Justia Civil Rights Opinion Summaries

Raunona Mays, an African American woman employed as a Sergeant with the Arkansas Highway Police, applied for four promotions between 2022 and 2023 but was denied each time. She alleges that less qualified Caucasian males or individuals with less experience and education received the positions. After filing an internal grievance regarding one promotion and receiving no relief, Mays filed an Equal Employment Opportunity Commission (EEOC) complaint alleging race and sex discrimination, as well as retaliation. The EEOC dismissed her charge and issued a right-to-sue letter, after which Mays brought suit seeking damages, a promotion, and injunctive relief.The Pulaski County Circuit Court denied the Arkansas Highway Police’s motion to dismiss, which was based on sovereign immunity. The agency argued that it could not be sued under the United States Constitution and federal statutes, as well as the Arkansas Civil Rights Act, because it is protected by sovereign immunity. The circuit court rejected this argument, allowing all claims to proceed.The Supreme Court of Arkansas reviewed the appeal and held that Mays’s claims under 42 U.S.C. § 1983, 42 U.S.C. § 1981, and the Arkansas Civil Rights Act could not proceed against the state agency because the agency is not considered a “person” under these statutes and is protected by sovereign immunity. The court reversed and remanded those claims for dismissal. However, the court determined that claims under Title VII of the Civil Rights Act of 1964 are not barred by sovereign immunity when brought against a state agency, and that Mays had pleaded sufficient facts to state a Title VII claim. The decision of the Pulaski County Circuit Court was affirmed as to the Title VII claim but reversed and remanded for dismissal of the other claims. View "ARKANSAS HIGHWAY POLICE v. MAYS" on Justia Law

After a long-term romantic relationship began to deteriorate between Elijah Singleton and Ja’Keya Hampton, Singleton stole Hampton’s cellphone and refused to return it. The day before Hampton’s death, the two communicated via Facebook Messenger, arranging to meet so Singleton could return the phone. Hours later, Hampton was found dead in her car from a gunshot wound. Surveillance footage captured the shooting, with audio indicating Hampton called out to Singleton moments before being shot. After the incident, Singleton attempted to elude law enforcement and destroy evidence, but was arrested following a standoff. He was charged with capital murder and a firearm enhancement.During jury selection in the Crittenden County Circuit Court, a prospective juror who worked at the county jail expressed concerns about a conflict of interest in open court, prompting Singleton to move for a mistrial, which was denied. The State exercised peremptory strikes against four Black prospective jurors. Singleton raised a Batson challenge, arguing the strikes were racially motivated. The State provided race-neutral reasons, such as relationships with the victim’s family, perceived reluctance to serve, and inattentiveness. The circuit court credited the State’s reasons, found them race-neutral, and denied the Batson challenge. Singleton was convicted of first-degree murder and employing a firearm, and sentenced as a habitual offender.On appeal, the Supreme Court of Arkansas reviewed Singleton’s claims that the circuit court erred in denying his mistrial motion and his Batson challenge. The court held there was no abuse of discretion in denying the mistrial because the prospective juror’s statement did not prejudice the jury. It further held that the circuit court’s findings regarding the Batson challenge were not clearly against the preponderance of the evidence. The Supreme Court of Arkansas affirmed the convictions. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

The plaintiff, David John Campbell, brought suit under 42 U.S.C. § 1983 against Broome County, the City of Binghamton, various officials and employees, and an unnamed New York State Police Trooper. He alleged that his rights under the Fourth and Fourteenth Amendments were violated in a series of incidents beginning in May 2022, related to his efforts to maintain or regain possession of firearms that he claimed he was licensed to possess. Specifically, Campbell described interactions with local law enforcement concerning the surrender and non-return or damage of his firearms, a traffic stop that he claimed was undocumented, and two police entries into his home in January 2023, during which firearms and other items were allegedly seized.The United States District Court for the Northern District of New York dismissed Campbell’s amended complaint sua sponte under 28 U.S.C. § 1915(e), finding the allegations factually frivolous. The district court also ruled, in the alternative, that the complaint failed to allege the personal involvement of certain individual defendants and did not contain sufficient facts to support municipal liability under Monell v. Department of Social Services. The court denied Campbell leave to further amend his complaint.On appeal, the United States Court of Appeals for the Second Circuit affirmed most of the district court’s dismissal, agreeing that the majority of Campbell’s claims were frivolous, that there were insufficient allegations of personal involvement for most individual defendants, and that the municipalities could not be held liable. However, the Second Circuit vacated and remanded the dismissal of Campbell’s Fourth Amendment claim against Officer Nicholas Mushalla, finding that the allegations regarding Mushalla’s search of Campbell’s home and seizure of property on January 13, 2023, were sufficient to state a claim. In all other respects, the judgment was affirmed. View "Campbell v. Broome County" on Justia Law

A public hospital district in California established and recorded covenants, conditions, and restrictions (CC&Rs) in 1991 for a common interest development known as the Tulare Medical Center. These CC&Rs included a prohibition on abortion clinics within the development. In 2001, certain property subject to these CC&Rs was transferred to individual owners, who later sought to lease it to a family planning organization that provides a range of services, including abortion. The property owners association, comprised of all parcel owners and authorized to enforce the CC&Rs, objected to the lease and sought to enjoin the operation of the clinic, arguing that any abortion services would violate the CC&Rs.The Superior Court of Tulare County reviewed the association’s request for a preliminary injunction. After considering the parties’ submissions and arguments, the court denied the injunction. The court found there was a credible threat that abortion services would be provided but concluded the association had not shown a likelihood of prevailing on the merits. Specifically, the trial court noted unresolved legal questions regarding whether restrictions on abortion clinics in CC&Rs violated the Unruh Civil Rights Act or California constitutional protections, and found the association failed to demonstrate that the balance of harms favored an injunction.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that the prohibition on abortion clinics, adopted by a public entity, constituted government action that interfered with the fundamental constitutional right to reproductive choice under the California Constitution. The court applied the compelling interest test, found no compelling interest justifying the restriction, and concluded the prohibition violated fundamental public policy. Additionally, the court held that the prohibition was void under Civil Code section 53 because it indirectly limited property use based on a characteristic protected by the Unruh Act. The order denying the preliminary injunction was affirmed. View "Tulare Medical Center Property v. Valdivia" on Justia Law

Two men approached a van in a Denny’s parking lot in Los Angeles in the early morning hours of December 19, 1981. One of the men, holding a gun, demanded valuables from the occupants, Toney Lewis and Carolyn Spence. After robbing them, the gunman shot Lewis, who died from the wound. At trial, there was conflicting eyewitness identification as to whether the defendant or his brother was the shooter. An accomplice, who testified in exchange for a plea deal, stated that the defendant was the gunman and shot Lewis. Other witnesses recounted statements by the defendant suggesting his brother was not the killer and that he was the one who shot Lewis.The defendant was convicted in the Superior Court of Los Angeles County of murder, robbery, and attempted robbery, with the jury finding true that a principal was armed with a firearm but not true that the defendant personally used a firearm or that the robbery special circumstance (which, as instructed, required the defendant to have personally killed the victim) applied. On direct appeal, the California Court of Appeal affirmed the conviction. Subsequently, the defendant petitioned for resentencing under Penal Code section 1172.6 (formerly 1170.95), which provides relief for certain felony-murder convictions. The resentencing court initially denied relief, finding the defendant aided and abetted the murder. The Court of Appeal reversed and remanded, instructing reconsideration under the theories that the defendant was either the actual killer or a major participant acting with reckless indifference.In the most recent proceeding, the California Court of Appeal, Second Appellate District, Division One, held that the jury’s not-true findings on the firearm enhancement and special circumstance did not preclude the resentencing court from finding the defendant was the actual killer. The court found substantial evidence supported that finding and affirmed the denial of resentencing. View "People v. Player" on Justia Law

The case centers on Kenny Faulk, a Black man, who was conditionally offered a sales position by Dimerco Express USA, a transportation company. The offer was rescinded after the company’s president learned of Faulk’s race, despite Faulk successfully passing a background check that revealed only a prior misdemeanor conviction. Internal communications and testimony showed that Dimerco’s leadership, particularly its president, maintained a policy of hiring only white individuals for sales positions and had rejected non-white applicants for this reason. Faulk later learned that a white applicant with a more significant criminal history was hired for a similar position, and after discovering the discriminatory policy, he filed suit against Dimerco for racial discrimination under 42 U.S.C. § 1981.The United States District Court for the Northern District of Georgia presided over the trial. At trial, Dimerco sought to introduce evidence of Faulk’s unrelated 2019 arrest to undermine his emotional distress claim, but the district court ultimately excluded this evidence, finding it minimally relevant and highly prejudicial. The jury returned a verdict for Faulk, awarding him $90,000 in lost wages, $300,000 in emotional distress damages, and $3 million in punitive damages. Dimerco moved for a new trial, arguing that misconduct by Faulk’s counsel and evidentiary errors required one, or alternatively, for remittitur of the damages as excessive. The district court denied these motions.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The court held that any misconduct by Faulk’s counsel was effectively cured by the district court’s instructions and did not deprive Dimerco of a fair trial. The evidentiary rulings were not erroneous or, if so, were harmless. The compensatory and punitive damages were supported by the evidence and not unconstitutionally excessive. The judgment in Faulk’s favor was affirmed in all respects. View "Faulk v. Dimerco Express USA Corp." on Justia Law

After his wife disappeared in May 2020, the plaintiff became the primary suspect in her case. Significant evidence was collected, and law enforcement focused on the possibility that he had staged the scene to make it appear as an abduction. Despite his consistent claims of innocence and multiple meetings with investigators, prosecutors charged him with first-degree murder in May 2021, even though his wife's body had not been found. Before trial, the defense discovered that prosecutors had withheld exculpatory evidence, leading the State to dismiss charges without prejudice. The plaintiff then filed a federal civil rights lawsuit against various officials involved in his arrest and prosecution, alleging fabrication of evidence, conspiracy, malicious prosecution, and related claims.The United States District Court for the District of Colorado reviewed the complaint, the lengthy arrest affidavit, and the parties' arguments. It granted the defendants' motions to dismiss under Rule 12(b)(6), finding that the plaintiff’s allegations failed to plausibly allege an absence of probable cause for his arrest and prosecution. The court noted the presence of extensive inculpatory facts and determined that the complaint did not sufficiently link individual defendants to the alleged misconduct. Certain claims were also dismissed as conclusory, and some defendants were found to have immunity. The court declined to exercise supplemental jurisdiction over the remaining state law claims.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal. The Tenth Circuit held that the plaintiff’s federal claims for malicious prosecution, fabrication of evidence under the Fourth Amendment, Franks violations, conspiracy, failure to intervene, and municipal liability all required plausible allegations that probable cause was lacking, which the complaint did not provide. The court also found the Fourteenth Amendment claims for fabrication of evidence and reckless investigation deficient due to lack of causal allegations. The judgment of dismissal was affirmed. View "Morphew v. Chaffee County" on Justia Law

A New York citizen brought suit in federal court against a federally chartered corporation headquartered in Washington, D.C., alleging disability discrimination under New York law. The plaintiff invoked diversity jurisdiction under 28 U.S.C. § 1332, arguing that the defendant should be considered a citizen of the District of Columbia based on its principal place of business, even though it was not incorporated under the laws of any state.In the United States District Court for the Eastern District of New York, the defendant moved to dismiss for lack of subject matter jurisdiction, asserting that federally chartered corporations are not citizens of any state for diversity purposes absent unusual circumstances. The plaintiff initially argued for a judge-made expansion of diversity jurisdiction but later abandoned this theory in favor of a statutory argument based on § 1332(c)(1). The district court dismissed the complaint, finding that diversity jurisdiction was not established because the statute does not extend state citizenship to federally chartered corporations. The court also denied the plaintiff’s post-judgment motions for reconsideration and to reopen the case to pursue possible federal claims.On appeal, the United States Court of Appeals for the Second Circuit held that § 1332(c)(1) applies only to corporations incorporated by a state or foreign state, not to federally chartered corporations. The court reasoned that the statute’s principal-place-of-business provision does not operate independently of the state-of-incorporation provision, and Congress did not intend to expand diversity jurisdiction to reach federally chartered corporations generally. The Second Circuit affirmed the district court’s dismissal for lack of subject matter jurisdiction and its refusal to reconsider or reopen the case. View "Schneiderman v. American Chemical Society" on Justia Law

A former member of a city council in Brecksville, Ohio, who owned a roofing company, participated in several council votes related to the construction of a new police station. His company was selected as the roofing subcontractor for the project, but he did not disclose his financial interest to the council. After his ownership came to light through the mayor’s review of project documents, the mayor and the city law director reported his actions to the Ohio Ethics Commission. The Ethics Commission investigated and ultimately referred the matter to the Cuyahoga County Prosecutor, resulting in a grand jury indictment on charges of unlawful interest in a public contract. The councilmember was acquitted after a bench trial. He alleged that the city officials had initiated the ethics complaint in retaliation for his public criticism of the council’s handling of a separate debt issue and that the officials had made false statements or omitted material facts in their communications with the Ethics Commission.The United States District Court for the Northern District of Ohio granted summary judgment to the individual officials and the city on all claims. On appeal, the plaintiff limited his arguments to his claims under 42 U.S.C. § 1983 for retaliatory prosecution and malicious prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s judgment. The court held that the grand jury indictment established a presumption of probable cause that the plaintiff was unable to rebut. The court found that, because the plaintiff voted on ordinances advancing the contract in which he had a financial interest, he could not invoke the relevant statutory affirmative defense. Additionally, the court ruled that the exception in Lozman v. City of Riviera Beach, 585 U.S. 87 (2018), did not apply, as the facts and legal context differed. The Sixth Circuit therefore affirmed the dismissal of all claims. View "Petsche v. Hruby" on Justia Law

Two former police officers sued their employer, the Puerto Rico Police Department, alleging illegal retaliation after one reported age discrimination to the Equal Employment Opportunity Commission and the other testified in support. The plaintiffs claimed that, as a result, they suffered adverse employment actions such as dangerous shift changes, loss of duties, and fabricated complaints. The challenged conduct primarily occurred after Puerto Rico filed for financial reorganization under PROMESA, a federal statute enacted in response to the Commonwealth’s fiscal crisis.The United States District Court for the District of Puerto Rico presided over the case while Puerto Rico’s reorganization plan was pending in the Title III court. After the reorganization plan’s "Effective Date" passed, and while the plaintiffs’ suit was ongoing, the Department asserted that the claims had been discharged under the plan because the plaintiffs had not timely filed proofs of claim. The District Court agreed, permanently stayed the case, and enjoined the plaintiffs from pursuing their claims, finding that the claims must have arisen at least in part before the plan’s Effective Date since the suit was filed prior to that date. The District Court did not address the plaintiffs' judicial estoppel argument or their contention that post-petition claims were not dischargeable.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment, but on different grounds. The appellate court held that the plaintiffs’ retaliation claims qualified as administrative expense claims under PROMESA (via incorporation of the Bankruptcy Code), and because the plaintiffs did not timely file such claims before the administrative claims bar date, they were discharged by the plan. The court also rejected the plaintiffs' judicial estoppel argument, finding no inconsistency in the Department’s litigation positions. The First Circuit’s judgment affirmed the permanent stay and injunction. View "Villalobos-Santana v. PR Police Department" on Justia Law