Justia Civil Rights Opinion Summaries

The Supreme Court of Arkansas affirmed a lower court's decision dismissing Floyd Sagely's claim that Arkansas Code Annotated section 5-73-103, which prohibits a person who has been involuntarily committed to a mental institution from owning or possessing a firearm, is unconstitutional. Sagely was involuntarily committed to a mental health treatment facility in 2010, and in 2019, was charged with a misdemeanor for possessing a firearm in his car due to his previous commitment.Sagely argued that the statute violated both the Equal Protection Clause of the Fourteenth Amendment and the precedent set by the Supreme Court in New York State Rifle & Pistol Ass’n v. Bruen. He contended that the law treated felons and persons involuntarily committed to a mental health facility differently, as felons could petition to have their gun rights reinstated, while those who were involuntarily committed could not.The Supreme Court of Arkansas found that Sagely's equal protection claim failed because he could not demonstrate that he and persons convicted of a felony offense were similarly situated. The court stated that civil litigants like Sagely are not similarly situated to criminal defendants for equal-protection purposes. The court further held that the statute is presumptively constitutional under Supreme Court precedent. Therefore, the court affirmed the lower court's dismissal of Sagely's complaint. View "SAGELY v. HUTCHINSON" on Justia Law

The plaintiff, Peter Massaro, a police officer with the Fairfax County Police Department, alleged that his employer retaliated against him by transferring him to an inferior position after he filed a complaint about discrimination in promotion practices within the department. He sought relief under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983. The district court granted summary judgment to Fairfax County, dismissing all of Massaro's claims. The court held that Massaro failed to establish a causal connection between his initial discrimination complaint and his subsequent job transfer.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court ruled that the time gap between Massaro's complaint and his transfer was too long to support a causal inference. It found no evidence that the transfer was a result of a scheme to punish Massaro for his complaint. Instead, the court concluded that Massaro's transfer was a result of his own subsequent behavior that led to a violation of departmental policy.The court also dismissed Massaro's First Amendment claim, ruling that his promotion complaint made via an internal grievance process did not reflect a matter of public concern, and thus did not meet the threshold for First Amendment protection. View "Massaro v. Fairfax County" on Justia Law

The case involves Yonas Fikre, a U.S. citizen and Sudanese emigree, who brought a lawsuit alleging that the government unlawfully placed him on the No Fly List. Fikre claimed that the government violated his rights to procedural due process and placed him on the list for constitutionally impermissible reasons related to his race, national origin, and religious beliefs. In 2016, the government removed Fikre from the No Fly List, and argued in court that this action rendered Fikre's lawsuit moot. The district court agreed with the government's assessment, but the Ninth Circuit reversed, stating that a party seeking to moot a case based on its own voluntary cessation of challenged conduct must show that the conduct cannot “reasonably be expected to recur.”The Supreme Court of the United States affirmed the Ninth Circuit's decision. It held that the government failed to demonstrate that the case was moot. The Court stated that a defendant's "voluntary cessation of a challenged practice" will moot a case only if the defendant can prove that the practice cannot "reasonably be expected to recur." The Court found that the government's declaration that it will not relist Fikre based on "currently available information" did not suffice to demonstrate that Fikre will not be placed on the No Fly List in the future if he engages in the same or similar conduct. Therefore, the government has not borne its burden of proving that the dispute is moot. View "FBI v. Fikre" on Justia Law

In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law

The case concerns the plaintiff, Tina Gerlach, who claimed that Indiana officials violated her right to just compensation under the Fifth Amendment's Takings Clause. Gerlach's unclaimed property had been taken into custody by the state under the Revised Indiana Unclaimed Property Act. She asserted that Indiana did not compensate her for interest accrued while the state held her property.Gerlach filed a lawsuit against several state officials, seeking declaratory and injunctive relief, as well as compensation. The defendant officials moved for judgment on the pleadings, arguing that Gerlach's claim for prospective relief was moot and her claims for retrospective relief were barred by the Eleventh Amendment. The district court granted the defendants' motion, and Gerlach appealed.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The court found Gerlach's claim for prospective relief was moot due to Indiana's new legislation requiring the payment of interest on all recovered property. The court also held that Gerlach could not obtain compensation in federal court from the Indiana officials because no exception to Eleventh Amendment sovereign immunity applied, and Indiana state courts were open to hear Gerlach's claims. Lastly, the court concluded that Gerlach's claim for compensatory relief was actually against the State of Indiana, and therefore barred by sovereign immunity and Section 1983 of the Civil Rights Act, which does not create a cause of action against a state. View "Gerlach v. Rokita" on Justia Law

In the Supreme Court of the State of Hawaii, four plaintiffs, Sonia Davis, Jessica Lau, Lauralee Riedell, and Adam Walton, challenged the actions of the County of Maui, the County of Maui Office of the Mayor, and other related defendants. The dispute arose from a sweep of a large encampment of houseless individuals in Maui County in September 2021. The plaintiffs had requested a contested case hearing before the sweep, which was ignored, and the sweep proceeded as planned, leading to the seizure of Davis and Lau's personal property.The plaintiffs asserted they were denied procedural due process under the state and federal constitutions when the county seized their personal property without proper notice or an opportunity to be heard. The County moved to dismiss, arguing the plaintiffs did not have a protected property interest in continuing to store their belongings on County land. The circuit court granted the motion as to Riedell and Walton, who had not lost property during the sweep, but denied the motion as to Davis and Lau, who had.The Supreme Court affirmed the circuit court's decision. The court held that plaintiffs possessed a property interest in their personal items protected by the Constitution of the State of Hawaii. Therefore, the due process clause required a hearing before the County could seize the plaintiffs’ property. The circuit court properly granted the County’s motion to dismiss Riedell and Walton’s claims because they did not lose property during the sweep and properly denied the County’s motion to dismiss as to Davis and Lau, who did. View "Davis v. Bissen" on Justia Law

Two former police officers, Thomas Noon and Christopher Skidmore, were dismissed from their jobs in Platte Woods, Missouri, after submitting a letter of grievances about the police chief, James Kerns, to the city's mayor and Board of Aldermen. The officers filed a lawsuit against the mayor and police chief, claiming their First Amendment rights were violated under 42 U.S.C. § 1983. The defendants moved for summary judgment based on qualified immunity, but the district court denied their motion. The defendants then brought an interlocutory appeal.Noon and Skidmore had raised several concerns about Kerns's performance as Chief of Police, including issues with department vehicles, radar equipment, personnel, and Kerns's use of department time for personal business. After their concerns were not addressed, the officers sent a document outlining their grievances to the mayor and the Board of Aldermen. After the officers admitted to authoring the document, they were both removed from the department's schedule and eventually fired.In reviewing the case, the United States Court of Appeals for the Eighth Circuit found that the officers had established a First Amendment violation. The court determined that the officers' speech, criticizing the police chief's leadership and alleging corruption and financial mismanagement, was made as citizens on matters of public concern. The court also concluded that the defendants failed to show that the officers' speech had an adverse impact on the department's operations. Finally, the court determined that the officers' First Amendment right to be free from retaliation for protected speech was clearly established. Therefore, the defendants were not entitled to qualified immunity. The court affirmed the district court's decision. View "Noon v. Smedley" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

In this case, the United States Court of Appeals for the Fifth Circuit ruled on a civil rights lawsuit filed by James Everard and Christopher Grisham against the City of Olmos Park and several police officers. Everard and Grisham, self-identified "Second Amendment protestors", claimed their arrests on March 27, 2018, violated their First, Fourth, and Fourteenth Amendment rights. They were arrested after 911 operators received several calls about a man "with an AK-47" around his neck, standing on a busy street corner in Olmos Park. The officers arrived and found Everard with a large gun in a holster in front of his chest, and Grisham with a handgun in a holster on his hip. Everard and Grisham were charged with disorderly conduct and interference with the duties of a public servant respectively, but all charges were dismissed for insufficient evidence.The district court granted summary judgment in favor of the City and the officers, a decision that Everard and Grisham appealed. The Court of Appeals, however, affirmed the district court's decision, agreeing that the officers had probable cause to believe that Plaintiffs were engaging in criminal activity and that the officers were not objectively unreasonable in believing such probable cause existed.The court also rejected the Plaintiffs’ First Amendment claims, stating that officers cannot execute their law enforcement duties while someone is engaging in speech, where probable cause exists. The court ruled that the officers had probable cause to make the arrests for disorderly conduct and resisting arrest, thus precluding the arrestees’ retaliatory arrest claims. The court further rejected the Plaintiffs’ Fourth Amendment claims, stating that the officers are protected by qualified immunity since both Everard and Grisham could not point to any clearly established law that such force was unreasonably excessive under the circumstances. Lastly, the court affirmed the dismissal of the Plaintiffs' municipal liability claims, as they failed to establish that there were constitutional violations. View "Grisham v. Valenciano" on Justia Law

In the case under review, the plaintiff-appellant, Thomas Eugene Creech, currently on death row for the 1981 murder of David Dale Jensen, had sought commutation of his death sentence. The State of Idaho had granted Creech a commutation hearing before the Commission of Pardons and Parole, which ultimately denied his petition. Consequently, Creech filed a § 1983 action in federal court, alleging various due process violations during the commutation proceedings and sought a preliminary injunction. The United States District Court for the District of Idaho denied his motion, and he appealed.The United States Court of Appeals for the Ninth Circuit affirmed the lower court's decision. The Court held that the state had met the minimal procedural safeguards required by the Due Process Clause of the Fourteenth Amendment in the commutation proceedings. It rejected Creech's arguments that he was not given adequate notice of the issues to be considered by the Commission and the evidence to be presented at the commutation hearing. Additionally, the Court found that Creech was not entitled to the appointment of a replacement commissioner when one Commissioner recused himself. The Court also refuted Creech's claims that the Ada County Prosecuting Attorney’s Office violated his due process rights by suggesting to the Commission that Creech had committed another murder and got away with it, and by introducing misleading or fabricated evidence during the hearing. The Court found no violation or arbitrariness that would warrant judicial intervention. View "CREECH V. BENNETTS" on Justia Law