Justia Civil Rights Opinion Summaries

A suit seeking to represent a class of inmates at the “supermax” Tamms Correctional Center, alleging due process violations, was dismissed. The Seventh Circuit reversed. While remand was pending, the Illinois Department of Corrections developed a “Ten-Point Plan,” revising procedures for transferring inmates to Tamms, with a detailed transfer-review process. Although it had not been implemented, IDOC submitted the Plan at trial. The court held that conditions at Tamms impose atypical and significant hardship, establishing a due-process liberty interest in avoiding transfer to Tamms, and that procedures for transfer decisions were unconstitutional. The court entered an injunction incorporating the Ten-Point Plan. The Seventh Circuit vacated. The scope and specificity of the injunction exceed what is required to remedy the due process violation, contrary to the Prison Litigation Reform Act, 18 U.S.C. 3626(a)(1)(A), and to Supreme Court statements about remedial flexibility and deference to prison administrators in this type of litigation. Injunctive relief to remedy unconstitutional prison conditions must be “narrowly drawn,” extend “no further than necessary” to remedy the violation, and use the “least intrusive means” to correct the violation of the federal right. Making the Plan a constitutional baseline eliminated operational discretion and flexibility, exceeding what due process requires and violating the PLRA.

This case stemmed from a class action that began more than a quarter century ago where Idaho state prisoners at the Idaho State Correctional Institution (ISCI) prevailed on their claims that, inter alia, because of deliberate indifference, without any connection to a legitimate penological purpose, the inmates were subjected to needless pain and suffering on account of inadequate medical and psychiatric care. The district court issued an injunction to remedy the constitutional violations and the injunctions remained in effect in 2008 and 2009 when the facts giving rise to this case occurred. The Portland law firm of Stoel Rives, LLP was appointed to represent the prisoner class. At issue on appeal was whether Stoel Rives was entitled to an attorneys' fee award in the class action under the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e. The court held that, in this case, the judge had discretion to consider whether Stoel Rives's work on a motion to compel conformity to the injunction was "directly and reasonably incurred in enforcing the relief." The district court acted within the bounds of its discretion in awarding fees in a reasonable amount for bringing about that conformity with the injunction. Here, Stoel Rives's work was what one would expect of a lawyer working for a client that could afford its efforts but that was not indifferent to the cost. The firm showed no evidence of milking the case, and the fees were "directly and reasonably incurred." Accordingly, the court affirmed the judgment.

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings.

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services.

Plaintiff Bruce Roger Mills, individually and on behalf of those similarly situated, appealed a judgment that dismissed his claims against the City of Grand Forks to recover the amount of fines and fees collected in the past for noncriminal traffic violations by the City exceeding the amount the City could legally impose under state law. The City cross-appealed that judgment. In 2004, a Grand Forks police officer cited Plaintiff with careless driving. Under Grand Forks City Code, the maximum fine for violation of a noncriminal offense was $1,000 "in the discretion of the court." Plaintiff pled not guilty and proceeded to trial in municipal court. Plaintiff was found guilty. The municipal court imposed against Plaintiff "a fine in the amount of $151 with $0 suspended" and a hearing fee of $15. Plaintiff appealed to district court for a new trial; the court affirmed the conviction and the fine and fees totaling $166. Plaintiff appealed to the Supreme Court, but on December 1, 2004, the Court dismissed the appeal because the district court judgment was "not appealable under N.D.C.C. 39-06.1-03(5)." On August 16, 2010, Plaintiff brought a "Class Action Complaint for Restitution" in state district court seeking the amount of monies paid to Grand Forks exceeding the state law limits for fines for similar state offenses. Plaintiff asserted the excess fines, fees and charges were "involuntary and void." The City argued Plaintiff's claims were precluded by both res judicata and collateral estoppel based on the prior federal court action, and by res judicata because Mills failed to challenge the City's fine scheme in the 2004 state court proceedings. Because the district court correctly ruled Plaintiff's claims were thus barred by res judicata, the Supreme Court affirmed the judgment.

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction.

Main & Associates, Inc., d/b/a Southern Springs Healthcare Facility, filed an action in the Bullock Circuit Court, on behalf of itself and a putative class of Alabama nursing homes, against Blue Cross and Blue Shield of Alabama (BCBS), asserting claims of breach of contract, intentional interference with business relations, negligence and/or wantonness, and unjust enrichment and seeking injunctive relief. BCBS removed the case to the the federal court, arguing among other things, that Southern Springs' claims arose under the Medicare Act and that the Medicare Act, as amended by the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (the MMA) completely preempted Southern Springs' state-law claims. Southern Springs moved the federal court to remand the case to the circuit court, arguing that the federal court did not have jurisdiction over its claims. The federal court granted the motion and remanded the case to the Bullock Circuit Court. After remand, BCBS moved the circuit court for a judgment on the pleadings, arguing that Southern Springs had not exhausted its administrative remedies and that the circuit court did not have subject-matter jurisdiction over the case. The circuit court denied BCBS's motion, and BCBS petitioned the Supreme Court for a writ of mandamus to direct the circuit court to dismiss Southern Springs' claims. Upon review, the Court concluded that Southern Springs' claims were inextricably intertwined with claims for coverage and benefits under the Medicare Act and that they were subject to the Act's mandatory administrative procedures and limited judicial review. Southern Springs did not exhaust its administrative remedies, and the circuit court did not have jurisdiction over its claims. Therefore, the Court granted BCBS's petition and issue a writ of mandamus directing the circuit court to dismiss the claims against BCBS.

In 2003, the New Hampshire Department of Health and Human Services and a certified class of Medicaid-eligible children reached a settlement agreement and proposed a consent decree that outlined the Department's obligations to provide dental services to Medicaid-enrolled children in accordance with federal law. The district court approved the Decree in 2004. Between 2007 and 2010, the district court denied four motions alleging that the Department was not in compliance. The First Circuit affirmed, upholding the district court's requirement that the Class to file a motion for contempt to enforce the Decree; denial of a 2010 motion for contempt; denial of a request for an evidentiary hearing in 2010; and holding the Class to a clear and convincing burden of proof on its 2010 motion to modify or extend the Decree.

Appellants were arrested for speeding in excess of 30 mph above the posted speed limit and subsequently filed a class action on behalf of all individuals who have been arrested and subjected to criminal penalties for such speeding in the last three years. Appellants alleged that the district's traffic enforcement policies denied them the equal protection of law and thus violated the Fifth Amendment. Specifically appellants objected to the district's policy of subjecting motorists who speed in excess of 30 mph over the speed limit to different penalties, depending on how they were caught. The district court granted the district's motion to dismiss under Rule 12(b)(6). The court affirmed the district court's judgment, but on different grounds. The court held that appellants' claim lacked merit because their challenge could not survive rational basis review where the district's traffic policy neither burdened a fundamental right nor targeted a suspect class.

Appellants appealed the dismissal of their class action complaint against Nextel, the law firm of Leeds, Morelli & Brown, P.C. (LMB), and seven of LMB's lawyers (also LMB). Appellants were former clients of LMB who retained the firm to bring discrimination claims against Nextel. The complaint asserted that, inter alia, LMB breached its fiduciary duty of loyalty to appellants and the class by entering into an agreement with Nextel in which Nextel agreed to pay: (i) $2 million to LMB to persuade en masse its approximately 587 clients to, inter alia, abandon ongoing legal and administrative proceedings against Nextel, waive their rights to a jury trial and punitive damages, and accept an expedited mediation/arbitration procedure; (ii) another $3.5 million to LMB on a sliding scale as the clients' claims were resolved through that procedure; and (iii) another $2 million to LMB to work directly for Nextel as a consultant for two years beginning when the clients' claims had been resolved. The court held that appellants have alleged facts sufficient to state a claim against LMB for, inter alia, breach of fiduciary duty and against Nextel for aiding and abetting breach of fiduciary duty. Therefore, the court vacated and remanded for further proceedings.