Justia Civil Rights Opinion Summaries

The Eighth Circuit held that the district court did not abuse its discretion in granting preliminary injunctions enjoining enforcement of the Gestational Age Provisions and the Down Syndrome Provision of Missouri House Bill 126. The Gestational Age Provision provides, in relevant part, that "no abortion shall be performed or induced upon a woman at eight weeks gestational age or later, except in cases of medical emergency." The Down Syndrome Provision prohibits abortions if the provider "knows that the woman is seeking the abortion solely because of a prenatal diagnosis, test, or screening indicating Down [s]yndrome or the potential of Down [s]yndrome in an unborn child."As a preliminary matter, the court concluded that RHS has standing because the provisions at issue directly target physician conduct and put physicians at risk of civil and criminal sanctions. The court concluded that the Gestational Age Provisions do not merely have "the incidental effect of making it more difficult or more expensive to procure an abortion" before viability. Rather, the Gestational Age Provisions are bans, and the court agreed with the district court that RHS is likely to succeed on the merits of this claim. The court also concluded that, unlike a regulation, the Down Syndrome Provision does not set a condition that—upon compliance—makes the performance of a pre-viability abortion lawful, thus preserving the constitutional right to elect the procedure. Rather, it bans access to an abortion entirely. Therefore, RHS is likely to succeed on the merits of its challenge to the Down Syndrome Provision. The court concluded that the remaining Dataphase factors - irreparable harm, balance of hardships and public interest - also supported the grant of the preliminary injunction. View "Reproductive Health Services of Planned Parenthood of the St. Louis Region, Inc. v. Parson" on Justia Law

Plaintiffs, four Black firefighters who suffer from a skin condition that causes pain and sometimes scarring when they shave their facial hair, filed suit alleging that the FDNY discriminated against them in violation of the Americans with Disabilities Act (ADA), Title VII of the Civil Rights Act of 1964, and various other laws. Plaintiffs' claims stemmed from the FDNY's refusal to offer them a medical accommodation to the department's grooming policy. The policy requires firefighters to be clean shaven in the areas where an oxygen mask or "respirator" seals against their skin.The Second Circuit reversed the district court's grant of summary judgment in favor of plaintiffs on their ADA claim, holding that the OSHA regulation, 29 C.F.R. 1910.134(g)(1)(i)(A), unambiguously prohibits plaintiffs' proposed accommodation and that a binding federal regulation presents a complete defense to an ADA failure-to-accommodate claim. Furthermore, plaintiffs waived the issue of alternative accommodation because they failed to raise it until their reply brief on appeal. The court also concluded that plaintiffs' Title VII disparate impact claim mirrors their ADA claim and meets a similar fate. The court explained that, although plaintiffs have made a prima facie case, the FDNY has conclusively rebutted that case by showing that complying with the respiratory-protection standard is a business necessity. Just as in the ADA context, the court concluded that Title VII cannot be used to require employers to depart from binding federal regulations. Nor can the court agree with plaintiffs that the FDNY's failure to consistently enforce the respiratory-protection standard means that complying with the regulation is not a business necessity. Accordingly, the court affirmed in part and reversed in part. View "Bey v. City of New York" on Justia Law

After Houston Methodist fired plaintiff following a job candidate's allegation that he had sexually harassed him, plaintiff filed suit against Houston Methodist for sex discrimination, retaliation, and race discrimination under Title VII.The Fifth Circuit affirmed the district court's dismissal of the sex discrimination and retaliation claims because plaintiff failed to exhaust his administrative remedies. In this case, plaintiff failed to establish that he satisfied the EEOC verification requirements for a charge. The court also affirmed the district court's grant of summary judgment on the race discrimination claim where plaintiff failed to show that he was replaced or that a comparator received more favorable treatment. View "Ernst v. Methodist Hospital" on Justia Law

The Supreme Court affirmed Defendant's conviction of the sexual abuse of a nine-year-old girl and upheld the constitutionality of his sentence requiring lifetime GPS monitoring, holding that there was no reversible error.Specifically, the Supreme Court held (1) the district court erred to the extent it admitted the victim's taped forensic interview as a prior consistent statement, but there was not a reasonable possibility that the forensic interview contributed to Defendant's conviction; (2) Defendant did not sustain his burden to demonstrate that the prosecutor's closing arguments justified reversal of his conviction for plain error; and (3) the requirement for GPS monitoring imposed by Mont. Code Ann. 45-5-625(4)(b) is not facially unconstitutional under either the Montana or the United States Constitutions. View "State v. Smith" on Justia Law

The First Circuit affirmed the judgment of the district court holding that the Federal National Mortgage Association (Fannie Mae) and the Federal Housing Finance Agency (FHFA) were not subject to Appellants' Fifth Amendment claims, holding that there was no error.Appellants obtained loans secured by mortgages on their real property in Rhode Island. The loans and mortgages were later sold to Fannie Mae while the FHFA was acting as Fannie Mae's conservator. Consistent with Rhode Island law, when Appellants defaulted on their loans Fannie Mae conducted nonjudicial foreclosure sales of the mortgaged properties. Appellants brought suit in a federal district court, arguing that the nonjudicial foreclosure sales violated their procedural due process rights under the Fifth Amendment. The district court dismissed those claims. The First Circuit affirmed, holding that FHFA and Fannie Mae were not government actors subject to Appellants' due process claims. View "Montilla v. Federal National Mortgage Ass'n" on Justia Law

The Fourth Circuit held that "job sharing" a single full-time position with a willing partner does not qualify as a reasonable accommodation that an employer must provide under the Americans with Disabilities Act (ADA). The court explained that, if the job share in question did not exist at the time it was proposed as an accommodation, the ADA does not require the employer to create the new position to accommodate a disabled employee.In this case, the court concluded that providing plaintiff with the job share position with another employee was not a reasonable accommodation required by the ADA—not because the position was not "vacant" but because the position she sought did not exist. Therefore, summary judgment should have been granted to Sanofi on plaintiff's failure-to-accommodate claim on this ground. Furthermore, because plaintiff failed to demonstrate the existence of a reasonable accommodation, Sanofi cannot separately be liable for failing to engage in the interactive process. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Sanofi. View "Perdue v. Sanofi-Aventis U.S., LLC" on Justia Law

The Ninth Circuit filed (1) an order granting respondent's petition for panel rehearing and denying as moot her petition for rehearing en banc, (2) a superseding opinion affirming the district court's denial of petitioner's habeas corpus petition challenging his California conviction for first-degree murder, and (3) a partial dissent/concurrence.The panel concluded that the prosecutor's repeated statements to the jury during final argument that the presumption of innocence no longer applied were misstatements of clearly established law as articulated by the Supreme Court. However, the panel deferred to the state court's finding, applying the Darden standard, that there was not a reasonable probability of a different outcome had the prosecutor not misstated the law. The panel also concluded that the state court did not err under Dunn v. United States, 442 U.S. 100 (1979), in upholding the jury's arguably inconsistent verdict. Accordingly, the panel affirmed the district court's denial of relief. View "Ford v. Peery" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

Plaintiff, who seeks to knock down his beachfront mansion and to build a new one, filed suit against the town, claiming that the criteria the town's architectural review commission used to deny his building permit violated his First Amendment free speech rights and his Fourteenth Amendment rights to due process and equal protection. In this case, plaintiff wants to knock down his "traditional" beachfront mansion and to build a new one, almost twice its size, in the midcentury modern style. The district court granted summary judgment in favor of the town.The Eleventh Circuit concluded that summary judgment was not granted too early and affirmed on the First Amendment claim because there was no great likelihood that some sort of message would be understood by those who viewed plaintiff's new beachfront mansion. The court also affirmed the district court's summary judgment on the Fourteenth Amendment claims because the commission's criteria were not unconstitutionally vague and plaintiff has not presented evidence that the commission applied its criteria differently for him than for other similarly situated mansion-builders. View "Burns v. Town of Palm Beach" on Justia Law