Justia Civil Rights Opinion Summaries

Plaintiffs David Moore and David Ermold sued Kim Davis, the clerk of Rowan County, Kentucky, under 42 U.S.C. § 1983 for refusing to issue them a marriage license, claiming it violated their constitutional right to marry. This refusal occurred after the Supreme Court's decision in Obergefell v. Hodges, which legalized same-sex marriage nationwide. Davis, citing her religious beliefs, stopped issuing all marriage licenses until the state provided her with an accommodation. Plaintiffs sought damages for the emotional distress caused by Davis's actions.The United States District Court for the Eastern District of Kentucky ruled in favor of the plaintiffs on liability, and a jury awarded them compensatory damages. Davis appealed, arguing she was entitled to qualified immunity, had defenses under the Free Exercise Clause and the Kentucky Religious Freedom Restoration Act (RFRA), and that the evidence of emotional distress was insufficient to support the jury's award.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Davis was not entitled to qualified immunity because Obergefell clearly established the right to same-sex marriage, and Davis's actions violated that right. The court also rejected Davis's Free Exercise Clause defense, stating that the First Amendment does not protect state actions that violate constitutional rights. Additionally, the court found that Kentucky's RFRA did not apply in this case because the state was not a party to the lawsuit.The court further upheld the jury's award of damages, finding that the plaintiffs provided sufficient evidence of emotional distress. The court noted that the plaintiffs' detailed testimony about their emotional harm was corroborated and not merely conclusory. Davis's request for remittitur was not considered because it was raised for the first time in her reply brief. The Sixth Circuit thus affirmed the district court's judgment in favor of the plaintiffs. View "Ermold v. Davis" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

Reed Day and Albert Jacobs, Arizona residents, wanted to ship wine directly from out-of-state retailers who do not have in-state premises in Arizona. Arizona law, however, requires retailers to have a physical presence in the state to ship wine directly to consumers. Plaintiffs filed a civil rights action under 42 U.S.C. § 1983 against Arizona state officials, claiming that this statutory scheme violates the Commerce Clause.The United States District Court for the District of Arizona granted summary judgment in favor of the state officials and the intervenor-defendant, the Wine and Spirits Wholesalers Association of Arizona. The district court found that the plaintiffs likely lacked standing and that, even if they did, the Arizona laws were not discriminatory. The court reasoned that the physical presence requirement applied equally to in-state and out-of-state retailers and was essential to Arizona’s three-tier system for alcohol distribution.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the plaintiffs had standing because the district court could grant some form of relief. However, the court found that the plaintiffs failed to show that Arizona’s physical presence requirement was discriminatory. The requirement applied even-handedly to all retailers, regardless of their state of origin, and was not so onerous as to be discriminatory. The court noted that out-of-state businesses could and did obtain retail licenses in Arizona, indicating that the laws did not have a discriminatory effect in practice. The court concluded that Arizona’s laws did not violate the dormant Commerce Clause. View "Day v. Henry" on Justia Law

Ryan Smith was shot and killed by Seattle police officers Christopher Myers and Ryan Beecroft during a response to a 911 call from Smith's girlfriend, Katy Nolan, who reported that Smith was threatening to kill both himself and her with a knife. When the officers arrived, they kicked in the door to Smith's apartment, and within 5.87 seconds, they shot Smith, who was holding a pocketknife. Smith raised his right arm across his chest and took a step forward before being shot. The officers did not issue any warnings before using deadly force.The United States District Court for the Western District of Washington denied the officers' motion for partial summary judgment based on qualified immunity. The district court found that there were factual disputes regarding whether a reasonable officer would have believed Smith posed an immediate threat and whether less drastic measures were feasible. The court concluded that the law was clearly established that officers may not use deadly force against suspects who do not pose an immediate threat.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that it had jurisdiction over the interlocutory appeal and that, viewing the evidence in the light most favorable to the plaintiffs, the officers were not entitled to qualified immunity. The court determined that a reasonable juror could conclude that Smith did not pose an immediate threat to the officers or others, and that the use of deadly force was not justified. The court emphasized that it was clearly established law that a fatal shooting under these circumstances violated the Fourth Amendment. The Ninth Circuit affirmed the district court's denial of qualified immunity. View "JOHNSON V. MYERS" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

Chanon Miller was arrested by deputies from the Palm Beach County Sheriff’s Office for simple battery against her ex-fiancé. She subsequently sued the Sheriff’s Office and unnamed deputies, alleging violations of her constitutional right to be free from unreasonable seizure, including claims of false arrest, false imprisonment, and malicious prosecution. Miller's complaint was amended to name specific deputies as defendants.The United States District Court for the Southern District of Florida denied the deputies' motion to dismiss based on qualified immunity, stating that the issue was more appropriately resolved at the summary judgment stage or later in the proceedings. The court found that Miller's allegations were sufficient to state a plausible claim for relief and allowed her to file an amended complaint naming the appropriate defendants. The district court reiterated its position when the deputies renewed their motion to dismiss after being named in the amended complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court erred by failing to adjudicate the defense of qualified immunity at the motion to dismiss stage. The appellate court emphasized that qualified immunity is an immunity from suit, not just a defense to liability, and must be resolved at the earliest possible stage in litigation. The court vacated the district court’s order and remanded the case with instructions to rule on the deputies' entitlement to qualified immunity, requiring a claim-by-claim and defendant-by-defendant analysis. View "Miller v. Ramirez" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law