Justia Civil Rights Opinion Summaries

Roy Lee Williams, a death-row inmate with a history of mental illness, was held in solitary confinement for twenty-six years. Williams filed a lawsuit claiming that his prolonged solitary confinement without penological justification violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Americans with Disabilities Act (ADA). The District Court granted summary judgment in favor of the defendants, ruling that the former Secretary of the Pennsylvania Department of Corrections (DOC) was entitled to qualified immunity on the Eighth Amendment claim and that Williams could not prove deliberate indifference under the ADA.Before the summary judgment, the District Court dismissed Williams' Fourteenth Amendment claim for failure to state a claim. Williams appealed both the summary judgment and the dismissal of his Fourteenth Amendment claim.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the Secretary had "fair and clear warning" that keeping Williams in solitary confinement without penological justification was unconstitutional, thus rejecting the qualified immunity defense. The court held that it was clearly established that someone with a known preexisting serious mental illness has a constitutional right not to be held in prolonged solitary confinement without penological justification.Regarding the ADA claim, the court found that the District Court erred in concluding that a trier of fact could not find the DOC deliberately indifferent to the risk of harm caused by placing and keeping Williams in solitary confinement despite his mental illness. The court vacated the District Court's grant of summary judgment on both the Eighth Amendment and ADA claims and remanded for further proceedings. However, the court affirmed the dismissal of Williams' Fourteenth Amendment claim. View "Williams v. Secretary Pennsylvania Department of Corrections" on Justia Law

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law

F.A. has been involuntarily committed to state mental health facilities since 1999 after being found not guilty of a sexual offense due to mental illness. In 2020, a District Court judge renewed F.A.'s commitment and imposed a restriction confining F.A. to the buildings and grounds of the facility. F.A. challenged the constitutionality of this restriction.Previously, the Worcester Division of the District Court Department had renewed F.A.'s commitment annually and imposed similar restrictions since 2013. In 2020, F.A. opposed the Commonwealth's motion for the restriction, but the judge granted it after an evidentiary hearing. The judge did not require the Commonwealth to prove beyond a reasonable doubt that the restriction was necessary. In 2021, a different judge imposed the same restriction without an evidentiary hearing. The Appellate Division of the District Court affirmed the 2020 restriction but vacated the 2021 restriction due to the lack of a hearing. F.A. appealed the 2020 decision, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the 2020 order violated F.A.'s substantive and procedural due process rights. The court held that a restriction under G. L. c. 123, § 16 (e) must be narrowly tailored to a compelling government interest and be the least restrictive means available. The judge failed to make such findings and did not consider less restrictive alternatives. Additionally, the court found that the judge used an incorrect standard of proof and did not provide timely, specific findings to support the restriction. Consequently, the court vacated the 2020 order. View "In the Matter of F.A." on Justia Law

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

Amir Meshal, a professional truck driver, was stopped by Georgia State Police officers for a minor traffic infraction. During the stop, the officers discovered Meshal was on the FBI’s No Fly List. Despite instructions not to detain him based solely on this status, the officers handcuffed Meshal, placed him in a patrol car, and searched his truck. They questioned him about his religion and international travel while waiting for guidance from the FBI. After 91 minutes, the FBI cleared Meshal, and he was released with a warning citation for the traffic infraction.Meshal sued the officers in the United States District Court for the Southern District of Georgia, alleging violations of his Fourth Amendment rights due to the extended detention and the search of his truck. The officers moved to dismiss the complaint on qualified immunity grounds, arguing that Meshal failed to allege a violation of clearly established law. The district court denied the motion, finding that the complaint sufficiently alleged that the officers detained Meshal without arguable reasonable suspicion and searched his truck without arguable probable cause.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court agreed with the district court, holding that the officers were not entitled to qualified immunity at this stage. The court found that the officers lacked even arguable reasonable suspicion to justify prolonging the traffic stop beyond the time necessary to complete tasks related to the traffic infraction. Additionally, the court held that the search of Meshal’s truck was not supported by arguable probable cause. Therefore, the Eleventh Circuit affirmed the district court’s denial of qualified immunity. View "Meshal v. Commissioner, Georgia Department of Public Safety" on Justia Law

In 2020, the Springfield R-12 School District mandated "equity training" for its employees. Two employees, Brooke Henderson and Jennifer Lumley, attended the training and later sued the school district and several officials under 42 U.S.C. § 1983. They claimed that the training compelled them to speak on matters of public concern and engaged in viewpoint discrimination, violating their First and Fourteenth Amendment rights. The training included interactive sessions and online modules that required participants to discuss prompts and select "correct" answers to questions about equity and diversity.The United States District Court for the Western District of Missouri granted summary judgment in favor of the school district, ruling that the plaintiffs lacked standing because they did not suffer an injury in fact. The court also deemed the lawsuit frivolous and awarded attorney’s fees to the school district. The plaintiffs appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal, agreeing that the plaintiffs did not establish an injury in fact. The court found that the plaintiffs' fear of punishment for their speech during the training was speculative and not objectively reasonable. The court also concluded that the plaintiffs' completion of online modules did not constitute a First Amendment injury. However, the Eighth Circuit reversed the award of attorney’s fees, determining that the plaintiffs' claims were not frivolous given the nuanced and unsettled nature of the constitutional issues involved. View "Henderson v. Springfield R-12 School District" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

Kate Adams, the former Chief of Police for the City of Rancho Cordova, was forced to resign over allegations that she sent racist text messages while working for the Sacramento County Sheriff’s Office. The messages, sent in 2013, included offensive images forwarded to two friends during a private conversation. Adams claimed she was merely expressing disapproval of the images. After her resignation, the messages were publicized, leading to further professional and personal repercussions for Adams.The United States District Court for the Eastern District of California dismissed Adams’s First Amendment retaliation and conspiracy claims, ruling that her speech did not address a matter of public concern. The court found that the private nature of the text messages and their content did not relate to broader societal issues or public interest.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that Adams’s private text messages, which were part of a casual conversation and not intended for public dissemination, did not constitute speech on a matter of public concern under the Pickering v. Board of Education standard. The court emphasized that the content, form, and context of the messages indicated they were of personal interest rather than public interest. Consequently, Adams’s First Amendment retaliation and conspiracy claims were dismissed, and the case was remanded for further proceedings on other unresolved claims. View "ADAMS V. COUNTY OF SACRAMENTO" on Justia Law