Justia Civil Rights Opinion Summaries

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Gary Hicks, a corrections sergeant, was suspended for 10 days by the Illinois Department of Corrections after an internal investigation into his Facebook posts, which were described as "Islamophobic" and "offensive" by a news article. The investigation concluded that Hicks violated Department policies prohibiting conduct unbecoming of a State employee or that may reflect unfavorably on the Department. Hicks admitted to making the posts, which included derogatory comments about various groups and a prayer for a civil war or government overthrow. He sued the Department and officials under 42 U.S.C. § 1983, alleging First Amendment retaliation and a Fourteenth Amendment challenge to the Department’s policies.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants on both claims. The court held that Hicks’s suspension did not violate the First Amendment because his posts were not on matters of public concern, and the Department’s interest in maintaining discipline outweighed his interest in speaking. The court also found that the Department’s policies were not impermissibly vague as applied to Hicks’s conduct and granted qualified immunity to the defendants.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court concluded that the Department’s interest in managing its affairs outweighed Hicks’s interest in posting the content, thus he could not sustain a First Amendment retaliation claim. Additionally, the court found that the Department’s code of conduct was not impermissibly vague as applied to Hicks, as a reasonable officer would understand that his posts were unbecoming and could reflect unfavorably on the Department. Therefore, the court affirmed the summary judgment in favor of the defendants on both the First and Fourteenth Amendment claims. View "Hicks v. Illinois Department of Corrections" on Justia Law

On June 7, 2019, around 4:20 a.m., two police officers detained Anthry Milla, who was sitting in his car in his driveway. The officers were investigating a nearby stabbing but had no description of a suspect. Milla was cooperative but closed his car door when the officers approached. The officers, suspecting involvement in the stabbing, detained Milla at gunpoint, searched his car, and found no evidence. Milla's parents confirmed his identity, and he was released after about eight minutes.Milla filed a pro se complaint under 42 U.S.C. § 1983, alleging Fourth Amendment violations. The United States District Court for the Eastern District of Virginia granted summary judgment to the officers, finding their actions justified under the totality of the circumstances. The court also held that the officers were entitled to qualified immunity, as they did not violate Milla's constitutional rights.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and vacated the district court's decision. The appellate court found that the officers lacked reasonable, particularized suspicion to detain Milla. The court emphasized that proximity to a crime scene and Milla's actions, such as closing his car door, did not constitute reasonable suspicion. The court also vacated the district court's award of qualified immunity, as the officers' actions were not justified under established Fourth Amendment standards. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Milla v. Brown" on Justia Law

The case involves Robert Paul Rundo and Robert Boman, who were charged with conspiracy to violate the Anti-Riot Act and with substantively violating the Act. The indictment alleges that Rundo is a founding member of the "Rise Above Movement" (RAM), a militant white supremacist group. Rundo and Boman, along with other RAM members, attended several political rallies where they violently attacked counter-protesters. The indictment details their involvement in rallies in Huntington Beach, Berkeley, San Bernardino, and Charlottesville, where they engaged in organized violence and later boasted about their actions online.The United States District Court for the Central District of California initially dismissed the indictment, finding the Anti-Riot Act unconstitutional due to facial overbreadth under the First Amendment. The Ninth Circuit reversed this decision, holding that the Act was not facially overbroad except for certain severable portions. On remand, the district court dismissed the indictment again, this time based on a claim of selective prosecution. The district court concluded that the government selectively prosecuted RAM members while ignoring the violence of Antifa and related far-left groups, suggesting that the prosecution was based on the offensive nature of RAM's speech.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's judgment. The Ninth Circuit held that Rundo did not meet his burden to demonstrate that similarly situated individuals were not prosecuted and that his prosecution was based on an impermissible motive. The court found that the district court erred by comparing collective conduct to individual conduct and by holding that individual Antifa members were similarly situated to Rundo. The Ninth Circuit also held that Rundo failed to show that his prosecution was based on an impermissible motive, noting that timing and other factors cited by the district court were insufficient. The court reinstated the indictment and remanded the case for trial. View "USA V. RUNDO" on Justia Law

Phillip Robbin was removing a tree from a residential lot in the City of Berwyn when he was confronted by Sarah Lopez, a city inspector. Lopez berated Robbin using racial slurs, which led Robbin to demand disciplinary action against her. The Mayor of Berwyn denied Robbin's request for Lopez's termination, leading Robbin to sue the City, the Mayor, and Lopez for violations of his substantive due process rights under the Fourteenth Amendment and state law.The United States District Court for the Northern District of Illinois dismissed Robbin’s complaint under Federal Rule of Civil Procedure 12(b)(6), finding that he failed to state a federal claim. The court also declined to exercise supplemental jurisdiction over the state law claims, leading to Robbin's appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that Robbin failed to allege a violation of a fundamental right and that the conduct described did not "shock the conscience," which are necessary elements for a substantive due process claim under the Fourteenth Amendment. The court noted that while Lopez's use of racial slurs was deplorable, it did not rise to the level of a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's dismissal of Robbin's complaint. View "Robbin v. City of Berwyn" on Justia Law

Three gun rights organizations and their members challenged Minnesota’s permit-to-carry statute, which requires applicants to be at least 21 years old, arguing it violates the Second and Fourteenth Amendments. The district court granted summary judgment to the plaintiffs, finding that the Second Amendment’s plain text covered their conduct and that the government failed to show that restricting 18 to 20-year-olds’ right to bear handguns in public was consistent with the nation’s historical tradition of firearm regulation. Minnesota appealed the decision.The United States District Court for the District of Minnesota ruled in favor of the plaintiffs, declaring the age restriction facially unconstitutional for otherwise qualified 18 to 20-year-olds and enjoining its enforcement. The district court applied the two-part test from New York State Rifle & Pistol Association, Inc. v. Bruen, focusing on the Second Amendment’s text and historical tradition. The court found that the plain text covered the plaintiffs’ conduct and that the government did not meet its burden to demonstrate a historical tradition of similar firearm regulations.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that ordinary, law-abiding 18 to 20-year-olds are part of “the people” protected by the Second Amendment. The court found that Minnesota failed to provide sufficient historical analogues to justify the age restriction, noting that the state’s proffered evidence did not meet the burden of demonstrating a historical tradition of similar firearm regulations. Consequently, the court ruled that the age restriction in Minnesota’s permit-to-carry statute is unconstitutional. View "Worth v. Jacobson" on Justia Law

Three foreign nationals, crewmembers aboard the vessel MARGUERITA, were detained in the United States after the vessel was held in port in Maine due to alleged improper disposal of bilge water and inaccurate record-keeping. The plaintiffs were ordered to remain in the U.S. as potential material witnesses. They were later allowed to leave but returned for trial and were awarded for their contributions to the conviction of the vessel's operator.The plaintiffs filed a lawsuit under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and the Federal Tort Claims Act (FTCA) against various U.S. government entities and officials, alleging violations of their constitutional rights and various tort claims. The U.S. District Court for the District of Maine dismissed the Bivens claim and granted summary judgment for the defendants on the FTCA claims. The court found that the plaintiffs' detention and the revocation of their landing permits were authorized and that the plaintiffs did not show that the actions taken by the government officials were unlawful or unreasonable.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the requirement for ships to maintain an Oil Record Book under 33 C.F.R. § 151.25 is valid and that the plaintiffs' detention was justified under the circumstances. The court also found that the plaintiffs failed to establish their claims for false arrest, false imprisonment, abuse of process, and intentional infliction of emotional distress under the FTCA. Additionally, the court concluded that the Bivens claim presented a new context and that special factors counseled hesitation in extending a Bivens remedy, particularly given the availability of alternative remedies and the implications for government policy and international relations. View "Hornof v. United States" on Justia Law

In this case, a citizen-journalist named Inge Berge recorded a video in the Gloucester school superintendent's office, questioning COVID-19 policies. He openly filmed the interactions and later posted the video on Facebook. The school district's human resources director, Roberta Eason, sent Berge a letter demanding he remove the video, citing a violation of Massachusetts's wiretap act, which prohibits secret recordings. However, Berge's recording was not secret, and he did not remove the video. Instead, he filed a lawsuit against the Gloucester School Committee and individual officials, alleging First Amendment retaliation and seeking declaratory relief.The United States District Court for the District of Massachusetts dismissed Berge's complaint. The court granted the individual defendants qualified immunity on the First Amendment retaliation claim, ruling that Berge had not shown a clearly established right to publish the video. The court also dismissed the declaratory relief claims as moot, noting that the school district had revoked the demand letter and assured no further action would be taken against Berge. Additionally, the court denied Berge's motion for a temporary restraining order and preliminary injunction as moot.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's dismissal of the First Amendment retaliation claim against the individual defendants, holding that Berge plausibly alleged a violation of a clearly established right to publish on a matter of public concern. The court affirmed the dismissal of the declaratory relief claims as moot, given the school district's retraction of the demand letter and assurances. The court also affirmed the denial of the motion for a temporary restraining order and preliminary injunction as moot. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Berge v. School Committee of Gloucester" on Justia Law

The case involves a challenge to Tennessee's policy of not allowing amendments to the sex listed on birth certificates based on gender identity. The plaintiffs, transgender individuals, argue that this policy violates their rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment. They seek a procedure that permits changes to the sex designation on birth certificates based on self-reported gender identity.The United States District Court for the Middle District of Tennessee dismissed the plaintiffs' claims. The court found that Tennessee's policy did not violate the Equal Protection Clause because it treated all individuals equally by requiring proof of an error to amend a birth certificate. The court also rejected the substantive due process claim, holding that there is no fundamental right to a birth certificate that reflects gender identity rather than biological sex.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court held that Tennessee's policy does not discriminate based on sex or transgender status and is subject to rational basis review. The policy was found to be rationally related to legitimate state interests, such as maintaining accurate and consistent vital records. The court also concluded that the plaintiffs did not have a substantive due process right to amend their birth certificates to reflect their gender identity, as such a right is not deeply rooted in the nation's history and tradition.The Sixth Circuit's main holding is that Tennessee's policy of not allowing amendments to the sex listed on birth certificates based on gender identity does not violate the Equal Protection or Due Process Clauses of the Fourteenth Amendment. The court emphasized that the Constitution does not require states to adopt the plaintiffs' preferred policy and that such decisions are best left to the democratic process. The court affirmed the district court's dismissal of the plaintiffs' claims. View "Gore v. Lee" on Justia Law