Justia Civil Rights Opinion Summaries

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

Steven D’Braunstein was involved in a serious single-vehicle accident, resulting in his car being totaled. California Highway Patrol Officer Samantha Diaz-Durazo arrived at the scene and found D’Braunstein disoriented and in physical distress. Despite his evident symptoms, she did not call for medical assistance. Instead, she arrested him for driving under the influence of drugs and took him to jail. A nurse at the jail refused to admit D’Braunstein due to his medical condition, prompting Durazo to finally take him to the hospital, where he was diagnosed with a stroke. The delay in receiving medical treatment allegedly led to permanent injuries for D’Braunstein.The United States District Court for the Central District of California granted summary judgment in favor of Officer Durazo, holding that although she violated D’Braunstein’s Fourth Amendment rights by failing to provide reasonable medical care, she was entitled to qualified immunity. The court reasoned that the constitutional violation was not clearly established, as D’Braunstein’s injury was sustained prior to his arrest and not during the arrest process.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that a reasonable jury could find that Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, given the serious nature of the collision and his symptoms. The court further held that Durazo’s failure to provide medical care was a violation of clearly established law, which requires officers to seek medical assistance for an injured detainee or arrestee facing a substantial and obvious risk of serious harm. The case was remanded for further proceedings. View "D’Braunstein v. California Highway Patrol" on Justia Law

Two professors of Indian descent and adherents to the Hindu religion challenged California State University's (CSU) anti-discrimination and harassment policy, which included "caste" as a protected class. They argued that this inclusion stigmatized their religion and caused them to self-censor certain religious practices. They filed a lawsuit alleging violations of the Due Process Clause, Free Exercise Clause, and Establishment Clause of the U.S. Constitution, as well as equivalent claims under the California Constitution.The United States District Court for the Central District of California dismissed the professors' Equal Protection claim and the equivalent state law claim for lack of standing. The court also dismissed the Free Exercise claim for failing to state a claim without deciding on standing. The Due Process and Establishment Clause claims proceeded to a bench trial, where the court ultimately dismissed these claims as well, finding that the professors lacked sufficient injury for a pre-enforcement challenge and that the policy did not express government disapproval of Hinduism.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the professors lacked Article III standing for their Due Process claim because they failed to show that they intended to engage in any religious practice that could reasonably constitute caste discrimination or harassment. The court also found that the professors lacked standing for their Free Exercise claim, as they did not demonstrate any injury to their ability to exercise their religion. Finally, the court held that the professors lacked standing for their Establishment Clause claim, as the district court's factual finding that the policy had no hostility toward religion was not clearly erroneous. The court affirmed the judgment for the defendants and remanded for entry of judgment of dismissal without prejudice. View "Kumar v. Koester" on Justia Law

Lars Jensen, a math professor at Truckee Meadows Community College (TMCC), voiced concerns about a policy change to the math curriculum standards. He criticized the new co-requisite policy, which placed students needing remedial instruction in college-level classes, arguing it lowered academic standards. Following his criticism, Jensen faced several adverse actions, including reprimands, negative performance reviews, and a termination hearing.The United States District Court for the District of Nevada dismissed Jensen’s claims, including First Amendment retaliation, procedural due process, and equal protection violations. The court held that Jensen’s First Amendment claim was barred by qualified immunity and that his official capacity claim was barred by sovereign immunity. The court also found that Jensen failed to identify a protected interest for his due process claim and did not allege membership in a discrete class for his equal protection claim. The court dismissed all claims with prejudice and denied leave to amend.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Jensen’s First Amendment retaliation claim. The appellate court held that Jensen’s criticism of the curriculum changes addressed a matter of public concern and was protected speech related to scholarship or teaching. The court found that the adverse actions against Jensen were motivated by his speech and that the state had not shown a substantial disruption to outweigh his First Amendment rights. The court also held that the Administrators were not entitled to qualified immunity and that Jensen’s official capacity claim for prospective relief was not barred by sovereign immunity. The court affirmed the dismissal of Jensen’s due process and equal protection claims but reversed the denial of leave to amend, remanding for further proceedings. View "JENSEN V. BROWN" on Justia Law

Defendant-Appellant Kenston Harry was convicted of possessing controlled substances with intent to distribute and conspiracy to distribute the same. The case centers on the use of a stationary pole camera by the Drug Enforcement Administration (DEA) to monitor the exterior of Harry's business, Action Audio, for approximately 50 days without a warrant. The camera captured footage of the business's exterior, parking lot, and occasionally the interior when the garage door was open. Harry was arrested after investigators found narcotics and firearms at Action Audio and his residence.The United States District Court for the District of Connecticut denied Harry's motion to suppress the pole-camera evidence, which was introduced at trial. The jury convicted Harry, and the district court sentenced him to ten years for the fentanyl- and cocaine-related charges, including conspiracy, and five years for the marijuana charge, to run concurrently. The court also denied Harry's request for safety-valve relief from the mandatory minimum sentence under 18 U.S.C. § 3553(f).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the use of the stationary pole camera did not constitute a Fourth Amendment search, as Harry did not have a reasonable expectation of privacy in the publicly visible areas of his business. The court also found that the district court did not err in denying Harry safety-valve relief, as he failed to prove that the firearms found were not connected to his drug-trafficking activities. The Second Circuit affirmed the judgment of the district court. View "United States v. Harry" on Justia Law

Plaintiffs David Moore and David Ermold sued Kim Davis, the clerk of Rowan County, Kentucky, under 42 U.S.C. § 1983 for refusing to issue them a marriage license, claiming it violated their constitutional right to marry. This refusal occurred after the Supreme Court's decision in Obergefell v. Hodges, which legalized same-sex marriage nationwide. Davis, citing her religious beliefs, stopped issuing all marriage licenses until the state provided her with an accommodation. Plaintiffs sought damages for the emotional distress caused by Davis's actions.The United States District Court for the Eastern District of Kentucky ruled in favor of the plaintiffs on liability, and a jury awarded them compensatory damages. Davis appealed, arguing she was entitled to qualified immunity, had defenses under the Free Exercise Clause and the Kentucky Religious Freedom Restoration Act (RFRA), and that the evidence of emotional distress was insufficient to support the jury's award.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Davis was not entitled to qualified immunity because Obergefell clearly established the right to same-sex marriage, and Davis's actions violated that right. The court also rejected Davis's Free Exercise Clause defense, stating that the First Amendment does not protect state actions that violate constitutional rights. Additionally, the court found that Kentucky's RFRA did not apply in this case because the state was not a party to the lawsuit.The court further upheld the jury's award of damages, finding that the plaintiffs provided sufficient evidence of emotional distress. The court noted that the plaintiffs' detailed testimony about their emotional harm was corroborated and not merely conclusory. Davis's request for remittitur was not considered because it was raised for the first time in her reply brief. The Sixth Circuit thus affirmed the district court's judgment in favor of the plaintiffs. View "Ermold v. Davis" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law