Justia Civil Rights Opinion Summaries

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision.Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days.Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

The case involves claims brought by the parents of a minor child, P.F., who was allegedly bullied, harassed, and assaulted by another student at Clay Elementary School during the 2022–2023 school year due to his sexual orientation. The parents assert that the school district and three employees were aware of these incidents but failed to protect P.F. or notify his parents, instead blaming P.F. or dismissing the other student’s conduct. After removing P.F. from the school and filing reports with authorities, the parents pursued legal action, first filing a complaint with the Iowa Civil Rights Commission (ICRC), which issued a right-to-sue letter. The parents then filed an amended petition in the Iowa District Court for Polk County, asserting three claims under the Iowa Civil Rights Act (ICRA) and three common law tort claims.The defendants moved to dismiss all claims, arguing that the heightened pleading requirements and qualified immunity provisions of the Iowa Municipal Tort Claims Act (IMTCA), as amended by Iowa Code section 670.4A, applied. The Iowa District Court for Polk County denied the motion, finding that the ICRA claims were not torts subject to the IMTCA and that the common law claims met the IMTCA’s pleading standard. The defendants appealed, asserting a right to immediate appeal under section 670.4A(4).The Iowa Supreme Court reviewed the appeal and held that the IMTCA’s qualified immunity and heightened pleading requirements do not apply to claims brought under the ICRA or to common law tort claims, as clarified in Doe v. Western Dubuque Community School District. Because section 670.4A did not apply to any of the claims, the defendants were not entitled to an appeal as of right. The court dismissed the appeal for lack of appellate jurisdiction and remanded the case. View "Fogle v. Clay Elementary School-Southeast Polk Community School District" on Justia Law

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

A group of student and parent organizations, along with individual students, brought suit against state and city officials responsible for New York City’s public education system. They alleged that admissions and screening policies, curriculum content, and a lack of teacher diversity in the city’s schools discriminated against Black and Latino students, resulting in segregation, unequal educational opportunities, and poor educational outcomes. The plaintiffs claimed these practices violated the New York State Constitution’s Education Article, the State Equal Protection Clause, and the New York State Human Rights Law, seeking declaratory and injunctive relief to eliminate admissions screens and address alleged discrimination.The Supreme Court, New York County, dismissed the complaint, finding the issues nonjusticiable as they involved educational policy decisions reserved for the legislature. The Appellate Division, First Department, modified that decision, holding that the claims were justiciable and that the complaint stated viable causes of action under the Education Article, the Equal Protection Clause, and, as to the City defendants, the Human Rights Law. The Appellate Division granted leave to appeal and certified the question of whether its order was properly made.The New York Court of Appeals reviewed the sufficiency of the complaint under the standard for motions to dismiss. The Court held that the plaintiffs failed to adequately plead a deprivation of a sound basic education, as their allegations of deficient resources and discriminatory policies were vague, conclusory, and did not demonstrate a district-wide failure or causation. The Court also found that the equal protection claim lacked sufficient allegations of intentional discrimination, and the Human Rights Law claim was not supported by specific facts. The Court of Appeals modified the Appellate Division’s order and dismissed the complaint, answering the certified question in the negative. View "IntegrateNYC, Inc. v State of New York" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

A private Christian school in Vermont forfeited a girls’ basketball playoff game because it objected, on religious grounds, to playing against a team with a transgender athlete. The school believes that requiring its female athletes to compete against biological males would violate its religious convictions about the immutability of sex. Following the forfeit, the Vermont Principals’ Association (VPA), which oversees extracurricular activities for Vermont schools, expelled the school from all state-sponsored extracurricular activities, including both athletic and non-athletic events.After the expulsion, the school and several students and parents filed suit in the United States District Court for the District of Vermont, seeking a preliminary injunction to reinstate the school’s VPA membership and alleging a violation of their rights under the Free Exercise Clause of the First Amendment. The district court denied the motion, finding that the VPA’s policies regarding transgender athletes were neutral and generally applicable, and thus subject only to rational-basis review. The court concluded that the plaintiffs were unlikely to succeed on the merits of their claim.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s denial of a preliminary injunction. The Second Circuit held that the plaintiffs are likely to succeed in showing that the VPA’s expulsion was not neutral, as it was accompanied by official expressions of hostility toward the school’s religious beliefs. The court found that the plaintiffs also satisfied the requirements of irreparable harm and public interest. Accordingly, the Second Circuit reversed the district court’s order and remanded the case with instructions to grant a preliminary injunction reinstating the school’s VPA membership pending further proceedings. View "Mid Vermont Christian School v. Saunders" on Justia Law

A plaintiff alleged that, between 1965 and 1969, while he was a young child attending an elementary school in a California school district, he was repeatedly sexually assaulted by the school’s principal. The complaint stated that school staff and faculty were aware or suspected the abuse, and that similar abuse occurred to other students. The plaintiff claimed ongoing psychological and emotional harm as a result. He brought four negligence-based causes of action against the school district, asserting that he was not required to present a government tort claim before filing suit due to statutory changes exempting such claims.The Superior Court of Merced County sustained the school district’s demurrer without leave to amend, dismissing the complaint. The court found that the plaintiff’s failure to comply with the Government Claims Act’s claim presentation requirement was fatal to his case, and concluded that legislative changes extending the statute of limitations for childhood sexual assault did not alter the deadline for filing a claim against a public entity.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed whether Assembly Bill No. 218’s retroactive waiver of the Government Claims Act’s claim presentation requirement for claims under Code of Civil Procedure section 340.1 violated the California Constitution’s gift clause. The appellate court held that the retroactive waiver did not create a new liability or cause of action, but merely removed a procedural barrier to suit. The court further found that the legislative purpose of aiding victims of childhood sexual assault served a valid public purpose and did not constitute an unconstitutional gift of public funds. The judgment of dismissal was reversed and the case remanded for further proceedings. View "Doe R.L. v. Merced City School District" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law