Justia Civil Rights Opinion Summaries

Plaintiff filed suit against his former employer, the City of Newport News, alleging that it failed to accommodate his disability in violation of the Americans with Disabilities Act (ADA). Plaintiff alleged that the City concluded that he could not perform the essential functions of his job as a detective and then offered him the options of either retiring early or accepting reassignment to a civilian position he did not want. Plaintiff reluctantly retired.The Fourth Circuit vacated the district court's grant of summary judgment in favor of the City, concluding that it is generally inappropriate for an employer to unilaterally reassign a disabled employee to a position the employee does not want when another reasonable accommodation exists that would allow the disabled employee to remain in their current, preferred position. The court clarified that it did not hold that an employer can never reassign an employee when there exists a reasonable accommodation that will keep the employee in their current and preferred position. This broad question was not before the court. Nor should this opinion be read in any way to restrict the ability of employers and employees to agree to a voluntary transfer. Rather, the court simply reiterated that reassignment is strongly disfavored when an employee can still do their current job with the assistance of a reasonable accommodation, and that reassignment should therefore be held "in reserve for unusual circumstances." View "Wirtes v. City of Newport News" on Justia Law

Plaintiff and his wife filed suit against defendants alleging claims related to the kidnapping and murder of Jacob E. Wetterling. Jacob was abducted at the end of plaintiff's wife's driveway. Plaintiff asserted First Amendment retaliation, a derivative claim for municipal liability, and state law claims for defamation and intentional infliction of emotional distress.The Eighth Circuit concluded that the district court did not err in determining that plaintiff's 42 U.S.C. 1983 was time-barred by the six year statute of limitations under Minnesota law. The court also concluded that the district court did not err in determining that the defamation claim and intentional infliction of emotional distress claim were time-barred by the two-year statute of limitations under Minnesota law. In this case, plaintiff's claims accrued in 2010, when the alleged tortious acts of naming plaintiff as a person of interest and searching plaintiff and his wife's property occurred, regardless of when they believed they had enough evidence to convince a judge or jury and obtain relief. Finally, the court concluded that the district court did not err by denying plaintiff's request to equitably toll the statutes of limitations where plaintiffs lacked diligence in filing, which was not prevented by invincible necessity. Furthermore, no factor outside plaintiff's control prevented the filing. View "Rassier v. Sanner" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the ruling of the district court granting Defendant's motion to suppress the fruits of a vehicle search conducted by the Kansas Highway Patrol, holding that the suppression motion was improperly granted.The vehicle search in this case was based on a drug dog alert that occurred following a highway patrol trooper's processing of Defendant's traffic offense. The district court concluded that the duration of Defendant's detention to await the drug dog was unlawful and excessive. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trooper acted diligently under the circumstances; and (2) the continued detention was not excessive or unlawful. View "State v. Arrizabalaga" on Justia Law

The Supreme Court vacated Defendant's judgment of conviction and remanded the case, holding that the district court denied Defendant due process by failing to conduct a competency hearing when reasonable doubt arose about Defendant's competency.Pursuant to a jury verdict, Defendant was convicted of murder with the use of a deadly weapon. On appeal, Defendant argued that he was denied due process under the United States and Nevada Constitutions when the district court failed to order a competency hearing. The Supreme Court vacated Defendant's judgment of conviction, holding that a trial court must order a hearing sua sponte to determine whether a defendant is competent when their is a reasonable doubt about his competency, and to fulfill its duty to order a competency hearing a trial court must follow Nevada's statutory competency procedures. View "Goad v. State" on Justia Law

Plaintiff filed suit against GoJet for violations of the Family Medical Leave Act (FMLA) and the Americans with Disabilities Act (ADA) after GoJet terminated him following his Diabetes Type II diagnosis. The jury found in plaintiff's favor and the district court granted him back pay, liquidated damages, and front pay. GoJet appealed and plaintiff cross-appealed.The Seventh Circuit affirmed the district court's denial of GoJet's motion to dismiss, holding that the arbitration provisions in the Collective Bargaining Agreement (CBA) did not clearly, unmistakably, or explicitly state that plaintiff's FMLA claims could only be brought in arbitration. The court rejected GoJet's arguments that the district court erred in denying its motion for judgment as a matter of law. In regard to damages, the court held that the district court did not abuse its discretion in calculating damages based on minimum hours at GoJet because it plausibly could have found that plaintiff would have worked the minimum number of hours from his termination date onward. However, the court held that the district court erred when it calculated front pay based on two different values for how much work the court expected plaintiff to work at GoJet and SkyWest. Accordingly, the court reversed and remanded on this issue for the district court to apply a uniform hourly figure to calculate expected earnings at GoJet and SkyWest for the purposes of front pay. Finally, the court concluded that plaintiff waived his argument regarding the district court's front pay calculations based on post-trial evidence and his argument regarding the correct methodology for calculating damages. Accordingly, the court affirmed as to all other issues on appeal. View "Cloutier v. GoJet Airlines, LLC" on Justia Law

Under the Prison Litigation Reform Act (PLRA), the suit of a prisoner filing a petition to proceed in a suit in forma pauperis (IFP) must be dismissed if the prisoner deliberately misrepresented his financial status. Reyes, an Illinois prisoner, filed a 42 U.S.C. 1983 action in 2017 and another in 2018 and petitioned to proceed IFP in both cases. The district court initially granted those IFP petitions but later dismissed both cases under 28 U.S.C. 1915(e)(2)(A), after the defendants presented evidence that Reyes deliberately misled the court about his finances on his 2017 IFP application. He did not disclose information about his income for three months in 2017, during which time he had received $1,692 in gifts deposited to his trust account. He had spent $785 at the commissary for non-essential items, such as a television. He claimed to have received no income in 2018 but had received $26.The Seventh Circuit affirmed the dismissal of the 2017 case because the district court did not clearly err in finding that Reyes was dishonest about his financial status. The court did not give Reyes a chance to explain any potential issues with his 2018 IFP application and the defendants conceded that he should have been given that opportunity. The court vacated that dismissal. View "Reyes v. Ashcraft" on Justia Law

Plaintiffs, seven adults claiming that they were molested by a priest when they were children, filed suit against the Archdiocese, alleging that it was vicariously liable for ratifying the molestation and directly liable for its own negligence in failing to supervise the priest. The Archdiocese moved to strike the operative complaint under the anti-SLAPP law, Code of Civil Procedure, section 425.16.The Court of Appeal affirmed the trial court's denial of the Archdiocese's anti-SLAPP motion, concluding that the gravamen of the suit against the Archdiocese is not speech – it is the molestation and failure to supervise. The court concluded that the Archdiocese mischaracterizes the complaint by arguing that it has established that the child sexual abuse cause of action arises from protected activity because it is based on the Archdiocese's conduct in the Roe litigation and sheriff’s investigation. The court explained that, because the Archdiocese chooses to ignore the bulk of the allegations of the complaint against it, it makes no attempt to argue that these actual allegations are protected activity under the anti-SLAPP law. The court further explained that the focus must be on the alleged acts of sexual abuse and battery that form the basis of the tort cause of action, not the acts of the Archdiocese by which it is alleged to be vicariously liable for those acts. The court concluded that those underlying tortious acts are not protected activity. The court also concluded that a similar analysis defeats the Archdiocese's argument that the negligence cause of action is based on protected speech. Finally, the court concluded that the ruling on demurrer is not before it, and the ruling on the demurrer did not affect, and could not have affected, the order denying the anti-SLAPP motion. View "Ratcliff v. The Roman Catholic Archbishop of Los Angeles" on Justia Law

The Court of Appeal reversed the trial court's order granting the school district's special motion to strike plaintiff's complaint for discrimination and retaliation in violation of California's Fair Employment and Housing Act (FEHA). Plaintiff's complaint stemmed from his removal from his school and placement on reassignment due to an unspecified allegation of misconduct. Plaintiff remained on paid suspension for more than three years, during which time he was told to stay home and not allowed to teach or pursue continuing education or professional development.As a preliminary matter, the court concluded that plaintiff's appeal of the Code of Civil Procedure section 425.16 (anti-SLAPP statute) order is properly before the court. On the merits, the trial court erred by granting the school district's special motion to strike where plaintiff's complaint does not arise from the school district's protected activity. The court explained that the school district's decisions to place plaintiff on leave and terminate his employment are not protected activity within the meaning of section 425.16, subdivision (e)(2), even if those decisions were made in conjunction with an official investigation. Furthermore, the school district's participation in, or preparation for, the statutorily defined procedures for dismissal or suspension, without more, does not constitute conduct in furtherance of the school district's own right to petition. View "Verceles v. L.A. Unified School District" on Justia Law

Smith has been in state prison for 19 years for a 2001 murder and robbery that he insists he did not commit. Smith had been charged on the basis of the confession by another (Houghtaling) and was tried three times. The state had no physical evidence linking Smith to the crime. In 2020, the district court held that he is entitled to release unless the state decides to retry him but Smith was seeking more: an unconditional writ based on the insufficiency of the evidence. The state appealed from the issuance of the conditional writ and Smith cross-appealed.The Seventh Circuit reversed and ordered the issuance of an unconditional writ and Smith’s immediate release. Even taking the highly deferential view required by 28 U.S.C. 2254(d), the evidence failed to support Smith’s conviction beyond a reasonable doubt; the Illinois Appellate Court was unreasonable, in holding otherwise. The court noted the flaws in Houghtaling’s confession, the exclusion of evidence vital to Smith’s defense, and the trial court’s refusal to allow Smith to impeach prosecution evidence. View "Smith v. Brookhart" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and verdict of death, holding that there was no prejudicial error in the proceedings below and that Defendant was not entitled to reversal of his conviction.A jury convicted Defendant of the first degree murder of a deputy sheriff. When the jury was unable to reach a penalty verdict the trial court declared a mistrial. Following a penalty retrial, the jury returned a verdict of death. The Supreme Court affirmed, holding (1) even if prosecutorial misconduct occurred during the guilt phase, it was not prejudicial, and there were no other errors during the guilt phase; and (2) no prejudicial error occurred during the penalty phase, and Defendant's challenges to the constitutionality of the death penalty statute were unavailing. View "People v. Steskal" on Justia Law