Justia Civil Rights Opinion Summaries

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

An elderly couple in Greenville, North Carolina, reported a breaking-and-entering at their residence around 4:00 a.m., hearing glass break and a male voice yelling. Officer David Johnson, who was nearby, responded to the call. Upon arrival, Johnson heard loud yelling and saw Sean Rambert running towards him while yelling. Johnson commanded Rambert to get on the ground eight times, but Rambert did not comply and continued to charge at Johnson. Johnson fired multiple shots at Rambert, who continued to advance even after being shot. Rambert eventually fell and later died from his injuries.The United States District Court for the Eastern District of North Carolina denied Johnson’s motion for summary judgment based on qualified immunity. The court found genuine disputes of material fact regarding the reasonableness of Johnson’s conduct and concluded that a jury could determine that Johnson violated Rambert’s Fourth Amendment rights by using excessive force. The court also denied summary judgment on the remaining federal and state law claims against Johnson and the City of Greenville.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Johnson was entitled to qualified immunity on the Fourth Amendment claim. The court found that Johnson’s use of deadly force was not objectively unreasonable given the circumstances, including Rambert’s aggressive behavior and failure to comply with commands. The court also determined that the law did not clearly establish that Johnson’s conduct was unconstitutional at the time of the incident. Consequently, the court reversed the district court’s denial of summary judgment on the § 1983 claim against Johnson. However, the court dismissed the appeal regarding the related state and federal claims and claims against the City of Greenville, remanding those issues for further proceedings. View "Rambert v. City of Greenville" on Justia Law

Emilee Carpenter, a wedding photographer, filed a preenforcement challenge against New York’s public accommodations laws, which prohibit discrimination based on sexual orientation. Carpenter argued that these laws violated her First and Fourteenth Amendment rights by compelling her to provide photography services for same-sex weddings, which she claimed conflicted with her religious beliefs. She sought declaratory and injunctive relief, including a preliminary injunction to prevent enforcement of the laws against her.The United States District Court for the Western District of New York dismissed all of Carpenter’s claims. The court found that Carpenter had not sufficiently pled that the public accommodations laws violated her rights to free speech, free association, free exercise of religion, or the Establishment Clause. The court also rejected her claims that the laws were unconstitutionally overbroad or vague. Consequently, the court denied her request for a preliminary injunction as moot.The United States Court of Appeals for the Second Circuit reviewed the case. Following the Supreme Court’s decision in 303 Creative LLC v. Elenis, the appellate court agreed that Carpenter had plausibly stated a free speech claim. However, the court denied her request for a preliminary injunction at this stage, remanding the case to the district court for further proceedings to develop a factual record. The appellate court affirmed the district court’s dismissal of Carpenter’s other claims, including those related to free association, free exercise of religion, the Establishment Clause, and vagueness. The court concluded that the public accommodations laws were neutral, generally applicable, and did not provide for individualized exemptions that would undermine their general applicability. The court also found that Carpenter had waived her overbreadth claim due to inadequate pleading and briefing.The Second Circuit thus affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings. View "Carpenter v. James" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois, citing concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued the hospitals and certain medical professionals under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities could only be liable under § 1983 if they were engaged in state action. The court found that the hospitals and their staff were not acting under color of state law when they reported the parents to DCFS or took temporary custody of the children. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no entwinement or symbiotic relationship between the hospitals and the state that would make the hospitals state actors. Therefore, the parents' § 1983 claims could not proceed. View "Scott v. University of Chicago" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois due to concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights by the hospitals and medical professionals.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities were not engaged in state action and thus not liable under § 1983. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the private hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no symbiotic relationship or entwinement between the hospitals and the state to the point of largely overlapping identity.The Seventh Circuit affirmed the district court's dismissal of the parents' claims, concluding that without state action, there could be no § 1983 liability. View "Bougher v. Silver Cross Hospital and Medical Centers" on Justia Law

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

The case revolves around Jack Potter, a man who lived in a 23-foot travel trailer hitched to his truck, which he parked on public lots and streets in the city of Lacey, Washington. In 2019, the city passed an ordinance barring people from parking such large vehicles and trailers on public lots and streets for more than four hours per day. The city then ordered Potter to move his trailer and truck off the city hall parking lot and off Lacey streets. Potter sued the city, claiming that its new ordinance violated his state constitutional “right to reside,” which he argued was inherent in the state constitutional right to intrastate travel.The case was initially filed in Thurston County Superior Court but was later moved to the federal district court for the Western District of Washington. The district court granted summary judgment to the city on nearly all of its claims, including Potter’s state right to intrastate travel claim. The court explained that the ordinance did not fundamentally impede the right to exist or reside in a given area. It was a parking ordinance applicable to all people in Lacey, and only by extension did it restrict the manner in which a person could live in Lacey. The right to travel did not include a right to live in a certain manner.The case was then appealed to the Ninth Circuit Court of Appeals, which certified questions of state law to the Supreme Court of the State of Washington. The Supreme Court held that the RV parking ordinance did not violate Potter’s claimed Washington State constitutional right to intrastate travel. Potter had not established that his claimed right to reside was inherent in a Washington state constitutional right to intrastate travel or that it protected his preferred method of residing in Lacey: by siting his 23-foot trailer on a public street in violation of generally applicable parking ordinances. View "Potter v. City of Lacey" on Justia Law

The case involves a dispute between Wendell Shane Mackey, a local resident, and Jeff Rising, a real-estate agent who served one term as a part-time City Commissioner for Adrian, Michigan. Mackey posted information about Rising on Facebook that Rising believed to be false. Rising responded by calling Mackey’s mother and allegedly threatened to “hurt” Mackey if he did not delete the post. Mackey sued, arguing that Rising’s threat of physical violence violated the First Amendment because Rising made it in his capacity as a Commissioner to stifle Mackey’s speech.The United States District Court for the Eastern District of Michigan granted summary judgment to Rising, concluding that he had acted as a private citizen when he made the alleged threats. Mackey appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the lower court's decision. The court found that Rising, as a legislator, did not have any “authority” to use (or threaten) physical force on behalf of the City of Adrian. His alleged “misuse” of the power, therefore, could not qualify as state action. The court also found that Rising’s acceptance of the City’s insurance for his defense did not conflict with his state-action defense on the merits, and thus, neither waiver nor judicial estoppel applied. View "Mackey v. Rising" on Justia Law