Justia Civil Rights Opinion Summaries

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

John Doe, a high school student with several psychological disabilities, repeated his freshman year at an out-of-state boarding school. Upon returning to Rhode Island, he sought a waiver from the Rhode Island Interscholastic League (the League) to extend his eligibility to play sports into his fifth year of high school, citing his disabilities as the reason for his request. The League denied the waiver, stating that his ineligibility was due to his voluntary decision to repeat the ninth grade, not his disabilities.Doe's parents appealed the League's decision to the Waiver Request Hearing Committee and the Principals' Committee, both of which upheld the denial. Subsequently, Doe filed a lawsuit in the District of Rhode Island, claiming that the League's refusal violated Titles II and III of the Americans with Disabilities Act (ADA). The district court granted a permanent injunction, allowing Doe to play sports in his fifth year, reasoning that the League's rule was not an essential aspect of its program and that Doe's disability was the but-for cause of his ineligibility.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's injunction. The appellate court concluded that Doe's disability was not the but-for cause of his ineligibility, as his decision to repeat the ninth grade was unrelated to his disability. Additionally, the court held that waiving the eight-semester rule would fundamentally alter the League's interscholastic athletics program, which aims to ensure competitive parity and maximize student participation. Thus, the requested accommodation was deemed unreasonable. View "Doe v. Rhode Island Interscholastic League" on Justia Law

Neysha Cruz, on behalf of her son O.F., filed a lawsuit against the New York City Department of Education (DOE) under the Individuals with Disabilities Education Act (IDEA). Cruz rejected the DOE's education plan for O.F., who has multiple disabilities, and sought reimbursement for his private school tuition. Cruz argued that the DOE's placement of O.F. in a twelve-student classroom violated a New York regulation requiring students with highly intensive management needs to be placed in classes of six or fewer students. The DOE acknowledged the regulation but argued that another regulation allowing a maximum of twelve students for those with severe multiple disabilities also applied, giving them discretion in class size placement.An Impartial Hearing Officer (IHO) initially found that the DOE offered O.F. a Free Appropriate Public Education (FAPE) but that the recommended school could not implement the IEP due to scheduling issues. The IHO ordered partial reimbursement for private tuition. The State Review Officer (SRO) reversed the IHO's finding on the school's ability to implement the IEP and concluded that the DOE provided a FAPE, thus denying reimbursement.The United States District Court for the Southern District of New York upheld the SRO's decision, agreeing that the DOE could choose between the two class size regulations. Cruz appealed to the United States Court of Appeals for the Second Circuit.The Second Circuit found that the case hinged on interpreting New York's education regulations and certified the question to the New York Court of Appeals. The court sought clarification on whether the DOE must satisfy both class size regulations or if it can choose between them when both apply to a student. The Second Circuit retained jurisdiction pending the state court's response. View "Cruz v. Banks" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

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

The plaintiffs, January and Jeffrey Littlejohn, allege that the Leon County School Board and its officials violated their parental due-process rights. The dispute arose when school officials met with the Littlejohns' thirteen-year-old child to discuss the child's gender identity and developed a "Student Support Plan" without involving the parents, contrary to their wishes. The school officials acted in compliance with the Board's guidelines, which did not require parental notification if the child did not request it.The United States District Court for the Northern District of Florida dismissed the Littlejohns' claims. The court found that the release of a new guide in 2022 mooted the claims for injunctive relief based on the superseded 2018 guide. It also determined that the individual defendants were entitled to qualified immunity on the damages claims. The court concluded that the school officials' actions did not "shock the conscience" and thus did not violate the Littlejohns' substantive due-process rights. Consequently, the court dismissed the federal claims and declined to exercise supplemental jurisdiction over the state constitutional claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the actions of the school officials were executive, not legislative, in nature. Therefore, the appropriate standard was whether the officials' conduct "shocked the conscience." The court concluded that the school officials' actions did not meet this standard as a matter of law. The court emphasized that the officials did not act with intent to injure and sought to help the child, even if their actions were contrary to the parents' wishes. Thus, the dismissal of the Littlejohns' claims was affirmed. View "Littlejohn v. School Board of Leon County" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law