Justia Civil Rights Opinion Summaries

The University of Iowa expelled graduate student John Doe after investigating two accusations of sexual misconduct brought against him by different complainants. The Iowa Board of Regents affirmed the decision. Doe sued the University and University officials, claiming, in part, discrimination on the basis of sex under Title IX, 20 U.S.C. Section 1681(a), and procedural due process violations, 42 U.S.C. Section 1983. The district court granted qualified immunity to the University officials, dismissed the procedural due process claims against them, and granted the University summary judgment on the remaining claims.   The Eighth Circuit affirmed. The court explained that it is not convinced that institutional efforts to prevent sexual misconduct on campus, including educational programs that challenge students to evaluate the impact of gender norms on rape culture, amount to evidence of external pressure on the University that supports an inference of bias. The court held that Doe failed to provide “sufficient evidence to allow a reasonable jury to find that [the University] disciplined him on the basis of sex.” Accordingly, the court affirmed the district court’s grant of summary judgment on Doe’s Title IX claim. Further, the court explained that the University provided adequate notice of the charges. Therefore, the court wrote that because Doe failed to show the University officials’ conduct violated his federal rights, it affirmed the district court’s dismissal of Doe’s claims against the University officials. View "John Doe v. University of Iowa" on Justia Law

Plaintiff alleged that two sheriff deputies unlawfully entered his home. The deputies claim Armstrong’s then-wife invited them in. But although they disagree on whether the deputies’ conduct was reasonable, they do not dispute the historical facts as to what happened. Plaintiff filed a claim under 42 U.S.C. Section 1983. The deputies moved for summary judgment on the merits claiming that, even construing the facts in the light most favorable to Plaintiff, their conduct was objectively reasonable. Alternatively, the deputies claimed they should be granted summary judgment based on qualified immunity. The district court agreed with the deputies on the merits, finding the deputies reasonably believed that Roadcap had the authority to consent to the deputies’ entry.   The Fourth Circuit affirmed. The court explained that, construing the evidence in the light most favorable to Plaintiff, the deputies did, as the district court concluded, briefly detain Plaintiff. But the court agreed with the district court that the deputies acted reasonably as a matter of law because they were responding to a domestic situation, there were guns in the house, and Plaintiff was argumentative. Accordingly, the court affirmed the district court’s order granting summary judgment on the seizure of person claim as well. Moreover, the court wrote that, construing the evidence in the light most favorable to Plaintiff, the deputies exercised some care. Thus, the district court properly dismissed the gross negligence claim. Last, as to the conversion claim, the district court properly explained that there is no evidence in the record that the deputies possessed, touched or exercised any authority over Plaintiff’s personal property. View "Adam Armstrong v. Bryan Hutcheson" on Justia Law

The Verona Police Department twice arrested L.B. for his connection to violent shootings. Both times, however, he was released while his charges were pending. Just five months after his second arrest, L.B. drove to Annie Walton’s house and opened fire—killing Annie Walton and injuring her grandson, Aliven Walton. Annie Walton’s wrongful death beneficiaries (collectively, Plaintiffs ) believe the City of Verona and the Verona Chief of Police, J.B. Long, are responsible for the shooting at Annie Walton’s home, so they sued under 42 U.S.C. Section 1983 and the Mississippi Tort Claims Act. At summary judgment, the district court initially dismissed all claims. But Plaintiffs filed a motion for reconsideration, and the district court reversed course—finding the City of Verona was not entitled to sovereign immunity under the Mississippi Tort Claims Act. Plaintiffs and the City of Verona subsequently filed interlocutory appeals.   The Fifth Circuit dismissed Plaintiffs appeal for lack of jurisdiction and reversed the district court’s finding against the City regarding sovereign immunity. The court explained that Long had no special duty to protect Plaintiffs besides his general duty to keep the public safe as the City’s Chief of Police. The court explained that the only evidence that demonstrates Long had knowledge of any connection between L.B. and Plaintiffs comes from Long’s investigative file, where there is a copy of a trespassing complaint that Annie filed against L.B. in 2016. Accordingly, the court held Long did not owe a duty to protect Plaintiffs from L.B.’s drive-by shooting. Thus, Plaintiffs cannot sustain their negligence claims or their MTCA claims against the City. View "Walton v. City of Verona" on Justia Law

AB 2571, as later amended by AB 160, is codified at Section 22949.80 of the California Business and Professions Code. The statute mandates that “[a] firearm industry member shall not advertise, market, or arrange for placement of an advertising or marketing communication offering or promoting any firearm-related product in a manner that is designed, intended, or reasonably appears to be attractive to minors.” Junior Sports Magazines Inc. publishes Junior Shooters, a youth-oriented magazine focused on firearm-related activities and products. According to Junior Sports Magazines, its ability to publish Junior Shooters depends on advertising revenue. Junior Sports Magazines ceased distributing the magazine in California and has placed warnings on its website deterring California minors from accessing its content. Shortly after California enacted AB 2571, Junior Sports Magazines challenged its constitutionality under the First and Fourteenth Amendments. Junior Sports Magazines also moved to preliminarily enjoin the enforcement of Section 22949.80. The district court denied the injunction.   The Ninth Circuit reversed the district court’s denial. The panel first concluded that because California permits minors under supervision to possess and use firearms for hunting and other lawful activities, Section 22949.80 facially regulates speech that concerns lawful activity and is not misleading. Next, the panel held that section 22949.80 does not directly and materially advance California’s substantial interests in reducing gun violence and the unlawful use of firearms by minors. Finally, the panel held that section 22949.80 was more extensive than necessary because it swept in truthful ads about lawful use of firearms for adults and minors alike. View "JUNIOR SPORTS MAGAZINES INC., ET AL V. ROB BONTA, ET AL" on Justia Law

Zen Group, Inc., is “a Florida Medicaid provider of services to developmentally-disabled minors.” Zen Group alleges that beginning in 2018, the Florida Agency for Health Care Administration wrongfully attempted to recoup payments rendered under the Agency’s “Behavior Analysis Services Program.” Zen Group asserts that the officials made baseless referrals for investigation of fraud and suspended payments to Zen Group in retaliation for the previous exercise of its constitutional rights in an administrative proceeding. Zen Group complained that the officials’ retaliation violated its due-process rights under the Fourteenth Amendment and its speech and petition rights under the First Amendment. The district court dismissed the complaint.   The Eleventh Circuit affirmed. The court held that Zen Group’s due process and First Amendment claims for damages are both barred by qualified immunity. And Zen Group lacks standing to seek injunctive relief. The court explained that Zen Group alleged that it had “completely ceased operations” in June 2020. It did not allege that it had resumed providing services to Medicaid recipients. The court explained that in that context, the most it can fairly infer from the assertion that Zen Group “remains a Florida Medicaid provider” is that Zen Group remains an active corporation authorized by the state to provide Medicaid services, even though it is not currently doing so. The allegations in the amended complaint do not support the inference that Zen Group faces anything more than a speculative risk of future injury if it resumes providing services or the officials decide to engage in retaliatory fraud referrals against an inactive provider with respect to services rendered in the past. View "Zen Group, Inc., et al v. State of Florida Agency for Health Care Administra, et al" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting certain testimony pursuant to the constancy of accusation doctrine; (2) the trial court did not err in excluding impeachment evidence of pending criminal charges against the State's key witness; and (3) the first degree of sexual assault charge was not ambiguous and therefore did not violate Defendant's right to jury unanimity under the Sixth Amendment. View "State v. Velasquez-Mattos" on Justia Law

Conner was convicted in Indiana state court for three counts of felony drug dealing and maintaining a common nuisance. Conner qualified as a habitual offender and was sentenced to an aggregate term of 72 years in prison. He had remained in custody pre-trial, but there was a delay of 1,029 days from the charging date (1,034 days from his arrest). Conner’s attorney never made a Sixth Amendment objection to the pretrial delays and Conner’s own objections were rejected because he was represented by counsel. State courts rejected his post-trial Sixth Amendment and ineffective assistance claims. Conner was advised by his postconviction counsel to postpone filing his federal habeas petition until the U.S. Supreme Court ruled on the petition for a writ of certiorari filed after his state postconviction proceedings. Conner relied on that advice, to his detriment. The one-year period in which to file the habeas petition continued to run while the certiorari petition was pending.The district court dismissed his subsequent habeas petition as untimely, 28 U.S.C. 2244(d)(1)(A) & (d)(2). The Seventh Circuit affirmed, acknowledging that the postconviction lawyer’s mistake was particularly grave but holding that Supreme Court and circuit precedent j foreclose equitably tolling the deadline. View "Conner v. Reagle" on Justia Law

Fillmore County Park in Genoa Charter Township, Michigan, includes a 15-station “Leopold the Lion Reading Trail” with large signs, telling the story. On a wooded 40-acre property a few miles away, Catholic Healthcare created a prayer trail with 14 “Stations of the Cross.” None of the improvements were visible from outside the property. The Township treated the prayer trail as a church building, for which a “special land use” permit was required. At considerable expense, Catholic Healthcare submitted two unsuccessful applications. The Township demanded the removal of the Stations of the Cross, plus a stone altar and mural.Catholic Healthcare sought a preliminary injunction to restore the Stations of the Cross, altar, and mural. The district court twice denied that request, holding that its free-exercise and statutory claims are unripe. The Sixth Circuit reversed. In land-use cases, claims are ripe when the government has adopted a “definitive position” as to “how the regulations at issue apply to the particular land in question.” Here, the Township has uniformly insisted that Catholic Healthcare obtain a special land-use permit and has twice refused to grant a permit. Those events have “inflicted an actual, concrete injury” because the Township has actually forced them to remove the religious displays. Catholic Healthcare is likely to succeed on the merits of its claim under 42 U.S.C. 2000cc(a)(1), the Religious Land Use and Institutionalized Persons Act. View "Catholic Healthcare International Inc. v. Genoa Charter Township, Michigan" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law