Justia Civil Rights Opinion Summaries

Devon Arseneau and her ex-husband were involved in a child custody dispute in the St. Louis County Circuit Court. The court appointed Elaine Pudlowski and Brian Dunlop as guardians ad litem to represent the child's best interests and James Reid to conduct psychological evaluations. Following their testimonies, the court awarded sole legal custody to Arseneau’s ex-husband and joint physical custody to both parents. Arseneau subsequently filed a lawsuit under 42 U.S.C. § 1983 against Pudlowski, Dunlop, and Reid, alleging that their actions during the custody proceedings violated her constitutional rights.The United States District Court for the Eastern District of Missouri dismissed Arseneau’s complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court concluded that the defendants were entitled to absolute immunity and had not acted under color of state law. The district court did not address the defendants' arguments regarding Younger abstention or the Rooker-Feldman doctrine.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court determined that Younger abstention did not apply because there were no ongoing state proceedings. It also bypassed the Rooker-Feldman issue, finding that the merits of the case warranted dismissal. The court held that the defendants, as guardians ad litem and a court-appointed psychologist, were entitled to absolute immunity for actions within the scope of their judicial duties, even if those actions were alleged to be wrongful or illegal. Consequently, the court affirmed the dismissal of Arseneau’s § 1983 claims. View "Arseneau v. Pudlowski" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law

A mother, K.G., gave birth to twins in September 2020. Due to concerns about her mental health and ability to care for the children, Muskingum County Adult and Child Protective Services (the agency) took emergency temporary custody of the children. The children were placed with their maternal aunt. The juvenile court adjudicated the children as dependent and continued the agency's temporary custody. K.G. was required to undergo a psychological evaluation, which revealed several mental health conditions that could impair her parenting abilities.The juvenile court later transferred temporary legal custody to the maternal aunt, with the agency maintaining protective supervision. The agency then moved for the maternal aunt to be granted legal custody and for the agency's supervision to be terminated. At the hearing, the agency presented a psychological report by Dr. Wolfgang, which K.G. objected to, arguing she should be able to cross-examine the psychologist. The juvenile court admitted the report and granted legal custody to the maternal aunt.The Fifth District Court of Appeals reversed the juvenile court's decision, holding that K.G.'s due process rights were violated because she was not able to cross-examine Dr. Wolfgang. The agency appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the appellate court's decision, holding that the juvenile court was permitted to consider the psychologist’s report under the statutory scheme governing legal-custody proceedings. The court found that K.G. was not denied an opportunity to cross-examine Dr. Wolfgang and that her due process rights were not violated. The case was remanded to the appellate court for consideration of K.G.'s remaining assignment of error. View "In re R.G.M." on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

The case revolves around a dispute between Sheena Hayes and Morgan Lawrence-Hayes, and Richard Penkoski. The dispute arose from Penkoski's social media posts, which the Hayes couple claimed were harassing and stalking. Penkoski, a public figure who identifies as a pastor, activist, and street preacher, posted content on Facebook criticizing the Hayes couple's church and their organization, Oklahomans for Equality. The Hayes couple, who are also public figures, claimed that they and their minor child were pictured in the posts, which they found offensive and threatening.The Hayes couple obtained a protective order against Penkoski from the District Court of Washington County. The court issued a permanent order of protection for five years, prohibiting Penkoski from posting any pictures, images, videos, or any likenesses of the Hayes couple or their minor child on any social media, making reference to them, or coming within 500 feet of them.Penkoski appealed the decision, arguing that his actions did not meet the requirements of stalking or harassment as defined by the Protection from Domestic Abuse Act, and that his posts were protected by his constitutional right to free speech.The Supreme Court of the State of Oklahoma reversed the lower court's decision. The court found that Penkoski's actions were not directed toward an individual person, but rather were public Facebook posts that named two organizations, not individuals. The court concluded that Penkoski did not direct his posts or comments toward the Hayes couple, and therefore, the district court abused its discretion in issuing the order of protection. The court vacated the order of protection. View "Hayes v. Penkoski" on Justia Law

The case involves Dr. Adam Lowther and his wife, Jessica Lowther, who sued various state officials on behalf of themselves and their children, alleging constitutional claims under 42 U.S.C. § 1983 and state law claims under the New Mexico Tort Claims Act. The claims arose from the warrantless entry into their home, the arrest of Dr. Lowther, and the removal of their children by officials from New Mexico’s Children, Youth, and Family Department (CYFD) and the Bernalillo County Sheriff’s Department (BCSD). The actions of the officials were based on an anonymous report alleging that Dr. Lowther was sexually abusing his four-year-old daughter.The United States District Court for the District of New Mexico granted summary judgment in favor of the defendants, concluding that they were entitled to qualified immunity on the § 1983 claims and that the state law claims failed for similar reasons. The Lowthers appealed the decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the officials had reasonable suspicion that the children had been abused and were in imminent danger, which justified the warrantless entry into the Lowthers' home and the removal of the children. The court also held that the officials had probable cause to arrest Dr. Lowther. Therefore, the officials were entitled to qualified immunity, and the Lowthers' claims were dismissed. View "Lowther v. Children Youth and Family Department" on Justia Law

In the Supreme Court of Wyoming, a case involving minor children was brought forward by their parents, MK and JP-W, against the State of Wyoming. The parents challenged the juvenile court's decision to change the permanency plan for their five children from family reunification to adoption or guardianship. The parents had separated, and the children were taken into protective custody after the father was arrested for aggravated assault.The court affirmed the juvenile court's decision, stating that the Department of Family Services (DFS) had made reasonable efforts to reunify the family without success and that reunification was no longer in the children's best interest. The court found that both parents had significant obstacles to providing suitable environments for the children. The father struggled to obtain appropriate housing and had inconsistent communication with the DFS, while the mother had issues related to domestic violence and failed to complete necessary paperwork concerning past abuse allegations.Additionally, the court rejected the mother's argument that the DFS had violated her due process rights by employing the Interstate Compact on the Placement of Children (ICPC) mechanism to assess her fitness for placement. The court also rejected the claim that the Guardian ad Litem (GAL) should not have been allowed to prove the grounds for the permanency change. Finally, the court found no violation of Mother's due process rights in admitting evidence and witness testimony by the GAL that was not disclosed until shortly before the permanency hearing. The court determined that the parents had been given adequate opportunity to cross-examine witnesses, call their own witnesses, and present their case for reunification. View "MK v. The State of Wyoming" on Justia Law

In this case, Alexandra Gamble (Mother) and Sean Rourke (Father) are divorced and have three children. They had a final parenting plan approved by the 10th Circuit Court-Portsmouth Family Division, which considered Father's residence in Costa Rica and Mother's in New Hampshire. However, Father later decided to reside in New Hampshire. As a result, Father filed a petition to modify the parenting plan, arguing that due to the change in residences, it would be in the children’s best interests to modify the parenting schedule.The Supreme Court of New Hampshire affirmed the decision of the lower court to modify the parenting plan, citing that the lower court exercised its discretion sustainably. The Court held that the trial court correctly interpreted the parenting plan when it ruled that modification was appropriate under RSA 461-A:11, I(g). This statute allows for modification of a parenting plan if changes in the distances between the parents' residences affect the children's best interest.Mother's argument that her due process rights were violated because the trial court considered grounds not raised by Father was rejected. The Supreme Court held that the trial court did not base its decision on these factors. Instead, it found that Father met his burden to modify the parenting plan under RSA 461-A:11, I(g), which was the ground Father had indeed raised.The Supreme Court also rejected Mother's argument that the trial court violated her procedural due process rights by making changes to the parenting plan that were not sought in Father's petition. The Court concluded that the trial court had statutory authority to make these modifications once it found that a statutory predicate circumstance is satisfied, as per RSA 461-A:11, I. View "In re Rourke & Rourke" on Justia Law

In the State of Nevada, Alexander M. Falconi, operating as the press organization Our Nevada Judges, petitioned against the Eighth Judicial District Court, the Honorable Charles J. Hoskin, District Judge, and parties in interest, Troy A. Minter and Jennifer R. Easler. Falconi challenged local rules and a statute that required certain court proceedings to be closed to the public.Falconi filed a media request for camera access in a child custody proceeding between Minter and Easler. Minter opposed the request, arguing it was not in the child's best interest to have his personal information publicly available. The district court denied Falconi's request, citing that the case was sealed and thus required to be private according to local rules.The Supreme Court of the State of Nevada held that the public has a constitutional right to access court proceedings. The local rules and the statute, NRS 125.080, requiring the district court to close proceedings, bypassed the exercise of judicial discretion and were not narrowly tailored to serve a compelling interest. Thus, the court held that these local rules and NRS 125.080 were unconstitutional to the extent they permitted closed family court proceedings without exercising judicial discretion.The court instructed the district court to reverse its order denying media access in the underlying child custody case. The court emphasized the importance of public access to court proceedings, including family court proceedings, which historically have been open to the public. The court rejected the automatic closure of such proceedings and emphasized the necessity of case-by-case judicial discretion in deciding whether to close proceedings. View "Falconi v. Eighth Jud. Dist. Ct." on Justia Law

In this case, the Supreme Court of Alaska ruled on the legal process applying to the Office of Children's Services (OCS) when it seeks to admit a child in its custody to a hospital for psychiatric care. The case centered on a minor named Mira J., a member of the Native Village of Kwinhagak (the Tribe), who was placed in OCS custody and hospitalized for 46 days for psychiatric treatment without a hearing to determine if the hospitalization was justified.The Tribe argued that her hospitalization should have been governed by the civil commitment statutes or, alternatively, that the constitution did not permit OCS to hospitalize a child for such a long time without a court hearing to determine whether the hospitalization was justified. The court rejected the Tribe's statutory argument but agreed that Mira's due process rights under the Alaska Constitution were violated.The court held that while OCS was not required to follow the civil commitment statutes when admitting Mira to either hospital, due process required OCS to promptly notify parties to the child in need of aid (CINA) case when admitting a child to the hospital for psychiatric care. Further, due process required the court to hold a hearing as soon as reasonably possible to determine whether the hospitalization was justified. The court held that the 46-day wait between Mira's first admission to the hospital and the hearing was too long to satisfy due process, and thus reversed the lower court's order authorizing Mira's continued hospitalization. View "Native Village of Kwinhagak v. State of Alaska" on Justia Law