Justia Civil Rights Opinion Summaries

Amelia Baca, a 75-year-old woman with dementia, was fatally shot by Officer Jared Cosper in Las Cruces, New Mexico. On April 16, 2022, Baca's daughter called 911, reporting that Baca had become aggressive and threatened to kill her and her daughter. Officer Cosper, who was nearby, responded to the call. Upon arrival, he saw Baca holding knives and ordered her to drop them. Baca did not comply and took two slow steps towards Cosper, who then shot her twice, resulting in her death.The Estate of Amelia Baca filed a complaint in the United States District Court for the District of New Mexico, alleging that Officer Cosper used excessive force in violation of the Fourth Amendment. The district court granted summary judgment in favor of Cosper on qualified immunity grounds, concluding that the Estate had not raised a genuine dispute of material fact regarding Cosper's perception of an immediate threat.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court concluded that the district court erred in granting summary judgment. Viewing the evidence in the light most favorable to the Estate, the Tenth Circuit determined that a reasonable jury could find a Fourth Amendment excessive-force violation. The court also held that such a violation was clearly established under controlling law at the time of the shooting. Consequently, the Tenth Circuit reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Baca v. Cosper" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

A transgender woman, Darlene Griffith, filed a civil rights lawsuit regarding her pretrial confinement at the El Paso County Jail in Colorado. She alleged that the jail's policies, which assigned housing based on genitalia and denied her access to female clothing and products, violated her constitutional rights and the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court dismissed her complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), leading to this appeal.The United States District Court for the District of Colorado dismissed Ms. Griffith’s complaint, concluding that she failed to state a plausible claim for relief. The court applied rational-basis review to her Equal Protection claim, finding that transgender individuals are not a protected class under existing precedent. The court also dismissed her ADA and Rehabilitation Act claims for lack of subject matter jurisdiction, as she did not properly name the county as a defendant according to state law requirements.The United States Court of Appeals for the Tenth Circuit reviewed the case and concluded that remand was required for some of Ms. Griffith’s claims. The court reversed and remanded for further proceedings on her Fourteenth Amendment Equal Protection claim against Sheriff Elder in his official capacity, her Fourth and Fourteenth Amendment cross-gender search claims against Sheriff Elder in his official capacity, and her Fourth Amendment abusive search claim against Deputy Mustapick. The court vacated the district court’s order dismissing Ms. Griffith’s ADA and Rehabilitation Act claims under Rule 12(b)(6) because those claims were dismissed without prejudice for lack of subject matter jurisdiction under Rule 12(b)(1), and that ruling was unchallenged on appeal. The court otherwise affirmed the district court’s dismissal of the remaining claims. View "Griffith v. El Paso County, Colorado" on Justia Law

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law

A bakery refused to sell a predesigned white cake to a same-sex couple for their wedding reception, citing a policy against providing cakes for same-sex weddings based on the owner's religious beliefs. The California Civil Rights Department (CRD) filed a lawsuit on behalf of the couple, alleging discrimination under the Unruh Civil Rights Act (UCRA). The trial court ruled in favor of the bakery, finding no violation of the UCRA because the CRD failed to prove intentional discrimination and concluded that referring the couple to another bakery constituted full and equal access under the UCRA. The trial court also considered the bakery's First Amendment defenses, concluding that the UCRA compelled the bakery to speak a message about marriage to which they objected.The CRD appealed, challenging the trial court's interpretation and application of the UCRA and its conclusions regarding the bakery's affirmative defenses. The California Court of Appeal reviewed the case and determined that the bakery's policy was not facially neutral and misconstrued the intentional discrimination standard. The court found that the policy was inherently discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court also concluded that referring the couple to another bakery did not satisfy the UCRA's full and equal access requirement.The court further analyzed the bakery's First Amendment defenses, determining that the cake in question did not constitute pure speech or expressive conduct protected by the First Amendment. The court found that the cake was a generic, multi-purpose product and that its preparation and delivery did not convey any particularized message about marriage. Additionally, the court concluded that the UCRA is a neutral and generally applicable law that satisfies rational basis review and does not violate the bakery's free exercise of religion under the federal or state constitutions.The California Court of Appeal reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

A high school student, K.J., was involved in a fight on campus and was initially suspended for three days. After reviewing surveillance footage and learning about injuries sustained during the fight, school officials extended K.J.'s suspension and recommended his expulsion, without informing him of the new charges or evidence. K.J. was not given an opportunity to respond to these new allegations.The United States District Court for the Southern District of California found that the school officials violated K.J.'s procedural due process rights by not informing him of the new charges or evidence. However, the court granted summary judgment in favor of the defendants, holding that they were entitled to qualified immunity because the law was not clearly established regarding due process protections for suspension extensions. The court also held that K.J. lacked standing to seek expungement of his disciplinary record, as it was speculative that the record would harm his reputation or future prospects.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment. The Ninth Circuit agreed that K.J.'s due process rights were violated, as he was not given notice of the new charges or an opportunity to respond. The court held that the defendants were not entitled to qualified immunity because the requirements for due process in school suspensions were clearly established in Goss v. Lopez. The court also held that K.J. had standing to seek expungement of his disciplinary record and that such relief was not barred by Eleventh Amendment sovereign immunity. The case was remanded to the district court to consider K.J.'s claims for damages and expungement. View "K. J. V. JACKSON" on Justia Law

Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law