Justia Civil Rights Opinion Summaries

Plaintiff sued Defendants L.A. Central Plaza LLC and Central Liquor & Market, Inc. for alleged violations of the Americans with Disabilities Act (“ADA”). After Plaintiff moved for summary judgment on the merits, the district court instead sua sponte dismissed the case on the ground that Plaintiff’s amended complaint had failed adequately to plead the elements of Article III standing. Plaintiff timely appealed the dismissal.   The Ninth Circuit vacated and remanded. The panel held that because Plaintiff had a full and fair opportunity to prove his case as to standing, the district court had discretion in resolving Plaintiff’s summary judgment motion, to also consider sua sponte whether to grant summary judgment against Jones on the issue of standing. The panel held, however, that when presented with the issue of standing in the context of Plaintiff’s fully briefed summary judgment motion, the district court could not ignore the factual evidence of standing presented at summary judgment and instead sua sponte examine the adequacy of the complaint’s allegations of standing. View "GEORGE JONES V. L.A. CENTRAL PLAZA, LLC, ET AL" on Justia Law

Plaintiff’s claim under the Americans with Disabilities Act (“ADA”) was dismissed for lack of standing. Thereafter, the district court considered and granted Malibu Road and Bungalow Lighting’s motion for attorneys’ fees under the ADA’s fee provision. Plaintiff did not appeal the dismissal of his ADA claim for lack of standing, but he appeals the award of attorneys’ fees, arguing that his lawsuit was not frivolous. However, the issue before the court was not whether Plaintiff’s claim was frivolous and therefore justified an award of fees, but rather whether there is a basis to award attorneys’ fees under the ADA’s fee provision after the underlying claim has been dismissed on jurisdictional grounds.   The Ninth Circuit reversed and vacated. The panel held that because the district court dismissed Plaintiff’s claim for lack of standing, it lacked jurisdiction to award fees under the Americans with Disabilities Act’s fee provision, 42 U.S.C. Section 12205 View "ANTONIO FERNANDEZ V. 23676-23726 MALIBU ROAD, LLC, ET AL" on Justia Law

Dixon Correctional Center Officer Brinkmeier informed inmate Walker that prison policy prohibited prisoners from maintaining “unsearchable” hairstyles like dreadlocks. Walker told Brinkmeier that he was a Rastafarian and had taken a vow not to cut his hair. Brinkmeier later returned with another officer and again ordered Walker to cut his dreadlocks. The officers disciplined Walker for his disobedience, placing him in segregated housing for several days. Walker submitted an emergency grievance, which was denied without explanation. Walker was told that if he did not acquiesce, a tactical unit would forcibly remove his dreadlocks. Walker allowed the prison barber to shave his hair. Walker regrew his dreadlocks and kept them for three years. During security checks, officers ran their gloved hands through his dreadlocks. When he was released from Dixon, Walker’s dreadlocks were roughly the same length as they had been when he entered prison.Walker sued for violations of the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1. The district court noted that under Circuit precedent, Walker could not seek monetary damages against individual defendants under RLUIPA; “the only relief available under RLUIPA,” injunctive relief, was moot because Walker had been released. The court also granted the defendants summary judgment on Walker’s First Amendment claim, citing qualified immunity. The Seventh Circuit dismissed an appeal, finding that Walker abandoned his RLUIPA damages claim. View "Walker v. Baldwin" on Justia Law

Plaintiff appealed the dismissal of his claims against various Arkansas Department of Corrections staff members for damages stemming from injuries that he received when he was beaten by another inmate. Plaintiff alleged that Defendants failed to protect him from the beating. The district court dismissed Plaintiff’s claim on summary judgment, finding that he had failed to exhaust his administrative remedies even though he remained hospitalized from his injuries until the time for filing expired. At issue is whether the district court erred in dismissing Plaintiff’s complaint for failure to exhaust administrative remedies.   The Eighth Circuit reversed and remanded. The court concluded that the district court’s rant of summary judgment was premature. The court explained that the district court legally erred in declining to decide whether administrative remedies were “unavailable” to Plaintiff. As the Supreme Court stressed in Ross, the PLRA “contains its own textual exception to mandatory exhaustion.” The court explained that under the PLRA, the exhaustion requirement hinges on the ‘availability’ of administrative remedies. The court reversed because the district court declined to decide whether the prison’s grievance procedure was unavailable to Plaintiff. View "John Smith v. Jeremy Andrews" on Justia Law

Fehlman was the Neillsville Police Department’s interim police chief in 2019. In 2020, Mankowski was hired as the permanent chief. Fehlman returned to being a rank-and-file officer. Over the next several months, Fehlman raised concerns about the management of the department, which Mankowski rebuffed. Fehlman and other officers requested a meeting with the Police & Fire Commission (PFC), where Fehlman raised concerns that Mankowski instilled fear in officers; Mankowski lacked professionalism and, while on duty, told a bar owner that he should consider having the owner’s wife dance topless; Mankowski ordered officers to turn off their body cameras in violation of department policy; Mankowski verbally abused suspects; Mankowski changed radio talk procedures in ways that threatened officer safety; Mankowski prioritized speed limit enforcement over responding to an allegation of child abuse at a school.Mankowski subsequently harassed Fehlman, taking away his work credit card and threatening charges of insubordination. Fehlman resigned from the NPD. Mankowski allegedly interfered with Fehlman’s job search by making false, negative comments (Fehlman was hired nonetheless). Fehlman also discovered that his NPD personnel file had been altered and that Mankowski gave information to the unemployment compensation office that led to a delay in benefits.Fehlman sued Mankowski under 42 U.S.C. 1983, alleging violation of his First Amendment rights. The Seventh Circuit affirmed the dismissal of his complaint. Fehlman’s statements to the PFC were made in his capacity as a public employee, not a private citizen. View "Fehlman v. Mankowski" on Justia Law

The Supreme Court held that indefinite sentencing under the "Reagan Tokes Law," which became effective in March 2019 and requires that for certain felony offenses a sentencing court impose on the offender an indefinite sentence consisting of a minimum and a maximum prison term, is not unconstitutional.The two appellants in this case - Christopher Hacker and Danan Simmons - were both subject to sentencing under the Reagan Tokes Law. On appeal, Appellants argued that Ohio Rev. Code 2967.271, which allows the Ohio Department of Rehabilitation and Correction to maintain an offender's incarceration beyond the minimum prison term imposed by a trial court, violates the separation of powers doctrine, procedural due process, and the right to a jury trial. The Supreme Court disagreed and affirmed, holding that Appellants failed to rebut the Reagan Tokes Law's presumption of constitutionality in their facial challenge. View "State v. Hacker" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions other than his unlawful possession conviction, which the Court vacated in light of its recent opinion in Commonwealth v. Guardado, 491 Mass. 666 (2023), holding that Defendant's rights under the Second Amendment and his due process rights were violated as to this conviction because the jury was not instructed that licensure was an essential element of the crime.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress his statement at the police station on the grounds that police officers impermissibly recorded it without his express consent and that he was not informed promptly of his right to make a telephone call; (2) the prosecutor did not improperly refer to omissions in Defendant's statement to police officers; (3) there was no reason to reduce the degree of guilt or order a new trial; and (4) in light of this Court's recent opinion in Guardado, Defendant's unlawful possession of a firearm conviction must be vacated. View "Commonwealth v. Morris" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this lawsuit against the Financial Oversight and Management Board for Puerto Rico (FOMB) and its executive director challenging the FOMB's alleged failure to review a sale agreement on untimeliness grounds, holding that the dismissal was proper, albeit on standing grounds.Appellants - several Puerto Rico corporations and individuals - brought this action claiming that the FOMB's alleged failure to review a $384 million loan sale agreement between the Economic Development Bank for Puerto Rico (BDE) and a private investment company violated their constitutional rights under the Fourteenth Amendment's Due Process and Equal Protection Clauses, and a statutory violation under the Puerto Rico Oversight, Management, and Economic Stability act . The district court granted the FOMB's motion to dismiss, concluding that the claims were time-barred. The First Circuit affirmed but on different grounds, holding that Appellants lacked standing because their complaint failed to allege that the FOMB's inaction caused their claimed injury. View "R&D Master Enterprises, Inc. v. Financial Oversight & Management Bd. for P.R." on Justia Law

Plaintiff worked as a Telecommunications Network Coordinator for the Virginia Department of Corrections (VDOC). After VDOC fired Plaintiff for declining a random drug test, Garrett sued, alleging that VDOC employees violated his Fourth Amendment rights by applying VDOC’s drug testing policy to him. Defendants asserted qualified immunity and moved to dismiss. The district court denied the motion, concluding that general constitutional principles clearly establish Plaintiff’s right to be free from suspicionless drug testing.   The Fourth Circuit reversed. The court wrote that based on the facts as alleged in the complaint here, VDOC has some degree of government interest in drug testing Plaintiff. Whether that interest amounts to a “special need” within the meaning of Fourth Amendment jurisprudence is a debatable legal question. By baking into its analysis the absence of a sufficient special need, the district court glossed over the central question for immunity purposes: whether every reasonable official in Defendants’ position would understand that VDOC’s proffered interests were not substantial enough to override Plaintiff’s privacy interest. In view of existing law, the constitutionality of Defendants’ drug testing is simply not “beyond debate.” View "Jacoby Garrett v. Harold Clarke" on Justia Law

Plaintiff filed this action in May 2018, alleging federal claims under Section 1981 and Section 1983 and state law claims against a building inspector Troy Seguirant, the City and County of Honolulu, and other defendants. Only Plaintiff’s Section 1981 claim against Seguirant is at issue in this appeal; the district court dismissed the Section 1983 claims against Seguirant with prejudice.   The Ninth Circuit vacated the district court’s order denying qualified immunity on a claim under Section 1981, and remanding, the en banc court held that Section 1981 does not provide an implied cause of action against state actors. Joining other circuits and overruling Federation of African American Contractors v. City of Oakland, 96 F.3d 1204 (9th Cir. 1996), the en banc court held that Section 1981, as amended in 1991, establishes substantive rights that a state actor may violate but does not itself contain a remedy against a state actor for such violations. Thus, a plaintiff seeking to enforce rights secured by Section 1981 against a state actor must bring a cause of action under 42 U.S.C. Section 1983. The en banc court remanded with instructions to allow the plaintiff to replead his Section 1981 claim as a Section 1983 claim. View "HITOSHI YOSHIKAWA V. TROY SEGUIRANT, ET AL" on Justia Law