Justia Civil Rights Opinion Summaries

Petitioner is an alien who challenges Exxon Mobil Corporation’s hiring policy as discriminatory. Petitioner received deferred deportation and eligibility for temporary work authorization under the Deferred Action for Childhood Arrival program. While a student at North Carolina State University, Petitioner was recruited by ExxonMobil for an internship. Petitioner told ExxonMobil that he is not a United States citizen, but erroneously represented that he had permanent work authorization under federal law. Petitioner was hired on this basis. However, when he presented his paperwork, it showed he lacked permanent work authorization, and ExxonMobil rescinded its offer.Petitioner claims that ExxonMobil’s policy discriminates against aliens as prohibited by 42 U.S.C. Sec. 1981. ExxonMobil filed a motion to dismiss, which the district court granted.The Fourth Circuit affirmed. Section 1981 only protects against intentional discrimination, and Petitioner failed to allege that ExxonMobil intentionally discriminates against aliens. While ExxonMobil’s policy requiring that applicants have permanent work authorization will only exclude aliens, discriminatory impact is not enough. And, given ExxonMobil’s policy, Petitioner did not plausibly allege that ExxonMobil intended to discriminate against aliens. View "Aldo De Leon Resendiz v. Exxon Mobil Corporation" on Justia Law

Plaintiff, a package delivery driver for United Parcel Service, Inc. (“UPS”), injured his hip and buttocks. He requested he be allowed to drive his route with a smaller truck that would have a softer suspension or, alternatively, that he be assigned to an “inside job.” However, UPS determined that Plaintiff's route required a larger truck and there were no openings for inside work; thus, UPS offered Plaintiff an unpaid leave of absence until he could return to work.Plaintiff filed a claim, asserting that UPS’s refusal to provide him with the accommodations he requested violated his rights under the ADA. The district court granted summary judgment to UPS, concluding, as a matter of law, that Plaintiff had not shown that the accommodations he requested were reasonable and that his unpaid leave of absence constituted a reasonable accommodation in the circumstances.The Fourth Circuit affirmed, finding Plaintiff failed to establish that UPS needed to allow him to drive a smaller vehicle on his existing route and that the leave of absence was not a reasonable alternative. View "Jay Hannah v. UPS" on Justia Law

Under Texas law, parties to municipal contracts must certify that they do not and will not boycott Israel for the duration of their contracts. The City of Houston offered A&R Engineering and Testing, Inc. a contract with an anti-boycott clause. A&R refused to sign and brought a Section 1983 suit against the City and the Texas Attorney General. The district court entered a preliminary injunction against the City and the Attorney General. The Attorney General appealed, arguing that A&R lacks standing.   The Fifth Circuit reversed and remanded with instructions to vacate the injunction and dismiss the suit against the Attorney General. The court explained that t, A&R has not shown that the Attorney General could interfere with the City’s contracts. Chapter Section 2271 merely provides a list of definitions and then a list of requirements. It doesn’t expressly provide a way for the Attorney General to enforce those requirements. The statute’s “textually unenforceable language” poses a traceability problem. Second, the Attorney General hasn’t taken any action to suggest he might enforce the provision even if he has such power. Plaintiffs must assert “an injury that is the result of a statute’s actual or threatened enforcement.” Finally, the City’s conduct severs any link between A&R’s economic injury and the Attorney General. View "A & R Engineering v. Scott" on Justia Law

Tennessee enacted the Prohibition on Medical Procedures Performed on Minors Related to Sexual Identity, citing concerns that gender dysphoria treatments “can lead to the minor becoming irreversibly sterile, having increased risk of disease and illness, or suffering adverse and sometimes fatal psychological consequences” while less risky, non-irreversible treatments remain available. Prohibited procedures include surgically removing, modifying, or entering into tissues, cavities, or organs and prescribing or dispensing any puberty blocker or hormone with exceptions for treating congenital defects, precocious puberty, disease, physical injury, and continuation of ongoing treatment. It provides for professional discipline of healthcare providers and creates a private right of action.The district court entered a preliminary injunction, finding that the challengers lacked standing to contest the surgery ban but that the ban on hormones and puberty blockers infringes the parents’ “fundamental right” to direct their children’s medical care, improperly discriminates on the basis of sex, that transgender persons constitute a quasi-suspect class, and that the state could not satisfy the necessary justifications.The Sixth Circuit stayed the injunction, finding that Tennessee is likely to succeed on appeal. The district court erred in its facial invalidation of the law, as opposed to an as-applied invalidation. “Life-tenured federal judges should be wary of removing a vexing and novel topic of medical debate from the ebbs and flows of democracy by construing a largely unamendable federal constitution to occupy the field.” A right to new medical treatments is not “deeply rooted" in history and traditions. Tennessee could rationally exercise caution before permitting irreversible medical treatments of children. View "L. W. v. Skrmetti" on Justia Law

In 2012, Horton was convicted of multiple drug trafficking and firearm crimes. Horton had been convicted of four prior state drug felonies. The court imposed three concurrent life sentences. Horton’s direct appeal and collateral relief motion under 28 U.S.C. 2255, failed. Under 2255(h) a successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.” Horton filed a habeas petition under 28 U.S.C. 2241, citing the “saving clause,” 28 U.S.C. 2255(e); a 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit previously held (Davenport) that 2255 is “inadequate or ineffective”— and 2241 is available—when the limits on successive 2255 motions bar relief and the prisoner’s claim is based on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Horton's Davenport claim challenged his sentences based on the Supreme Court’s 2016 Mathis decision.In the interim, the Supreme Court decided Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy 2255’s conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all." The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Horton v. Lovett" on Justia Law

Sanders was convicted in 2006 of firearms offenses. The court imposed an enhanced sentence under the Armed Career Criminal Act, based on three prior convictions, including one for Illinois residential burglary. His direct appeal and 28 U.S.C. 2255 motion for collateral relief failed. Sanders has three times unsuccessfully sought permission to file a successive 2255 motion. A successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.”Sanders filed a 28 U.S.C. 2241 habeas petition, citing the “saving clause.” 28 U.S.C. 2255(e); A federal prisoner’s 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.” Seventh Circuit precedent (Davenport) applied the saving-clause gateway to habeas claims premised on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Sanders’s Davenport claim challenged his ACCA-enhanced sentence based on the Supreme Court’s 2016 Mathis decision.The district judge denied relief. The Supreme Court held, in Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy the 2255 conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all. The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Sanders v. Joseph" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

While serving a 55-year sentence for murder, Love assaulted a correctional officer, resulting in state convictions for felony battery. The Indiana Department of Correction also found Love guilty of violating prison rules and imposed sanctions including revocation of 5,700 days of his accrued good time credit, which extended Love’s release date by more than 15 years. Love unsuccessfully pursued prison appeals. The district court denied his 28 U.S.C. 2254 petition. The Seventh Circuit affirmed. Love procedurally defaulted his constitutional claims and forfeited them by failing to present them in administrative proceedings or the district court.One argument concerned Executive Directive 17-09, under which the Department must revoke all accrued good time credit from inmates found guilty of qualifying offenses. There is no additional hearing; the inmate is not provided an opportunity to argue why revocation of less time is appropriate. Love argued that the Department cannot, consistent with due process, predetermine how it will use its discretionary power over sanctions without first considering arguments in mitigation. Love also argued that Directive 17-09 is facially arbitrary in tying punishment to the amount of good time credit an inmate has rather than the severity of his misconduct. Love offered two examples where other inmates presumably should have been punished in accordance with the Directive but were allegedly shown leniency instead. View "Love v. Vanihel" on Justia Law

In 2007, Hogsett was convicted of crimes, including being a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The court found that Hogsett was an armed career criminal, with three prior convictions for violent felonies, and sentenced him to 295 months. In 2021, the Supreme Court (Borden) interpreted “violent felony” in 924(e) to exclude crimes that can be committed with a mens rea of recklessness. Hogsett sought to challenge his sentence under Borden. To collaterally attack a conviction or sentence, a federal prisoner files a 28 U.S.C. 2255 motion, not a habeas petition, 28 U.S.C. 2241. Hogsett had filed a 2255 motion in 2010. A prisoner can only file another 2255 motion in two circumstances: newly discovered evidence sufficient to establish innocence or a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court. Hogsett argued that he was eligible to file under 2255(e), the “saving clause,” which applies when “the remedy by motion is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit ordered the dismissal of Hogsett’s petition for lack of jurisdiction. The court cited the Supreme Court’s intervening Jones holding: “The inability of a prisoner with a statutory claim to satisfy” 2255(h)’s requirements “does not mean that he can bring his claim in a habeas petition under the saving clause … he cannot bring it at all.” Borden is a statutory interpretation decision. View "Hogsett v. Lillard" on Justia Law

Sacramento County Sheriffs’ Deputies encountered Celia and William Bernal (collectively “the Plaintiffs”) at their home during the Deputies’ investigation into allegations that Plaintiffs’ son planned a shooting at his school that day. During the interaction, the Deputies held Celia’s arms and used a twistlock to prevent her from leaving. The Deputies also pointed a firearm at William, forcibly restrained him, and put him in handcuffs. The district court held that the Deputies did not violate the Fourth Amendment by detaining Plaintiffs even in the absence of reasonable suspicion. The district court further found that the Deputies did not use excessive force during Plaintiffs’ detention and, even if they had, qualified immunity applied.
The Ninth Circuit affirmed in part and reversed in part the district court’s summary judgment in favor of the Deputies in Plaintiffs’ Section 1983 action. The panel first considered whether the initial seizure of Plaintiffs was reasonable. Because Plaintiffs were detained but not arrested, the reasonableness of their detention depends on a balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers. The panel held that the Deputies had limited authority to briefly detain and question Plaintiffs about Ryan’s location due primarily to the exigencies inherent in preventing an imminent school shooting. Further, on balance, the panel concluded that the Deputies’ use of force against Celia was reasonable under the circumstances. The panel concluded that the district court erred in finding that the Deputies’ use of force against William was not excessive. The intrusion on William’s liberty was too great in the context of detaining a non-suspect witness. View "WILLIAM BERNAL, ET AL V. SACRAMENTO COUNTY SHERIFF'S DEPARTMENT, ET AL" on Justia Law