Justia Civil Rights Opinion Summaries

At the onset of the COVID-19 pandemic, the Governor of Kentucky issued orders prohibiting mass gatherings, including religious services, and closing non-life-sustaining organizations, which included religious organizations. Maryville Baptist Church held an Easter service in defiance of these orders, leading to a lawsuit against the Governor, alleging violations of the First and Fourteenth Amendments.The United States District Court for the Western District of Kentucky initially declined to issue a preliminary injunction. However, the Sixth Circuit Court of Appeals issued a partial stay, allowing outdoor worship. Subsequently, the district court granted a preliminary injunction, permitting both indoor and outdoor worship. The Governor later allowed places of worship to reopen, and the Kentucky General Assembly limited the Governor's authority to issue similar orders in the future. The underlying action was dismissed as moot, and the Church sought attorney’s fees, which the district court denied, ruling that the Church did not prevail.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court referenced the U.S. Supreme Court's decision in Lackey v. Stinnie, which held that a party who receives a preliminary injunction but whose case becomes moot before a final judgment does not qualify as a prevailing party under 42 U.S.C. § 1988. Applying this precedent, the Sixth Circuit affirmed the district court's denial of attorney’s fees, concluding that the Church's preliminary injunction did not constitute enduring judicial relief that materially altered the legal relationship between the parties. View "Maryville Baptist Church v. Beshear" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

On November 30, 2021, a 15-year-old student, E.C., brought a gun to Oxford High School in Michigan and shot ten students and one teacher, resulting in four student deaths. E.C. pled guilty to first-degree murder and is serving a life sentence. His parents were also convicted of manslaughter. Victims of the shooting filed multiple lawsuits in state court against school and law enforcement officials, alleging various tort claims. The consolidated federal cases here involve claims that school officials violated the plaintiffs' constitutional rights to due process.The United States District Court for the Eastern District of Michigan largely dismissed the plaintiffs' claims, holding that the plaintiffs had not alleged facts sufficient to support an inference that the school officials' actions were so outrageous as to shock the conscience. However, the court allowed one claim to proceed, finding that a statement made by a school counselor, Shawn Hopkins, to E.C.'s parents about contacting Child Protective Services if they did not get counseling for E.C. within 48 hours, could potentially support a constitutional claim.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal of most claims. The appellate court agreed that the plaintiffs had not plausibly alleged that the school officials' actions were so egregious as to violate due process. The court found that the actions of returning E.C.'s backpack and failing to inform other officials about the risk did not constitute affirmative acts that increased the danger to the plaintiffs. The court also held that Hopkins' statement to E.C.'s parents did not demonstrate reckless or callous indifference. Consequently, the Sixth Circuit reversed the district court's decision to allow the claim based on Hopkins' statement to proceed and remanded the case with instructions to dismiss all claims. View "St. Juliana v. Oxford Community School District" on Justia Law

The case involves Plaintiff Tyler Luethje, who filed a § 1983 complaint against Defendants Travis Kyle and Scott Kelly, both employed by the Douglas County Sheriff’s Office. On February 11, 2022, the deputies responded to a 911 call about a broken window at Luethje’s residence. Upon arrival, they sent a police canine, Sig, into the house without announcing themselves. Sig bit Luethje, who was in bed, and continued to bite him while the deputies questioned him. Luethje was then handcuffed and taken to the hospital. He was not charged with any crime.The United States District Court for the District of Colorado reviewed the case and denied the deputies' motion to dismiss based on qualified immunity. The court held that the deputies violated Luethje’s Fourth Amendment rights regarding unlawful entry and search, unlawful arrest, and excessive force. The court found that the law clearly established these rights.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the deputies were not entitled to qualified immunity. The court held that the deputies’ actions violated Luethje’s constitutional rights and that these rights were clearly established. The court found that the deputies lacked an objectively reasonable belief in an ongoing emergency to justify the warrantless entry, did not have probable cause for the arrest, and used excessive force by allowing the canine to continue biting Luethje after he was subdued. View "Luethje v. Kyle" on Justia Law

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation. View "Doe v. Charter Communications" on Justia Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects. View "Alexander v. City of Syracuse" on Justia Law

Keith Paul Bird, a prisoner at High Desert State Prison in Nevada, requested a cell transfer due to concerns about his cellmate, fearing a potential fight. Officer Bruce Huinker, the officer in charge, called for assistance, and Officers Paryga and Atherton responded. Bird explained his concerns, and Officer Paryga allegedly threatened him. The officers then instructed Bird to gather his belongings for a move but later changed their minds, leading to a confrontation. Bird's property was confiscated, and he claimed this was in retaliation for his request. Bird filed grievances, which were denied at all levels.Bird then filed a pro se complaint in federal court against the officers and other prison administrators, alleging retaliation and other claims. The district court found that only the retaliation claim survived screening and was properly exhausted. The district court denied the prison officials' motion for summary judgment on the retaliation claim, holding that they were not entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Bird's request for a cell transfer based on concerns with his cellmate did not constitute "protected conduct" under clearly established law. The court noted that neither the Supreme Court nor the Ninth Circuit had ever held that retaliation for complaints against other prisoners violated the First Amendment right to petition for redress of grievances. Consequently, the prison officials were entitled to qualified immunity. The Ninth Circuit reversed the district court's denial of qualified immunity and remanded with instructions to grant summary judgment on Bird's retaliation claim. View "BIRD V. DZURENDA" on Justia Law

Pollyann Sorcan, a member of the Rock Ridge School District board, was excluded from committee assignments and meetings by the board. The board alleged that Sorcan undermined the District’s mission and violated policies and data privacy laws. Sorcan filed a 42 U.S.C. § 1983 action against the District and Bill Addy, the board chair, claiming retaliation for her protected speech under the First Amendment.The United States District Court for the District of Minnesota dismissed Sorcan’s case. The court concluded that Addy was entitled to legislative immunity and that Sorcan failed to state a claim against the District under Monell v. Department of Social Services, 436 U.S. 658 (1978). The court found that Sorcan did not identify a persistent pattern of unconstitutional behavior by the District.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Addy, sued in his official capacity, was not entitled to legislative immunity because such immunity does not extend to local officials in their official capacities. The court also found that the district court erred in requiring Sorcan to identify a persistent pattern of unconstitutional misconduct. Instead, a single decision by authorized decisionmakers can represent an official policy under Monell. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Sorcan v. Rock Ridge School District" on Justia Law