Justia Civil Rights Opinion Summaries

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

The case involves two groups of Montgomery residents who were jailed for failing to pay traffic fines. They sued the City of Montgomery, a private contractor (Judicial Correction Services, Inc.), and a lawyer (Branch D. Kloess), alleging that the process of converting fines into jail sentences violated the U.S. Constitution and Alabama law. The plaintiffs sought to certify their claims as class actions, arguing that the City and its contractors systematically failed to conduct proper inquiries into their ability to pay before jailing them.The U.S. District Court for the Middle District of Alabama denied class certification in both cases. The court found that the plaintiffs failed to meet the requirements of Federal Rule of Civil Procedure 23, particularly the predominance and superiority requirements under Rule 23(b)(3). The court concluded that the claims would require individualized inquiries into each probationer's circumstances, such as whether they were given proper hearings and whether the City or its contractors acted wrongfully or in bad faith.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The appellate court affirmed the lower court's denial of class certification. It agreed that the plaintiffs' claims necessitated individualized proof, making it difficult to resolve the issues on a class-wide basis. The court emphasized that the evidence required to prove the claims, such as records of what happened at individual probation hearings, was not available on a common, class-wide basis. The court also noted that the plaintiffs' claims involved a variety of individual incidents rather than a single, systemic issue that could be addressed collectively.In summary, the Eleventh Circuit held that the district court did not abuse its discretion in denying class certification, as the plaintiffs' claims required individualized inquiries that did not satisfy the predominance requirement of Rule 23(b)(3). The decision to deny class certification was affirmed. View "Carter v. The City of Montgomery" on Justia Law

The case involves the city of Grants Pass, Oregon, and its laws restricting public camping. The city's laws prohibit activities such as camping on public property or parking overnight in the city’s parks. Violations can result in fines and, in the case of multiple violations, imprisonment. A group of homeless individuals filed a class action lawsuit against the city, arguing that these ordinances violated the Eighth Amendment's prohibition against cruel and unusual punishment. The district court agreed with the plaintiffs, citing a previous Ninth Circuit decision, Martin v. Boise, which held that cities cannot enforce public camping ordinances against homeless individuals when the number of homeless individuals exceeds the number of available shelter beds.The Ninth Circuit affirmed the district court's decision, leading to the city's appeal to the Supreme Court. The Supreme Court reversed the Ninth Circuit's decision, holding that the enforcement of laws regulating camping on public property does not constitute "cruel and unusual punishment" prohibited by the Eighth Amendment. The Court reasoned that the Eighth Amendment focuses on the punishment a government may impose after a criminal conviction, not on whether a government may criminalize particular behavior in the first place. The Court also noted that the punishments imposed by the city of Grants Pass, such as fines and temporary bans from public parks, did not qualify as cruel and unusual under the Eighth Amendment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "City of Grants Pass v. Johnson" on Justia Law

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

The case involves a group of former detainees at the Medium Security Institution (MSI) in St. Louis, who alleged that they were subjected to inhumane conditions in violation of the Eighth and Fourteenth Amendments. They sought to represent classes of pre-trial and post-conviction detainees, asserting that both categories of detainees were subjected to poor physical conditions and inadequate operations. After the district court denied their first motion to certify, the plaintiffs returned with new proposed classes and renewed their motion. The district court granted the renewed motion, and the City of St. Louis appealed.The district court had initially denied the plaintiffs' motion to certify four classes, citing the open-ended class periods and the City's undisputed improvements to conditions at MSI over time. However, the court suggested that a more focused claim covering a more discrete time period and a more uniform class might be appropriate for class certification. In response, the plaintiffs filed a renewed motion for class certification, proposing four new, more narrowly defined classes. The district court granted the renewed motion, certifying the four new classes.The City of St. Louis appealed the district court's decision to the United States Court of Appeals for the Eighth Circuit, challenging both the decision to certify the classes and several of its procedural aspects. The appellate court reversed the certification of the classes and remanded the case for further proceedings. The court found that the district court had abused its discretion in certifying the classes, as the classes were not "sufficiently cohesive to warrant adjudication by representation." The court also found that the district court had erred in describing the standard for liability and had failed to conduct a rigorous analysis of the requirements for class certification. View "Cody v. City of St. Louis" on Justia Law

The case involves Quintin Scott, a former pretrial detainee at the Cook County Jail, who filed a class action lawsuit against Cook County and its sheriff. Scott alleged that the county provided him and other pretrial detainees with inadequate dental care, violating the Fourteenth Amendment. The district court refused to certify the class, and Scott settled his individual claim but reserved his right to appeal the class ruling and to seek an incentive award for his role as the named plaintiff.The County argued that Scott lacked standing to pursue the class aspects of the case, contending that he no longer had a live interest in the litigation and that courts were forbidden from granting incentive awards. The United States Court of Appeals for the Seventh Circuit disagreed, finding that Scott had standing and that incentive awards were permissible. The court also concluded that the district court had abused its discretion in denying class certification, as it had misapplied a previous decision and used too strict a standard.The Court of Appeals vacated the district court's order and remanded the case for further proceedings, noting that the district court was free to revise the class definition as needed to address any overbreadth issues. The court also noted that the district court had not addressed whether the proposed class met the requirements of numerosity and adequacy of representation, which must be satisfied before the class can be certified. View "Scott v. Dart" on Justia Law

The case involves a class action lawsuit brought against the Illinois Department of Corrections (IDOC) by four parents who were convicted of sex offenses and were on mandatory supervised release (MSR). The plaintiffs challenged an IDOC policy that restricts contact between a parent convicted of a sex offense and their minor child while the parent is on MSR. The plaintiffs argued that this policy violates their Fourteenth Amendment rights to procedural and substantive due process.The district court upheld the policy, with two exceptions. It ruled that the policy's ban on written communications was unconstitutional and that IDOC must allow a parent to submit a written communication addressed to their child for review and decision within seven calendar days. The plaintiffs appealed, challenging the policy's restrictions on phone and in-person contact.The United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part. The court agreed with the district court that the policy does not violate procedural due process. However, it held that the policy's ban on phone contact violates substantive due process. The court found that call monitoring is a ready alternative to the phone-contact ban that accommodates the plaintiffs’ right to enjoy the companionship of their children at a de minimis cost to IDOC’s penological interests. View "Montoya v. Jeffreys" on Justia Law

A group of current and former inmates, or their representatives, filed a class action lawsuit against Kate Brown, the Governor of Oregon, and Patrick Allen, the Director of the Oregon Health Authority, claiming that the state's COVID-19 vaccine rollout plan, which prioritized corrections officers over inmates, violated their Eighth Amendment rights. The defendants moved to dismiss the claim, asserting immunity under the Public Readiness and Emergency Preparedness (PREP) Act. The district court denied the motion, and the defendants appealed.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision, finding that the defendants were immune from liability for the vaccine prioritization claim under the PREP Act. The court held that the statutory requirements for PREP Act immunity were met because the "administration" of a covered countermeasure includes prioritization of that countermeasure when its supply is limited. The court further concluded that the PREP Act's provisions extend immunity to persons who make policy-level decisions regarding the administration or use of covered countermeasures. The court also held that the PREP Act provides immunity from suit and liability for constitutional claims brought under 42 U.S.C. § 1983, even if those claims are federal constitutional claims. View "MANEY V. BROWN" on Justia Law

In 2015, a group of parents brought a class action lawsuit on behalf of their children, who were enrolled in Minneapolis and Saint Paul public schools. The parents claimed that the state of Minnesota violated their children's right to an adequate education under the Education Clause of the Minnesota Constitution due to the racial and socioeconomic segregation present in the schools. The case went through several years of litigation, and the district court certified a question for immediate appeal: whether racial imbalances in Minneapolis and Saint Paul public schools are sufficient, standing alone, to establish a violation of the Education Clause. The Minnesota Supreme Court reformulated the certified question and held that racial imbalances in Minneapolis and Saint Paul public schools, standing alone, are not sufficient to establish a violation of the Education Clause. The court ruled that while the parents do not have to establish that state action caused the racial imbalances, they must show that the racial imbalances are a substantial factor in causing their children to receive an inadequate education. The case was remanded back to the district court for further proceedings. View "Cruz-Guzman, as guardian and next friend of his minor children vs. State of Minnesota" on Justia Law

In a class action suit brought by George Mandala and Charles Barnett against NTT Data, Inc., the plaintiffs argued that NTT's policy of not hiring individuals with a felony conviction disproportionately impacted Black applicants, constituting disparate impact discrimination under Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed the plaintiffs' complaint, and that decision was affirmed by the United States Court of Appeals for the Second Circuit. The plaintiffs then filed a motion to vacate the dismissal judgment and sought leave to file a first amended complaint, which the district court denied as untimely under Federal Rule of Civil Procedure 60(b)(1).On appeal, the Second Circuit reversed the district court's decision, holding that the plaintiffs' motion should have been evaluated under Rule 60(b)(6) rather than Rule 60(b)(1). Rule 60(b)(6) allows for relief from a judgment under "extraordinary circumstances," which the court found to be present in this case. The court reasoned that the plaintiffs had not previously had a chance to amend their complaint, and that their decision to stand by their initial complaint was not unreasonable given that its sufficiency had been a point of dispute. Additionally, the court found that the proposed amendments to the complaint were not futile. Consequently, the Second Circuit ordered the case to be remanded to the district court for further proceedings consistent with its opinion. View "Mandala v. NTT Data, Inc." on Justia Law