Justia Civil Rights Opinion Summaries

An Arizona state inmate, Michael Ray Fuqua, who identifies as a Christian-Israelite, requested a religious dietary accommodation to observe Passover and the Feast of Unleavened Bread. The prison chaplain, Jeffrey Lind, denied this request, arguing that Fuqua did not substantiate his request with appropriate documentation and that his beliefs were theologically inconsistent. Fuqua claimed that this denial forced him to either starve or spend significant money on commissary food, causing him physical and financial hardship.The United States District Court for the District of Arizona granted summary judgment in favor of Lind on Fuqua’s First Amendment Free Exercise, Fourteenth Amendment Equal Protection, and Religious Land Use and Institutionalized Persons Act (RLUIPA) claims. The court found that Fuqua failed to show a substantial burden on his religious exercise and that Lind had legitimate reasons for denying the request. The court also held that RLUIPA only authorizes equitable relief, which was moot in Fuqua’s case.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Fuqua’s First Amendment and Equal Protection claims, finding that a reasonable trier of fact could conclude that Lind’s denial was based on his own theological assessment rather than a neutral procedural rule. This could constitute a substantial burden on Fuqua’s religious exercise and intentional discrimination. However, the court affirmed the summary judgment on the RLUIPA claim, citing the Ninth Circuit’s decision in Wood v. Yordy, which precludes suits seeking monetary damages under RLUIPA against state officers, and Fuqua’s equitable claims were moot. The case was remanded for further proceedings consistent with this opinion. View "FUQUA V. RAAK" on Justia Law

A transgender woman, who had legally changed her name and gender marker in 2018, sought to have the entire record of her name change and gender marker correction sealed in 2023. She argued that the public availability of these records had led to harassment and threats after her transgender status was disclosed on social media, revealing her personal information and former name. The trial court denied her request to seal the entire record but did seal her application to seal, its supporting documentation, and a physician’s letter attached to her initial petition.The Superior Court of Stanislaus County initially granted her petition for a name and gender change in 2018 without any objections. In 2023, she filed an application to seal the entire record, citing harassment and threats due to the public availability of her records. The trial court denied the request to seal the entire record, reasoning that there was no evidence the harassment was initiated by the court’s records and that sealing the records would not necessarily solve the problem. The court also noted the strong presumption that name changes be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court’s findings were not supported by substantial evidence. The appellate court concluded that the appellant’s privacy and safety interests in concealing her transgender identity outweighed the public’s right of access to the records. The court held that the entire record should be sealed to protect her privacy and safety, as there was no less restrictive means to achieve these interests. The appellate court reversed the trial court’s order and remanded the case with instructions to seal all records revealing the appellant’s name change or gender marker correction. View "In re M.T." on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed that this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, had previously determined that Field’s equal protection argument had merit and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher’s case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and found that the People had not satisfied their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated by requiring Field and Asher to testify during their commitment trials and ordered new commitment trials for both.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court’s orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the orders for new trials were affirmed. View "P. v. Field" on Justia Law

Several contractors and an employee, who regularly handle public works projects for PennDOT and SEPTA, challenged Philadelphia's requirement for project labor agreements (PLAs) on public projects. These PLAs mandated union recognition and membership, and set workforce diversity goals. The plaintiffs argued that these requirements violated their First Amendment rights and the Equal Protection Clause, as well as 42 U.S.C. § 1981. They were ineligible to bid on certain city projects due to their existing collective bargaining agreements with the United Steelworkers, which is not affiliated with the required unions.The United States District Court for the Eastern District of Pennsylvania granted summary judgment to Philadelphia. The court found that the plaintiffs lacked standing to challenge the union-eligibility requirement and failed to show that the diversity requirement caused them harm based on race. The court also concluded that the plaintiffs' § 1981 claim failed because race was not a but-for cause of their inability to work on city projects with PLAs.The United States Court of Appeals for the Third Circuit reviewed the case and found that the plaintiffs had standing to challenge the union-eligibility requirement under the First Amendment. The court determined that the plaintiffs suffered a concrete and particularized injury by being ineligible to bid on city projects due to the PLAs. The court also found that the plaintiffs' claims were not moot despite Philadelphia's subsequent changes to the PLAs, as the plaintiffs sought damages for past violations and prospective relief.The Third Circuit also found that the plaintiffs had standing to raise an Equal Protection claim, as they demonstrated an intent to bid on future projects covered by the PLAs. The court vacated the District Court's judgment and remanded the case for further proceedings to consider the merits of the plaintiffs' First Amendment, Equal Protection Clause, and § 1981 claims. View "Road-Con Inc v. City of Philadelphia" on Justia Law

Three practicing Muslim men alleged that federal agents asked them to serve as informants in Muslim communities. When they refused, the agents placed or retained them on the "No Fly List" and suggested they could be removed from the list if they agreed to work as informants. The plaintiffs sought damages under the Religious Freedom Restoration Act (RFRA), claiming that their religious beliefs precluded them from serving as informants and that the agents substantially burdened their exercise of religion by conditioning their removal from the No Fly List on actions that violated those beliefs.The United States District Court for the Southern District of New York dismissed the complaint on qualified immunity grounds, concluding that the agents were entitled to qualified immunity because there was no clearly established right not to be pressured to inform on members of one's religious community through the coercive or retaliatory use of the No Fly List.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the agents were entitled to qualified immunity because a reasonable person in their position would not have understood that their conduct implicated the plaintiffs' religious beliefs. The court noted that the plaintiffs did not disclose their religious objections to the agents, and there were no facts plausibly supporting the conclusion that the agents knew the plaintiffs' objections were grounded in their religious beliefs. Therefore, the agents were entitled to qualified immunity from damages in their personal capacities. View "Tanvir v. Tanzin" on Justia Law

A man was unable to purchase a firearm because a background check revealed he was subject to a long-term domestic violence protective order (DVPO). He sued the State, claiming he was no longer subject to a protective order as defined by federal statute and sought a permanent injunction and declaratory judgment to have the Department of Public Safety (DPS) notify a national database that he was no longer subject to a protective order under 18 U.S.C. § 922(g)(8). He filed a motion for summary judgment, which the State opposed, filing a cross-motion for summary judgment. The superior court granted the State’s cross-motion, and the man appealed.The superior court found that the DVPO had not expired and remained a qualifying order under Section 922(g)(8). It also concluded that the man’s constitutional claims were not ripe because he had not initiated modification or dissolution of the order. The court entered a final judgment in favor of the State.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the DVPO remained in effect and was a qualifying order under 18 U.S.C. § 922(g)(8). The court found that the legislative history supported the interpretation that DVPOs issued under AS 18.66.100(c)(1) are effective until further order of the court. The court also concluded that the man’s remaining claims were not ripe for adjudication because he had not attempted to dissolve or modify the DVPO. View "Eng v. State" on Justia Law

The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law

In 2006, an individual was convicted of first-degree sexual abuse and later subjected to civil management under New York's Mental Hygiene Law due to a "mental abnormality." Initially confined, he was released to a strict and intensive supervision and treatment (SIST) program in 2016. In 2019, he violated SIST conditions by tampering with an alcohol monitoring bracelet, leading to his temporary confinement based on a psychologist's evaluation and a probable cause finding by the court.The Supreme Court initially found probable cause to believe he was a "dangerous sex offender requiring confinement" and ordered his detention pending a final hearing. He filed a habeas corpus petition, arguing that the statutory scheme violated procedural due process by not providing an opportunity to be heard at the probable cause stage. The Supreme Court denied the petition, and the Appellate Division converted the proceeding to a declaratory judgment action, ultimately declaring the statute constitutional.The New York Court of Appeals reviewed the case and upheld the lower court's decision. The court held that the statutory scheme under Mental Hygiene Law § 10.11 (d) (4) appropriately balances individual and state interests. It concluded that the statute provides sufficient procedural safeguards, including a prompt judicial probable cause determination and a full hearing within 30 days, to mitigate the risk of erroneous confinement. The court found that the petitioner failed to demonstrate that the statute is unconstitutional either on its face or as applied to him. The order of the Appellate Division was affirmed without costs. View "People ex rel. Neville v Toulon" on Justia Law