Justia Civil Rights Opinion Summaries

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm'n" on Justia Law

Plaintiff filed suit against the school district, claiming that he was retaliated against by the school district because he made public statements to the press regarding the accreditation investigation of the school district. Because plaintiff was not speaking pursuant to any official duties for the school district, bur rather was speaking in his capacity as president of the Georgia Association of Educators, the district court erred when it held that plaintiff's speech fell under the rule announced in Garcetti v. Ceballos. Accordingly, the court vacated the district court's order granting summary judgment in favor of the school district and remanded for further proceedings. View "Hubbard v. Clayton Co. Sch. Dist., et al." on Justia Law

Plaintiffs filed an action alleging that the practice by which the Nation’s pledge of allegiance is recited each morning in Defendants’ public schools violated (1) Plaintiffs’ equal protection rights under the Massachusetts Constitution because the pledge included the words “under God,” and (2) Mass. Gen. Laws ch. 76, 5, which prohibits discrimination in Massachusetts public school education. The superior court granted summary judgment in favor of Defendants and the intervenors. The Supreme Judicial Court affirmed, holding that the recitation of the pledge, which no student is required to recite, does not violate the Constitution or the statute. View "Doe v. Acton-Boxborough Reg'l Sch. Dist." on Justia Law

Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law

Sjöstrand graduated magna cum laude from Ohio State University in only two and a half years. She applied to the school’s Ph.D program in School Psychology, where her grade-point average (3.87) was tied for highest in the applicant pool and her GRE scores (combined 1110) exceeded OSU requirements. Sjöstrand suffers from Crohn’s disease. She claims that, in interviews, two of the program’s professors focused on her disease. Of seven applicants interviewed by the school, only Sjöstrand was rejected. She was initially told only that she did “not fit the program.” She sued under Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, and the Rehabilitation Act, 29 U.S.C. 701. The district court granted OSU summary judgment. The Sixth Circuit reversed, finding that jury questions remained regarding whether she was rejected because of her disability.View "Sjostrand v. Ohio St. Univ." on Justia Law

After the Supreme Court decided that the University of Michigan’s undergraduate admissions plan’s use of race-based preferences violated the Equal Protection Clause, but that its law school admission plan’s limited use did not, Michigan voters adopted a new section of the state constitution (Proposal 2), prohibiting use of race-based preferences in the admissions process for state universities. The district court upheld Proposal 2, but the Sixth Circuit reversed, concluding that it violated Supreme Court precedent. The Supreme Court reversed. Justice Kennedy, with Chief Justice Roberts and Justice Alito, reasoned that the principle that consideration of race in admissions is permissible when certain conditions are met was not challenged; the issue was whether, and how, state voters may choose to prohibit consideration of such racial preferences. The decision by Michigan voters reflects an ongoing national dialogue; there was no infliction of a specific injury of the type at issue in cases cited by the Sixth Circuit. Individual liberty has constitutional protection, but the Constitution also embraces the right of citizens to act through a lawful electoral process, as Michigan voters did. Justices Scalia and Thomas stated that the question here, as in every case in which neutral state action is said to deny equal protection on account of race, is whether the challenged action reflects a racially discriminatory purpose. Stating that it did not, the Justices stated that the proposition that a facially neutral law may deny equal protection solely because it has a disparate racial impact “has been squarely and soundly rejected.” Justice Breyer agreed that the amendment is consistent with the Equal Protection Clause, but reasoned that the amendment only applies to, and forbids, race-conscious admissions programs that consider race solely in order to obtain the educational benefits of a diverse student body; the Constitution permits, but does not require, the use of that kind of race-conscious program. The ballot box, not the courts, is the instrument for resolving debates about such programs. This case does not involve a diminution of the minority’s ability to participate in the political process. View "Schuette v. Coal. Defend Affirmative Action, Integration & Immigration Rights" on Justia Law

Plaintiff filed suit against OCCC, alleging claims of discrimination on the basis of a "perceived disability" and retaliation in violation of Title II of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. The district court concluded that plaintiff, who was enrolled in OCCC's medical Laboratory Technology program, failed to establish that OCCC perceived his shaking hands to substantially limit a major life activity, and granted the motion for summary judgment in favor of OCCC as to the ADA discrimination claim. The district court also granted summary judgment in favor of OCCC on the retaliation claim because plaintiff had not presented any evidence that OCCC's good faith belief that plaintiff had falsified documents was a legitimate, non-discriminatory reason for the disciplinary referral. The court concluded that plaintiff failed to demonstrate that OCCC perceived him as having an impairment that substantially limited a major life activity; plaintiff failed to demonstrate that OCCC's explanation for its decision to bring disciplinary proceedings against him was pretext for retaliation; and plaintiff's remaining arguments were without merit. Accordingly, the court affirmed the judgment of the district court. View "Widomski v. Orange County Community College" on Justia Law

Plaintiff filed suit against an elementary school principal who did not allow him to distribute religious material to other adults at his son's in-class winter party. On appeal, plaintiff challenged the district court's dismissal of his constitutional claim based on qualified immunity. The court found that plaintiff failed to establish that a right to distribute religious gifts was clearly established for the purpose of qualified immunity analysis. Accordingly, plaintiff's allegations were not sufficient to overcome the principal's qualified immunity defense. The district court did not address the actual constitutionality of the principal's conduct and the court concluded that it need not reach the question. The court affirmed the district court's judgment. View "Morgan, et al. v. Plano Indep. Sch. Dist., et al." on Justia Law

The Board and School District appealed from the district court's grant of summary judgment permanently enjoining defendants from enforcing Reg. I.Q. Reg. I.Q. governs the "extended use" of school facilities outside of school hours by outside organizations and individuals. The district court found that enforcement of Reg. I.Q. to exclude religious worship services would violate the Free Exercise and Establishment Clauses. The court concluded that the Free Exercise Clause did not entitle Bronx Household to a grant from the Board of a subsidized place to hold religious worship services; the Supreme Court's ruling in Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah that invidiously discriminatory ordinances targeting a religious practice of a particular religion were subject to strict scrutiny had no application to Reg. I.Q.; if the Board has a reasonable, good faith concern that making its school facilities available for the conduct of religious worship services would give rise to a substantial risk of violating the Establishment Clause, the permissibly of the Board's refusal to do so did not turn on whether such use of school facilities would in fact violate the Establishment Clause; and therefore, Reg. I.Q. did not violate plaintiffs' rights to free exercise of religion, whether or not it was subject to strict scrutiny. The court also concluded that the district court erred in concluding that Reg. I.Q. violates the Establishment Clause because it compelled the Board to become excessively entangled with religion by deciding what were religious worship services. The court considered Bronx Household's other arguments and found them to be without merit. Accordingly, the court reversed the judgment of the district court and vacated the injunction barring enforcement of Reg. I. Q. View "Bronx Household v. Board of Education" on Justia Law

In this nearly fifty-year-old desegregation case, the United States appealed the district court's order implementing a freedom of choice plan intended to desegregate the formerly de jure African-American middle school and high school in the Cleveland School District. At issue was the district court's adoption of a plan that abolished attendance zones and a majority-to-minority transfer program and implemented a freedom of choice plan that allowed each student in the district to choose to attend any junior high or high school. The court concluded that, given the available statistics that not a single white student chose to enroll at the schools after the district court's order, and that historically, over the course of multiple decades, no white student has ever chosen to enroll in the school, the district court's conclusion that a freedom of choice plan was the most appropriate desegregation remedy at those schools certainly needed to be expressed with sufficient particularity to enable the court to review it. Accordingly, the court reversed and remanded for a more explicit explanation of the reasons for adopting the freedom of choice plan, and/or consideration of the alternative desegregation plans proposed by the parties. View "Cowan v. Bolivar County Bd. of Educ." on Justia Law