Justia Civil Rights Opinion Summaries

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law

The case involves a non-verbal student, Alexandre Le Pape, and his family who repeatedly requested that the Lower Merion School District change his educational program to include a new communication protocol known as "Spelling to Communicate" (S2C). The school district denied these requests, leading to Alexandre's withdrawal from public education. The family filed an administrative special education due process complaint against the school district, alleging that the district failed to protect Alexandre's rights and denied him a Free Accessible Public Education (FAPE) under various laws. An administrative hearing officer ruled against the family on all claims, leading them to file a suit in the United States District Court for the Eastern District of Pennsylvania.The District Court granted the school district's motions for summary judgment on the Americans with Disabilities Act (ADA) claim and judgment on the administrative record for the denial-of-FAPE claims. The Le Papes appealed the court's decision, arguing that the court granted judgment without applying the summary judgment standard to which they were entitled under Federal Rule of Civil Procedure 56.The United States Court of Appeals for the Third Circuit reversed and remanded the case. The court held that the District Court erred in granting summary judgment for the school district on the Le Papes' ADA discrimination claim and judgment on the administrative record for their discrimination claims under both the ADA and Section 504. The court clarified that a denial-of-FAPE claim under the Individuals with Disabilities Education Act (IDEA) can be resolved through an administrative appeal, but ADA and Section 504 discrimination claims seeking compensatory damages, even if on the same facts, should be resolved through summary judgment and, possibly, trial. View "Le Pape v. Lower Merion School District" on Justia Law

The case involves two students, Chad Ayach and Joseph Nofal, who were expelled from the University of California Riverside (UC Riverside) following an administrative hearing. The university's Student Conduct and Academic Integrity Programs office (SCAIP) initiated an investigation into the Phi Gamma Delta fraternity (PGD) after receiving a report expressing concern for the health of a member of the fraternity's pledge class. During the investigation, it was revealed that the fraternity engaged in activities that appeared to meet UC Riverside's definitions of hazing. Ayach and Nofal, who held leadership roles in the fraternity, were subsequently expelled.The Superior Court of Los Angeles County reviewed the case after Ayach and Nofal filed a petition for writ of mandate challenging their expulsions. They argued that the university's administrative hearings did not afford them due process because the charging documents and evidence presented used pseudonyms to identify witnesses, and they were purportedly denied the opportunity to confront or cross-examine these witnesses at the hearing. The court denied the petition, and Ayach and Nofal appealed.The Court of Appeal of the State of California, Second Appellate District, Division One, affirmed the lower court's decision. The appellate court concluded that the administrative proceedings afforded Ayach and Nofal the process they were due, given the nature of the charges and their response. The court found that the hearings before the committee provided Ayach and Nofal with a full opportunity to present their defenses, which is what due process requires. The court also noted that the credibility of the witnesses was not central to the disciplinary decision, and therefore, the lack of cross-examination, lack of witness confrontation, and the use of pseudonyms in the description of witness statements did not prejudice Ayach's and Nofal's ability to present a meaningful defense. View "Ayach v. The Regents of the University of California" on Justia Law

The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

The case involves Charles and Lisa Kass, parents of Brody Kass, who sued the Western Dubuque Community School District (the District) alleging that the District violated the Individuals with Disabilities Education Act (IDEA) and other statutes when it developed Brody’s individualized education program (IEP) for the 2020–21 school year. Brody has epilepsy, autism, attention deficit/hyperactivity disorder, severe vision impairment, and intellectual disabilities. Despite Brody having enough credits to graduate, his IEP Team determined he had unmet transitional needs and should remain in school. The District proposed that Brody would not enroll in general education courses in the traditional classroom setting. Instead, Brody would spend a half-day focusing on developing his reading and math skills through individualized and practical training. The Kasses objected to the proposed IEP and filed a complaint with the Iowa Department of Education.The administrative law judge (ALJ) ruled in favor of the District on all claims, concluding the District did not violate Brody’s right to a free appropriate public education (FAPE) in the 2018–19 or 2019–20 school years. The ALJ also determined neither the draft IEP nor its development violated any procedural or substantive provisions of the IDEA. The Kasses brought this action in federal district court, alleging violations of the IDEA, the Americans with Disabilities Act (ADA), and the Rehabilitation Act. The district court affirmed the ALJ’s decision on the IDEA claims and dismissed the other claims as subsumed under the IDEA claims.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The court held that compensatory education may be available beyond a student’s twenty-first birthday. The court also concluded that the District complied with the IDEA’s procedural requirements in drafting the May 2020 IEP. The court found that the May 2020 IEP’s specific and measurable goals were reasonably calculated to enable Brody to progress in light of his circumstances, and thus met the IDEA’s requirements. View "Kass v. Western Dubuque Community School District" on Justia Law

Jason Doherty, a former student at Purchase College, State University of New York, who has Asperger Syndrome, sued several administrators of the college under the Americans with Disabilities Act (ADA) for declaratory and injunctive relief and emotional distress damages. The lawsuit was initiated after the college issued no-contact orders against Doherty at the request of three other students during his freshman orientation in August 2017.The United States District Court for the Southern District of New York dismissed Doherty's claims, ruling that it lacked subject matter jurisdiction over his claims for declaratory and injunctive relief since they were moot, and that Doherty failed to state a claim for damages because emotional distress damages are not available under Title II of the ADA. The district court based its decision on the Supreme Court’s ruling in Cummings v. Premier Rehab Keller, P.L.L.C., which held that emotional distress damages are not available under the Rehabilitation Act, a law that Title II of the ADA explicitly tracks.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Doherty's claims for declaratory and injunctive relief were moot given that the no-contact orders were not disciplinary actions, were not part of his permanent record, and expired upon his graduation. The court also agreed that emotional distress damages are not available under Title II of the ADA, which explicitly tracks the remedies, procedures, and rights available under the Rehabilitation Act. Finally, the court ruled that Doherty had forfeited any claims for other damages. View "Doherty v. Bice" on Justia Law

Paul Montemuro was elected as the President of the Jim Thorpe Area School Board. However, a week later, the Board elected someone else without giving Montemuro any prior notice. Montemuro sued the Board members who voted against him and the Jim Thorpe Area School District, alleging that they had deprived him of his property without due process, in violation of 42 U.S.C. § 1983 and the Fourteenth Amendment. The defendants claimed qualified immunity.The District Court held that Montemuro had a clearly established property right in his employment and had been deprived of that right without due process. The defendants appealed this decision, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court found that Pennsylvania law clearly established that Montemuro had a property interest in his job as the Board President. The Court also accepted Montemuro's allegation that he was removed from office without notice. Therefore, the Court concluded that the defendants were not entitled to qualified immunity because they had violated Montemuro's clearly established right to due process. View "Montemuro v. Jim Thorpe Area School District" on Justia Law