Justia Civil Rights Opinion Summaries

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

A group of nine individuals, representing a putative class, alleged that a credit union systematically discriminated against racial minorities in its residential mortgage lending practices. The plaintiffs varied in racial background (eight Black, one Latino), state of residence, type of loan product sought, and financial circumstances. Despite these differences, they claimed the credit union used a single, semi-automated underwriting process for all applicants, which, through its proprietary algorithm, resulted in discriminatory outcomes against minority applicants. The complaint sought both damages and injunctive relief, and proposed a class consisting of all minority applicants for mortgage-related products from 2018 to the present who faced adverse actions compared to similarly situated non-minority applicants.The United States District Court for the Eastern District of Virginia partially granted the defendant’s motion to dismiss and struck the class allegations, relying on Federal Rules of Civil Procedure 12(f) and 23(d)(1)(D). The district court focused on the diversity of the plaintiffs’ circumstances, suggesting that the variations in loan types and applicant characteristics defeated the possibility of class certification, particularly under Rule 23(b)(3).On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit addressed the standards governing class certification denials at the pleading stage before discovery. The Fourth Circuit held that district courts should only deny class certification at this stage if, on the face of the complaint, the Rule 23 requirements are not met as a matter of law. The appellate court affirmed the district court’s denial of class certification under Rule 23(b)(3), finding the lack of predominance and superiority apparent from the complaint due to the differences among the plaintiffs. However, the Fourth Circuit vacated the district court’s order as to Rule 23(b)(2), concluding that the complaint sufficiently alleged commonality for classwide declaratory and injunctive relief, and that the district court acted prematurely in denying certification under that provision. View "Oliver v. Navy Federal Credit Union" on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law

Ryan O’Donnell and Michael Goree each had their vehicles disposed of by the City of Chicago after failing to pay multiple traffic tickets. The City acted under a municipal code provision that allows for immobilization, towing, and eventual disposition of vehicles registered to owners with outstanding violations. O’Donnell’s vehicle was sold to a towing company at scrap value; Goree’s vehicle was relinquished to a lienholder. Neither was compensated or had proceeds offset against their ticket debt.After these events, O’Donnell and Goree filed a putative class action in the United States District Court for the Northern District of Illinois, Eastern Division. Their complaint alleged that the City’s forfeiture scheme was facially unconstitutional under the Fifth Amendment’s Takings Clause and the Illinois constitution, and included a state-law unjust enrichment claim. They also asserted a Monell claim against the towing company, URT United Road Towing, Inc. The district court dismissed all claims for failure to state a claim, finding that the vehicle forfeiture under the traffic code was not a taking.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that the City’s graduated forfeiture scheme is an exercise of its police power to enforce traffic laws rather than a taking for public use. The court reasoned that this type of law enforcement forfeiture does not trigger the Takings Clause of either the federal or Illinois constitutions. The court further found that because there was no constitutional violation, the plaintiffs’ Monell and unjust enrichment claims also failed. The Seventh Circuit affirmed the district court’s dismissal of all claims. View "O'Donnell v City of Chicago" on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law

Several individuals, representing a class, challenged a health insurance company’s refusal to cover gender-affirming care for transgender individuals diagnosed with gender dysphoria. The company, acting as a third-party administrator for employer-sponsored, self-funded health plans, denied coverage for such treatments based on explicit plan exclusions requested by the employer sponsors. Some plaintiffs also alleged that they were denied coverage for treatments that would have been covered for other diagnoses, such as precocious puberty, but were denied solely because of the concurrent diagnosis of gender dysphoria.The United States District Court for the Western District of Washington certified the class and granted summary judgment in favor of the plaintiffs. The district court rejected the company’s arguments that it was not subject to Section 1557 of the Affordable Care Act because its third-party administrator activities were not federally funded, that it was merely following employer instructions under ERISA, and that it was shielded by the Religious Freedom Restoration Act (RFRA). The district court also found that the exclusions constituted sex-based discrimination under Section 1557.On appeal, the United States Court of Appeals for the Ninth Circuit agreed with the district court that the company is subject to Section 1557, that ERISA does not require administrators to enforce unlawful plan terms, and that RFRA does not provide a defense in this context. However, the Ninth Circuit held that the district court’s analysis of sex-based discrimination was undermined by the Supreme Court’s intervening decision in United States v. Skrmetti, which clarified the application of sex discrimination standards to exclusions for gender dysphoria treatment. The Ninth Circuit vacated the summary judgment and remanded the case for further proceedings to consider whether, under Skrmetti, the exclusions at issue may still constitute unlawful discrimination, particularly in cases involving pretext or proxy discrimination or where plaintiffs had other qualifying diagnoses. View "PRITCHARD V. BLUE CROSS BLUE SHIELD OF ILLINOIS" on Justia Law

A plaintiff who lost his job during the COVID-19 pandemic applied for and received regular unemployment benefits from the Washington State Employment Security Department (ESD). After exhausting those benefits, he applied for and received additional benefits under the federally funded Pandemic Emergency Unemployment Compensation (PEUC) program, created by the CARES Act. Following an audit, ESD redetermined his eligibility, reduced his weekly benefit, and assessed overpayments, sending him multiple, confusing notices with inconsistent information and deadlines. While the plaintiff appealed, ESD began offsetting his ongoing PEUC benefits to recover the alleged overpayments.An administrative law judge later found that ESD’s notices failed to provide adequate explanation or legal basis for the benefit reductions and overpayment assessments, and ordered ESD to issue a new redetermination. ESD reimbursed the plaintiff for the offset amounts, but its system continued to show a balance owed. The plaintiff, on behalf of himself and similarly situated individuals, filed a putative class action in the United States District Court for the Western District of Washington, alleging deprivation of property without due process under the Fourteenth Amendment and the Social Security Act. The district court held that while the plaintiff had a property interest in regular unemployment benefits, he did not have a constitutionally protected property interest in PEUC benefits, because state participation in the PEUC program was voluntary and could be terminated at any time.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s ruling. The Ninth Circuit held that the CARES Act’s PEUC program, once a state opted in, created a constitutionally protected property interest in PEUC benefits for eligible individuals. The Act’s mandatory language and objective eligibility criteria significantly constrained state discretion, giving rise to legitimate claims of entitlement. The case was remanded for further proceedings. View "STERLING V. FEEK" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law