Justia Civil Rights Opinion Summaries

A police dispatcher who worked for a Michigan city alleged that she and other female dispatchers were required to conduct searches of female arrestees, even when female officers were available, exposing them to health and safety risks. The department did not have a similar policy for male dispatchers. In 2020, the dispatcher and several colleagues filed a lawsuit alleging sex discrimination. Eleven days after filing, the dispatcher became the subject of an Internal Affairs investigation, which ultimately led to her termination for violating department policy by using a case-management system for personal reasons. She later settled with the department, resulting in her reinstatement with a demotion, suspension, and loss of promotion eligibility.Following these events, the dispatcher filed a second lawsuit in the United States District Court for the Eastern District of Michigan, claiming that the city and its police commissioner retaliated against her for exercising her First Amendment rights by filing the original lawsuit. She also brought a claim under Michigan’s Elliott-Larsen Civil Rights Act. The district court granted summary judgment to the city on the retaliation claim, finding no municipal liability, but denied summary judgment to the commissioner in his individual capacity, holding that there was a genuine issue of material fact regarding causation. The commissioner appealed, asserting qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that the dispatcher alleged legally cognizable adverse actions and that her right to be free from retaliation for protected speech was clearly established. The court affirmed the district court’s denial of qualified immunity to the commissioner and dismissed the remainder of the appeal for lack of appellate jurisdiction over factual disputes. The court declined to exercise pendent appellate jurisdiction over the state-law claims. View "DeVooght v. City of Warren" on Justia Law

An armed fugitive fleeing law enforcement entered a print shop owned by the plaintiff, forcibly removed him, and barricaded himself inside. After a thirteen-hour standoff, Los Angeles Police Department SWAT officers used dozens of tear gas canisters to subdue the fugitive, causing significant damage to the shop and its contents. The parties agreed that the officers’ actions were authorized, reasonable, and lawful. The plaintiff alleged that the damages, which exceeded $60,000, were caused exclusively by the police.The plaintiff initially sought compensation from the United States Marshals Service, which denied the claim and referred him to the City of Los Angeles. After the City did not respond to his claims or his attorney’s letter, the plaintiff filed a federal lawsuit under 42 U.S.C. § 1983, asserting a violation of the Fifth Amendment’s Takings Clause. The City moved for judgment on the pleadings, arguing that the Takings Clause does not require compensation for property destroyed by police acting reasonably in an emergency. The United States District Court for the Central District of California denied the City’s initial motion but later granted summary judgment for the City, finding that the destruction was a valid exercise of police power and not a compensable taking.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The court held that the government’s destruction of private property, when necessary and reasonable for public safety, is exempt from the Takings Clause. The court relied on historical understanding and longstanding precedent, concluding that such actions fall outside the scope of the Takings Clause. Accordingly, the Ninth Circuit affirmed the district court’s judgment, holding that the plaintiff failed to state a claim for a compensable taking under the Fifth Amendment. View "PENA V. CITY OF LOS ANGELES" on Justia Law

Bartlesville, Oklahoma police officers responded to a domestic disturbance call at the home of Willis Gay Jr., who reported his son Thomas Gay was behaving erratically and possibly under the influence of drugs. Willis informed the officers that Thomas was unarmed but had made furtive movements toward his back pocket. Upon entering the home, the officers observed Thomas holding an innocuous object and appearing disoriented. Officer Lewis immediately pointed his Taser at Thomas and, after a single command, tased him. Officer Pitts drew her firearm. Thomas retreated into a bedroom, where Officer Lewis tased him again, but the Taser failed to incapacitate him. A brief struggle ensued, and as Thomas moved toward the bedroom door, making a motion toward his back pocket, Officer Pitts shot him twice, resulting in his death within minutes of the officers’ arrival.The Estate of Thomas Gay sued the officers in their individual capacities under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. The officers moved for summary judgment, asserting qualified immunity. The United States District Court for the Northern District of Oklahoma denied the motion, finding that disputed facts could allow a reasonable jury to conclude the officers violated Thomas’s clearly established constitutional rights. The court determined that a reasonable jury could find Thomas was unarmed and not holding any object when shot, and that the officers’ actions were not objectively reasonable.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity. The appellate court held it lacked jurisdiction to revisit the district court’s factual determinations, as the record did not blatantly contradict those findings and no legal error was committed. The court further held that, under clearly established law, the officers’ use of force was objectively unreasonable, precluding qualified immunity. View "Burke v. Pitts" on Justia Law

Late one night in Santa Fe, New Mexico, Jason Roybal led police officers on a low-speed chase in a stolen car. After stopping, Roybal leaned out of his vehicle and fired a BB gun at the officers. The officers responded by firing their guns. Roybal then exited his car, dropped the BB gun, and fled on foot toward a civilian-occupied vehicle. The officers shot and killed Roybal as he was running away. The personal representative of Roybal’s estate filed suit under 42 U.S.C. § 1983, alleging that the officers used excessive force in violation of the Fourth Amendment, specifically claiming that Roybal was unarmed and fleeing when he was shot.The case was initially filed in New Mexico state court, then removed to the United States District Court for the District of New Mexico. The officers moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), asserting qualified immunity and arguing that the complaint omitted key facts, such as Roybal firing a BB gun and running toward an occupied car. They also asked the district court to consider dash- and body-camera footage. The district court denied the motion to dismiss, ruling that it could not consider the videos at this stage and that the complaint plausibly alleged a Fourth Amendment violation.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of the motion to dismiss. The Tenth Circuit held that the district court properly refused to consider the video evidence at the motion-to-dismiss stage and that the complaint plausibly alleged a violation of Roybal’s clearly established right to be free from excessive force under the Fourth Amendment. The court found that, accepting the complaint’s allegations as true, the officers’ conduct was not justified by the circumstances described, and the right at issue was clearly established by precedent. View "Fuqua v. Santa Fe County Sheriff's Office" on Justia Law

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

Mary Timmins worked as general counsel and litigation counsel for the Green Mountain Water and Sanitation District in Colorado. During her employment, she discovered that certain members of the District’s Board were engaging in conduct she believed to be corrupt and potentially unlawful, including violating open meetings laws, improperly communicating with a state-employed attorney, and destroying public records relevant to ongoing litigation. After repeatedly warning the Board internally without effect, Timmins disclosed her concerns to reporters and private citizens, alleging that the Board members were acting against the interests of the District and its residents. She was subsequently terminated from her position.Timmins filed suit in the United States District Court for the District of Colorado against the District and three Board members, asserting a claim under 42 U.S.C. § 1983 for First Amendment retaliation. The district court dismissed her claim under Federal Rule of Civil Procedure 12(b)(6), concluding that her speech was not protected by the First Amendment because it was made pursuant to her official duties as a public employee. The court reasoned that her statements to the press and private citizens were essentially identical to those made in her official capacity and stemmed from her work responsibilities.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissal de novo. The Tenth Circuit held that Timmins’s speech to reporters and private citizens was not made pursuant to her official duties, as her job did not ordinarily require her to make such disclosures outside the chain of command. The court reversed the district court’s dismissal of Timmins’s amended complaint and remanded the case for further proceedings, declining to address alternative grounds for affirmance at this stage. View "Timmins v. Plotkin" on Justia Law

A professor at a public university alleged that several university administrators violated his First Amendment rights. The professor, known for his outspoken criticism of university policies and administrators on social media and in public forums, claimed that university officials attempted to silence him. He asserted that they threatened his job security, pay, research opportunities, and academic freedom, and that a university employee requested police surveillance of his speech. The professor stated that these actions caused him to self-censor, including making his social media account private and ceasing to post, out of concern for potential retaliation.The United States District Court for the Western District of Texas reviewed the case after the professor filed suit under 42 U.S.C. § 1983, alleging both retaliation for protected speech and the existence of an unwritten speech code that chilled his speech. The district court dismissed the retaliation claim, finding that the professor had not sufficiently alleged an adverse employment action, and granted summary judgment on the chilled-speech claim for the same reason. The court also dismissed the claim regarding the unwritten speech code, concluding that the professor had not adequately alleged a facial or as-applied First Amendment violation. Additionally, the court resolved two discovery disputes in favor of the university.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the professor had standing to bring his claims but could not prevail on the merits. The court determined that, under established Fifth Circuit precedent, a First Amendment retaliation claim requires an adverse employment action, which the professor did not experience. The court also found that the chilled-speech claim was not distinct from the retaliation claim and failed for the same reason. The court further held that the allegations regarding an unwritten speech code were too conclusory to state a plausible claim. The court upheld the district court’s discovery rulings, finding no abuse of discretion or prejudice. The judgment was affirmed. View "Lowery v. Mills" on Justia Law

Legacy Housing Corporation purchased several hundred vacant lots in Horseshoe Bay, Texas, intending to develop manufactured housing. The lots were subject to zoning restrictions, including a cap on speculative housing permits, contractor requirements, utility hookup fees, and setback rules. Legacy also acquired adjacent land in the city’s extraterritorial jurisdiction (ETJ) to build a road connecting the lots to a nearby highway, but this land was restricted to agricultural and residential use. Despite these limitations, Legacy constructed a road over the ETJ property, a greenbelt strip, and some development lots, advertising it as a shortcut and access to planned amenities. The City and other defendants opposed the road, citing violations of existing restrictions. Legacy alleged a conspiracy among the City, the property owners’ association (POA), and developers to prevent its development.The United States District Court for the Western District of Texas addressed multiple claims and counterclaims. It denied Legacy’s motion to dismiss the City’s counterclaims, granted the City’s motion to dismiss most claims against it, and granted summary judgment to all defendants on the remaining claims, including regulatory takings, Section 1983 violations, civil conspiracy, breach of fiduciary duty, negligence, and a strips and gores claim. Legacy’s own motion for partial summary judgment was denied, and final judgment was entered.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s rulings, with one modification. The appellate court held that Legacy’s regulatory takings claim regarding the two-permit cap was not prudentially ripe and should be dismissed without prejudice. The court otherwise affirmed summary judgment for the defendants, finding no genuine dispute of material fact and concluding that Legacy did not have property rights to build the road, nor did the defendants breach any legal duties or restrictive covenants. View "Legacy Hsing v. City of Horseshoe Bay" on Justia Law

A man committed several felonies in New York and Virginia between 2000 and 2001. After serving his prison sentences, he was subject to both state and federal post-release supervision. He repeatedly violated the terms of his supervision, resulting in multiple periods of reincarceration. In 2006, the United States Court of Appeals for the Second Circuit held in Earley v. Murray that New York’s practice of administratively imposing post-release supervision without a judicial pronouncement was unconstitutional. The state legislature responded in 2008 by authorizing corrections officials to initiate resentencing proceedings. The plaintiff was incarcerated in New York from June 2007 to February 2008 for violating post-release supervision, and again in 2010, before being resentenced without post-release supervision.The United States District Court for the Eastern District of New York dismissed the plaintiff’s claims for damages related to his 2010 incarceration, finding the defendants acted reasonably at that time, but allowed claims related to the 2007-08 incarceration to proceed to trial. At trial, the defendants were barred from introducing evidence that legal and administrative obstacles prevented them from initiating resentencing for the plaintiff during 2007-08. The jury awarded the plaintiff $100,000 in compensatory and $750,000 in punitive damages. The district court denied the defendants’ motion for a new trial and rejected their qualified immunity defense for the 2007-08 period.The United States Court of Appeals for the Second Circuit held that the district court abused its discretion by excluding evidence of impediments to resentencing and erred in denying a new trial for the 2007-08 period. The court reversed the denial of a new trial for that period, vacated the dismissal of the 2010 claims on qualified immunity grounds, and remanded for further proceedings. The court also held that qualified immunity was properly denied for both periods under existing precedent. View "Santiago v. Fischer" on Justia Law

A group of voters in Tarrant County, Texas, challenged the county’s decision to redraw the boundaries of its four commissioners precincts in 2025, a process that occurred outside the usual post-census redistricting cycle. The new map, adopted by a narrow 3–2 vote, shifted a significant number of voters—disproportionately Black, Latino, and Democratic—into precincts that would not hold commissioner elections until 2028, effectively postponing their opportunity to vote for a county commissioner by two years. The plaintiffs, who are racially diverse, argued that the redistricting was intended to harm racial minorities and Democratic voters, and that the mid-cycle timing unlawfully disenfranchised certain residents.The United States District Court for the Northern District of Texas denied the plaintiffs’ request for a preliminary injunction to block the use of the new map in the 2026 election. The district court dismissed the First Amendment claims as nonjusticiable under Supreme Court precedent, but allowed the race discrimination and vote postponement claims to proceed, ultimately finding that the plaintiffs had not shown a likelihood of success on the merits.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s denial of a preliminary injunction. The Fifth Circuit held that claims of partisan gerrymandering are nonjusticiable in federal court, even when staggered elections result in some voters’ ballots being postponed. The court further held that the plaintiffs had not demonstrated that race was a motivating factor in the adoption of the new map, applying the Arlington Heights framework and finding no clear error in the district court’s assessment of the evidence. Finally, the court concluded that postponement of voting opportunities due to redistricting in a staggered election system does not violate the Constitution, as there is no right to vote on a particular schedule. View "Jackson v. Tarrant County" on Justia Law