Justia Civil Rights Opinion Summaries

Brownsburg Community School Corporation requires its high school teachers to call all students by the names registered in the school’s official student database. Kluge, a teacher, objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students in Kluge’s classes and in the school generally, and the faculty.Kluge brought a Title VII religious discrimination and retaliation suit after he was terminated from his employment. The district court granted the school summary judgment, concluding that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students and rejected Kluge’s retaliation claim.The Seventh Circuit affirmed. The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment. No reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business. View "Kluge v. Brownsburg Community School Corp." on Justia Law

This case involves the City of Clovis’s (City) housing element and related zoning ordinances and whether they comply with specific statutory requirements designed to assure affordable housing opportunities to lower-income families in California. These requirements for a municipality’s housing element have statewide importance because the housing elements of all cities and counties must include compliant zoning that accommodates the municipality’s need for lower-income housing. Adequacy of Housing Element. Plaintiff, a Clovis resident, sued the City, alleging its housing element for the 2015-2023 planning period, including amendments and zoning changes adopted in March 2019, did not substantially comply with the Housing Element Law. The trial court ruled in Plaintiff’s favor.The Fifth Appellate District reversed the judgment issuing the peremptory writ of mandate to the extent the writ is based on the trial court’s finding the amended housing element does not satisfy the requirements of section 65583.2, subdivision (g) because it does not include the required analysis for sites within the P-F Zone. The court otherwise  affirmed the trial court’s issuance of a peremptory writ of mandate compelling the City to (1) adopt “a housing element for the 2015-2023 planning period that substantially complies with Government Code section 65754”; and (2) implement Program 4 “by zoning or rezoning an adequate number of sites, compliant with Government Code Section 65583.2(h), to accommodate the City’s unmet share of the RHNA from the 2008-2013 planning period, pursuant to Government Code section 65584.09.” View "Martinez v. City of Clovis" on Justia Law

Plaintiff was cited for misuse of a vehicle horn under Section 27001 after she honked in support of protestors gathered outside a government official’s office.  Plaintiff filed suit to block future enforcement of 27001 against any expressive horn use―including honks not only to “support candidates or causes” but also to “greet friends or neighbors, summon children or co-workers, or celebrate weddings or victories.” She asserted that Section 27001 violates the First and Fourteenth Amendments as a content-based regulation that is not narrowly tailored to further a compelling government interest. Alternatively, she argued that even if the law is not content-based, it burdens substantially more speech than necessary to protect legitimate government interests.   The Ninth Circuit affirmed the district court’s summary judgment in favor of California. The panel determined that, at least in some circumstances, a honk can carry a message that is intended to be communicative and that, in context, would reasonably be understood by the listener to be communicative. The panel next held that because section 27001 applies evenhandedly to all who wish to use a horn when a safety hazard is not present, it draws a line based on the surrounding factual situation, not based on the content of expression. The panel, therefore, evaluated Section 27001 as a content-neutral law and applied intermediate scrutiny. The panel concluded that Section 27001 was narrowly tailored to further California’s substantial interest in traffic safety and, therefore, that it passed intermediate scrutiny. View "SUSAN PORTER V. KELLY MARTINEZ, ET AL" on Justia Law

Several defendants were charged by indictment in separate cases with various offenses arising from their alleged participation in the Capitol riot on January 6, 2021. Among other charges, the government also charged each Defendant with one count of Obstruction of an Official Proceeding under 18 U.S.C. Section 1512(c)(2). The district court granted each Defendant’s motion to dismiss. The government filed a motion to reconsider, which the district court denied. At issue on consolidated appeal is whether individuals who allegedly assaulted law enforcement officers while participating in the Capitol riot can be charged with corruptly obstructing, influencing, or impeding an official proceeding, in violation of 18 U.S.C. Section 1512(c)(2). The DC Circuit reversed. The court held that the district court erred in dismissing the counts under 18 U.S.C. Section 1512(c)(2). The court wrote that Defendants’ alleged conduct falls comfortably within the plain meaning of “corruptly . . . obstruct[ing], influenc[ing], or imped[ing] [an] official proceeding, or attempt[ing] to do so.” The alternative interpretations of Section 1512(c)(2) proffered by the district court and Defendants failed to convince the court to depart from the natural reading of the statute’s unambiguous text. View "USA v. Joseph Fischer" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of possession of a controlled substance with intent to deliver and two counts of failure to possess a tax stamp, holding that the district court did not err in denying Defendant's motion to suppress.Officers entered Defendant's apartment without a warrant over the objections of the occupants. They then obtained a search warrant, finding evidence resulting in criminal charges. Defendant filed a motion to suppress, arguing that the initial warrantless entry was unconstitutional. The district court denied the motion, concluding that the search was justified under the emergency aid doctrine. The Supreme Court affirmed, holding that the emergency aid doctrine permitted the police officers' entry into the residents to render emergency aid to a possible shooting victim hidden inside. View "State v. Youm" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Defendants discriminated against prospective tenants in violation of municipal law by steering prospective tenants of a protected religion or national origin away from their rental properties, holding that there was insufficient evidence against Defendants under the proper jury instruction.The Des Moines Civil and Human Rights Commission brought this action alleging that Defendants, a husband and wife who owned rental properties together, engaged in housing discrimination. The jury found the husband was liable for steering and imposed a civil penalty of $50,000 against him. The Supreme Court reversed and remanded for dismissal of the steering charge against the husband, holding that the district court's instructions misled the jury to the husband's detriment. View "Des Moines Civil & Human Rights Comm'n v. Knueven" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of operating a motor vehicle while intoxicated, second offense, harassment of a public official, and interference with official acts, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was out drinking when his wife called him. When Defendant arrived home, his wife had been arrested for child endangerment and was handcuffed in a squad car. Knowing Defendant was agitated, the followed him inside his home where a social worker was interviewing three children in her investigation of child endangerment. At issue was whether the police needed a warrant to enter the home to protect the social worker. The Supreme Court affirmed, holding that the officers' warrantless entry under these exigent circumstances did not violate Defendant's rights pursuant to the Fourth Amendment or Iowa Const. I, 8. View "State v. Torres" on Justia Law

Around midnight, Woolridge walked through an Akron neighborhood where police were searching for a fugitive. Officer Collins approached him and asked for his name. Woolridge turned and ran, tossing several items. Officers caught Woolridge, who immediately said, “I got a warrant” and “I got a parole violation.” Collins moved Woolridge to a containment van while, Woolridge tried to speak with Collins, who brushed him off. Eventually, Collins asked Woolridge about the items he threw during the chase. Woolridge ultimately explained that his brother had been murdered and “I had a firearm.” Officers found the gun only after asking Woolridge to specify where he threw the gun. As Collins began reading the Miranda warnings, Woolridge said “I know my rights.” Collins proceeded to give them. Woolridge again explained that he had carried the gun due to his brother’s murder.Charged as a felon in possession of a firearm, 18 U.S.C. 922(g). Woolridge moved to suppress the statements he made before receiving the Miranda warnings. The district court suppressed the unwarned statements and permitted the admission of the post-Miranda statements. Woolridge pleaded guilty. The court varied upward by 13 months, imposing a 46-month sentence. The Sixth Circuit affirmed. Woolridge knew he had a choice and decided to speak anyway. The court explained its reasons for the sentence: Woolridge’s numerous offenses, his pattern of illegally possessing firearms, and many prison rule infractions. View "United States v. Woolridge" on Justia Law

In 1991, Jackson was wrongfully convicted of murder. In 2016, the Innocence Project requested from the Cleveland Police documents relating to the investigation, pursuant to the Ohio Public Records Act. Receiving no response, Innocence Project sent a request to the Cuyahoga County Prosecutor’s Office. Assistant Prosecuting Attorney Marburger produced a heavily redacted file. The Act exempts “investigatory work product” and “[t]rial preparation record[s]” from production as public records. Months later, the Ohio Supreme Court held that the investigatory-work-product exception did not extend beyond the conclusion of a trial. Cleveland then produced the unredacted file, which included significant exculpatory evidence. The Cuyahoga County Prosecutor’s Office also produced an unredacted file. A state-court judge vacated Jackson’s conviction. In 2019, he was finally exonerated. Jackson filed suit under 42 U.S.C. 1983. Against Marburger, Jackson alleged denial of access to courts.The Sixth Circuit held that Marburger is not entitled to absolute immunity. Responding to a records request after the conclusion of a trial and appeal is not an action that is an inherent part of a prosecutor’s adversarial function. The court reversed the denial of qualified immunity. Jackson plausibly stated a claim that Marburger violated his right of access to the courts when she removed exculpatory information from the file and effectively prevented him from filing for postconviction relief but in 2016 it was not clearly established that redacting exculpatory information from a response to a public-records request effectively covered-up evidence. View "Jackson v. City of Cleveland" on Justia Law

A gambling dispute incited a fistfight between gang subsets. Witnesses later testified that after they thought the fight was over, they saw Ferrell shoot a gun, then saw Rawlings, lying on the ground, bloodied. Ferrell dropped the gun and fled. Ferrell later claimed he had only shot once, into the air. The juvenile court transferred Ferrell, age 17, to a court of criminal jurisdiction, where he was charged with murder, with alleged sentencing enhancements for use of a firearm.The Court of Appeal affirmed Ferrell’s second-degree murder conviction and 40-year sentence. The California Supreme Court granted Ferrell habeas relief. The jury instructions erroneously permitted the conviction based on a felony-murder theory invalidated in 2009. The unadorned guilty verdict does not show that the jury avoided that theory. The court rejected an argument that the jury’s additional finding — that Ferrell intentionally discharged a firearm and caused death in committing his offense — along with other evidence, establish that any rational jury would have found Ferrell guilty under a valid theory of second-degree murder, implied malice. Even in light of the entire record, the jury’s additional finding fails to establish the mental component of implied malice, which requires a defendant to act with a conscious disregard for life, knowing his act endangers another’s life. The jury could have, consistent with its finding, concluded Ferrell shot Rawlings while trying to stop a fight without believing he was shooting toward any person. View "In re Ferrell" on Justia Law