Justia Civil Rights Opinion Summaries

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

Two nonprofit organizations challenged the constitutionality of a North Carolina statute that made it a felony for individuals with felony convictions to vote before their rights were restored, regardless of whether those individuals mistakenly believed they were eligible. The statute, originally enacted in the late 19th century, was shown to have been motivated by racial animus and to have a disproportionate impact on Black North Carolinians. In 2023, the North Carolina General Assembly amended the statute to add a requirement that a person must “know” their rights had not been restored to be prosecuted, effective January 1, 2024.The United States District Court for the Middle District of North Carolina considered the plaintiffs’ claims under the Equal Protection and Due Process Clauses. After the statute was amended, a magistrate judge recommended dismissal for lack of standing, but the district court found the case was not moot because prosecutions under the old statute for pre-2024 conduct could still occur, potentially chilling voter participation and requiring the plaintiffs to divert resources. The district court granted summary judgment for the plaintiffs, holding the statute unconstitutional and enjoining its enforcement.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the case was not moot because prosecutions under the prior version of the statute could still proceed, and the plaintiffs retained a concrete interest in the outcome. On the merits, the Fourth Circuit affirmed the district court’s ruling that the challenged statute violated the Equal Protection Clause. The court found that the statute’s original enactment and reenactment were motivated by racial discrimination, and that subsequent legislative changes did not “cleanse” the statute of its discriminatory origins, as the statute itself had not been substantively reenacted or amended in a way that would warrant a presumption of legislative good faith. The court affirmed the district court’s judgment. View "A. Philip Randolph Institute v. North Carolina State Board of Elections" on Justia Law

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

After the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which struck down New York’s “proper cause” requirement for public handgun carry, New Jersey enacted Chapter 131. This law removed its own “justifiable need” standard but imposed new licensing requirements, increased permit fees, mandated liability insurance for handgun carriers, and designated numerous “sensitive places” where firearms are prohibited, such as parks, entertainment venues, healthcare facilities, and private property without express consent. Two groups of plaintiffs, including individuals and gun rights organizations, challenged these provisions under 42 U.S.C. § 1983, arguing they violated the Second Amendment.The United States District Court for the District of New Jersey consolidated the cases and allowed legislative leaders to intervene as defendants. The District Court preliminarily enjoined enforcement of several “sensitive place” restrictions, the vehicle carry ban, the liability insurance requirement, and the private property default rule, finding these likely unconstitutional under Bruen’s historical tradition test. The State and some plaintiffs appealed, and the Third Circuit Court of Appeals granted a partial stay, allowing most of the law to take effect pending appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s preliminary injunction, applying de novo review to the underlying Second Amendment questions. The Third Circuit held that most of New Jersey’s “sensitive place” restrictions—such as those covering parks, entertainment venues, healthcare facilities, libraries, museums, and places serving alcohol—are likely constitutional, finding them consistent with a historical tradition of regulating firearms in locations set aside for civic, educational, or recreational purposes. However, the court affirmed the injunction against the liability insurance mandate, the portion of the permit fee allocated to the Victims of Crime Compensation Office, the private property default rule as applied to places open to the public, and the ban on carrying operable firearms in private vehicles, holding these provisions likely violate the Second Amendment. The court vacated the injunction as to film sets and certain hunting regulations for lack of standing or mootness, and remanded for further proceedings consistent with its opinion. View "Koons v. Attorney General New Jersey" on Justia Law

A private Christian school in Vermont forfeited a girls’ basketball playoff game because it objected, on religious grounds, to playing against a team with a transgender athlete. The school believes that requiring its female athletes to compete against biological males would violate its religious convictions about the immutability of sex. Following the forfeit, the Vermont Principals’ Association (VPA), which oversees extracurricular activities for Vermont schools, expelled the school from all state-sponsored extracurricular activities, including both athletic and non-athletic events.After the expulsion, the school and several students and parents filed suit in the United States District Court for the District of Vermont, seeking a preliminary injunction to reinstate the school’s VPA membership and alleging a violation of their rights under the Free Exercise Clause of the First Amendment. The district court denied the motion, finding that the VPA’s policies regarding transgender athletes were neutral and generally applicable, and thus subject only to rational-basis review. The court concluded that the plaintiffs were unlikely to succeed on the merits of their claim.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s denial of a preliminary injunction. The Second Circuit held that the plaintiffs are likely to succeed in showing that the VPA’s expulsion was not neutral, as it was accompanied by official expressions of hostility toward the school’s religious beliefs. The court found that the plaintiffs also satisfied the requirements of irreparable harm and public interest. Accordingly, the Second Circuit reversed the district court’s order and remanded the case with instructions to grant a preliminary injunction reinstating the school’s VPA membership pending further proceedings. View "Mid Vermont Christian School v. Saunders" on Justia Law

Two police officers responded to a domestic battery call at a residential home. While one officer spoke with a woman at the door, the other saw a person flee over a backyard wall into a neighboring yard. Instead of immediately pursuing, the officer returned to his car, called for backup, and drove to establish a perimeter. Eighteen minutes later, a K-9 unit arrived and began searching within the perimeter. The K-9 alerted toward the plaintiffs’ backyard, which was locked and posted with a “Beware of Dog” sign. Without a warrant or consent, officers entered the backyard. The plaintiffs’ three dogs were roused, and two of them attacked the police K-9. One officer shot and killed the two dogs. The suspect was never found.The United States District Court for the District of Nevada granted summary judgment to the officers and the City of North Las Vegas, finding the officers’ entry justified under the “hot pursuit” exception to the warrant requirement and the use of force against the dogs reasonable. The court also granted summary judgment to the City on the plaintiffs’ Monell claims, and declined to exercise supplemental jurisdiction over the state law claim after dismissing the federal claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the “hot pursuit” exception did not apply because the officers lost track of the suspect for eighteen minutes, breaking the continuity required for exigent circumstances. Therefore, the officers were not entitled to qualified immunity for the warrantless search. However, the court affirmed qualified immunity for the officer’s use of force against the dogs, finding no clearly established law prohibiting his actions in the spontaneous circumstances. The court also affirmed summary judgment for the City on the Monell claims, finding insufficient evidence of a policy or deliberate indifference. The case was remanded for further proceedings. The disposition was affirmed in part, reversed in part, and remanded. View "JONES V. CITY OF NORTH LAS VEGAS" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law

Paul Schwartz, while incarcerated at a federal correctional facility in Tucson, alleged that prison officials were deliberately indifferent to his serious medical needs over an eighteen-month period. He experienced a range of severe symptoms, including tachycardia, blood in his urine, and significant thyroid dysfunction, but claimed he received inadequate and delayed medical care despite repeated attempts to seek help. Schwartz specifically alleged that a mid-level practitioner, Ms. Tatad, refused to provide treatment or access to a physician and instructed others to deny him care. He also claimed that the warden and associate warden ignored his efforts to alert them to his condition, resulting in irreversible kidney injury and other long-term health risks.The United States District Court for the District of Arizona initially dismissed several defendants and later granted summary judgment for the remaining defendants. On appeal, the United States Court of Appeals for the Ninth Circuit reversed in part, allowing Schwartz’s claim against Tatad to proceed. After remand, the district court denied Schwartz’s motion to amend his complaint, then later granted Tatad’s motion for judgment on the pleadings, concluding that the Prison Litigation Reform Act (PLRA) constituted a special factor that placed Schwartz’s claim in a new Bivens context, foreclosing a damages remedy.The United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The Ninth Circuit held that Schwartz’s claim was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, which recognized a Bivens remedy for Eighth Amendment claims of deliberate indifference to serious medical needs. The court found that neither the PLRA, the Bureau of Prisons’ Administrative Remedy Program, nor the factual specifics of Schwartz’s case created a new Bivens context. The court also held that the district court abused its discretion in denying Schwartz leave to amend his complaint. View "SCHWARTZ V. MILLER" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law