Justia Civil Rights Opinion Summaries

A Caucasian high school football player (H) accidentally hit an African-American team member (D) with his car, causing D to suffer a sprained ankle. H got out and apologized. D threatened to kill him. The principal had instructed staff to be lenient with African-Americans because too many were serving suspensions. Although the Code of Conduct prohibits threats, the school did not discipline D. D's parents threatened suit. The principal admitted suspending H for 10 days to "cover" himself and the school. H's witness statements were not provided to panelists in advance. H's attorney was limited to passing notes and not allowed to present witnesses. Employees were informed that they would lose their jobs if they attended the hearing. The board sustained the charge of reckless endangerment and suspension, so that it went on H's record. An appeal was denied. Before his suspension, college recruiters had approached H and a congressman had offered an appointment, the first step to attend a military academy. H alleges he lost those opportunities. The district court dismissed 42 U.S.C. 1983 claims for substantive due process violations, failure to train, and negligence; claims by H's parents; claims against individuals in their official capacities; claims against the board of education and the public school system. The Sixth Circuit affirmed denial of the motion to dismiss procedural due process and equal protection claims based on the conduct of three defendants and that those defendants are not protected by qualified immunity.

A former public high school student alleged that his history teacher violated his rights under the Establishment Clause by making comments during class that were hostile to religion in general, and to Christianity in particular. At issue was whether the teacher was entitled to qualified immunity. The court affirmed the district court's conclusion that the teacher was entitled to qualified immunity. The court also held that because it was readily apparent that the law was not clearly established at the time of the events in question, and because the court could resolve the appeal on that basis alone, the court declined to pass upon the constitutionality of the teacher's challenged statements.

Plaintiff sued his former music teacher, the Logan-Rogersville R-VII School District, and the school principal, asserting nine different claims stemming from the teacher's alleged sexual abuse of plaintiff. At issue was whether the district court erred in dismissing plaintiff's claims and denying his motion to amend his complaint. The court held that the district court correctly concluded that Counts 3, 4, 7, 8, and 9 were time-barred where plaintiff's complaint established that his cause of action accrued in 1992 when he was 15 years old, the statute of limitations was tolled until his 21st birthday, and he had five years, until November 22, 2003, to file his complaint. The court also held that plaintiff's claims under 42 U.S.C. 1983 and Title IX were also time-barred where both claims relied on the state's statute of limitations governing personal-injury claims and Missouri imposed a five-year statute of limitations for personal injury actions, Mo. Rev. Stat. 516.120.4. For the same reasons, plaintiff's state-law claims were time barred by section 516.120.4. The court further held that the district court's dismissal of plaintiff's childhood sexual abuse claim was affirmed where Mo. Rev. Stat. 537.046 required him to commence his action within five years of his 18th birthday. The court finally held that the district court properly dismissed plaintiff's sexual abuse claim against the school district and principal and the district court did not err in denying as futile plaintiff's motion to amend. Accordingly, the court affirmed the judgment of the district court.

Plaintiffs appealed from a judgment of the district court granting summary judgment in favor of a school district and principal on 42 U.S.C. 1983 claims arising out of the treatment of their son, a middle school student with a history of misbehavior in school, who wrote an essay with descriptions of illegal activity, violence, and suicide (Racing Time essay). Plaintiffs appealed the dismissal of a First Amendment retaliation claim brought on behalf of their son and the dismissal of their own Fourth Amendment substantive due process claim. The court held that none of the principal's actions in response to the student's speech constituted retaliation; and because neither of the principal's actions in response to the essay were adverse, the court affirmed the district court's grant of summary judgment to the principal on the First Amendment retaliation claim. The court also held that the principal's call to Child and Family Services (CFS) did not violate the parents' substantive due process rights where there was no actual loss of the parents' custody and no reasonably jury could conclude that the principal's report to CFS, or the resulting requirement that the student by psychiatrically evaluated, was even remotely "outrageous" or "conscience-shocking." The court did not reach the question of qualified immunity. Accordingly, the court affirmed the judgment of the district court.

A special education support teacher sued the school district and administrators under 42 U.S.C. 1983, asserting that her constitutional rights were violated because she was ordered to a room with an autistic fourth-grade student even though he was known to be violent and should have been previously transferred to an alternative school. The district court granted summary judgment for defendants. The Seventh Circuit affirmed, stating that the district's actions were flawed and short-sighted, but do not "shock the conscience" as required to maintain a substantive due process claim.

Appellant filed suit against the Fayetteville, Arkansas School District (District) alleging he was a victim of sexual harassment in violation of Title IX, 20 U.S.C. 1681. At issue was whether the district court erroneously instructed the jury and further erred in empaneling a twelve-member jury as oppose to a six-member jury. The court held that the district court did not abuse its discretion because the instruction provided by the district court accurately portrayed the law underlying appellant's Title IX claim where the "harasser must be motivated by [appellant's] gender or his failure to conform to stereotypical male characteristics" and because appellant was not entitled to an instruction on his theory of the case since it did not comport with the law where mere name-calling and rumors with sexual connotations were insufficient to provide relief under Title IX. The court also held that appellant's argument regarding the district court's error in empaneling a twelve-member jury had no merit where the district court had discretion to select "at least 6 and no more than 12 members" for a jury. Accordingly, the judgment was affirmed.

Plaintiffs sued, inter alia, the Covington County School District, its Board of Education, its president, and other persons, in their official and individual capacities (collectively, Education Defendants), as well as other known and unknown persons, under 42 U.S.C. 1983 and 1985, alleging violations of Jane Doe's Fourteenth Amendment substantive due process rights and various state law violations where the Education Defendants were deliberately indifferent to nine-year-old Jane's safety when they forced her into the sole custody of an unauthorized adult who took her off of the school's grounds. At issue was what were the circumstances under which a compulsory-attendance, elementary public school had a "special relationship" with its nine-year-old students such that it had a constitutional "duty to protect" their personal security. The court held that plaintiffs have pleaded a facially plausible claim that the school violated Jane's substantive due process rights by virtue of its special relationship with her and its deliberate indifference to known threats to her safety. Accordingly, the court reversed the district court's grant of the Education Defendants' Federal Rule of Civil Procedure 12(b)(6) motion, affirmed that court's qualified immunity dismissal of plaintiffs' special relationship claims against those Education Defendants sued in their individual capacities, and remanded to the district court for further proceedings.

Matt Onnen was terminated from the position of registrar at Southeast Technical Institute (STI), an entity of the Sioux Falls School District, after STI officials found several degrees or diplomas had been approved and awarded by Onnen to students who had not earned them, and several students entitled to a degree or diploma had not received one. The Sioux Falls School Board affirmed the decision. Onnen appealed the District's and Board's decision to circuit court, which affirmed the District. On appeal, the Supreme Court affirmed, holding (1) the district court did not err in concluding that the District's decision was not arbitrary and capricious or an abuse of discretion; (2) because Onnen was not a teacher at STI, he was not entitled to sixty days' notice before termination, and therefore Onnen was not denied procedural due process when he was terminated; and (3) the district court did not abuse its discretion in denying Onnen's motion for a new trial.

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

Plaintiffs, a Christian sorority and fraternity, as well as several of their officers at San Diego State University, brought suit in federal district court challenging the university's nondiscrimination policy under the First and Fourteenth Amendments. Plaintiffs subsequently appealed the district court's grant of summary judgment on all counts in favor of defendants. At issue was whether the Supreme Court's holdings in Christian Legal Society Chapter of the University of California, Hastings College of the Law v. Martinez extended to a narrow nondiscrimination policy that, instead of prohibiting all membership restrictions, prohibited membership restrictions only on certain specified bases. The court held that the narrower policy was constitutional. The court held, however, that plaintiffs have raised a triable issue of fact as to whether the narrower policy was selectively enforced in this particular case, thereby violating plaintiffs' rights under the First and Fourteenth Amendments. Accordingly, the court affirmed in part and reversed in part, and remanded to the district court for further proceedings.