Justia Civil Rights Opinion Summaries

Appellants wish to openly carry handguns in California for self-protection, but California’s current licensing regime effectively establishes a statewide ban on open carry by ordinary law-abiding Californians. Appellants brought a Second Amendment suit against the Attorney General of California in his official capacity and sought a preliminary injunction enjoining the enforcement of California Penal Code sections that impose criminal penalties for unlicensed open carry. The district court denied the preliminary injunction.   The Ninth Circuit reversed the district court’s denial of Appellants’ motion. The panel held that the district court abused its discretion by applying an incorrect legal standard to deny Appellants’ motion for a preliminary injunction. Instead of analyzing the first factor set forth in Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008)—whether Appellants were likely to succeed on the merits of their claim—the district court erroneously determined that because the public interest and balance of harms disfavored the issuance of a preliminary injunction, it was not necessary to assess Appellants’ likelihood of success on the merits. The panel set forth three requirements to guide the district court’s preliminary injunction analysis on remand. View "MARK BAIRD, ET AL V. ROB BONTA" on Justia Law

Gnutek alleged that he was unlawfully terminated from his position as a Gaming Senior Special Agent with the Illinois Gaming Board in violation of Title VII, the First Amendment under 42 U.S.C. 1983, and the Illinois Ethics Act. His termination followed his arrest after Gnutek assaulted another driver. The district court dismissed the Illinois Ethics Act claims against the Board and individual defendants in their official capacities. Gnutek voluntarily dismissed the claims against two individual defendants. The district court then granted summary judgment in favor of the Board and three other individuals on the remaining claims.The Seventh Circuit affirmed. Other than the fact that he has previously engaged in prior litigation against the defendants, Gnutek presented no evidence from which a trier of fact could infer that his termination was retaliatory nor did he establish that he was treated less favorably than similarly situated individuals. View "Gnutek v. Illinois Gaming Board" on Justia Law

Plaintiff, an African American woman, claims that her employer, defendant-appellee General Motors, LLC ("General Motors"), subjected her to a hostile work environment, race and sex discrimination, and retaliation at her place of employment, the General Motors plant in Lockport, New York. In the district court, Plaintiff presented evidence that, for example: a manager called her a "dumb n****r" in front of other employees; racist and sexist words or material were displayed around the plant; sexist comments were directed at her; the Confederate flag was depicted on employees' vehicles and clothing; and nooses were displayed on three separate occasions near the workstations of Black employees. The district court granted summary judgment in favor of General Motors, dismissing initially Plaintiff’s hostile work environment and disparate treatment claims and eventually her retaliation claim as well.   The Second Circuit vacated and remanded. The court concluded that the district court erred because a reasonable jury could find that General Motors's decisions to delay Plaintiff’s return to work and to reassign her upon her return are adverse actions that give rise to an inference of discrimination. The court explained that a reasonable jury could also infer discriminatory intent in General Motors's decision to require that Plaintiff obtain psychiatric approval in contravention of company policy and contrary to the approval process Plaintiff had undergone for her prior disability leaves. The district court erred in determining that Plaintiff did not establish an inference of discrimination" when the proper inquiry was, instead, whether there was sufficient evidence for a reasonable jury to infer a discriminatory motive. View "Billie R. Banks v. General Motors, LLC" on Justia Law

Freed fell behind approximately $1,100 on his property taxes. Thomas, Gratiot County’s treasurer, foreclosed on Freed’s property and sold it at a public auction for $42,000. The County retained the entire proceeds. Freed sued the County and Thomas under 42 U.S.C. 1983, alleging an unconstitutional taking under the Fifth and Fourteenth Amendments and an unconstitutional excessive fine under the Eighth Amendment.Following a remand, the district court granted Freed summary judgment on his Fifth Amendment claim, rejecting Freed’s argument that he was entitled to the fair market value of his property, minus his debt, and holding that Freed was owed just compensation in the amount of the difference between the foreclosure sale and his debt, plus interest from the date of the foreclosure sale. Freed was owed about $40,900 plus interest, $56,800 less than he was seeking. The court also held that Freed’s claims against Thomas were barred by qualified immunity and denied Freed’s subsequent motion for attorney’s fees. The Sixth Circuit affirmed. Following a public sale, a debtor is entitled to any surplus proceeds from the sale, which represent the value of the equitable title extinguished. Thomas did not violate a right that was clearly established at the time of her alleged misconduct. View "Freed v. Thomas" on Justia Law

Plaintiff was booked into a federal corrections center in San Diego for an alleged sex offense. Given the nature of his charges, Plaintiff requested protective custody. Jail officials, however, declined his request, instead placing him in general population. Plaintiff experienced harassment by other inmates, and at some point, the inmates forced Plaintiff to exercise to the point of collapse, leading to serious medical complications requiring hospitalization. Plaintiff filed suit under Bivens against two jail classification officers in their individual capacities. The officers moved to dismiss the complaint, contending that Plaintiff did not state a viable Bivens claim. The district court denied the motion. Although the district court found that Plaintiff’s claim presented a “new Bivens context,” it concluded that an extension of Bivens could be warranted in his case.   The Ninth Circuit reversed. The court explained that when a party seeks to bring a Bivens action, courts apply a two-step test: whether the case presents a new Bivens context, and, if so, whether there are “special factors” that counsel against extending Bivens. Applying the first step, the panel held that this case presents a new Bivens context that the Supreme Court has not recognized in its Bivens jurisprudence. Applying the second step, the panel held that special factors counsel against extending Bivens to this case. The legislature and executive were best positioned to address Plaintiff’s interest and have, in fact, provided alternative remedies through administrative review procedures offered by the Board of Prisons. Accordingly, the panel declined to overstep its constitutional role to create a new damages action. View "STEVE MARQUEZ V. C. RODRIGUEZ, ET AL" on Justia Law

Plaintiff brought a claim under 42 U.S.C. Section 1983 and Louisiana state law against Louisiana Department of Public Safety and Corrections (“DPSC”) supervisory officials Tracy DiBenedetto, Angela Griffin, and Sally Gryder in their individual capacities alleging that he was wrongfully detained for sixty days after the expiration of his prison sentence. The district court denied qualified immunity at the motion-to-dismiss stage for DiBenedetto and Gryder but found Griffin enjoys qualified immunity. DiBenedetto and Gryder appealed, arguing that they are entitled to qualified immunity because they neither violated Plaintiff’s constitutional rights nor acted unreasonably in light of clearly established law   The Fifth Circuit affirmed. The court first explained that Plaintiff’s right to timely release was clearly established under these particular circumstances because governing law required DPSC to follow the state court’s orders requiring them to credit the Arkansas time. Further, the court found that Plaintiff plausibly alleged that DiBenedetto and Gryder were direct participants in violating his right to timely release from prison. According to the complaint, DiBenedetto reviewed all of Plaintiff’s ARPs, knew he was not being credited for the Arkansas time, yet did not take any action to correct the error. Indeed, she personally informed Hicks that her (incorrect) calculation was correct and refused to modify it despite Hicks’ pointing out that his Arkansas time was not credited. View "Hicks v. LeBlanc" on Justia Law

The Supreme Court affirmed the judgment of the trial court dissolving Plaintiff's marriage to Defendant, holding that Plaintiff was not entitled to relief on his allegations of error.At issue in this case was the extent to which a Connecticut court may enforce the terms of a "ketubah," a contract governing marriage under Jewish law. The trial court in this case denied Plaintiff's motion to enforce the terms of the parties' ketubah as a prenuptial agreement on the ground that doing so would be a violation of the First Amendment to the United States constitution. The Supreme Court affirmed, holding (1) the trial court properly denied Plaintiff's motion to enforce the ketubah; and (2) the trial court's alimony order, considered in light of Plaintiff's net earning capacity, was not an abuse of discretion. View "Tilsen v. Benson" on Justia Law

A school bus driver filed an action under 42 U.S.C. Section 1983 against two public-sector unions and her employer, the New Hartford Central School District, alleging that their continued deduction of union fees from her paycheck following her resignation from both unions violated her First and Fourteenth Amendment rights under Janus v. Am. Fed’n of State, Cnty., and Mun. Emps., Council 31, 138 S. Ct. 2448 (2018). She appealed the dismissal of her claims, arguing that the district court erred by prematurely dismissing her claims against the unions for, among other things, failing to adequately plead state action.   The Second Circuit affirmed. The court concluded that because Appellant voluntarily became a union member and affirmatively agreed to pay union dues through payroll deductions for a set period, the district court properly dismissed her claims. The court explained that New York’s Taylor Law guarantees public employees the right to choose whether to join the union as members, N.Y. Civ. Serv. Law Section 202 and prohibits any union or public employer from “interfering with, restraining or coercing public employees in the exercise of their rights.” Here,  it is undisputed that Appellant voluntarily joined the Unions and authorized dues deductions from her wages when she signed the Membership Agreement in 2018. View "Wheatley v. New York State United Teachers, et al." on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law