Justia Civil Rights Opinion Summaries

In August 2021, New York City’s Department of Education mandated COVID-19 vaccinations for all staff and contractors working in school settings. This mandate was updated over time, including a religious exemption process. The plaintiffs, New York City public sector employees, challenged the constitutionality of the mandate and the exemption process, both facially and as applied.The Southern District of New York denied a preliminary injunction and dismissed the consolidated amended complaint on the merits. The Eastern District of New York also denied a similar preliminary injunction motion. The plaintiffs appealed these decisions, leading to a consolidated review by the United States Court of Appeals for the Second Circuit.The Second Circuit affirmed in part and dismissed in part the denials of preliminary injunctions, affirmed the dismissal of the facial challenges, and affirmed in part while vacating and remanding in part the dismissal of the as-applied challenges. The court found that the request to rescind the vaccine mandate was moot due to its official rescission and denied the request for reinstatement and backpay, as the plaintiffs could not show irreparable harm post-termination. The court upheld the dismissal of the facial challenges, finding no evidence that the Citywide Panel process preferred certain religions or was infected with religious animus. However, the court vacated and remanded the as-applied challenges for plaintiffs Natasha Solon and Heather Clark, who plausibly alleged that their religious accommodation requests were improperly denied. View "New Yorkers for Religious Liberty v. City of New York" on Justia Law

Ronda Jones was arrested by Officer Steven Naert after attempting to walk to the scene of her son's car accident. Jones had been drinking at home and was suspected by Naert of having driven the car while intoxicated due to her prior DUI arrest. When Jones tried to leave her home to check on her son, Naert arrested her for disorderly conduct, citing a Michigan statute that prohibits such behavior. The statute does not criminalize public intoxication alone; it requires probable cause to believe that the individual would pose a danger to others.The United States District Court for the Western District of Michigan granted Officer Naert qualified immunity on Jones's false arrest claim, holding that he had probable cause for the arrest. The court also granted summary judgment on Jones's malicious prosecution claim, concluding that Naert did not participate in the decision to prosecute her. Jones appealed these decisions.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that Officer Naert lacked probable cause to arrest Jones for disorderly conduct. The court found that Jones's actions did not indicate she would pose a danger to others by walking a short distance while intoxicated. However, the court affirmed the district court's decision to grant Naert qualified immunity because Jones failed to show that the unlawfulness of the arrest was "clearly established" at the time. The court also affirmed the summary judgment on the malicious prosecution claim, as there was no evidence that Naert influenced the decision to prosecute Jones. View "Jones v. Naert" on Justia Law

Enrique Sanchez, the petitioner, sought a writ of mandate to vacate a trial court order that directed the San Bernardino County Public Defender to assign a new attorney to represent him. This order was issued after the current deputy public defender made remarks during plea negotiations that invoked Sanchez's race, potentially violating the Racial Justice Act (RJA). Sanchez argued that the trial court abused its discretion in ordering the reassignment.The trial court received a motion from the prosecutor to disclose exculpatory evidence and evaluate a conflict of interest after the deputy public defender made racially charged comments. During a closed hearing, Sanchez expressed his desire to retain his current counsel. However, the trial court ordered the reassignment of the deputy public defender, citing potential issues under the RJA and the risk of ineffective assistance of counsel.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the trial court did not abuse its discretion in removing the deputy public defender. The appellate court noted that the RJA's provisions and the potential for implicit bias created an actual conflict of interest that the deputy public defender could not objectively investigate. Additionally, the court found that the trial court's decision to prevent a potential future RJA claim was within its discretion to avoid substantial impairment of the proceedings.The appellate court concluded that Sanchez's arguments regarding constitutional violations and the necessity of an actual conflict were without merit. The court emphasized that the trial court's order was narrowly tailored and did not violate Sanchez's rights. Consequently, the petition for writ of mandate was denied, and the stay on trial court proceedings was vacated. View "Sanchez v. Superior Court" on Justia Law

Mitchell Sanderson filed a lawsuit against North Dakota state senator Janne Myrdal under 42 U.S.C. § 1983, claiming that Myrdal violated his First Amendment rights by blocking him on Facebook. Sanderson argued that Myrdal's Facebook page was a public forum, and he sought damages and injunctive relief. Myrdal responded that her Facebook page was not an official state website and denied Sanderson's entitlement to relief. Sanderson also filed a motion for default judgment, which the district court denied, noting that Myrdal had answered the complaint before the motion was filed.The District Court of Walsh County, Northeast Judicial District, granted summary judgment in favor of Myrdal, concluding that Sanderson's § 1983 claim failed as a matter of law. The court found no genuine issue of material fact and determined that Myrdal's Facebook page was not a public forum and her actions did not constitute state action. The court also denied Sanderson's various motions and requests for hearings, finding some of his motions frivolous and awarding Myrdal attorney’s fees for responding to them.The Supreme Court of North Dakota affirmed the district court's judgment. The court held that Myrdal's blocking of Sanderson on Facebook was not state action because her Facebook page was created and maintained in her private capacity, not as an official state communication. The court also upheld the denial of Sanderson's motion for default judgment, agreeing with the lower court's preference for resolving cases on their merits. Additionally, the court found no abuse of discretion in the district court's denial of Sanderson's requests for hearings and the award of attorney’s fees to Myrdal for responding to frivolous motions. View "Sanderson v. Myrdal" on Justia Law

Nicole Stone, a person with disabilities who uses a motorized wheelchair, resides in St. Johnsbury, Vermont. In 2020, her mother’s boyfriend, Johnathan Chase, built an outdoor structure to facilitate socially distanced meetings for Stone. A neighbor complained about the structure, leading the town zoning administrator to inform Chase that it violated setback requirements and to advise him to seek a variance. The Development Review Board (DRB) denied the variance request without discussing Stone’s disability-related needs. Stone did not appeal the decision but filed a discrimination complaint with the Vermont Human Rights Commission.The Commission investigated and found reasonable grounds to believe the Town of St. Johnsbury discriminated against Stone based on her disability. The Commission filed a complaint in the Civil Division of the Superior Court, seeking various forms of relief, including declaratory and injunctive relief, damages, and civil penalties. The Town moved to dismiss the complaint, arguing that only the Environmental Division had jurisdiction over such claims. The Civil Division dismissed the complaint, concluding it lacked subject-matter jurisdiction because ruling on the discrimination claim would constitute an impermissible collateral attack on the final zoning decision.The Vermont Supreme Court reviewed the case and concluded that the Civil Division has jurisdiction over all Vermont Fair Housing and Public Accommodations Act (VFHPAA) claims. The Court held that the finality provisions of 24 V.S.A. § 4472 do not preclude the Commission from seeking remedies for discrimination that do not require reopening the final zoning decision. The Court also determined that the Commission is not an "interested person" under the statute and is therefore not bound by the exclusivity-of-remedy provisions. The Supreme Court reversed the dismissal and remanded the case for further proceedings. View "Vermont Human Rights Commission v. Town of St. Johnsbury" on Justia Law

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Randy Ethan Halprin, a member of the "Texas Seven," escaped from prison in December 2000 and was involved in the murder of Irving Police Officer Aubrey Hawkins during a robbery. Halprin was charged with capital murder and, in 2003, was convicted and sentenced to death by Judge Vickers Cunningham. Halprin's conviction and sentence were affirmed on direct appeal, and his initial habeas application was denied. Subsequent applications were dismissed. In 2019, Halprin filed a new writ application alleging that Judge Cunningham was biased against him because he is Jewish, violating his right to due process and the free exercise of his religion.The Texas Court of Criminal Appeals reviewed Halprin's claim after the trial court held an evidentiary hearing. The trial court found that Judge Cunningham exhibited actual bias against Halprin due to his Jewish faith and recommended granting Halprin a new trial. The State agreed that the evidence showed Cunningham's bias. The Texas Court of Criminal Appeals independently reviewed the record and confirmed that Cunningham's anti-Semitic remarks and behavior demonstrated actual bias.The Texas Court of Criminal Appeals concluded that Halprin had shown by a preponderance of the evidence that Judge Cunningham was biased against him at the time of the trial. This bias constituted a structural due process violation, entitling Halprin to a new trial. The court granted Halprin a new trial and dismissed his second claim challenging the constitutionality of the future dangerousness special issue as an abuse of the writ. View "In re Halprin" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

Six former commanders of the Cook County Jail filed a lawsuit under 42 U.S.C. §1983, claiming their layoffs in late 2017 violated their First Amendment rights. The layoffs occurred during a budget crisis, which led to the elimination of their positions. The plaintiffs argued that the layoffs were retaliatory, linked to their support for unionization efforts by the Teamsters Union, which the Sheriff opposed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Sheriff. The court found that the evidence did not support an inference that the commanders' pro-union speech caused the layoffs. The court concluded that the layoffs were a result of a significant budget shortfall, not retaliation for union activities.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the budget crisis was the primary reason for the layoffs. It noted that the Illinois Labor Relations Board had determined the commanders were supervisors and not entitled to collective bargaining. The court found no evidence that the Sheriff's Office targeted the commanders for their union activities, as the layoffs affected all commanders regardless of their stance on unionization. The court also observed that the overall unionized workforce increased after the layoffs, further undermining the plaintiffs' claims of anti-union retaliation. The court concluded that reasonable jurors could not find the Sheriff's explanation for the layoffs to be pretextual. View "Consolino v. Dart" on Justia Law

The plaintiff, a transgender woman, was diagnosed with gender dysphoria and prescribed hormone replacement therapy (HRT) while detained at the Oklahoma County jail. After being transferred to the Oklahoma Department of Corrections (ODOC), she continued her HRT regimen. However, upon her transfer to the Dick Conner Correctional Center, a staff psychologist evaluated her and concluded she did not have gender dysphoria. Based on this evaluation, the prison physician at the Davis Correctional Facility, where she was subsequently transferred, decided to taper and discontinue her HRT.The plaintiff filed a 42 U.S.C. § 1983 claim for deliberate indifference to serious medical needs against the prison physician and the health services administrator. The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of the defendants, concluding that no reasonable jury could find deliberate indifference because the discontinuation of HRT was in compliance with correctional policy, which required a confirmed diagnosis of gender dysphoria for HRT to continue.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The appellate court held that the defendants did not act with deliberate indifference by discontinuing the plaintiff’s HRT based on the psychologist’s evaluation and the correctional policy. The court found no evidence that the defendants knew or strongly suspected that the psychologist’s diagnosis was incorrect. Additionally, the court concluded that the plaintiff’s disagreement with the diagnosis and the course of treatment did not constitute a constitutional violation. The court also rejected the argument that the defendants were required to arrange for a second evaluation, as there was no indication that they suspected the initial diagnosis was wrong. View "Johnson v. Sanders" on Justia Law