Justia Civil Rights Opinion Summaries

A nonprofit organization, Students for Fair Admissions (SFFA), challenged the University of Texas at Austin (UT) for its admissions policies, alleging they violated the Equal Protection Clause and Title VI by considering race as a factor. After the Supreme Court's decision in Students for Fair Admissions, Inc., v. President & Fellows of Harvard College, UT revised its admissions policy to exclude race as a factor but allowed admissions officers access to applicants' racial data. SFFA claimed this access still constituted a violation and sought declaratory and injunctive relief.The United States District Court for the Western District of Texas dismissed all claims as moot, reasoning that UT's policy changes addressed the issues raised by SFFA. The district court concluded that the claims related to the old policy were moot and that the new policy did not violate the law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court agreed that claims related to UT's pre-Harvard policy were moot because the policy had been repealed and could not reasonably be expected to recur. However, the court found that claims related to UT's post-Harvard policy were not moot. The court noted that admissions officers' access to racial data could still potentially allow for racial discrimination, thus maintaining a live controversy.The Fifth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The court held that SFFA's claims regarding the revised admissions policy remained live and required further examination to determine if the policy was a subterfuge for continued race discrimination. View "Students for Fair Admissions v. University of Texas Austin" on Justia Law

In 2023, Maine voters passed "An Act to Prohibit Campaign Spending by Foreign Governments" to prevent foreign governments and entities influenced by them from contributing to or influencing elections. The Act also requires media platforms to ensure they do not distribute communications that violate this prohibition, with violators facing civil and criminal penalties. Several companies and individuals, including Central Maine Power (CMP) and Versant Power, challenged the Act, claiming it violated the First Amendment. The district court granted a preliminary injunction against the Act, and Maine appealed.The United States District Court for the District of Maine granted the preliminary injunction, finding that the Act was likely unconstitutional under the First Amendment. The court held that the Act's prohibition on spending by entities with at least 5% foreign ownership was not narrowly tailored to a compelling state interest. It also found that the definition of "foreign government-influenced entity" was overly broad and likely to stifle domestic speech regardless of actual foreign influence. The court declined to sever the unconstitutional provisions from the rest of the Act, reserving the issue for later consideration.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that the Act's 5% foreign ownership threshold was not narrowly tailored and that the definition of "foreign government-influenced entity" was overly broad. The court also found that the Act's restrictions on contributions and expenditures were likely unconstitutional. The court did not address the issue of severability, leaving it for the district court to decide. The court also did not find it necessary to discuss the preemption determination in affirming the injunction. View "Central Maine Power Co. v. Commission on Governmental Ethics and Election Practices" on Justia Law

Ronnie Alexander was arrested and detained in Henderson County Jail while awaiting trial. He falsely informed jail officials that he was suicidal to be transferred out of the group holding cell. Consequently, he was moved to the jail's suicide-prevention cell, known as the "violent cell," which lacked basic amenities such as a toilet, running water, or bedding, and had lights on at all hours. Alexander was housed there for five days before being released. He subsequently filed a lawsuit challenging the conditions of his confinement and the adequacy of the jail's mental health services.The United States District Court for the Northern District of Texas granted the defendants' motions to dismiss Alexander's federal and state-law claims. The court found that Alexander failed to state a claim under 42 U.S.C. § 1983 against the Taft defendants, Henderson County, and the correctional officers. The court also declined to exercise supplemental jurisdiction over Alexander's remaining state-law claims and dismissed them without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The court held that the conditions of the violent cell were reasonably related to the legitimate governmental interest of protecting suicidal inmates from self-harm. The court found that the conditions, although harsh, were not punitive and did not violate Alexander's constitutional rights. The court also determined that the mental health care provided to Alexander met the constitutional minimum required, and there was no deliberate indifference by the Taft defendants or the county. Consequently, Alexander's claims were dismissed. View "Alexander v. Taft" on Justia Law

Joseph Heid filed a lawsuit under 42 U.S.C. § 1983 against Orange County Sheriff's Deputies Mark Rutkoski and Forrest Best, alleging they used unreasonable force in violation of the Fourth Amendment. The incident occurred after Heid had a domestic dispute, left his house, and later returned armed with a rifle. He engaged in a gunfight with deputies in his backyard and then re-entered his house. When he exited the house again, Deputies Rutkoski and Best, believing he was still armed, shot him multiple times.In the Circuit Court of the Ninth Judicial Circuit, Heid was found guilty of several charges, including Attempted Second Degree Murder of a Law Enforcement Officer and Resisting an Officer with Violence. Heid then filed a civil lawsuit, and the United States District Court for the Middle District of Florida denied the deputies' motion for summary judgment, which asserted qualified immunity. The District Court found there was a genuine factual dispute regarding whether the deputies used excessive force and whether Heid posed a threat when he exited the house.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that Deputies Rutkoski and Best did not violate Heid's Fourth Amendment rights. The court reasoned that the deputies reasonably believed Heid was armed and dangerous based on the information they had, including Heid's recent gunfight with other deputies and his rapid exit from the house. The court held that the use of force was reasonable under the circumstances and that the deputies were entitled to qualified immunity. The judgment of the District Court was reversed, and the case was remanded. View "Heid v. Rutkoski" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

John Labriola, a media aide for the Miami-Dade Board of County Commissioners, wrote an inflammatory opinion piece criticizing the Equality Act, using derogatory language towards the LGBT community. Following public backlash and internal complaints, the County suspended him without pay, mandated anti-discrimination training, and eventually terminated him for not completing the training.Labriola sued Miami-Dade County in the United States District Court for the Southern District of Florida, alleging retaliation for exercising his First Amendment rights, compelled speech, and that the County's anti-discrimination policy was unconstitutionally overbroad. The district court granted summary judgment in favor of the County on all counts, applying the Pickering-Connick test to Labriola's free speech and free exercise claims, and ruling that his free-press claim was invalid because he was not a journalist.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Labriola's free speech and free exercise claims failed the Pickering-Connick balancing test, as his speech impeded the County's ability to perform its duties efficiently and disrupted workplace harmony. The court also rejected Labriola's free-press claim, noting that even though the district court erred in stating he couldn't bring the claim as a non-journalist, his claim failed on the merits. Additionally, the court found no evidence to support Labriola's compelled speech claim, as the required training did not compel him to express views he disagreed with. Lastly, the court dismissed Labriola's overbreadth challenge to the County's anti-discrimination policy, as he failed to demonstrate that the policy was substantially overbroad.The Eleventh Circuit affirmed the district court's grant of summary judgment to Miami-Dade County on all counts. View "Labriola v. Miami-Dade County" on Justia Law

In 2021, the Federal Reserve Bank of New York implemented a policy requiring all employees to be vaccinated against Covid-19, with exemptions for religious or medical reasons. Lori Gardner-Alfred and Jeanette Diaz, employees of the Federal Reserve, applied for religious exemptions, claiming that the vaccine conflicted with their religious beliefs. The Federal Reserve denied their requests and subsequently terminated their employment for non-compliance with the vaccination policy. Gardner-Alfred and Diaz filed a lawsuit, alleging that the Federal Reserve's actions violated their religious liberties under the Free Exercise Clause of the First Amendment and various federal statutes.The United States District Court for the Southern District of New York granted summary judgment in favor of the Federal Reserve on all federal claims. The court found no genuine dispute of fact regarding the sincerity of Gardner-Alfred's religious objections and concluded that the vaccination policy did not conflict with Diaz's professed religious beliefs. Additionally, the district court imposed discovery sanctions on Gardner-Alfred and Diaz for repeatedly neglecting their discovery obligations, withholding relevant documents, and violating court orders.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's summary judgment on Gardner-Alfred's claims, agreeing that she failed to provide sufficient evidence of sincerely held religious beliefs. However, the court vacated the summary judgment on Diaz's claims, finding that there were disputed issues of material fact regarding the sincerity of her religious beliefs and whether the vaccination policy burdened those beliefs. The court also upheld the district court's imposition of discovery sanctions, finding no abuse of discretion. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gardner-Alfred v. Federal Reserve Bank of New York" on Justia Law

Officer Alexandra Weaver took a fourteen-year-old child, J.M., from her home during a child welfare investigation. The child and her parents sued, claiming Weaver searched the apartment and seized the child in violation of their Fourth and Fourteenth Amendment rights. Weaver appealed the district court’s order denying her motion for summary judgment on the basis of qualified immunity.The United States District Court for the Western District of Texas found that Weaver was not entitled to qualified immunity and denied summary judgment on three claims: the Fourth Amendment claim for unreasonable search of the apartment, J.M.’s Fourth Amendment claim for unreasonable seizure, and the Fourteenth Amendment claim for procedural due process. Weaver then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that the warrantless search of the apartment was not justified by exigent circumstances, and no other exception applied. The court also found that J.M. was seized without a court order, parental consent, or exigent circumstances, violating her Fourth Amendment rights. Additionally, the court held that the procedural due process claim was valid because J.M. was seized without a court order or exigent circumstances, and this violation was clearly established by precedent.The Fifth Circuit concluded that Weaver was not entitled to qualified immunity on any of the claims and affirmed the district court’s denial of summary judgment. View "McMurry v. Weaver" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

Luis Martinez Jr. died in February 2021, and his body was taken by the Wayne County Medical Examiner’s Office (WCMEO). Despite identifying his next of kin, the WCMEO did not contact them. The family hired a social worker who located Luis Jr.'s body in April 2021, by which time it was severely decomposed and had to be cremated. The family sued Wayne County and various officials under § 1983 for a Fourteenth Amendment procedural due process violation, a Monell liability claim, and state-law claims.The United States District Court for the Eastern District of Michigan granted the defendants' motion to dismiss. The court found that the alleged conduct did not constitute a clearly established constitutional violation and that the Monell claim failed due to a lack of supporting facts. The court declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that the defendants' conduct did not violate a clearly established constitutional right, as existing precedent did not address delayed notification leading to natural decomposition. The court also found that the Monell claim failed because the complaint did not allege sufficient facts to show a policy or custom of unconstitutional conduct or a failure to train. The court concluded that without a clearly established constitutional violation, the Monell claim could not succeed. View "Martinez v. Wayne Cnty., Mich." on Justia Law