Justia Civil Rights Opinion Summaries

The case involves a challenge to the constitutionality of private prisons in Arizona. The plaintiffs, the Arizona State Conference of the National Association for the Advancement of Colored People (NAACP) and two former prisoners, argued that private prisons, driven by profit, compromise safety and security and reduce programming and services. They also claimed that private prisons have a financial incentive to keep prisoners incarcerated longer by manipulating disciplinary proceedings.The United States District Court for the District of Arizona dismissed the case, leading to an appeal to the United States Court of Appeals for the Ninth Circuit. The district court held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights, the Thirteenth Amendment, the Eighth Amendment, and the Fourteenth Amendment's Equal Protection and Due Process Clauses.The Ninth Circuit affirmed the district court's decision. The court found that the NAACP had standing to bring the suit. However, it held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights. The court also found that the Thirteenth Amendment does not prohibit incarceration in a private prison, and that the plaintiffs failed to plausibly allege that confinement in a private prison violates the Eighth Amendment. Finally, the court held that the Fourteenth Amendment's Due Process and Equal Protection Clauses do not prohibit incarceration in a private prison. View "NIELSEN V. THORNELL" on Justia Law

The case involves the Roman Catholic Diocese of Albany and other entities, who provide medical insurance plans to their employees. They challenged a regulation by the Department of Financial Services, which requires New York employer health insurance policies that provide hospital, surgical, or medical expense coverage to include coverage for medically necessary abortion services. The plaintiffs argued that the exemption for "religious employers" was too narrow, violating the First Amendment rights of certain types of religiously affiliated employers who do not meet the terms of the exemption.The case began in 2016, raising a federal Free Exercise Claim that was similar to a previous case, Catholic Charities of Diocese of Albany v Serio. The lower courts dismissed the plaintiffs' complaints based on the principle of stare decisis, and the Appellate Division affirmed on the same ground. The plaintiffs appealed to the Supreme Court of the United States, which remanded the case to the Appellate Division to reconsider in light of a recent decision, Fulton v Philadelphia.On remand, the Appellate Division held that Serio was still good law and affirmed its previous decision that neither the medically necessary abortion regulation nor the "religious employer" exemption as defined violated the Free Exercise Clause. The Court of Appeals agreed, stating that under Fulton, both the regulation itself and the criteria delineating a "religious employer" for the purposes of the exemption are generally applicable and do not violate the Free Exercise Clause. The court concluded that the "religious employer" exemption survives the general applicability tests delineated in Fulton, and therefore, the Appellate Division order should be affirmed. View "Roman Catholic Diocese of Albany v Vullo" on Justia Law

This case involves a mistaken identification by two sheriff's office investigators, Joseph Bultman and Jon Hixon, who identified George Angel Harris as the individual captured on security camera footage using a stolen debit card. Based on this identification, Hixon obtained two arrest warrants for Harris for financial transaction card fraud. Harris was arrested and held in jail for a few hours before being released. The criminal case against him was eventually dismissed.Previously, Harris filed a lawsuit against the investigators under 42 U.S.C. § 1983, alleging they violated his Fourth Amendment rights by causing him to be falsely arrested and unlawfully detained without probable cause. The district court construed Harris' claims as ones for malicious prosecution and granted summary judgment in favor of the investigators on qualified immunity grounds.In the United States Court of Appeals for the Eleventh Circuit, Harris argued that the investigation leading to his arrest was inadequate, that the district court erred in excluding his expert's testimony about the unreasonableness of the investigation, and that Hixon's arrest affidavit was based on conclusory statements without supporting facts, making the warrants for his arrest constitutionally inadequate.The Court of Appeals affirmed the district court's decision. It held that the investigators' mistaken identification of Harris was a reasonable mistake and did not violate Harris' Fourth Amendment rights. The court also found that the district court did not abuse its discretion in excluding Harris' expert's testimony, as it would not have been helpful to a jury. Finally, the court held that even if the arrest warrant application was insufficient, the investigators had probable cause to arrest Harris based on their own knowledge and the brief period of Harris' detention. View "Harris v. Hixon" on Justia Law

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The case revolves around a local ordinance in the Borough of Camp Hill that regulates the display of signs on private property. The ordinance categorizes signs into about twenty different types, each with its own set of restrictions. Two residents, Katherine Pearson and Caroline Machiraju, displayed political signs on their lawns in the lead-up to the 2022 midterm elections. However, they were told to remove their signs as they violated the local sign ordinance. The ordinance categorized their signs as "Temporary Signs" and further classified them as "Personal Expression Signs," which express a non-commercial message. The ordinance limited the number of such signs a resident could display and the time frame within which they could be displayed.The residents complied with the directive but subsequently sued Camp Hill, challenging the provisions of the ordinance under the First Amendment. The United States District Court for the Middle District of Pennsylvania granted them summary judgment on their facial challenge, ruling that the provisions were content-based and failed strict scrutiny.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the ordinance was content-based as it classified signs based on their content, favoring commercial expression over noncommercial and holiday messages over non-holiday messages. The court held that such content-based restrictions could only stand if they furthered a compelling government interest and were narrowly tailored to achieve that interest. The court found that Camp Hill's interests in traffic safety and aesthetics, while legitimate, were not compelling and that the ordinance was not narrowly tailored to serve those interests. The court concluded that the ordinance was unconstitutional on its face. View "Camp Hill Borough Republican Association v. Borough of Camp HIll" on Justia Law

Five registered gun owners in California challenged a state law, Assembly Bill 173 (AB 173), which permits the California Department of Justice (DOJ) to share information from its databases about firearm and ammunition purchasers and concealed carry weapon (CCW) permit holders with accredited research institutions. The plaintiffs argued that the law violated their right to informational privacy under the Fourteenth Amendment, their Second Amendment right to keep and bear arms, and the federal Privacy Act.The district court dismissed the case, finding that the plaintiffs failed to state a claim for violation of the right to informational privacy. The court reasoned that the personal information in the DOJ's databases was not highly sensitive or intimate and that the plaintiffs had no reasonable expectation that such information would never be disclosed. The court also found that AB 173 did not restrict conduct protected by the Second Amendment, as it did not impede the plaintiffs' ability to purchase, keep, carry, or use firearms. The court further held that AB 173 was not unconstitutionally retroactive, as it did not attach new legal consequences to past conduct. Finally, the court rejected the plaintiffs' claim that the Privacy Act preempted two California statutes relating to CCW permit applications, as neither statute required the disclosure of social security numbers.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision, agreeing with its findings and reasoning. The court held that the plaintiffs failed to state a claim for violation of the right to informational privacy, the Second Amendment, or the Privacy Act. View "JANE DOE V. BONTA" on Justia Law

DC Operating, a strip club in El Paso, Texas, and two of its employees, Nuvia Medina and Michelle Corral, challenged the constitutionality of S.B. 315, a Texas law that raised the minimum age of employment at sexually-oriented businesses from 18 to 21. The law was enacted to curb human trafficking. The plaintiffs argued that the law infringed on the employees' constitutional rights to expressive interest in nude dancing and occupational freedom. They also raised a claim of sex discrimination under the Equal Protection Clause for the first time on appeal.The United States District Court for the Western District of Texas upheld the constitutionality of S.B. 315, following similar rulings in other cases. The plaintiffs then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit dismissed the appeal for lack of jurisdiction. The court found that DC Operating lacked standing to bring the appeal because it did not assert any legal interests of its own, only those of its employees. The court noted that a plaintiff must assert its own legal rights and interests and cannot rest its claim to relief on the legal rights or interests of third parties. The court also found that the overbreadth claim brought by DC Operating did not alter the standing analysis because the plaintiff still needed to satisfy Article III requirements.Furthermore, the court found that the appeal was moot as to the two employees, Medina and Corral, because they had turned 21 and were no longer subject to the law they were challenging. The plaintiffs did not argue that the employees' claims remained justiciable or that an exception to mootness applied. Therefore, the court dismissed the appeal for lack of jurisdiction. View "DC Operating v. Paxton" on Justia Law

The Greenwald Family Limited Partnership, a landowner in the Village of Mukwonago, Wisconsin, had a longstanding positive relationship with the Village, collaborating on several development projects. However, this relationship soured after a failed land deal in 2014 and several other conflicts. The Partnership sued the Village, alleging that it had been irrationally singled out for unfavorable treatment, violating its Fourteenth Amendment rights. The Partnership pointed to several adverse municipal decisions, focusing primarily on the failed land deal and a new road that was rerouted from the Partnership’s property.The case was initially filed in state court but was later removed to federal court. The district court concluded that the Village had a rational basis for its actions regarding the failed land deal, the new road, and other decisions affecting the Partnership’s properties. The court entered summary judgment in favor of the Village and relinquished jurisdiction over the state-law claims.The case was then brought before the United States Court of Appeals for the Seventh Circuit. The court affirmed the district court's decision, stating that the Partnership had failed to show that the Village’s actions lacked any conceivable rational basis. The court found that the Village’s decisions were rationally related to its legitimate interests in promoting its land-use objectives and protecting public funds. The court concluded that the Partnership was a disappointed landowner, but not a victim of unconstitutional discrimination. View "Greenwald Family Limited Partnership v. Village of Mukwonago" on Justia Law

The case involves a challenge to the provisions of the Bipartisan Safer Communities Act of 2022, which expanded background checks for firearm purchases by individuals aged 18 to 20. The plaintiffs, Ethan McRorey, Kaylee Flores, Gun Owners of America, Inc., and Gun Owners Foundation, argued that the government failed to show a historical analogue for the Act's expanded background checks for this age group. They filed a lawsuit requesting a preliminary injunction after their attempts to purchase shotguns were delayed due to the National Instant Criminal Background Check System (NICS) protocols.The United States District Court for the Northern District of Texas denied the plaintiffs' request for a preliminary injunction. The court reasoned that while adults aged 18 to 20 are protected by the Second Amendment, laws barring the mentally ill and felons from possessing firearms are constitutional, and restrictions to further those ends are presumptively lawful. Therefore, the plaintiffs lacked a substantial likelihood of success on the merits and were not entitled to preliminary relief.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court held that background checks preceding firearm sales are presumptively constitutional, and the plaintiffs failed to rebut that presumption. The court also found that the plaintiffs had not shown that the challenged regulations had been put towards abusive ends or had otherwise rebutted the presumption of lawfulness. The court concluded that a period of 10 days for background checks does not qualify as being put towards abusive ends or as a de facto prohibition on possession. View "McRorey v. Garland" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law