Justia Civil Rights Opinion Summaries

In 2005, a federal district court entered a permanent injunction against several pro-life advocates enjoining them from entering the public sidewalk within fifteen feet of the entrance of any abortion clinic in the Western District of New York. Twelve years later, in 2017, Plaintiff, who was not a named party to the 2005 permanent injunction, started sidewalk counseling near the Planned Parenthood facility in Rochester, New York. After Defendants, the New York Attorney General and the City of Rochester decided that Plaintiff was bound by the 2005 permanent injunction, he sued, seeking a declaratory judgment that he was not bound by the injunction. He also moved for a preliminary injunction to prevent Defendants from applying the injunction to his counseling activities. The district court dismissed his suit for failure to state a claim and denied his motion for a preliminary injunction.   The Second Circuit reversed the judgment of the district court insofar as it dismissed Plaintiff’s complaint and vacated the judgment insofar as it denied Plaintiff’s motion for a preliminary injunction. The court remanded for further proceedings. The court held that a person who is not a named party to an injunction or legally identified with a named party is bound by the injunction only from acting for the benefit of, or to assist, an enjoined party in violating the injunction. The allegations in Plaintiff’s complaint do not establish that he so acted and therefore state a claim for declaratory relief. View "Havens v. James" on Justia Law

Plaintiffs are twenty-six former employees of International Business Machines Corporation (“IBM”) who signed separation agreements requiring them to arbitrate any claims arising from their termination by IBM. The agreements set a deadline for initiating arbitration and included a confidentiality requirement. Plaintiffs missed the deadline but nonetheless tried to arbitrate claims under the Age Discrimination in Employment Act of 1967 (“ADEA”). Their arbitrations were dismissed as untimely. They then sued IBM in district court, seeking a declaration that the deadline is unenforceable because it does not incorporate the “piggybacking rule,” a judge-made exception to the ADEA’s administrative exhaustion requirements. Shortly after filing suit, Plaintiffs moved for summary judgment and attached various documents obtained by Plaintiffs’ counsel in other confidential arbitration proceedings. IBM moved to seal the confidential documents. The district court granted IBM’s motions to dismiss and seal the documents. On appeal, Plaintiffs argued that (1) the filing deadline in their separation agreements is unenforceable and (2) the district court abused its discretion by granting IBM’s motion to seal.   The Second Circuit affirmed. The court first wrote that the piggybacking rule does not apply to arbitration and, in any event, it is not a substantive right under the ADEA. Second, the court held that the presumption of public access to judicial documents is outweighed here by the Federal Arbitration Act’s (“FAA”) strong policy in favor of enforcing arbitral confidentiality provisions and the impropriety of counsel’s attempt to evade the agreement by attaching confidential documents to a premature motion for summary judgment. View "In re IBM Arb. Agreement Litig." on Justia Law

Plaintiff Jane Doe alleged that for a period of seven years, she suffered sexual, physical, and psychological abuse at the hands of an Immigration and Customs Enforcement (ICE) officer. Four years after the alleged abuse ended, Doe brought this action against the officer, the United States, the Department of Homeland Security, and two senior DHS officials, asserting various federal and state claims. The district court granted Defendants’ motions for summary judgment based on the applicable statutes of limitations and denied Doe’s request for equitable tolling.   The Second Circuit vacated the district court’s ruling and held that the district court erred in granting summary judgment because the evidence in the record could have allowed it to conclude that the prerequisites for equitable tolling were met. The court explained that the record makes plausible the inferences that years of violent sexual abuse and threats to Doe’s life constituted an extraordinary circumstance preventing Doe from sooner pursuing her claims and that she acted with reasonable diligence. View "Doe v. United States" on Justia Law

The Bail Project, a nonprofit organization, advocates for the abolition of cash bail and pays cash bail for thousands of individuals across the country to show that conditioning a pretrial defendant’s release upon the payment of money is not necessary to secure appearances at future court dates. Indiana House Enrolled Act 1300 requires charitable bail organizations to register with the state and limits for whom such organizations can pay cash bail.The Project sought to enjoin Indiana’s Department of Insurance from enforcing the law, arguing that HEA 1300 (which had not yet gone into effect) would violate its First Amendment right to free speech and its Fourteenth Amendment right to equal protection. The district court held that The Project had not shown a likelihood of success on the merits. The Seventh Circuit affirmed. The payment of cash bail is not protected by the First Amendment. Although The Project pays bail with the intent to communicate its message and to further its advocacy, a reasonable observer would not understand the conduct itself as communicating any message without additional explanatory speech. HEA 1300 does not violate the Equal Protection Clause because it is rationally related to Indiana’s legitimate interest in regulating the pretrial detention of criminal defendants. View "The Bail Project, Inc. v. Commissioner, Indiana Department of Insurance" on Justia Law

Four employee benefit funds and their Boards of Trustees, as well as two labor unions (collectively, “Boards”), sued B.F.W. Contracting, LLC and B.F.W. Contractors, LLC (collectively, “Contractors”) to compel an audit and recover money damages pursuant to a collective bargaining agreement (CBA) signed onto by Contractors. The district court granted summary judgment for the Boards and found damages in the amount of $48,568.76.   The Eighth Circuit reversed. The court explained that the Boards argued that the Contractors forfeited the argument about supplemental dues because they failed to raise it before the district court. The court concluded that the Boards are incorrect. The Contractors made this argument in their Response to the Statement of Material Facts by Plaintiff, as well as in their Supplemental Reply Memorandum. The court found that this was enough to avoid forfeiture and allowed the court to consider the issue on appeal.   Additionally, the Boards argue that failure to pay the supplemental dues resulted in a breach of the CBA provision, which authorized the dues under the Labor Management Relations Act, 29 U.S.C. Section 186(c)(2). However, as the plain language of the CBA makes clear, there is no violation of that provision if the Contractors never received the employee authorization cards as required by both the CBA and 29 -6- U.S.C. Section 186(c)(4). Without a breach of this subsection of the CBA, these statutory provisions are inapplicable. View "Greater St. Louis Const. Laborers Welfare Fund v. B.F.W. Contracting, LLC" on Justia Law

Plaintiff appealed the district court’s judgment dismissing for failure to state a claim his suit against Defendant-Appellee New York State Department of Corrections and Community Supervision (“DOCCS”) for attorneys’ fees and costs under 20 U.S.C. Section 1415(i)(3)(B)(i), the fee-shifting provision of the Individuals with Disabilities Education Act (“IDEA”).   The Second Circuit reversed and remanded. The court explained that the relevant provision permits a court, in its discretion, to award reasonable attorneys’ fees and related costs to “a prevailing party who is the parent of a child with a disability.” 20 U.S.C. Section 1415(i)(3)(B)(i)(I). The IDEA defines “parent” broadly to include, inter alia, foster parents, guardians, individuals “acting in the place of a natural or adoptive parent . . . with whom the child lives,” and “individual[s] who [are] legally responsible for the child’s welfare.” On de novo review, the court concluded that the IDEA permits a court to award fees and costs to J.S. as “an individual who is legally responsible for the child’s welfare” because, as an adult “child with a disability” and without representation by a guardian, natural parent, or appointed individual, he prevailed in his action on his own behalf seeking required educational services from DOCCS. View "J.S. v. DOCCS" on Justia Law

Bureau Chief Korza received a complaint regarding Snowden’s handling of a claim. Korza found discrepancies in Snowden’s records. Korza and a division administrator met with Snowden and her union representative and gave Snowden copies of the records. Korza continued his review and found many additional problems. Korza consulted with the Department’s Labor Relations office. Korza lacked the authority to discharge anyone and was advised that discharge was an appropriate penalty for the falsification of records. Korza summarized his findings for the director of the Division and recommended termination. At a later pre-disciplinary meeting, Snowden and her union representative were given a statement of charges. Korza stated that the discipline was undetermined because Snowden had not had an opportunity to respond, but that the charged violations were subject to discipline including discharge. Snowden’s written rebuttal did not contest the factual basis for the charges but noted arguable shortcomings in the investigation. At a final meeting, Korza advised Snowden that she was being placed on suspension pending discharge. Director Hoffman later signed a form terminating Snowden. Snowden pursued a grievance, which resulted in Snowden being allowed to resign without reinstatement rights.Snowden filed suit, asserting due process violations, claiming that Korza had decided to discharge her before the pre-disciplinary meeting and was not the impartial decision-maker. The Third Circuit affirmed the summary judgment rejection of the suit. Korza was not the decision-maker. Snowden was given notice and the opportunity to respond before that decision was made, plus a post-discharge grievance process. View "Snowden v. Illinois Department of Human Services" on Justia Law

Luster was buying a house on contract and had already paid the owner at least 20 percent of the price of the home. The village contacted Luster to obtain the property to create a municipal park. Luster rebuffed this offer. The village then contacted the seller. Luster claims the village knew of his contract but convinced the seller to convey a warranty deed to the village without notifying Luster. The village then sent a letter to Luster demanding immediate possession of the property. According to Luster, he was unable to insure the house because of the ownership dispute. The house burned down while Luster was attempting to quiet title, destroying his family’s possessions and leaving them homeless. Luster sued the village under 42 U.S.C. 1983, seeking damages for his lost property and the village’s “malicious conduct.” He alleged that the village took the home without adequate notice and an opportunity to be heard.The Seventh Circuit vacated the dismissal of the complaint. Luster’s complaint does not allege or permit a reasonable inference that he was deprived of his property by the random, unauthorized acts of any village employee. Absent any obvious reason why the village could not have provided advance notice and a pre-deprivation hearing before it seized Luster’s property interest, the adequacy of a post-deprivation remedy is irrelevant. View "Luster v. Village of Ashmore" on Justia Law

This consolidated case concerns three appeals from orders entered by magistrate judges in the Western District of Pennsylvania in cases filed under 42 U.S.C. 1983. One case was involuntarily dismissed without prejudice for failure to prosecute; in the others, magistrates entered summary judgment for all defendants.Under 28 U.S.C. 636, precise limits govern a magistrate judge’s jurisdiction absent parties’ consent. A magistrate judge can oversee pretrial discovery even without the consent of the parties, but he cannot grant summary judgment or involuntarily dismiss a case; those limits dissolve if the parties voluntarily consent to a magistrate judge’s final judgment jurisdiction.The Third Circuit dismissed one appeal for lack of jurisdiction because all parties did not consent and, therefore, the magistrate judge lacked the power to involuntarily dismiss the case. However, the magistrate judges were empowered to enter summary judgment in the other cases because all parties either expressly or impliedly consented. The court then affirmed summary judgment based on the plaintiffs’ failure to exhaust administrative remedies. View "Prater v. Pennsylvania Department of Corrections" on Justia Law

A former BNSF Railway Company employee died from lung cancer in 2018. Plaintiff, on behalf of her late husband’s estate, brought this wrongful death action against BNSF under the Federal Employers’ Liability Act (FELA), alleging that her husband’s cancer was caused by his exposure to toxins at work. The district court excluded Plaintiff’s expert witness testimony and granted summary judgment to BNSF.   The Eighth Circuit affirmed. The court wrote that there is no direct evidence that Plaintiff’s husband was exposed to asbestos or diesel combustion fumes. Even if a jury could infer that Plaintiff’s husband had been exposed, there is no evidence of the level of exposure. The court explained that while a quantifiable amount of exposure is not required to find causation between toxic exposure and injury, there must be, at a minimum, “evidence from which the factfinder can conclude that the plaintiff was exposed to levels of that agent that are known to cause the kind of harm that the plaintiff claims to have suffered,” There is no such evidence here. Moreover, the court explained that the district court did not abuse its considerable discretion by determining that the expert’s opinion lacked a sufficient foundation and that, in turn, his methodology for proving causation was unreliable. View "Rebecca Lancaster v. BNSF Railway Company" on Justia Law