Justia Civil Rights Opinion Summaries

Churches, private religious schools, affiliated pastors, and the parents of students (on behalf of themselves and their minor children) sued Kentucky Governor Beshear in his individual capacity for alleged violations of their free-exercise rights, their rights to private-school education, and their rights to assemble peacefully and associate freely, based on Beshear’s Executive Order 2020-969, which temporarily barred in-person learning at all private and public elementary and secondary schools in Kentucky in response to a surge in COVID-19 transmission in the winter of 2020.The Sixth Circuit affirmed the dismissal of the suit on the basis of qualified immunity. Previous orders in cases involving challenges to pandemic-related executive orders did not make “sufficiently clear t[o] a reasonable official” that temporarily mandating remote learning for all elementary and secondary schools— religious and secular alike—ran afoul of the Free Exercise Clause. An “active and vibrant debate on the constitutional question existed at the time.” EO 2020-969 deprived the parent plaintiffs of neither a choice to send their children to private school over public school nor input in their children’s curriculum. The Governor did not violate the plaintiffs’ rights to assemble peacefully or associate freely. View "Pleasant View Baptist Church v. Beshear" on Justia Law

Following an investigation, Rollins determined that Plaintiff- John Doe violated its sexual misconduct policy. Doe was able to graduate and receive his undergraduate degree but was not allowed to participate in commencement/graduation ceremonies. Rollins imposed a sanction of dismissal, resulting in permanent separation of Doe without the opportunity for readmission; privilege restrictions, including a prohibition on participating in alumni reunion events on or off campus; and a contact restriction as to Roe. Doe sued Rollins in federal court, asserting two claims under Title IX, 20 U.S.C. Section 1681—one for selective enforcement and one for erroneous outcome—and a third claim under Florida law for breach of contract. Following discovery, the district court excluded the opinions proffered by Doe’s expert as to Rollins’ purported gender bias. Then, on cross-motions for summary judgment, the district court (a) entered summary judgment in favor of Rollins on the Title IX claims and (b) entered partial summary judgment in favor of Doe on the breach of contract claim.   The Eleventh Circuit affirmed. The court concluded that the district court did not abuse its discretion in precluding Doe’s expert from presenting opinions about Rollins’ purported gender bias and that it correctly granted summary judgment in favor of Rollins on Doe’s two Title IX claims. On the breach of contract claim, the court wrote that it cannot review Doe’s challenge to the district court’s partial denial of summary judgment because materiality is not a purely legal issue under Florida law and was later resolved by the jury. View "John Doe v. Rollins College" on Justia Law

The Montgomery County Board of Education adopted Guidelines for Gender Identity for 2020–2021 that permit schools to develop gender support plans for students. The Guidelines allow implementation of these plans without the knowledge or consent of the students’ parents. They even authorize the schools to withhold information about the plans from parents if the school deems the parents to be unsupportive. In response, three parents with children attending Montgomery County public schools challenged the portion of the Guidelines that permit school officials to develop gender support plans and then withhold information about a child’s gender support plan from their parents. Terming it the “Parental Preclusion Policy,” the parents alleged the policy unconstitutionally usurps the parents’ fundamental right to raise their children under the Fourteenth Amendment.   The Fourth Circuit vacated the district court’s order and remanded for the case to be dismissed. The court explained that the parents have not alleged that their children have gender support plans, are transgender or are even struggling with issues of gender identity. As a result, they have not alleged facts that the Montgomery County public schools have any information about their children that is currently being withheld or that there is a substantial risk information will be withheld in the future. Thus, under the Constitution, they have not alleged the type of injury required to show standing. Absent an injury that creates standing, federal courts lack the power to address the parents’ objections to the Guidelines. Thus, the court remanded to the district court to dismiss the case for lack of standing. View "John and Jane Parents 1 v. Montgomery County Board of Education" on Justia Law

Columbia Basin College officials terminated R.W. from the nursing program after learning that he had sought medical treatment for homicidal thoughts about three instructors. R.W. filed suit seeking damages, reinstatement in the nursing program, and expungement of his failing grades.   On interlocutory appeal, the Ninth Circuit  (1) affirmed the district court’s order determining that Plaintiff’s suit for injunctive relief against Columbia Basin College officials in their official capacity could proceed under the Ex parte Young exception to Eleventh Amendment sovereign immunity; and (2) dismissed in part defendants’ appeal for lack of jurisdiction in plaintiff R.W.’s action alleging First Amendment violations and other claims arising from his termination from a nursing program at Columbia Basin College.   The panel held that R.W.’s complaint alleged an ongoing violation of his constitutional rights given the uncertainty as to whether he could reenroll in the nursing program or qualify for financial aid; his claim for prospective relief was not moot; and the Dean of Student Conduct was a proper defendant because he was directly involved with the alleged constitutional violations and there was a question of fact as to whether he had authority to implement injunctive relief if so ordered.   the panel held that it lacked jurisdiction to review the district court’s order declining to reconsider its prior partial summary judgment for R.W. on his 42 U.S.C. Section 1983 claim for violation of the First Amendment. The merits of R.W.’s First Amendment claim were severable from, and neither necessary to nor necessarily resolved by, the district court’s ruling on the Ex parte Young issue and were reviewable upon entry of final judgment. View "R. W. V. COLUMBIA BASIN COLLEGE, ET AL" on Justia Law

Plaintiff worked for the City of Clarendon, Arkansas, as a full-time police officer. After he was terminated, he sued the City, then-Chief of Police Laura Rash, and then-Clarendon Mayor James L. Stinson, alleging a violation of the Arkansas Whistle-Blower Act and retaliation for the exercise of his free speech rights. The district court granted summary judgment to the defendants on the free speech claim, and the case proceeded to trial on the whistleblower claim. The jury returned a verdict for Defendants. Plaintiff appealed, arguing the district court erred in its pre-trial discovery rulings, its grant of summary judgment to the defendants, and its denial of his motion for a new trial.   The Eighth Circuit affirmed. The court explained that at summary judgment, there was no evidence that Plaintiff sought to convey that message when he gave the video to Deputy Thorne. Instead, the record showed that Plaintiff asserted the opposite, telling Whitcomb and Times that he was trying to “protect” them and expressly denying any intent to give the video to Thorne for investigatory purposes. The district court did not err in granting summary judgment on Plaintiff’s free speech claim. View "John Marlow v. City of Clarendon" on Justia Law

The Church of St. Theresa (St. Theresa’s) owned and operated the St. Theresa School. St. Theresa’s terminated art teacher and toddler room caregiver Victoria Crisitello for violating the terms of her employment agreement. That agreement required employees to abide by the teachings of the Catholic Church and forbade employees from engaging in premarital sex; Crisitello, who was unmarried, had become pregnant. In response to her firing, Crisitello filed a complaint against St. Theresa’s alleging employment discrimination in violation of the Law Against Discrimination (LAD), based on pregnancy and marital status. St. Theresa’s countered that its decision to terminate Crisitello was protected by both the First Amendment and the LAD. The New Jersey Supreme Court held: (1) the “religious tenets” exception of N.J.S.A. 10:5-12(a) was an affirmative defense available to a religious entity when confronted with a claim of employment discrimination; and (2) the uncontroverted fact was that St. Theresa’s followed the religious tenets of the Catholic Church in terminating Crisitello. The Court thus concluded St. Theresa’s was entitled to summary judgment and that the trial court correctly dismissed the complaint with prejudice. View "Crisitello v. St. Theresa School" on Justia Law

Petitioner is a former employee of International Business Machines Corporation (“IBM”) who signed a separation agreement requiring confidential arbitration of any claims arising from her termination. Petitioner arbitrated an age-discrimination claim against IBM and won. She then filed a petition in federal court under the Federal Arbitration Act (“FAA”) to confirm the award, attaching it to the petition under seal but simultaneously moving to unseal it. Shortly after she filed the petition, IBM paid the award in full. The district court granted Petitioner’s petition to confirm the award and her motion to unseal. On appeal, IBM argued that (1) the petition to confirm became moot once IBM paid the award, and (2) the district court erred in unsealing the confidential award.   The Second Circuit vacated the district court’s confirmation of the award and remanded with instructions to dismiss the petition as moot. The court reversed the district court’s grant of the motion to unseal. The court explained that Petitioner’s petition to confirm her purely monetary award became moot when IBM paid the award in full because there remained no “concrete” interest in enforcement of the award to maintain a case or controversy under Article III. Second, any presumption of public access to judicial documents is outweighed by the importance of confidentiality under the FAA and the impropriety of Petitioner’s effort to evade the confidentiality provision in her arbitration agreement. View "Stafford v. Int'l Bus. Machs. Corp." on Justia Law

Defendant asserts that he is required by his religious faith to abstain from psychiatric medication. Because he is not competent to stand trial, though, the government requested to involuntarily medicate him, and the district court granted the motion.   The Fifth Circuit held that the district court did not err in concluding that the government had satisfied the conditions for involuntary medication set out in Sell v. United States, 539 U.S. 166, 180–81 (2003). However, the court wrote that the district court should also have analyzed whether any statutory religious-freedom protections apply to Defendant. The court vacated and remanded for the district court to consider that issue. The court held that the government psychiatrist’s medical opinion is sufficient evidence that involuntary medication will “significantly further” the government’s interest. And “whatever the strength of that evidence,” Defendant “provides no reason to question its accuracy.” Thus, the court agreed with the district court that the government has provided enough evidence to satisfy the second prong. View "USA v. Harris" on Justia Law

Gunter and Grommet participated in a conspiracy to deliver methamphetamine, including a controlled purchase of actual methamphetamine from Gunter by law enforcement agents. A September 17, 2019 indictment charged Gunter and Grommet of conspiring to distribute and possessing with intent to distribute at least 50 grams of methamphetamine, 21 U.S.C. 841(a)(1), (b)(1)(A), 846. Gunter was arrested on July 2, 2020. The court set an initial trial date of August 31, 2020. Over the next 23 months, the trial was repeatedly rescheduled. Gunter first requested continuances; later continuances were at the request of Grommet, who was evaluated for competency and whose lawyer subsequently died. When Gunter eventually (unsuccessfully) sought severance, he did not cite Speedy Trial Grounds.Days before trial, Gunter unsuccessfully moved to dismiss the indictment alleging a violation of his Sixth Amendment speedy trial rights. The Seventh Circuit affirmed Gunter’s conviction after considering the length of and reasons for the delay, whether the defendant asserted his right to a speedy trial, and any prejudice the defendant suffered. Although Gunter first moved to dismiss the indictment on the basis of his right to a speedy trial immediately before trial, he opposed motions for continuances and asserted his desire for a speedy trial numerous times. The delays could not be attributed to the government. Gunter made no argument that he experienced any prejudice from the delay, and no strong showing of prejudice is obvious in the record. View "United States v. Gunter" on Justia Law

Plaintiff, a former employee, sued on behalf of herself and similarly situated employees, claiming that St. Luke’s violated the Fair Labor Standards Act’s (“FLSA”) overtime provisions by failing to fully compensate employees for work performed. She also brought an unjust-enrichment claim under state law. The district court certified two classes with different lookback periods: (1) an FLSA collective comprised of employees who worked for St. Luke’s between September 2016 and September 2018, 1 and (2) an unjust-enrichment class comprised of all employees who worked for St. Luke’s in Missouri between April 2012 and September 2018. Houston also asserted individual claims, one under the Missouri Minimum Wage Law, and one for breach of her employment contract. The district court granted summary judgment to St. Luke’s on all claims.   The Eighth Circuit vacated and remanded. The court explained that Plaintiff has raised a genuine dispute that the rounding policy does not average out over time. The court explained that no matter how one slices the data, most employees and the employees as a whole fared worse under the rounding policy than had they been paid according to their exact time worked. Here, the rounding policy did both. It resulted in lost time for nearly two-thirds of employees, and those employees lost more time than was gained by their coworkers who benefited from rounding. The court concluded that the employees have raised a genuine dispute that the rounding policy, as applied, did not average out over time. The district court, therefore, erred in granting summary judgment on the FLSA and Missouri wage claims. View "Torri Houston v. St. Luke's Health System, Inc." on Justia Law