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

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 The court found that the release of a new guide in 2022 mooted the claims for injunctive relief based on the superseded 2018 guide.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

A high school student, K.J., was involved in a fight on campus and was initially suspended for three days. After reviewing surveillance footage and learning about injuries sustained during the fight, school officials extended K.J.'s suspension and recommended his expulsion, without informing him of the new charges or evidence. K.J. was not given an opportunity to respond to these new allegations.The United States District Court for the Southern District of California found that the school officials violated K.J.'s procedural due process rights by not informing him of the new charges or evidence. However, the court granted summary judgment in favor of the defendants, holding that they were entitled to qualified immunity because the law was not clearly established regarding due process protections for suspension extensions. The court also held that K.J. lacked standing to seek expungement of his disciplinary record, as it was speculative that the record would harm his reputation or future prospects.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment. The Ninth Circuit agreed that K.J.'s due process rights were violated, as he was not given notice of the new charges or an opportunity to respond. The court held that the defendants were not entitled to qualified immunity because the requirements for due process in school suspensions were clearly established in Goss v. Lopez. The court also held that K.J. had standing to seek expungement of his disciplinary record and that such relief was not barred by Eleventh Amendment sovereign immunity. The case was remanded to the district court to consider K.J.'s claims for damages and expungement. View "K. J. V. JACKSON" on Justia Law

Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law

Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law

A medical student at Florida International University (FIU) failed nine courses, including six while on academic probation, and was required to repeat a year. He was also reported for unprofessional behavior by three professors. Despite receiving accommodations for his diagnosed ADHD and anxiety disorder, he continued to perform poorly, failing multiple exams and receiving low scores on others.The student was placed on academic probation and later took a voluntary medical leave. Upon returning, he failed additional courses and was given another chance to repeat the second year. In his third year, he failed five final exams and scored poorly on others, leading to a third hearing by the promotion committee, which recommended his dismissal. The student appealed, citing various personal issues but did not initially claim inadequate disability accommodations.The district court granted summary judgment in favor of FIU, concluding that the student was not a "qualified individual" under the Americans with Disabilities Act (ADA) because he could not meet the university's academic standards even with reasonable accommodations. The student appealed this decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the student was not a qualified individual under the ADA, as he failed to meet the essential eligibility requirements of the medical program despite receiving accommodations. The court emphasized the deference given to academic institutions in making judgments about students' academic performance and found that FIU had provided ample opportunities for the student to improve, which he failed to do. View "Nehme v. Florida International University Board of Trustees" on Justia Law

Grace Smith, a high school junior, was repeatedly suspended from Laramie High School for refusing to comply with a COVID-19 indoor-mask mandate imposed by the Albany County School District No. 1 Board of Trustees. After her suspensions, she was arrested for trespassing on school grounds. Grace and her parents, Andy and Erin Smith, filed a lawsuit in the United States District Court for the District of Wyoming against the Board members, the superintendent, and the principal, alleging violations of Grace’s constitutional rights and state law claims.The district court dismissed the federal claims for lack of jurisdiction, ruling that Grace did not suffer an injury in fact necessary for standing. The court reasoned that her injuries were hypothetical because the mask mandate had expired and she was no longer a student at LHS, and that her injuries were self-inflicted. The court declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Tenth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The appellate court held that Grace had standing to bring her claims because she suffered concrete and particularized injuries from the enforcement of the mask mandate, including suspensions and arrest. The court found that her injuries were directly inflicted by the defendants’ actions and were not self-inflicted. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Smith v. Albany County School District No. 1" on Justia Law

The case involves the Hawai‘i Disability Rights Center (HDRC), which represents individuals with developmental disabilities, including children with autism. HDRC alleges that the Hawai‘i Departments of Education (DOE) and Human Services (DHS) unlawfully deny students with autism access to Applied Behavioral Analysis (ABA) therapy during school hours, even when medically necessary. DOE provides ABA services only if deemed educationally relevant, and DHS does not provide ABA services during school hours, even if medically necessary and covered by Medicaid or private insurance.The United States District Court for the District of Hawaii granted summary judgment in favor of DOE and DHS, holding that HDRC's failure to exhaust administrative procedures under the Individuals with Disabilities Education Act (IDEA) was fatal to all its claims, including those under the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, and the Medicaid Act. The court concluded that HDRC, as a protection and advocacy organization, must ensure that parents of its constituents exhaust the IDEA’s administrative process.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that HDRC, as Hawai‘i’s designated protection and advocacy system, can pursue administrative remedies under the IDEA and is therefore bound by the IDEA’s administrative exhaustion requirement for its own claim. However, HDRC need not ensure that parents of individual children with autism exhaust their individual IDEA claims. The court found that HDRC did not exhaust its administrative remedies, and no exceptions to IDEA exhaustion applied.The Ninth Circuit also held that HDRC was not required to exhaust the IDEA’s administrative procedures before bringing its claims under the ADA, Section 504, and the Medicaid Act. The court concluded that HDRC’s non-IDEA claims do not allege the denial of a free appropriate public education (FAPE) and therefore do not require exhaustion under the IDEA. The court affirmed in part, reversed in part, and remanded the case. View "HAWAI'I DISABILITY RIGHTS CRT. V. KISHIMOTO" on Justia Law