Justia Civil Rights Opinion Summaries

A former Fire Chief of the Cincinnati Fire Department, who had worked for the department since 1993 and was promoted to Fire Chief in 2021, was terminated by the City Manager in 2023 without being given a pre-termination hearing. The City Charter provided that, after serving six months as Fire Chief, the individual could only be removed for cause. When promoted, the Fire Chief signed a memorandum stating the position was “unclassified” and subject to dismissal without cause, but the Charter’s language provided for-cause protection after the first six months. The City Manager provided the Fire Chief with a termination letter listing reasons for the firing and publicized the termination, including to the media, citing the reasons as “for cause.” The Fire Chief did not receive a pre-termination or post-termination hearing before a neutral decisionmaker.The United States District Court for the Southern District of Ohio denied summary judgment to the City Manager and the City, holding that the City Manager was not entitled to qualified immunity regarding pre-termination due process violations. The court found that, under the Charter, the Fire Chief had a property interest in continued employment after six months and that there were unresolved factual disputes regarding waiver of those rights. The district court also denied statutory immunity to the City Manager on the Fire Chief’s state law defamation claim, finding triable issues regarding whether her statements were knowingly false or made with malice.On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that the City Charter unambiguously gave the Fire Chief for-cause removal protection after six months, creating a property interest protected by procedural due process. It found that no “clear and unmistakable” waiver of those rights was effected by the memorandum. The court also held that sufficient evidence existed for a jury to decide whether the City Manager acted with malice or bad faith in making allegedly defamatory statements. The matter was remanded for further proceedings. View "Washington v. City of Cincinnati" on Justia Law

A Michigan resident who owned a smoke shop that offered a promotion—purchasing a pipe and receiving marijuana as a gift—became the subject of a multi-year investigation by state police officers. Undercover officers repeatedly visited the shop, purchased pipes, and received marijuana, gathering evidence that the business was operating without a state dispensary license. Officers also examined the business’s financial records and concluded that income was underreported. Based on these findings, an officer submitted an affidavit to obtain a search warrant for the owner’s home. During the search, the owner was handcuffed, detained outside, and denied use of his restroom, ultimately being forced to urinate in his yard. The search led to criminal charges, to which the owner later pled guilty to one count in exchange for dismissal of another.The United States District Court for the Western District of Michigan reviewed the owner’s civil suit brought under 42 U.S.C. § 1983, which alleged that the officers violated his Fourth Amendment rights by executing an invalid search warrant and by refusing to allow him to use his restroom while detained. He also brought a Fourteenth Amendment substantive due process claim. The district court granted the officers qualified immunity and dismissed all claims, finding the warrant supported by probable cause and the alleged constitutional violations not clearly established.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of the Fourth Amendment unlawful search claim, finding the warrant was supported by probable cause even after removing the alleged false statements from the affidavit. The court also affirmed dismissal of the Fourteenth Amendment claim as duplicative of the Fourth Amendment unreasonable seizure claim. However, the appeals court reversed the dismissal of the unreasonable seizure claim against the officer who denied restroom access, holding that, under the totality of the circumstances, the plaintiff plausibly alleged a violation of a clearly established Fourth Amendment right. The case was remanded for further proceedings on this claim. View "Antol v. English" on Justia Law

A group of former employees of a public university in Washington State were terminated after failing to comply with a COVID-19 vaccine mandate issued by the state’s governor. These employees had requested, and in some cases received, religious or medical exemptions from the vaccine requirement. However, the university determined that accommodating these exemptions would impose undue hardship and, as a result, denied many accommodation requests. None of the employees received the vaccine or could be accommodated, so they lost their jobs.The former employees filed a lawsuit in the United States District Court for the Western District of Washington against the university and certain human resources officers, alleging that their terminations violated their constitutional rights under the First and Fourteenth Amendments, and brought claims under 42 U.S.C. § 1983. Both parties moved for summary judgment on these claims. The district court ruled in favor of the university, finding that it is an “arm of the state” under the test articulated in Kohn v. State Bar of California and thus is not a “person” subject to suit under § 1983. The employees appealed this ruling.The United States Court of Appeals for the Ninth Circuit reviewed the case. While the appeal was pending, the Supreme Court decided Galette v. New Jersey Transit Corp., clarifying the “arm of the state” analysis. The Ninth Circuit held that its prior three-factor test remains valid but must be applied in accordance with the Supreme Court’s guidance, giving the greatest weight to whether the state intended to create a legally independent entity, less weight to formal liability for debts, and the least weight to state control. Applying the refined test, the Ninth Circuit concluded that the university is an arm of the state under the Eleventh Amendment and not a “person” under § 1983, affirming summary judgment for the university and dismissing the § 1983 claims. View "NILSEN V. UNIVERSITY OF WASHINGTON" on Justia Law

In 2004, a fourteen-year-old girl was sexually assaulted in Anoka County, Minnesota. She provided evidence for a rape kit, which was submitted to the Anoka County Sheriff’s Office. Detective Johnson was assigned to her case and assured her mother that no DNA was obtained, though in reality the kit was never tested. The suspect was charged but not convicted. In 2015, it was discovered that the Sheriff’s Office had hundreds of untested rape kits, including hers. Sixteen years after the assault, her kit was finally tested, revealing DNA evidence implicating the original suspect, and criminal charges were pursued again.After these events, she brought suit against Anoka County, Sheriff Stuart, and Detective Johnson in the United States District Court for the District of Minnesota. She asserted claims under the Fourteenth Amendment and the Minnesota Constitution for equal protection violations, a claim under the Minnesota Human Rights Act, a “failure to train” claim under 42 U.S.C. § 1983, and state tort claims for negligence and intentional infliction of emotional distress (IIED). The district court dismissed her MHRA and negligence claims but allowed the other claims to proceed, finding she had standing in light of Eighth Circuit precedent.On appeal, the United States Court of Appeals for the Eighth Circuit concluded that the plaintiff lacked standing to bring her federal constitutional claims for alleged failures to investigate or train, following Supreme Court and Eighth Circuit precedent holding that crime victims generally lack standing to challenge law enforcement or prosecutorial discretion in investigating crimes, even when alleging class-based discrimination. The Eighth Circuit vacated the district court’s judgment on the federal claims and remanded with instructions to dismiss those claims for lack of standing. The court remanded the IIED claim for the district court to determine whether standing existed for that state-law claim. View "Doe v. Anoka County" on Justia Law

Cody Henderson, a resident of New Holland, Ohio, was stopped and cited by police officers on multiple occasions while driving his black Prius. On September 13, 2022, he was stopped for speeding, and later cited for several infractions including expired registration. On September 22, officers again stopped him for driving with expired tags, impounded his car, and conducted an inventory search. Henderson objected, refused to comply with officer instructions, and was arrested for obstruction of official business. The search revealed hemp-related substances, which were later determined to be legal, and all charges were dismissed. Henderson subsequently filed a federal lawsuit alleging violations of his constitutional rights and state-law claims.The United States District Court for the Southern District of Ohio dismissed the claims against Officer Pate (who had died prior to the suit) and against the Village of New Holland. Most claims against Officer Lawless were also dismissed, except for Henderson’s Fourth Amendment and malicious prosecution claims. The district court denied qualified immunity to Officer Lawless on these remaining claims, allowing them to proceed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that Officer Lawless had probable cause for the traffic stop, inventory search, and subsequent arrest for obstruction of official business. The inventory search was found lawful under the Fourth Amendment, as it followed standardized procedures and was not pretextual. The court also determined that the state-law malicious prosecution claim failed because probable cause existed for the arrest. Accordingly, the Sixth Circuit reversed the district court’s denial of qualified immunity and dismissed the remaining claims against Officer Lawless. View "Henderson v. Village of New Holland" on Justia Law

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies.The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

Elizabeth Schulte, a co-owner of property in Cedar Lake, Wisconsin, challenged actions by Kenneth J. Leners, chairman of the Town’s Board of Supervisors. The Town maintained a website open to public comments, which Schulte used to criticize a post advocating stricter regulation of recreational vehicles. In response, Leners deleted Schulte’s and other critical comments, banned them from further commenting, and ultimately removed all comments from the post. After threats of legal action, the Board decided to eliminate comment sections from the website entirely, later restoring deleted comments in a separate thread unconnected to the original post.Schulte filed suit under 42 U.S.C. §1983 in the United States District Court for the Western District of Wisconsin, alleging violation of her First and Fourteenth Amendment rights due to viewpoint discrimination and vague criteria for regulating the comment section. She also claimed unlawful retaliation when the comment sections were shut down. Leners moved to dismiss, asserting qualified immunity. The district court denied the motion regarding the counts related to selective deletion of comments, finding Schulte had pleaded viewpoint discrimination and rejecting Leners’s qualified-immunity defense. The court dismissed other unrelated counts and allowed Leners and the Town to appeal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of qualified immunity for Leners’s selective deletion of comments. The appellate court held that it was clearly established in September 2022 that viewpoint discrimination in a public forum, such as a website comment section open to the public without content restrictions, violates the First Amendment. The lack of any policy regulating comment content made the speech private, not government speech. The Seventh Circuit affirmed the district court's denial of qualified immunity to Leners and dismissed the Town’s appeal. View "Schulte v Leners" on Justia Law

Halil Demir, a naturalized U.S. citizen and Executive Director of an international aid organization, frequently travels for work and has received security clearances for certain events. Since 2016, Demir experienced extended airport screening, leading him to suspect wrongful inclusion on the FBI’s Terrorist Watchlist and its Selectee List. After submitting five inquiries through the Department of Homeland Security’s Traveler Redress Inquiry Program (DHS TRIP), he received generic responses that neither confirmed nor denied his watchlist status. Demir then filed suit, alleging violations of his substantive and procedural due process rights and challenging the adequacy of DHS TRIP procedures under the Administrative Procedure Act.The United States District Court for the Northern District of Illinois dismissed Demir’s complaint for lack of subject matter jurisdiction. The court concluded that, under 49 U.S.C. § 46110, challenges to TSA orders—including those relating to DHS TRIP—must be brought directly in a federal court of appeals. It reasoned that Demir’s claims were essentially contesting a TSA decision, as reflected in the DHS TRIP determination letter, and thus should have originated in the Court of Appeals.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that § 46110 does not apply to Demir’s challenges to his inclusion on the Terrorist Watchlist and Selectee List, as the TSA does not control these lists—the FBI’s Threat Screening Center does. Thus, the district court has jurisdiction over those claims, and the appellate court reversed and remanded them for consideration on the merits. However, the appellate court affirmed the district court’s dismissal of Demir’s challenge to the DHS TRIP program itself, holding that the program constitutes an “order” under § 46110 and must be initially reviewed in a court of appeals. View "Demir v Mullin" on Justia Law

Two long-term employees of a township senior center lost their jobs when a newly elected board, led by a candidate from the opposing political party, reorganized the center's leadership structure. The plaintiffs, both Republicans, had campaigned for the losing Republican candidate in the local election. After the incoming Democratic supervisor and board took office, they voted to eliminate the plaintiffs' positions as part of a broader reorganization, creating new roles and appointing others, including one individual who had also supported the Republican candidate.After their terminations, the plaintiffs filed suit in Illinois state court, naming the township and certain officials as defendants. They alleged, among other claims, that their First Amendment rights had been violated because their political activity was a motivating factor in their dismissals. The defendants removed the case to the United States District Court for the Northern District of Illinois. Following partial dismissal of claims, only the First Amendment retaliation and breach of implied contract claims against the township remained. After discovery, the district court granted summary judgment for the township, finding plaintiffs had not shown that their political activity was a motivating factor in the terminations, nor had they rebutted the township's evidence of legitimate reasons for the reorganization.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that the plaintiffs had not produced sufficient evidence that their political activity motivated their terminations. The court found that the undisputed evidence showed neither the new supervisor nor the trustees knew of the plaintiffs' political involvement, and there were valid, non-retaliatory reasons for the personnel changes. The court affirmed the district court’s grant of summary judgment for the township. View "Fox v DuPage Township" on Justia Law

A man’s wife called 911 to request a welfare check after her husband threatened to harm himself. The dispatcher relayed to law enforcement that the man had made similar threats in the past, was not acting like himself, and was last known to be at a riverfront house. When the responding officer arrived, he found the man’s vehicle at the property but received no response to repeated knocks and announcements at multiple doors. The officer entered the house several times after announcing himself, ultimately discovering a suicide note and pill bottle. Upon further entry, the officer encountered the man in his bedroom. After a brief exchange in which the man repeatedly ordered the officer to leave, the man retrieved a rifle and advanced toward the officer, ignoring commands to stop. The officer fired, fatally wounding the man.The personal representative of the man’s estate filed suit in South Carolina state court against the responding officer, the county sheriff, and the sheriff’s office, alleging violations of the Fourth Amendment for unlawful entry and excessive force, as well as a claim for failure to train. The case was removed to the United States District Court for the District of South Carolina. The district court granted summary judgment to the defendants on all federal claims, holding that the officer’s entries and use of force were objectively reasonable and that he was entitled to qualified immunity. The court also found no basis for municipal liability and remanded the state-law claims to state court.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officer’s warrantless entries were justified under the emergency aid exception, given the objectively reasonable belief that the man was at risk of serious harm. The court also concluded that the use of deadly force was objectively reasonable under the circumstances. Accordingly, all federal claims were properly dismissed. View "Crosby v. Colleton County Sheriff's Office" on Justia Law