Justia Civil Rights Opinion Summaries

Greater Birmingham Ministries (“GBM”), an Alabamian non-profit organization dedicated to aiding low-income individuals, and several Alabamian felons (collectively “Appellants”) appealed the district court’s summary judgment denying their Equal Protection Clause challenge to Amendment 579 of the Alabama state constitution, their Ex Post Facto Clause, challenge to Amendment 579’s disenfranchisement provisions, and their National Voting Registration Act of 1993 (“NVRA”), challenge to the format of Alabama’s mail voting registration form.The Eleventh Circuit affirmed. The court held that (1) Amendment 579 successfully dissipated any taint from the racially discriminatory motives behind the 1901 Alabama constitution; (2) Amendment 579 does not impose punishment for purposes of the Ex Post Facto Clause; and (3) Alabama’s mail voting registration form complies with the NVRA. The court wrote that it rejects Appellants’ invitation to review the extent the Alabama legislature debated the “moral turpitude” language of Amendment 579. Further, the court explained that Section 20508(b)(2)(A) is a notice statute enacted for the convenience of voting registrants. Alabama’s mail-in voting form has provided sufficient notice by informing registrants that persons convicted of disqualifying felonies are not eligible to vote and providing an easily accessible link whereby voters convicted of felonies can determine their voter eligibility. Accordingly, Alabama has complied with the requirements of Section 20508(b)(2)(A). View "Treva Thompson, et al. v. Secretary of State for the State of Alabama, et al." on Justia Law

Plaintiff, a former New York State prisoner, sued defendants-appellants pursuant to 42 U.S.C. Section 1983 for purportedly violating his rights under the Eighth and Fourteenth Amendments when they denied his judicially ordered enrollment in New York's Shock Incarceration Program, thereby potentially extending his period of confinement. The district court denied the motion for judgment on the pleadings, holding that Plaintiff plausibly alleged that Defendants were not entitled to qualified immunity because they violated clearly established law.   The Second Circuit affirmed the district court's denial of Defendants' motion for judgment on the pleadings as to the Fourteenth Amendment claim, reversed the district court's denial of Defendants' motion for judgment on the pleadings as to the Eighth Amendment claim, and remanded for further proceedings. The court explained that Plaintiff’s Eighth Amendment claim fails at the second prong of the qualified immunity analysis: it was not clearly established at the time of Defendants' conduct that denying a prisoner the opportunity to obtain early release from his sentence of confinement by denying judicially ordered entry into the Shock program would violate the Eighth Amendment. Moreover, the court held that given the liberty interest at stake and the clarity of the statutory law, Plaintiff plausibly alleged that Defendants' actions were egregious, shocking to the conscience, and unreasonable. View "Michael Matzell v. Anthony J. Annucci et al." on Justia Law

Plaintiff opposed a new collective-bargaining agreement that passed by a 119-vote margin. Plaintiff sued the union for breach of its duty of fair representation and a violation of the Labor-Management Reporting and Disclosure Act. At their core, these claims are about whether the union hoodwinked members into ratifying the new collective-bargaining agreement by concealing what would happen to the 30-and-out benefit. The district court dismissed the Labor-Management Reporting and Disclosure Act claim, denied Plaintiff’s motion for class certification, and granted summary judgment to the union on the fair-representation claim. On appeal, Plaintiff alleged that the union concealed key information, but only nine members said it would have made a difference.   The Eighth Circuit affirmed, holding that Plaintiff failed to provide other evidence that the outcome of the vote would have changed. The court reasoned that the ratification vote was overwhelmingly in favor: 228 to 109, a 119-vote margin. Plaintiff offers only nine members who would have voted “no” if they had known about the elimination of the 30-and-out benefit. Even assuming each would have voted the way he thinks, the agreement still would have passed by a wide margin. The court wrote that no reasonable jury could conclude that the union’s alleged bad-faith conduct was the but-for cause of the union’s ratification of the collective-bargaining agreement. View "Matthew Nagel v. United Food and Com. Workers" on Justia Law

Plaintiff filed a class action against Defendants Amazon.com Services, Inc. and Amazon.com, Inc., alleging that Defendants’ failure to compensate employees for time spent waiting for and passing through mandatory security screening before and after work shifts and breaks violates Oregon’s wage and hour laws. The district court granted judgment on the pleadings to Defendants, and Plaintiff timely appealed.   The Ninth Circuit affirmed the district court’s judgment on the pleadings in favor of Defendants. The panel had certified the following issue to the Oregon Supreme Court: “Under Oregon law, is time that employees spend on the employer’s premises waiting for and undergoing mandatory security screenings compensable?” In response, the Oregon Supreme Court held that Oregon law aligns with federal law regarding what activities are compensable. Therefore, time that employees spend on the employer’s premises waiting for and undergoing mandatory security screenings before or after their work shifts is compensable only if the screenings are either (1) an integral and indispensable part of the employees’ principal activities, or (2) compensable as a matter of contract, custom, or practice. Plaintiff’s complaint did not allege that either of the identified exceptions applied. Accordingly, the panel held that the district court properly granted judgment on the pleadings to Defendants. View "LINDSEY BUERO V. AMAZON.COM SERVICES, INC., ET AL" on Justia Law

The case at issue began in 1994 when Plaintiffs sued the California Department of Corrections and Rehabilitation and the Governor (collectively, “Defendants”), alleging widespread violations of the Americans with Disabilities Act and the Rehabilitation Act (collectively “ADA”). The district court concluded that California prisons were failing to provide legally required accommodations, and this court affirmed. In these appeals, Defendants challenged two orders in which the district court found ongoing violations of disabled prisoners’ rights at the R.J. Donovan Correctional Facility (“RJD”) and at five additional prisons (“Five Prisons”) resulting from Defendants’ failure to investigate adequately and discipline staff misconduct. The district court entered injunctions requiring Defendants to adopt additional remedial measures at the six prisons.   The Ninth Circuit affirmed one district court order, and affirmed in part and vacated in part a second district court order. The panel first rejected Defendants’ threshold contention that the district court did not have authority to issue either of the orders because the orders addressed misconduct that was “categorically distinct” from the allegations of wrongdoing in the Complaint. The panel determined that the new allegations in the motions at issue here were closely related to those in the operative Complaint and alleged misconduct of the same sort—that Defendants failed to accommodate class members’ disabilities, in direct contravention of the ADA. The panel affirmed the particular provisions of each order that address the prisons’ investigatory and disciplinary failures. The panel concluded that the district court abused its discretion by ordering Defendants to reform their pepper-spray policies at the Five Prisons and vacated that portion of the order. View "JOHN ARMSTRONG, ET AL V. GAVIN NEWSOM, ET AL" on Justia Law

The Air Force ordered over 500,000 service members to get COVID-19 vaccinations. About 10,000 members requested religious exemptions; about 135 of these requests were granted, only to those planning to leave the service. It has granted thousands of exemptions for medical or administrative reasons. The Plaintiffs allege that the vaccine mandate substantially burdens their religious exercise in violation of the First Amendment and the Religious Freedom Restoration Act (RFRA). The district court granted a preliminary injunction that barred the Air Force from disciplining the Plaintiffs for failing to take a vaccine, then certified a class of thousands of similar service members and extended this injunction to the class.The Sixth Circuit affirmed. In opposing class-action certification, the Air Force argued that RFRA adopts an individual-by-individual approach: it must show that it has a compelling interest in requiring a “specific” individual to get vaccinated based on that person’s specific duties. In challenging the injunction, however, the Air Force failed to identify the specific duties or working conditions of any Plaintiff, citing the “general interests” underlying the mandate. The court reasoned that it could uphold the injunction based on RFRA alone but also noted common questions for the class: Does the Air Force have a uniform policy of relying on its generalized interests in the vaccine mandate to deny religious exemptions regardless of individual circumstances? Does it have a discriminatory policy of broadly denying religious exemptions but broadly granting secular ones? View "Doster v. Kendall" on Justia Law

Bennett contends that Division 10 of Cook County Jail does not satisfy the Americans with Disabilities Act and the Rehabilitation Act because it lacks grab bars and other fixtures that disabled inmates need in order to use showers and toilets safely. Bennett cited a regulation providing that as of 1988, "construction[] or alteration of buildings” must comply with the Uniform Federal Accessibility Standards (UFAS), 28 C.F.R. 42.522(b)(1). UFAS requires accessible toilets with grab bars nearby and accessible showers with mounted seats, Division 10 was constructed in 1992.In 2020, the Seventh Circuit reversed the denial of class certification, stating that Bennett “proposes a class that will win if the Standards apply (and were violated, to detainees’ detriment).” On remand, the district court certified a class. More than two years later, the judge decertified the class, reasoning that some class members, although using aids such as wheelchairs, may not be disabled under the statutes.The Seventh Circuit again reversed. The 2020 decision identified an issue relevant to every Division 10 detainee. Class certification under Rule 23(c)(4) resolves the issue, not the whole case. Class members could receive the benefit of a declaratory judgment on the issue but would need to proceed in individual suits to seek damages; if the class loses, every detainee would be bound by issue preclusion. The application of UFAS can be determined class-wide while leaving to the future any particular inmate’s claim to relief. View "Bennett v. Dart" on Justia Law

The Supreme Court affirmed the order of the trial court denying the motion for class certification brought by Plaintiffs, inmates in North Carolina Department of Public Safety (DPS) custody, seeking to represent certain individuals in DPS custody who are being or will be subjected to solitary confinement, holding that the trial court did not abuse its discretion.Plaintiffs filed a class action lawsuit seeking to certify a class of current and future inmates assigned to one of five restrictive housing classifications, alleging that the conditions of confinement constituted cruel or unusual punishment. The trial court denied Plaintiffs' motion for class certification, finding that a certifiable class did not exist. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in concluding that Plaintiffs failed to demonstrate a common predominating issue among the proposed class members. View "Dewalt v. Hooks" on Justia Law

Plaintiff filed a complaint against his former employer, Facility Solutions Group, Inc. (FSG), for disability discrimination and related causes of action under the Fair Employment & Housing Act. The same month Plaintiff filed this class action against FSG for Labor Code violations, which also included a claim under the Private Attorneys General Act of 2004.   The trial court in this action denied FSG’s motion, finding unconscionability permeated the arbitration agreement because it had a low to moderate level of procedural unconscionability and at least six substantively unconscionable terms, making severance infeasible. On appeal, FSG contends claim and issue preclusion required the trial court in this action to enforce the arbitration agreement.   The Second Appellate District affirmed. The court agreed with the trial court that the arbitration agreement is permeated with unconscionability, and the court cannot simply sever the offending provisions. Rather, the court would need to rewrite the agreement, creating a new agreement to which the parties never agreed. Moreover, upholding this type of agreement with multiple unconscionable terms would create an incentive for an employer to draft a onesided arbitration agreement in the hope employees would not challenge the unlawful provisions, but if they do, the court would simply modify the agreement to include the bilateral terms the employer should have included in the first place. View "Mills v. Facility Solutions Group" on Justia Law

This case involves challenges to five provisions of the Grants Pass Municipal Code (“GPMC”). The provisions can be described as an “anti-sleeping” ordinance, two “anticamping” ordinances, a “park exclusion” ordinance, and a “park exclusion appeals” ordinance.   The Ninth Circuit affirmed in part and vacated in part the district court’s summary judgment and its permanent injunction in favor of Plaintiffs; affirmed certification pursuant to Fed. R. Civ. P. 23(b)(2), of a class of “involuntary homeless” persons; and remanded in an action challenging municipal ordinances which, among other things, preclude homeless persons from using a blanket, a pillow, or cardboard box for protection from the elements while sleeping within the City’s limits.   The panel stated that this court’s decision in Martin v. City of Boise, 902 F.3d 1031 (9th Cir. 2018), which held that “the Eighth Amendment prohibits the imposition of criminal penalties for sitting, sleeping, or lying outside on public property for homeless individuals who cannot obtain shelter” served as the backdrop for this entire litigation. The panel held that there was abundant evidence in the record establishing that homeless persons were injured by the City’s enforcement actions in the past and it was undisputed that enforcements have continued. The panel further held that the relief sought by plaintiffs, enjoining enforcement of a few municipal ordinances aimed at involuntary homeless persons, was redressable within the limits of Article III. The panel held that based on the record in this case, the district court did not err by finding plaintiffs satisfied the requirements of Fed. R. Civ. P. 23(a) such that a class could be certified under Rule 23(b)(2). View "GLORIA JOHNSON, ET AL V. CITY OF GRANTS PASS" on Justia Law