Justia Civil Rights Opinion Summaries

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

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

In 1999, a Virginia state court jury convicted Askari Lumumba of second-degree murder and other related charges, sentencing him to fifty-eight years in prison. While serving his sentence, Lumumba engaged in communications that led to disciplinary action. He spoke on the phone about organizing inmates and sent emails discussing potential group actions within the prison. As a result, he was charged with attempting to garner support for a group demonstration, violating Disciplinary Offense Code 128, which prohibits participating in or encouraging work stoppages or group demonstrations.Lumumba's disciplinary hearing concluded with a finding of guilt, resulting in 30 days of disciplinary segregation and a loss of 180 days of good-conduct sentence credits. His appeals to the Warden and Regional Director were denied. He then petitioned for a writ of habeas corpus in the Supreme Court of Virginia, which was denied on jurisdictional grounds. Subsequently, Lumumba filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing that Offense Code 128 was void for vagueness and violated the First Amendment. The district court dismissed his petition, finding the regulation clear and reasonably related to legitimate penological interests.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Offense Code 128 is not facially unconstitutional under the First Amendment, as it reasonably relates to maintaining order and security in prisons. The court also found that the regulation is not void for vagueness, as it provides sufficient notice of prohibited conduct and does not invite arbitrary enforcement. Consequently, the Fourth Circuit affirmed the district court's dismissal of Lumumba's petition. View "Lumumba v. Kiser" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Russell Hotchkiss, a resident of Linn County, Iowa, began sending emails to the Cedar Rapids Community School District officials in September 2021, criticizing their COVID-19 masking and vaccination policies. His communications included threats of criminal charges against board members, particularly targeting Jennifer Borcherding, a board member. Hotchkiss attended board meetings in November and December 2021, where he voiced his opposition aggressively. Following these incidents, the District issued a no-trespass notice to Hotchkiss on January 10, 2022, barring him from District premises due to his disruptive and threatening behavior.Hotchkiss filed a lawsuit on May 17, 2023, claiming First Amendment retaliation under 42 U.S.C. § 1983 and a violation of the Iowa Open Meetings Act. He sought a preliminary injunction to prevent the enforcement of the no-trespass order. The United States District Court for the Northern District of Iowa denied his motion, concluding that Hotchkiss failed to demonstrate irreparable harm. The court noted that Hotchkiss had not attempted to return to District premises, had moved his child to another school district, and had not communicated with the District since the notice was issued.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision. The appellate court affirmed the denial of the preliminary injunction, agreeing that Hotchkiss did not show a likelihood of irreparable harm. The court emphasized that speculative harm does not justify a preliminary injunction and noted Hotchkiss's delay in seeking relief and lack of recent attempts to exercise his First Amendment rights. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction based on the failure to demonstrate irreparable harm. View "Hotchkiss v. Cedar Rapids Community School District" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

In the summer of 2020, Derrick Sanderlin attended a protest in San Jose, California, where he was struck in the groin by a 40mm foam baton round fired by Officer Michael Panighetti. Sanderlin alleged that Panighetti's use of force was retaliatory and excessive, violating his First and Fourth Amendment rights. Sanderlin claimed he was peacefully protesting and did not hear any warnings before being shot. Panighetti argued that Sanderlin was obstructing officers from targeting other individuals who posed a threat.The United States District Court for the Northern District of California denied Panighetti's motion for summary judgment, concluding that genuine disputes of material fact existed regarding whether Panighetti's actions were retaliatory and whether the force used was excessive. The court found that a jury could determine that Sanderlin was engaged in protected First Amendment activity and that Panighetti's actions were motivated by retaliatory animus. Additionally, the court held that a reasonable jury could find that Sanderlin was seized under the Fourth Amendment and that the force used was unreasonable.The United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of qualified immunity to Panighetti. The Ninth Circuit held that, viewing the evidence in the light most favorable to Sanderlin, genuine disputes of material fact existed as to whether Panighetti's use of force was retaliatory and excessive. The court concluded that it was clearly established that police officers may not use their authority to retaliate against individuals for protected speech and that the use of a 40mm foam baton round against a non-threatening individual constituted excessive force. The court also determined that subsequent legal developments did not alter the clearly established law at the time of the incident. View "SANDERLIN V. DWYER" on Justia Law