Justia Civil Rights Opinion Summaries

Cloetta Brady, a former Walmart employee, alleged sex discrimination under Title VII of the Civil Rights Act of 1964 after being denied a promotion to a daytime support manager position. Brady had worked at Walmart since 1987 and was a claims associate when she applied for the promotion in 2007. The position required passing the Supervisory Leadership Assessment (SLA), which Brady had not passed, while the selected candidate, Mike Harms, was already serving as a nighttime support manager and thus met the qualifications.The United States District Court for the Western District of Missouri granted summary judgment in favor of Walmart, dismissing Brady's claims. Brady appealed, challenging only the summary judgment on her disparate treatment claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court considered whether Brady presented direct evidence of sex discrimination or could create an inference of unlawful discrimination under the McDonnell Douglas framework. The court found that the statement by the store manager, Charles Cornelison, that Harms was promoted "because he was sick" and "had a family to support," was facially and contextually neutral and did not constitute direct evidence of sex discrimination. Additionally, Brady failed to establish a prima facie case of discrimination as she did not meet the job qualifications, specifically the SLA requirement.The Eighth Circuit affirmed the district court's grant of summary judgment, concluding that Brady neither presented direct evidence of sex discrimination nor created an inference of unlawful discrimination through the McDonnell Douglas analysis. View "Brady v. Walmart Stores, Inc." on Justia Law

A bus driver, Wendy Alberty, was involved in an incident where she locked a passenger in the luggage compartment of a bus during a layover. The passenger called the police from inside the compartment, leading to Alberty's arrest for reckless endangerment and breach of the peace, with an additional charge of unlawful restraint added later. All charges were eventually dropped, and Alberty sued three police officers for false arrest, malicious prosecution, and retaliatory prosecution, claiming lack of probable cause.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants, holding that the officers had probable cause to arrest Alberty and arguable probable cause to prosecute her. Alberty appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that the officers had probable cause to arrest Alberty based on the evidence available at the time, including the passenger's 911 call, her identification of Alberty, and statements from another bus driver about company policy. The court also found that the officers had probable cause to prosecute Alberty for all charges, despite a video suggesting the incident might have been accidental. The court held that the video and the opinion of a trooper who viewed it did not dissipate probable cause. Consequently, the court affirmed the dismissal of Alberty's claims for false arrest, malicious prosecution, and retaliatory prosecution. View "Alberty v. Hunter" on Justia Law

M.K., a minor, enrolled in the Pearl River County School District after being homeschooled. During his sixth-grade year, he was bullied by boys in four of his classes, who called him names like "gay." In October, M.K. exposed his genitals to one of the boys in a restroom, claiming it was either accidental or an attempt to prove he was not "gay." The District suspended M.K. and required him to attend an alternative school for six weeks, which he refused, considering it akin to a prison. M.K., through his father, sued the District and others, alleging deliberate-indifference sex-discrimination under Title IX.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of the District, concluding that Title IX does not cover sexual-orientation discrimination and that the alleged behavior was not severe enough to be actionable. M.K. appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the student behavior M.K. experienced, while mean-spirited, did not meet the Supreme Court's stringent standard for "severe, pervasive, and objectively offensive" conduct required for a Title IX claim. The court emphasized that the behavior M.K. described, such as name-calling and teasing, is common in schools and does not rise to the level of actionable harassment under Title IX. The court concluded that M.K.'s experiences, though unfortunate, were not sufficient to sustain his Title IX claim against the District. View "M.K. v. Pearl River County School District" on Justia Law

Kristopher Birtcher, experiencing a mental health crisis, was reported to law enforcement by a Hobby Lobby manager. Birtcher, unarmed and not threatening anyone, was detained by sheriff’s deputies. During the detention, Birtcher attempted to flee but was subdued by multiple deputies who restrained him in a prone position, applying bodyweight pressure to his back. Despite Birtcher’s pleas that he could not breathe, the deputies maintained the restraint, and Birtcher eventually stopped moving and died from asphyxiation and sudden cardiac arrest.In the Superior Court of San Diego County, the trial court granted summary judgment in favor of the defendants, finding no triable issues of material fact regarding the excessive force claim. The court concluded that the deputies’ actions were in accordance with their training and that Birtcher’s restraint was proper. The court also ruled that plaintiff failed to establish a legal basis for the negligent training claim against Sheriff William D. Gore.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court reversed the trial court’s decision, holding that there were indeed triable issues of material fact regarding the excessive force used by the deputies. The appellate court found that the evidence, including expert testimony, suggested that the deputies’ use of bodyweight pressure on Birtcher while he was restrained in a prone position could be considered excessive force. The court also held that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as there was a statutory basis for the claim and evidence suggesting his involvement in the training policies.The appellate court reversed the judgment in favor of all defendants and remanded the matter for further proceedings. View "A.B. v. County of San Diego" on Justia Law

Matthew Warman, a former graduate student at Mount St. Joseph University (MSJU), objected to taking the COVID-19 vaccine on religious grounds. When MSJU required all students and employees to be vaccinated, Warman applied for a religious exemption. He was allegedly detained by two MSJU Police Department officers who attempted to convince him to get vaccinated and disparaged his religious beliefs. Warman later sued MSJU, MSJPD, and several individual employees.The United States District Court for the Southern District of Ohio dismissed Warman’s complaint. The court dismissed his free exercise, equal protection, and disability discrimination claims with prejudice and dismissed MSJPD from all counts with prejudice. Warman appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of Warman’s free exercise, equal protection, and disability discrimination claims. However, the court found that Warman plausibly pleaded that the two officers who detained him violated his Fourth Amendment rights. Consequently, the court reversed the district court’s dismissal of Warman’s wrongful detention claim and reinstated the claim against those defendants. The court also vacated the district court’s declination of supplemental jurisdiction over Warman’s state-law claims and remanded for reconsideration.In summary, the Sixth Circuit affirmed the dismissal of most of Warman’s claims but reinstated his Fourth Amendment wrongful detention claim against the two officers and remanded the state-law claims for further consideration. View "Warman v. Mount St. Joseph University" on Justia Law

Officer Jeff Smith, the oldest and longest-tenured police officer in the City of Union, Ohio, was terminated after allegedly violating several police department policies over a two-day period. An arbitrator later ordered his reinstatement, finding the termination to be an overreaction to minor and excusable mistakes. However, the City delayed his return for two months, requiring a fitness-for-duty examination and acting slowly once he passed it. During this delay, a younger officer was promoted, and raises were secured for all officers except Smith.Smith sued the City under the Age Discrimination in Employment Act (ADEA) and its Ohio counterpart, alleging age-based termination and retaliatory delay in his return for filing a charge with the Equal Employment Opportunity Commission (EEOC). The United States District Court for the Southern District of Ohio granted summary judgment to the City on both claims, leading Smith to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that a jury could view the facts and agree with Smith, particularly given the arbitrator's decision and a comment by the police chief about "younger officers." The court held that Smith presented enough circumstantial evidence to raise a triable question of whether the City terminated him due to his age. Additionally, the court found that the City's delay in reinstating Smith, which caused him to miss a promotion and a raise, could be seen as retaliatory.The Sixth Circuit reversed the district court's grant of summary judgment for the City and remanded the case for further proceedings, allowing Smith's claims of age discrimination and retaliation to proceed. View "Smith v. City of Union" on Justia Law

In February 2022, a Minneapolis SWAT team executed a no-knock search warrant at an apartment in search of a murder suspect. Inside, they found Amir Locke, the suspect’s cousin, asleep on a couch. Upon entry, officers kicked the couch and commanded Locke to get on the ground. Locke, wrapped in a blanket, fell to the ground and reached for a nearby handgun. Officer Hanneman ordered Locke to show his hands. Locke began to comply by lowering the gun's barrel and raising his left hand, but before he could fully comply, Hanneman shot Locke three times, resulting in Locke's death.Karen Wells and Andre Locke, co-trustees for Locke’s next of kin, filed a lawsuit against Officer Hanneman and the City of Minneapolis under 42 U.S.C. § 1983 and Minnesota’s wrongful death statute. They claimed Hanneman violated Locke’s Fourth Amendment rights and that the City failed to properly train its officers and address unconstitutional practices. Hanneman moved for judgment on the pleadings, asserting qualified immunity, arguing that body camera footage showed Locke posed a threat. The District Court for the District of Minnesota denied the motion, finding the footage did not clearly contradict the complaint’s allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined it lacked jurisdiction to decide the appeal. The court found that the body camera footage did not blatantly contradict the district court’s assumed facts that Locke did not raise the gun in a threatening manner. Consequently, the court dismissed the appeal, stating it could not address Hanneman’s qualified immunity claim or the City’s municipal liability and state-law claims. View "Wells v. Hanneman" on Justia Law

In May 2018, Raynaldo Sampy Jr. was arrested by seven officers from the Lafayette Police Department after driving into an ice cooler. During the arrest, Sampy was forcibly removed from his vehicle, handcuffed, and bent over a police car. He kicked Officer Rabb while being restrained, leading to his conviction for battery of a police officer in Lafayette City Court. Sampy later filed a lawsuit under 42 U.S.C. § 1983, alleging excessive force by the officers and retaliation for his speech.The United States District Court for the Western District of Louisiana dismissed Sampy’s Fourth Amendment excessive force claim, Fourth Amendment bystander liability claim, and First Amendment retaliation claim under Heck v. Humphrey, which bars claims that would imply the invalidity of a conviction. The court did not dismiss a claim regarding a third instance of alleged excessive force, which went to trial, and the jury found for the defendants. Sampy appealed the dismissal of the initial two uses of force.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The court held that Sampy’s excessive force claims were barred by Heck because they were not temporally and conceptually distinct from his battery conviction. The court found that the facts in Sampy’s complaint were inconsistent with those adjudicated in the criminal case. The court also held that Sampy’s bystander liability and First Amendment retaliation claims were barred by Heck. Consequently, the Fifth Circuit affirmed the district court’s judgment. View "Sampy v. Rabb" on Justia Law

Jose E. Amstutz, a police officer employed by Harris County Precinct 6, was terminated after his wife filed a police report alleging domestic abuse. Amstutz was placed on leave and later terminated following an internal investigation that found he violated several policies. Amstutz claimed his wife had a history of making false allegations and had informed his supervisors about this potential. After his termination, Amstutz struggled to find other law enforcement employment, which he attributed to the General Discharge noted in his F-5 report.The United States District Court for the Southern District of Texas dismissed Amstutz’s Age Discrimination in Employment Act (ADEA) claims for failure to exhaust administrative remedies and for not responding to the timeliness challenge. The court also dismissed his 42 U.S.C. § 1983 claims, finding that he had not pleaded a protected property interest in his at-will employment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal of the ADEA claims, agreeing that Amstutz failed to address the timeliness challenge, thus waiving opposition to that argument. The court also affirmed the dismissal of the § 1983 claims, concluding that Amstutz did not identify any independent source of law that would create a property interest in his employment. The court found that Amstutz’s employment was at-will and that he did not have a legitimate claim of entitlement to continued employment. Consequently, the court also dismissed Amstutz’s Monell claim against Harris County, as there was no underlying constitutional violation. The court affirmed the district court’s denial of leave to amend, finding no abuse of discretion. View "Amstutz v. Harris County" on Justia Law

Richard Walker was arrested at his girlfriend Ramona Paulette's residence, where he was staying overnight. Officers conducted a protective sweep of the residence and found a loaded firearm under the mattress in Walker Jr.'s bedroom. Later, with consent from Paulette's mother, Laverne Shipp, officers conducted a second search and found drugs in Paulette's bedroom. Walker was indicted for being a felon in possession of a firearm and possession with intent to distribute fentanyl. He moved to suppress the evidence, arguing the searches violated the Fourth Amendment.The United States District Court for the Southern District of Illinois denied Walker's motion to suppress, finding the protective sweep and subsequent search justified. Walker entered a conditional guilty plea, reserving the right to appeal the denial of his suppression motion. He was sentenced to 51 months' imprisonment and three years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Walker argued that the firearm and drugs were discovered through an unconstitutional search. The court found that Walker had standing to challenge the search and that the protective sweep was unlawful in scope when officers lifted the mattress in Walker Jr.'s bedroom. The court also determined that the district court erred in applying the attenuation exception to the exclusionary rule and did not address the inevitable discovery exception.The Seventh Circuit reversed the district court's denial of Walker's suppression motion and remanded the case for further proceedings to determine if the inevitable discovery exception applied and to reassess whether Shipp's consent justified the second search. View "United States v. Walker" on Justia Law