Justia Civil Rights Opinion Summaries

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

The case involves the City of Myrtle Beach's response to a surge in violent crime in an area known as "the Superblock." Between 2015 and 2016, eleven people were shot, and dozens more were sexually assaulted, battered, or robbed in the Superblock, primarily around a small cluster of bars. The City increased police presence and investigated these establishments for compliance with safety regulations. Despite these measures, crime persisted, leading the City to shut down two bars for repeated legal violations, while a third bar closed due to lack of business. Years later, the bars and the landlord sued the City and the City Manager, alleging violations of the Takings Clause, Due Process Clause, Equal Protection Clause, and 42 U.S.C. § 1985, claiming the City unlawfully targeted them because their owners and clientele were predominantly racial minorities.The United States District Court for the District of South Carolina granted directed verdicts for the City on all claims during a jury trial. The court held that the appellants did not have a constitutionally protected property interest in the right to conduct their business. It found that the City's enforcement actions were within the legitimate bounds of state police power and rejected the § 1985 civil conspiracy claims based on the intra corporate conspiracy doctrine, which states that corporate and government agents cannot conspire with themselves.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the City acted within its lawful authority to address serious public safety threats and enforce compliance with state and local regulations. The appellants' claims were deemed speculative and unsupported by the evidence presented at trial. The court found no discriminatory intent or violation of due process, and it upheld the application of the intra corporate conspiracy doctrine, concluding that the City officials did not possess a personal stake independent of their relationship to the City. View "Brady v. City of Myrtle Beach" on Justia Law

Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law

Theresa Brooke, a woman with disabilities who uses a wheelchair, visited the Ramada by Wyndham Burbank Airport hotel in August 2023. She alleged that architectural barriers at the hotel deterred her from entering. Brooke sued the hotel's owner, Tsay JBR, LLC, for violations of Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act. She sought injunctive relief under the ADA and statutory damages under the Unruh Act.The United States District Court for the Central District of California granted partial summary judgment in favor of Brooke, finding that Tsay JBR had violated the ADA due to the lack of an access aisle in the hotel's passenger loading zone. This ADA violation also constituted a violation of the Unruh Act. However, the court found that there was a factual issue regarding whether Brooke personally encountered the violation or was deterred by it, which is necessary for statutory damages under the Unruh Act. The district court scheduled a bench trial, concluding that the Seventh Amendment right to a jury trial did not apply to claims for statutory damages under the Unruh Act.The United States Court of Appeals for the Ninth Circuit reviewed the case and granted Tsay JBR's petition for a writ of mandamus. The Ninth Circuit held that the Seventh Amendment entitles parties in federal court to a jury trial on claims for statutory damages under section 52(a) of the Unruh Act. The court determined that Brooke's claim was legal in nature, both in terms of its historical analog to 18th-century English public accommodations law and the punitive and deterrent nature of the statutory damages sought. The court directed the district court to set the matter for a jury trial. View "TSAY JBR LLC V. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA" on Justia Law

Yolanda Welch Atkins, a court clerk for Macon, Mississippi, since 2003, was placed on leave in October 2020 after $3,200 in municipal court fines and fees went missing, leading to her arrest and indictment for embezzlement. Despite this, she was reinstated by the board of aldermen. In January 2021, after running unsuccessfully for mayor against Patrick Hopkins's preferred candidate, Atkins was not reappointed as court clerk when Hopkins and other aldermen did not second the motion for her reappointment.Atkins sued Hopkins and others, claiming First Amendment retaliation. The United States District Court for the Southern District of Mississippi granted summary judgment to all defendants except Hopkins, finding a genuine dispute of material fact regarding whether Hopkins's refusal to second the motion was due to Atkins's protected speech. Hopkins appealed the denial of summary judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that under the doctrine of qualified immunity, government officials are protected from liability unless they violate clearly established statutory or constitutional rights. The court found that existing precedent, including Sims v. City of Madisonville, did not clearly establish that Hopkins's specific conduct—refusing to second a motion—violated the First Amendment. Consequently, the court held that Hopkins was entitled to qualified immunity.The Fifth Circuit reversed the district court's denial of summary judgment for Hopkins and remanded the case for further proceedings, without indicating what those proceedings should entail. View "Atkins v. Hopkins" on Justia Law

Michael Poffenbarger, a First Lieutenant in the Air Force Reserve, filed a lawsuit challenging the Air Force’s COVID-19 vaccine mandate, claiming it violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. He sought a religious exemption, which was denied, and subsequently refused the vaccine. As a result, he received a letter of reprimand and was placed on inactive status, losing pay and retirement points. Poffenbarger sought declaratory and injunctive relief, including restoration of lost pay and points.The United States District Court for the Southern District of Ohio initially granted a preliminary injunction preventing the Air Force from taking further punitive action against Poffenbarger. In a related case, Doster v. Kendall, the same court certified a class of affected service members and issued similar injunctions. The Sixth Circuit affirmed these injunctions, but the Supreme Court later vacated the decision on mootness grounds after Congress directed the rescission of the vaccine mandate. The district court then dismissed Poffenbarger's case as moot.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Poffenbarger’s claim for lost drill pay and retirement points was barred by federal sovereign immunity. The court explained that RFRA’s waiver of sovereign immunity does not unequivocally include claims for money damages against the federal government. Since Poffenbarger’s claim sought retrospective compensation for a previous legal wrong, it constituted money damages, which are not covered by RFRA’s waiver. Consequently, the Sixth Circuit affirmed the district court’s dismissal of the case. View "Poffenbarger v. Kendall" on Justia Law

In 2017, Gratiot County foreclosed on Donald Freed’s home due to unpaid taxes. Freed’s property, valued at $98,800, was sold for $42,000, although he owed just under $1,110. The county kept all proceeds from the sale, as Michigan’s General Property Tax Act (GPTA) did not require returning surplus proceeds to the property owner. Freed sued Gratiot County and its treasurer, Michelle Thomas, under 42 U.S.C. § 1983, claiming a violation of the Fifth and Fourteenth Amendments. Michigan intervened to defend the GPTA’s constitutionality.The United States District Court for the Eastern District of Michigan dismissed Freed’s complaint for lack of subject matter jurisdiction, citing Wayside Church v. Van Buren County. Freed appealed, and the Sixth Circuit reversed the dismissal, recognizing that the Supreme Court’s ruling in Knick v. Township of Scott partially abrogated Wayside Church. On remand, the district court granted partial summary judgment to Freed, affirming that the county had to pay Freed the difference between the foreclosure sale and his debt, but dismissed claims against Thomas due to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed Freed’s entitlement to attorneys’ fees from Gratiot County and Michigan. However, the court vacated the district court’s fee calculation and remanded for further proceedings. The Sixth Circuit held that Freed prevailed against both Gratiot County and Michigan, and Michigan’s intervention under 28 U.S.C. § 2403(b) subjected it to attorneys’ fee liability. The court found the district court’s explanation for reducing Freed’s hours and rate by 35% insufficient and required a more detailed justification for the fee award calculation. View "Freed v. Thomas" on Justia Law

The case involves the appellant, Gregory Smith, challenging the Municipality of Anchorage's decision to abate unauthorized campsites in Davis Park. The Anchorage Municipal Code (AMC) outlines procedures for campsite abatement, including posting a notice and allowing for an appeal to the superior court. In June 2022, the Municipality posted a notice in Davis Park, advising that the area was not legal for storage or shelter and that any personal property would be removed and disposed of as waste after ten days. Smith and five others appealed the abatement, arguing it violated due process and the Eighth Amendment.The superior court dismissed the appeal, agreeing with the Municipality that its jurisdiction was limited to reviewing the legal sufficiency of the posted notice, not the abatement decision itself. The court noted that the appellants did not challenge the notice's compliance with the Code, thus leaving no issues for the court to decide. The court also observed that the appellants' claims were not without merit and suggested that a civil suit could address their concerns.The Supreme Court of the State of Alaska reviewed the case and concluded that the superior court's jurisdiction was not limited to the notice's legal sufficiency. The court held that the superior court has jurisdiction to review the substantive decision to abate the campsite, including constitutional challenges. The court reversed the superior court's decision and remanded the case for further consideration of the constitutional issues raised by Smith. The court also directed the superior court to determine if the administrative record was sufficient for meaningful appellate review and to take necessary steps to ensure it has an adequate record. View "Smith v. Municipality of Anchorage" on Justia Law

In the fall of 2021, the League of United Latin American Citizens of Iowa (LULAC) filed a petition against the Iowa Secretary of State, the Iowa Voter Registration Commission, and several county auditors. LULAC challenged a 2008 permanent injunction from a different case, which prohibited the dissemination of voter registration forms in languages other than English under the Iowa English Language Reaffirmation Act. LULAC argued that the injunction was wrongly decided and sought its dissolution, along with a declaration that the Act allowed for non-English voting materials.The Iowa District Court for Polk County granted LULAC’s requests, dissolving the King injunction and issuing a declaratory judgment that the Act did not apply to voting materials. The court held that voting materials were necessary to secure the right to vote and thus fell within the rights exception of the Act.The Iowa Supreme Court reviewed the case and focused on the issue of standing. The court concluded that LULAC lacked standing to challenge the King injunction and the Secretary of State’s interpretation of the law. The court reasoned that LULAC’s general interest in the proper interpretation and enforcement of the law, as well as its resource diversion in response to the injunction, did not constitute a legally cognizable injury. The court emphasized that standing requires a specific personal or legal injury, which LULAC failed to demonstrate. Consequently, the Iowa Supreme Court reversed the district court’s decision and remanded the case for dismissal. View "League of United Latin American Citizens of Iowa v. Iowa Secretary of State" on Justia Law

Mr. Jorge Martinez was fatally shot by Officer Cheyenne Lee while being served with an emergency protective order. The incident began when Officer Lee arrived at Mr. Martinez's home, and a family member informed him that Mr. Martinez was asleep. Upon being awakened, Mr. Martinez told Officer Lee to leave. Officer Lee attempted to arrest Mr. Martinez, managing to handcuff one hand before a struggle ensued, ending with Officer Lee shooting Mr. Martinez. The administratrix of Mr. Martinez's estate filed a lawsuit under 42 U.S.C. § 1983, alleging violations of the Fourth Amendment due to unlawful arrest and excessive force.The United States District Court for the Northern District of Oklahoma initially granted summary judgment in favor of Officer Lee. However, upon appeal, the Tenth Circuit reversed this decision, stating that the district court had failed to consider the plaintiff's version of events, which could constitute an unlawful arrest and excessive force. The case was remanded to the district court to determine if these findings would clearly establish a constitutional violation. The district court concluded that they would and denied summary judgment to Officer Lee, leading to the current appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court held that Officer Lee lacked qualified immunity on the claims of unlawful arrest and excessive force. The court determined that no reasonable officer could have perceived probable cause for the arrest based on the plaintiff's version of events, which included no threats or violent actions by Mr. Martinez. Additionally, the court found that the use of deadly force was clearly established as unconstitutional in situations where the suspect posed no immediate threat. Consequently, the Tenth Circuit affirmed the district court's denial of summary judgment for Officer Lee. View "Ibarra v. Lee" on Justia Law