Justia Civil Rights Opinion Summaries

A high school student sought to establish a pro-life student club at her public high school. The school promptly approved the club after she followed the required procedures, including securing a faculty sponsor and submitting a club questionnaire. The student actively promoted the club at the school’s activities fair, wearing pro-life apparel and displaying related signs. The dispute arose when the student submitted flyers containing political slogans and images for posting on school walls. Administrators instructed her to revise the flyers to comply with the school’s neutral content policy, which limited flyers to the club’s name and meeting details and excluded political content. Instead of revising the flyers, the student and her mother approached another administrator to seek approval, which led the principal to suspend the club’s status for the semester, citing concerns that the club was no longer student-led and that established procedures had been violated. The student was allowed to reapply, and the club was later reinstated.The student and her parents filed suit in the United States District Court for the Southern District of Indiana, alleging violations of the First Amendment and the Equal Access Act, claiming that the rejection of the flyers and the club’s suspension were motivated by hostility to her pro-life views. The district court granted summary judgment to the school district and officials, finding no constitutional or statutory violations.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the school’s restriction on political content in student club flyers was a reasonable, viewpoint-neutral policy related to legitimate pedagogical concerns under Hazelwood School District v. Kuhlmeier. The court also found that the temporary suspension of the club was based on neutral, conduct-related reasons and not on the student’s viewpoint. The court further held that there was no violation of the Equal Access Act and that the plaintiffs had not preserved a separate claim regarding the flyers under that statute. View "E.D. v Noblesville School District" on Justia Law

A United States citizen, formerly known as Paul Anderson and now Saadiq Long, was placed on the federal government’s Terrorist Screening Dataset (commonly called the Terrorist Watchlist) and, at one point, on its No Fly List subset. After experiencing travel restrictions, employment issues, and other alleged harms, Long challenged his placement on these lists, asserting constitutional and statutory violations. He claimed that his inclusion was based on impermissible factors such as race, religion, and protected activities, and that the government’s information-sharing practices and redress procedures were unlawful. While the litigation was ongoing, Long was removed from the No Fly List, but remained on the broader Watchlist. He also alleged that his Watchlist status led to the denial of credentials necessary for his work as a truck driver.The United States District Court for the Eastern District of Virginia initially transferred some of Long’s claims to the Fourth Circuit and stayed others. After Long’s removal from the No Fly List, a prior Fourth Circuit panel found his No Fly List claims moot and remanded for the district court to determine which claims remained justiciable. On remand, the district court dismissed all of Long’s claims for lack of subject matter jurisdiction, finding that his removal from the No Fly List mooted those claims and that he lacked standing for his Watchlist-related claims, as his alleged injuries were either resolved or not sufficiently imminent.The United States Court of Appeals for the Fourth Circuit vacated the district court’s dismissal. The Fourth Circuit held that, in light of the Supreme Court’s decision in FBI v. Fikre, Long’s removal from the No Fly List did not necessarily moot his claims, as the government had not shown it could not repeat the challenged conduct. The court also found that Long had standing to challenge his Watchlist status based on the denial of transportation credentials, and remanded for the district court to consider the merits of his claims. View "Long v. Bondi" on Justia Law

A prisoner at Eastern Correctional Institution was suspected of possessing a knife, prompting two correctional officers to search him. The officers escorted the prisoner and his cellmate to a recreation area, where a strip search occurred. The parties dispute the events that followed: the officers claimed the prisoner was noncompliant and bit one of them during a struggle, while the prisoner alleged he complied with orders and was then violently assaulted without justification, suffering injuries to his head, neck, and back. Medical records documented a bruise and other injuries, and the prisoner sought treatment over several months. An internal investigation cleared the officers of wrongdoing.The United States District Court for the District of Maryland dismissed the prisoner’s state law claims and claims against a supervisory official, then granted summary judgment to the correctional officers on the remaining Eighth Amendment excessive force claim. The district court found that the undisputed evidence did not support a finding that the officers acted maliciously or sadistically, and characterized the prisoner’s injuries as minor. The court also denied the prisoner’s requests for discovery and for appointment of counsel.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the grant of summary judgment de novo. The Fourth Circuit held that genuine disputes of material fact remained regarding the amount and justification for the force used, as well as the officers’ intent. The court found that the prisoner’s verified complaint and medical evidence could support a finding of more than de minimis force and potentially malicious conduct. The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, allowing the prisoner to renew his motion for counsel and proceed to trial. View "Escobar-Salmeron v. Moyer" on Justia Law

Three California churches sought to challenge the California Child Day Care Facilities Act and its regulations, which require child day care facilities to be licensed, ensure that children are free to attend religious services or activities of their choice as decided by a child’s authorized representative, and provide notice to parents of this right. The churches, which either had their license revoked or had not yet applied for one, alleged that these requirements conflicted with their religious beliefs and practices, particularly their desire to operate preschools with mandatory religious curricula and without state licensure.Previously, the United States District Court for the Southern District of California dismissed the churches’ Free Speech and Free Exercise claims for lack of standing, and their Establishment Clause and Due Process claims for failure to state a claim. The district court entered judgment in favor of the state officials after the churches declined to amend their complaint.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the churches lacked standing to challenge the religious services provision under the Free Exercise Clause because there was no credible threat of enforcement against their intended conduct, given the state’s disavowal of such enforcement and the absence of any history of similar prosecutions. However, the court found that the churches had standing to challenge the licensure requirement under the Free Exercise Clause, but concluded that the requirement was neutral and generally applicable, thus subject only to rational basis review, which it satisfied. The court also rejected the Establishment Clause challenge, finding that the statutory exemptions were based on program type, not religion. The court found standing for the Free Speech challenge to the notice requirement but held that the compelled disclosure was factual, uncontroversial, and reasonably related to a substantial government interest. The Due Process challenge was also rejected. The court affirmed the district court’s judgment but remanded to amend the judgment so that the dismissal of the Free Exercise challenge to the religious services provision would be without prejudice. View "FOOTHILLS CHRISTIAN MINISTRIES V. JOHNSON" on Justia Law

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law

A federal inmate diagnosed with diabetes was initially prescribed medication and given certain accommodations while incarcerated. After being transferred to a new facility, his new medical provider discontinued his diabetes medication and accommodations based on a single blood test result, despite the inmate’s objections that the result was not representative of his condition. The inmate’s health deteriorated, leading to severe diabetic ulcers and ultimately the amputation of his toe. He alleged that medical staff repeatedly denied or delayed necessary care, and that his requests for treatment were falsely documented as refusals. The inmate later filed administrative claims with the Bureau of Prisons (BOP) and, after those were denied or not fully addressed, brought suit alleging deliberate indifference to his medical needs under the Eighth Amendment and also asserted a claim under the Rehabilitation Act.The United States District Court for the District of New Jersey screened the complaint and dismissed the Rehabilitation Act claim. The defendants moved to dismiss the Eighth Amendment claim brought under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The District Court granted the motion, reasoning that the case presented a new context from prior Supreme Court precedent because the injuries were not fatal and that the existence of the BOP’s administrative remedy program was a special factor counseling against extending Bivens. The inmate appealed.The United States Court of Appeals for the Third Circuit affirmed. The court held that the availability of the BOP’s administrative remedy program constituted a special factor not present in Carlson v. Green, and thus created a new context under the Bivens analysis. Because an alternative remedial structure existed and was available to the inmate, the court declined to extend a Bivens remedy. The court also affirmed dismissal of the Rehabilitation Act claim, as sovereign immunity barred damages claims against the federal government under that statute. View "Muniz v. United States" on Justia Law

A firefighter in Forrest City, Arkansas, was terminated after posting a provocative anti-abortion image on his personal Facebook page. The image, intended to express his pro-life views, was interpreted by some as racially insensitive, particularly because it included the caption “I can’t breathe!”—a phrase associated with protests following George Floyd’s death. After complaints from a retired fire supervisor and others, the firefighter deleted the post. However, the mayor placed him on administrative leave and, following a brief investigation, fired him, citing the public outcry and concerns about the city’s ability to provide public services. The firefighter, who had served over four years without prior incident, learned of his termination through a press release.The firefighter filed suit in the United States District Court for the Eastern District of Arkansas, alleging First Amendment retaliation against the mayor in both his individual and official capacities, and against the city for an alleged unwritten policy allowing officials to censor employee speech. The district court granted summary judgment for the defendants, holding that the mayor was entitled to qualified immunity and that there was no evidence of an unwritten policy justifying the official-capacity and policy-based claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the firefighter’s Facebook post addressed a matter of public concern and was made as a private citizen. The court found insufficient evidence of actual or reasonably predicted disruption to the fire department’s operations to justify summary judgment for the defendants. The court reversed the district court’s grant of summary judgment on the First Amendment retaliation claims against the mayor and the city, affirmed the dismissal of the unbridled-discretion claim, and remanded for further proceedings. View "Melton v. City of Forrest City, Arkansas" on Justia Law

A group of foster children in Oregon, through their representatives, brought a class action lawsuit against the Oregon Department of Human Services (ODHS) and state officials, alleging violations of their substantive due process rights due to serious abuses experienced while in ODHS’s legal custody. The plaintiffs sought relief on behalf of all children for whom ODHS had or would have legal responsibility, including those in ODHS’s legal custody but physically placed with their parents, either because they had not been removed from their homes or because they were on a temporary “Trial Home Visit” after removal.The United States District Court for the District of Oregon certified a general class that included all children in ODHS’s legal or physical custody. After extensive litigation, the parties reached a settlement agreement, but disagreed on whether the term “Child in Care” in the agreement included children in ODHS’s legal custody who were physically with their parents (the “Disputed Children”). The district court concluded that these children were not covered by the settlement, reasoning that children living with their biological parents did not have substantive due process rights to be free from serious abuses while in ODHS’s legal custody.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the settlement agreement and the scope of substantive due process protections. The Ninth Circuit held that the Disputed Children—those in ODHS’s legal custody but physically with their parents—are entitled to substantive due process protections. The court found that once the state assumes legal custody, it has an affirmative duty to provide reasonable safety and minimally adequate care, regardless of the child’s physical placement. The Ninth Circuit reversed the district court’s order and remanded for further proceedings. View "WYATT B. V. KOTEK" on Justia Law

The petitioner was convicted by an Arizona jury of child molestation after he helped bathe young girls who were in his and his wife’s care through the foster system. The relevant Arizona statute defined child molestation as any direct or indirect touching of a child’s private parts, and, at the time, allowed a defendant to raise an affirmative defense by proving he was not motivated by sexual interest. The petitioner admitted to the touching but argued he lacked sexual motivation.After his first trial ended in a mistrial, the Arizona Supreme Court decided State v. Holle, which held that sexual motivation was not an element of the crime and that the lack of sexual interest was an affirmative defense the defendant must prove by a preponderance of the evidence. At the petitioner’s second trial, the court instructed the jury accordingly, and he was convicted on some counts. The Arizona Court of Appeals affirmed, relying on Holle, and the Arizona Supreme Court denied review. The United States Supreme Court also denied certiorari. The petitioner then sought federal habeas relief in the United States District Court for the District of Arizona, arguing that the statutory scheme unconstitutionally shifted the burden of disproving an essential element of the crime to him. The district court denied relief, finding the state courts’ application of federal law was not objectively unreasonable.The United States Court of Appeals for the Ninth Circuit reversed. It held that Arizona’s statutory scheme violated the Due Process Clause of the Fourteenth Amendment by shifting to the defendant the burden of disproving sexual motivation, which is the critical fact distinguishing criminal from innocent conduct. The court concluded that the Arizona Court of Appeals’ decision upholding the conviction was an objectively unreasonable application of clearly established Supreme Court precedent. The Ninth Circuit ordered the district court to grant the writ of habeas corpus. View "BIEGANSKI V. SHINN" on Justia Law

Michael and Susan Mockeridge purchased a remote 40-acre property in northern Michigan, where they installed five prefabricated mini-cabins near their main cabin for family use. After neighbors became concerned that the property was being operated as a public campground, they filed complaints with local authorities. In response, three government officials—Harry Harvey, David Schmidt, and Kenneth Gibson—entered the Mockeridges’ property without a warrant or consent, inspected the mini-cabins and their surroundings, and gathered information regarding potential code violations. The officials’ entry was not via the customary driveway but through adjacent private land and dense woods, and at the time, the cabins were unoccupied.The Mockeridges subsequently received a letter from the county classifying their property as a campground and requiring licensing. After applying for permits and being told they would face penalties for prior unpermitted work, the Mockeridges filed suit in the United States District Court for the Eastern District of Michigan, alleging a violation of their Fourth Amendment rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of the Mockeridges on liability, denied qualified immunity to the officials, and found the only remaining issue was damages. The officials appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that the officials’ warrantless entry into the curtilage of the Mockeridges’ mini-cabins for the purpose of gathering information about code compliance constituted an unreasonable search under the Fourth Amendment. The court further held that the right to be free from such a warrantless search was clearly established at the time of the officials’ conduct. The court dismissed the Mockeridges’ cross-appeal and denied as moot a motion by Alcona County. View "Mockeridge v. Harvey" on Justia Law