Justia Civil Rights Opinion Summaries

The Supreme Court reversed the district court’s grant of summary judgment for Plaintiff inmates and grant of injunctive relief enjoining state officials and their agents from denying the inmates a marriage ceremony via videoconference or enforcing the Department of Correctional Services’ policy that interfered with Plaintiffs’ ability to marry. The Department denied Plaintiffs’ request to marry under an internal policy that it does not transport an inmate to another facility for a marriage ceremony. The inmates were also denied a marriage ceremony via videoconferencing because the Department interpreted Neb. Rev. Stat. 42-109 to require Plaintiffs to both appear physically before an officiant. Plaintiffs sued Defendants - state officials - in their individual capacities for interfering with the inmates’ request to marry. The district court concluded that the Department’s policy impermissibly burdened the inmates’ right to marry and that its interpretation of section 42-109 was constitutionally flawed and granted an injunction. The Supreme Court reversed, holding that the district court erred in granting the inmates juncture relief because Defendants could only be sued for injunctive relief in their official capacities. View "Gillpatrick v. Sabatka-Rine" on Justia Law

The money that a homosexual man paid to father children through in vitro fertilization—and in particular, to identify, retain, compensate, and care for the women who served as an egg donor and a gestational surrogate—was not spent "for the purpose of affecting" his body's reproductive "function" within the meaning of I.R.C. 213. In this case, the Eleventh Circuit held that it was constrained by I.R.C. 213's plain language where taxpayer's own function within the human reproductive process was to produce and provide healthy sperm, and because taxpayer was and remained capable of performing that function without the aid of IVF-related treatments, those treatments did not affect any function of his body and did not qualify as deductible "medical care" within the meaning of Section 213(a). The court also held that the IRS's disallowance of taxpayer's claimed deduction neither violated any fundamental right nor discriminated on the basis of any suspect (or quasi-suspect) characteristic. View "Morrissey v. United States" on Justia Law

The statutory presumption set forth in Ariz. Rev. Stat. 25-814(A)(1) that a man is presumed to be a legal parent if his wife gives birth to a child during the marriage applies to couples in same-sex marriages.After Kimberly McLaughlin and Suzan McLaughlin were married in California, Kimberly gave birth to a baby boy, E. When E. was almost two years old, Kimberly moved out of the parties’ home, taking E. with her. Thereafter, Suzan filed petitions for dissolution and for legal decision-making and parenting time in loco parentis. Suzan also challenged the constitutionality of Arizona’s refusal to recognize lawful same-sex marriages performed in other states. Based on Obergefell v. Hodges, 576 U.S. __ (2015), the trial court concluded that Kimberly could not rebut Suzan’s presumptive parentage under section 25-814(C). The court of appeals affirmed. The Supreme Court affirmed, holding that Suzan was a presumed parent under section 25-814(A)(1) and that Kimberly was equitably estopped from rebutting Suzan’s presumptive parentage of their son. View "McLaughlin v. Honorable Lori B. Jones" on Justia Law

The plain reading of the Pregnancy Discrimination Act (PDA) covers discrimination against breastfeeding mothers. Plaintiff filed suit against the police department under the PDA and the Family and Medical Leave Act (FMLA) after her reassignment and constructive discharge. The Eleventh Circuit affirmed the jury verdict in favor of plaintiff and held that there was sufficient evidence of intentional discrimination when plaintiff was reassigned from the narcotics task force to the patrol division; the denial of accommodations for a breastfeeding employee violated the PDA when it amounted to a constructive discharge; a reasonable person in plaintiff's position would have felt compelled to resign; and the City's remaining arguments were unavailing. View "Hicks v. Tuscaloosa, Alabama" on Justia Law

Kelcey Patton, a social worker for the Denver Department of Human Services (“DDHS”), was one of those responsible for removing T.D., a minor at the time, from his mother’s home, placing him into DDHS’s custody, and recommending T.D. be placed and remain in the temporary custody of his father, Tiercel Duerson. T.D. eventually was removed from his father’s home after DDHS received reports that T.D. had sexual contact with his half-brother, also Mr. Duerson’s son. DDHS later determined that during T.D.’s placement with Mr. Duerson, T.D. had suffered severe physical and sexual abuse at the hands of his father. T.D. sued Patton under 42 U.S.C. 1983 for violating his right to substantive due process, relying on a “danger-creation theory,” which provided that “state officials can be liable for the acts of third parties where those officials created the danger that caused the harm.” Patton moved for summary judgment on the ground that she is entitled to qualified immunity. The district court denied the motion. Finding no reversible error in that decision, the Tenth Circuit affirmed. View "T.D. v. Patton" on Justia Law

When a state fails to protect a foster child from harm, the foster child can sue the state under the special-relationship doctrine, pursuant to 42 U.S.C. 1983. The special-relationship doctrine provides an exception to the general rule that states aren’t liable for harm caused by private actors. This case is about the geographical reach of the special-relationship doctrine: whether the special relationship (and its accompanying duty to protect)—crosses state lines. James Dahn, a foster child, sued two Colorado social workers responsible for investigating reports that he was being abused, along with others involved with his adoption. Dahn had been in Oklahoma’s custody until, with Oklahoma’s approval, a Colorado-based private adoption agency placed him for adoption with a foster father in Colorado. The foster father physically abused Dahn before and after adopting him. The private adoption agency was responsible for monitoring Dahn’s placement. Together with Colorado, it recommended approval of his adoption by the abusive foster father. Dahn eventually escaped his abusive foster father by running away. Dahn then sued the private adoption agency, its employees, and the Colorado caseworkers who were assigned to investigate reports of abuse from officials at Dahn’s public school. The district court dismissed all of Dahn’s claims except a section 1983 claim against the two Colorado caseworkers and two state-law claims against the agency and its employees, concluding the special-relationship doctrine allowed Dahn to move forward with the 1983 claim, and it exercised supplemental jurisdiction over the remaining state-law claims. The Colorado caseworkers appealed. Though the Tenth Circuit condemned their efforts to protect the vulnerable child, the Court concluded, under the controlling precedents, that the Colorado caseworkers were entitled to qualified immunity, and reversed. View "Dahn v. Amedei" on Justia Law

The notice of termination itself constitutes an adverse employment action, even when the employer later rescinds the termination. The Second Circuit held that plaintiff's notice of termination in this case was itself an adverse employment action, despite its later revocation; likewise, the court saw no reason to construe plaintiff's Family Medical Leave Act (FMLA) claim differently from her Title VII claim with respect to whether the rescission of a notice of termination given to a pregnant employee establishes as a matter of law that the notice may not constitute an adverse employment action; the facts alleged were insufficient to establish constructive discharge nor a hostile work environment; plaintiff's retaliation claim was properly dismissed; and because plaintiff did state a plausible claim of discriminatory termination, and interference with her FMLA rights, the district court should reconsider on remand its decision to decline to exercise supplemental jurisdiction over the state and city law claims. Accordingly, the court vacated in part and remanded, and affirmed in all other respects. View "Shultz v. Shearith" on Justia Law

The Second Circuit vacated the district court's judgment in favor of defendants, agreeing with plaintiff that the district court wrongly instructed the jury that "but for" causation applied to Family Medical Leave Act (FMLA) claims. The court held that FMLA retaliation claims of the sort plaintiff brought here were grounded in 29 U.S.C. 2615(a)(1) and a "motivating factor" causation standard applied to those claims. The court also held that the district court exceeded the bounds of its discretion in admitting and permitting the adverse inferences to be drawn in this case. Accordingly, the court remanded for further proceedings. View "Woods v. START Treatment & Recovery Centers" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her child. Contrary to Mother’s contentions, the court held (1) Mother was not deprived of due process because the district court afforded her sufficient notice of the termination hearing before terminating her parental rights and did not place undue weight not he earlier termination of Mother’s rights to another child; and (2) the court’s findings were sufficient as a matter of law, and the court’s judgment was the “result of the application of independent judicial thought to the process of making fact-findings and conclusions.” View "In re Zoey H." on Justia Law

In 2014, father had partial custody of S.H.; S.H. accused mother of abuse and fled from her home to father. Father sought a temporary order of full custody. A Pennsylvania judge granted mother emergency custody. S.H. was referred to Centre County’s Children and Youth Services (CYS) because of the abuse allegations. CYS concluded that the allegation did not meet the definition of child abuse but continued its investigation, giving S.H. the option of moving into a group home or remaining with his mother. S.H. did not want to stay with her. Mother arranged for S.H. to stay in Youth Haven and objected to any contact with father, claiming that she had sole custody. CYS and Youth Haven allowed contact. After a visit, father complained about Youth Haven, which told CYS that S.H. could not stay due to problems with father. CYS informed father that he could no longer contact S.H. at Youth Haven. Hamilton filed a federal suit, seeking declaratory and injunctive relief, alleging that conspiracy to deprive him of his constitutional rights by “placing S.H. in a shelter tantamount to confinement” and “arbitrarily and capriciously terminating all paternal visits and contact.” While that case progressed, S.H. left Youth Haven. A new Pennsylvania judge vacated the prior emergency custody order, granted father physical custody of S.H., and prohibited contact between S.H. and mother. The Third Circuit affirmed dismissal, finding that the case was mooted when father obtained custody. View "Hamilton v. Bromley" on Justia Law