitioner CAT relief as to Ecuador, holding that remand was required for further proceedings.Petitioner was charged with removability for entering the country without admission or parole. Petitioner conceded removability and sought deferral of removal under CAT. An immigration judge (IJ) denied relief. The BIA affirmed. Petitioner petitioned for review and was subsequently removed to Ecuador. The First Circuit vacated the BIA's decision insofar as it denied Petitioner's CAT claim linked to the vernal violence in Ecuadorian prisons, holding that the BIA and IJ failed to apply the proper legal test in assessing whether the Ecuadorian government would consent or acquiesce to acts of torture by private actors in Ecuadorian prisons. View "Murillo Morocho v. Garland" on Justia Law

The First Circuit affirmed the district court's order entering summary judgment in favor of Defendant with respect to Plaintiff's assertion that he was wrongfully deprived of thousands of dollars in commissions he alleged he was due, holding that there was no error.After he resigned, Plaintiff brought suit against Defendant, his former employer, asserting claims for nonpayment of wages under the Act, breach of contract, unjust enrichment, and quantum meruit. Defendant successfully removed the action to federal district court, which granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that the district court (1) did not err in granting in part Defendant's motion to strike certain portions of his response to the summary judgment motion; and (2) did not err in granting summary judgment against Plaintiff on his claims. View "Klauber v. VMware, Inc." on Justia Law

This appeal centers around section 4(a)(1)–(3) of Alabama’s Vulnerable Child Compassion and Protection Act (the “Act”). Section 4(a)(1)–(3) of the Act states that “no person shall engage in or cause” the prescription or administration of puberty-blocking medication or cross-sex hormone treatment to a minor “for the purpose of attempting to alter the appearance of or affirm the minor’s perception of his or her gender or sex if that appearance or perception is inconsistent with the minor’s sex.” Shortly after the Act was signed into law, a group of transgender minors, their parents, and other concerned individuals challenged the Act’s constitutionality, claiming that it violates the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment. As part of that lawsuit, the district court issued a preliminary injunction enjoining Alabama from enforcing section 4(a)(1)–(3) of the Act.   The Eleventh Circuit vacated the preliminary injunction. The court held that the district court abused its discretion in issuing this preliminary injunction because it applied the wrong standard of scrutiny. The plaintiffs have not presented any authority that supports the existence of a constitutional right to “treat [one’s] children with transitioning medications subject to medically accepted standards.” Nor have they shown that section 4(a)(1)–(3) classifies on the basis of sex or any other protected characteristic. Accordingly, section 4(a)(1)–(3) is subject only to rational basis review. The court explained that the district court erred by reviewing the statute under a heightened standard of scrutiny, its determination that Paintiffs have established a substantial likelihood of success on the merits cannot stand. View "Paul Eknes-Tucker, et al. v. Governor of the State of Alabama, et al." on Justia Law