Justia Civil Rights Opinion Summaries

Plaintiff, a minor who had been diagnosed with autism, appealed the district court's affirmance of the Hawaii Department of Education (DOE) hearing officer's decision that plaintiff's free and appropriate public education placement complied with the Individuals with Disabilities Act (IDEA), 20 U.S.C. 1400 et seq. Plaintiff also claimed that his tuition reimbursement request for the 2007-2008 school year was timely, and that Loveland Academy was his "stay put" placement. The court held that Loveland Acadamy was not plaintiff's stay put placement because the DOE only agreed to pay tuition for the limited 2006-2007 school year and never affirmatively agreed to place plaintiff at Loveland Academy. The court also concluded that plaintiff's tuition reimbursement claim for the 2007-2008 school year was time-barred and that the district court did not err in finding that the 2007 and 2008 individualized education programs complied with IDEA requirements. Accordingly, the court affirmed the decision of the district court.

Plaintiff, a tenured professor at the University-defendant, was arrested by campus police and charged with stalking and disorderly conduct after unleashing an expletive-filled tirade against a colleague whom he suspected of causing him to receive a parking ticket. Plaintiff was temporarily banned from campus, removed as department head, and required to attend an anger-management class. Although the charges were later dismissed, Collins sued for false arrest, defamation, and violation of his due process rights. The district court granted judgment for the defendants. The First Circuit affirmed, first rejecting an argument that the arrest was illegal because the "violation" was civil in nature. The warrant was supported by probable cause. Suspension with pay for two months was a minimal deprivation that did not entitle plaintiff to pre-deprivation process. Plaintiff was allowed to visit campus several times during the ban and was given adequate process for the minimal deprivation of liberty. An email indicating that plaintiff's presence on campus should be reported was not defamatory.

Plaintiff, an Arab Muslim, served as an associate professor at a state from 2001 to 2006. His performance record was consistently sub-par, and he frequently sparred with policy decisions made by his supervisor. Informed that his contract would not be renewed, he filed suit, alleging that that the school refused to renew his contract based on his race, national origin, and religion, and in retaliation for several claimed instances of complaining about discrimination, all in violation of Title VII. The district court entered judgment for the school. The Seventh Circuit affirmed. There was no direct or circumstantial evidence that plaintiff was treated differently than similarly situated individuals outside his protected class, nor did plaintiff establish retaliation.

Plaintiff brought suit under 42 U.S.C. 1983, alleging that defendants had retaliated against her for exercising her rights under the First Amendment. The district court granted summary judgment to defendants, holding that the speech on which plaintiff based her claim was not protected under the First Amendment and that the individual defendants had qualified immunity from suit. The district court held, alternatively, that summary judgment would have been appropriate if the speech had been protected, because the school district would have fired plaintiff even in the absence of the speech. Plaintiff appealed. The court held that plaintiff had made a prima facie showing of retaliation for speech protected by the First Amendment; that appellees' rebuttal was subject to credibility questions and hence could not be resolved as a matter of law; and that appellees were not, at this stage of the proceedings, entitled to qualified immunity.

Parents "Madeline P." and "Rex P." challenged a school district's actions regarding their child's educational program under the Individuals with Disabilities Education Act (IDEA). A hearing officer found an IDEA violation but awarded less compensatory education services for the child than the parents requested. On appeal, the superior court affirmed the IDEA violation finding and the compensatory education award. The parents appealed, arguing that more compensatory education services should have been awarded; the school district cross-appealed, arguing that no compensatory education services should have been awarded. The Supreme Court affirmed the superior court's findings regarding the school district's violation of the IDEA's procedural and substantive requirements and the compensatory education award.

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed.

Plaintiff, who had a history of depression and bipolar disorder, filed a complaint against the Board when she was terminated from her position when she failed to complete at least six semester hours of professional development training to renew her certificate. At issue was whether a disabled teacher was a "qualified individual with a disability" under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that because plaintiff did not allege that the Board's legal authorization requirement was itself discriminatory, her failure to satisfy such requirement rendered her unqualified and the Board was not required to accommodate her disability. Accordingly, the judgment was affirmed.

Unable to maintain a satisfactory academic record in a state dental school, plaintiff was dismissed. He unsuccessfully petitioned school committees and administrators to overturn the decision, then filed a complaint alleging First Amendment, equal protection, and procedural due process violations. The district court dismissed. The Seventh Circuit affirmed, holding that petitioner received ample process. He had ample notice, having been on academic probation, he was given several opportunities to remediate, and was allowed to appeal.

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted.

Plaintiffs, four former elementary-school students, sued the school district because school officials have, at various times and in various ways, prevented them from evangelizing while at school. At issue was whether the school principals violated clearly established law when they restricted plaintiffs from distributing written religious materials while at school. The court held that the principals were entitled to qualified immunity because clearly established law did not put the constitutionality of their actions beyond debate. Accordingly, the court reversed the judgment of the district court and remanded with an instruction to dismiss plaintiffs' claims as to the principals in their individual capacities.