Justia Civil Rights Opinion Summaries

A student, John Doe, through his mother, Jane Doe, filed a lawsuit against Rocky Mountain Classical Academy (RMCA), Nicole Blanc, and Cullen McDowell, alleging that the school's dress code, which prohibited boys from wearing earrings, violated his rights under the Fourteenth Amendment's Equal Protection Clause and Title IX. The plaintiff also claimed that the school retaliated against him for complaining about sex discrimination.The United States District Court for the District of Colorado dismissed the plaintiff's claims, applying the "comparable burdens" test from the Seventh Circuit's decision in Hayden ex rel. A.H. v. Greensburg Cmty. Sch. Corp. The district court found that the dress code imposed comparable burdens on both boys and girls, and therefore did not constitute sex discrimination.On appeal, the United States Court of Appeals for the Tenth Circuit disagreed with the district court's application of the "comparable burdens" test. The appellate court held that the district court should have applied the intermediate scrutiny standard, which requires a sex-based classification to serve important governmental objectives and be substantially related to achieving those objectives. The court found that the plaintiff had stated a claim upon which relief could be granted under both the Equal Protection Clause and Title IX, as the school had not provided an "exceedingly persuasive justification" for its sex-based classification. Therefore, the court reversed the district court's dismissal of the plaintiff's sex discrimination claims.However, the appellate court agreed with the district court's dismissal of the plaintiff's Title IX retaliation claim. The court found that the plaintiff had not stated a plausible claim for retaliation, as the complaint only permitted the inference that the school took disciplinary actions because of the plaintiff's dress code violations. View "Doe v. Rocky Mountain Classical Academy" on Justia Law

The case involves Brandon Pryor, an advocate for quality educational opportunities in Far Northeast Denver, who was stripped of his volunteer position and restricted from accessing Denver School District No. 1 facilities after he criticized the district and its officials. The district claimed that Pryor's conduct was abusive, bullying, threatening, and intimidating. Pryor sued the district, Superintendent Alex Marrero, and Deputy Superintendent Anthony Smith, alleging First Amendment retaliation.The United States District Court for the District of Colorado granted a preliminary injunction in part, enjoining the defendants from enforcing the restrictions and from taking any other retaliatory action against Pryor, his family, or the school he co-founded, the Robert W. Smith STEAM Academy. The defendants appealed the preliminary injunction.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that Pryor was substantially likely to succeed on the merits of his First Amendment retaliation claim. The court also found that Pryor would suffer irreparable injury if the injunction was denied, that the harm to Pryor without the injunction outweighed the harm to the defendants with the injunction, and that the injunction was not adverse to the public interest. The court concluded that the district court did not abuse its discretion in granting the preliminary injunction. View "Pryor v. School District No. 1" on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law

A West Virginia law, known as the "Save Women's Sports Act," stipulates that athletic teams or sports designated for females, women, or girls shall not be open to students of the male sex, with "male" defined as an individual whose biological sex determined at birth is male. The law was challenged by a 13-year-old transgender girl, B.P.J., who has been taking puberty-blocking medication and has publicly identified as a girl since the third grade. B.P.J. argued that the law violated the Equal Protection Clause and Title IX by preventing her from participating in her school's cross country and track teams.The United States District Court for the Southern District of West Virginia initially granted a preliminary injunction, allowing B.P.J. to participate in her school's sports teams. However, upon review of cross-motions for summary judgment, the court reversed its decision, rejecting B.P.J.'s claims and ruling that the law was constitutional and did not violate Title IX.On appeal, the United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court held that the law could not lawfully be applied to prevent B.P.J. from participating in her school's sports teams. The court found that the law's sole purpose and effect were to prevent transgender girls from playing on girls' teams, which was not substantially related to an important government interest. The court also found that the law violated Title IX by treating B.P.J. worse than people to whom she was similarly situated, depriving her of any meaningful athletic opportunities, and doing so on the basis of sex. The court dismissed the cross-appeal, vacated in part, reversed in part, and remanded the case with instructions to enter summary judgment for B.P.J. on her Title IX claims. View "B.P.J. v. West Virginia State Board of Education" on Justia Law

The case revolves around Chris Corbitt, a holder of an Enhanced Concealed Carry License (ECCL), who filed a complaint for declaratory judgment and injunctive relief against Arkansas State University (ASU) and its trustees. Corbitt sought a declaration that he was entitled to enter the First National Bank Arena (FNB Arena), located on ASU's campus, with a firearm, except for areas hosting a collegiate sporting event. He also sought an order enjoining ASU from prohibiting ECCL holders from entering FNB Arena with a firearm. The FNB Arena is covered by an Alcoholic Beverage Control (ABC) permit, held by NEA Sports Club, which authorizes the consumption and sale of beer and wine on the premises during designated events.The Craighead County Circuit Court granted ASU's motion for summary judgment. The court found that under Arkansas law, FNB Arena can be covered by an ABC permit and ASU can lawfully prohibit firearms in FNB Arena to maintain the alcohol permit while complying with Ark. Code Ann. § 5-73-306(11)(B) as well as Title 3 permit requirements and ABC regulations.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that ASU can lawfully prohibit firearms at FNB Arena under section 5-73-306. The court reasoned that while universities do not have the discretion to prohibit firearms, ASU is prohibiting firearms at FNB Arena because the facility is covered by an alcohol permit, not because it is attempting to exercise discretion. The court concluded that the unambiguous language of subdivision (11)(B) supports ASU’s position that an ECCL holder may not enter FNB Arena with a firearm. View "CORBETT V. ARKANSAS STATE UNIVERSITY" on Justia Law

Four ninth-grade football players at Park Hill High School in Kansas City, Missouri, were suspended or expelled after one of them created an online petition titled "Start Slavery Again" and the others posted comments favoring the petition. They filed a lawsuit against the Park Hill School District and various school officials, claiming that their rights to equal protection and due process were violated.In their suit, the students argued that they were deprived of substantive and procedural due process in the disciplinary procedures. They also claimed that they were deprived of equal protection because another student, who they alleged was a willing participant in creating the petition, was not punished. The U.S. District Court for the Western District of Missouri granted summary judgment for the school district, dismissing all of the students' claims.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The appellate court found that the students received adequate notice and meaningful opportunity to present their case in the school disciplinary proceedings, satisfying the requirements of due process. The court further held that the disciplinary actions taken by the school district were not so egregious as to violate the students' substantive due process rights. Lastly, the court rejected the students' equal protection claim on the basis that the student who was not punished was not similarly situated to the plaintiffs given their greater involvement in creating and supporting the petition. View "Plaintiff A v. Park Hill School District" on Justia Law

A medical resident, Dr. Jacquelyn Mares, was dismissed from Wright State University’s (WSU) obstetrics and gynecology residency program due to ongoing complaints and escalating disciplinary actions related to her unprofessional behavior. Following her dismissal, Mares was also terminated from her position at Miami Valley Hospital, where she was employed during her residency. As a result, Mares sued WSU, the hospital, its owner-operator Premier Health Partners, and several WSU employees, alleging violations of her procedural and substantive due process rights, as well as various contract-based state law claims. The district court granted summary judgment to the defendants.In its ruling, the United States Court of Appeals for the Sixth Circuit held that WSU did not violate Mares' procedural due process rights when it dismissed her from the residency program. The court found that WSU had followed its internal procedures closely and that Mares was afforded more than enough process. Also, the court held that WSU did not violate Mares' substantive due process rights. It determined that WSU's decision to dismiss her was not arbitrary or capricious, nor was it conscience-shocking. Finally, the court held that Miami Valley Hospital did not breach its contractual duties when it terminated Mares after her dismissal from WSU’s residency program. The court concluded that the hospital acted within the scope of the employment contract. Therefore, the court affirmed the district court’s decision to grant the defendants' summary judgment. View "Mares v. Miami Valley Hospital" on Justia Law

In this case, a minor student known as A.J.T., who suffers from epilepsy, sued her school district, Osseo Area Schools, alleging disability discrimination for not providing her evening instruction sessions. A.J.T.'s epilepsy is severe in the mornings, preventing her from attending school until noon. The child's parents requested evening instruction so that she could have a school day closer in length to her peers. However, the school district denied these requests.A.J.T., through her parents, filed a lawsuit alleging violations of Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The district court granted Osseo Area Schools' motion for summary judgment, finding that the school district could not be held liable as it did not act with bad faith or gross misjudgment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court stated that while A.J.T. might have established a genuine dispute about whether the district was negligent or even deliberately indifferent, she failed to prove that school officials acted with "either bad faith or gross misjudgment." The court found that the school district did not ignore A.J.T.'s needs or delay its efforts to address them. It further held that in cases involving educational services for disabled children, mere noncompliance with applicable federal statutes or failure to provide a reasonable accommodation is not enough to trigger liability. The plaintiff must prove that the school officials acted with bad faith or gross misjudgment. In this case, A.J.T. failed to identify conduct that cleared that high bar, and as such, the court held that summary judgment was proper. View "A.J.T. v. Osseo Area Schools, Independent School District No. 279" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered the appeal of Osseo Area Schools (the District) against the ruling of the district court, which held that the District had denied A.J.T., a student with a disability, a Free Appropriate Public Education (FAPE) as mandated by the Individuals with Disabilities Education Act (IDEA). A.J.T. suffers from a rare form of epilepsy, causing seizures that prevent her from attending school before noon. Consequently, her parents had requested the District to provide evening instruction, which was refused.The district court found that the District's refusal to provide A.J.T. with evening instruction resulted in her making de minimis progress overall and even regressing in some areas, such as toileting. The court also determined that A.J.T. would have made more progress had she received evening instruction. On these grounds, the court concluded that the District had failed to provide A.J.T. with a FAPE.On appeal, the Eighth Circuit affirmed the district court's judgment. The court rejected the District's argument that the IDEA's scope was limited to regular school hours, noting nothing in the IDEA suggested such a limitation. Furthermore, the court agreed with the district court's assessment of A.J.T.'s limited progress and regression in toileting. After considering the evidence, the court concluded that the District's refusal to provide evening instruction, based solely on administrative concerns, resulted in A.J.T.'s minimal progress and denied her a FAPE. View "Osseo Area Schools, Independent School District No. 279 v. A.J.T." on Justia Law

In the United States Court of Appeals for the Seventh Circuit, Parents Protecting Our Children, an association of parents, sought an injunction against the Eau Claire Area School District in Wisconsin to stop the enforcement of the District’s Administrative Guidance for Gender Identity Support. The parents argued that the policy violated the Due Process and Free Exercise Clauses of the U.S. Constitution by interfering with their right to make decisions on behalf of their children. The District Court dismissed the case due to lack of subject matter jurisdiction, stating that the parents failed to identify any instance where the policy was applied in a way that infringed on parental rights.The Court of Appeals affirmed the lower court's ruling. The court held that the parents' concerns about potential applications of the policy did not establish standing to sue unless the policy resulted in an injury or created an imminent risk of injury. The court stated that the parents had brought a pre-enforcement facial challenge against the policy without any evidence of the School District applying the policy in a manner detrimental to parental rights.The court also noted that the Administrative Guidance did not mandate exclusion of parents from discussions or decisions regarding a student’s gender expression at school. The court found that the alleged harm was dependent on a speculative "chain of possibilities," which was insufficient to establish Article III standing. Therefore, the court upheld the dismissal of the lawsuit for lack of subject matter jurisdiction. View "Parents Protecting Our Children, UA v. Eau Claire Area School District" on Justia Law