Justia Civil Rights Opinion Summaries

A trial court that wishes to us the McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804 (1973), as part of its jury instructions should translate it into everyday parlance and fit it to the facts and circumstances of a particular case.In this case alleging violations of federal and state law, including the Family and Medical Leave Act and the Rhode Island Civil Rights Act, the First Circuit affirmed the judgment of the district court entering a take-nothing verdict in favor of Defendants. Plaintiff moved for a new trial, arguing, among other things, that the district court erred in employing the McDonnell Douglas framework in its jury instructions. The First Circuit affirmed, holding that the district court’s jury instructions as a whole were satisfactory. View "Teixeira v. Town of Coventry" on Justia Law

The Milchteins have 15 children. The two eldest refused to return home in 2011-2012 and were placed in foster care by Wisconsin state court orders. In federal court, the Milchteins argued that state officials violated the federal Constitution by either discriminating against or failing to accommodate their views of family management in the Chabad understanding of Orthodox Judaism. Those children now are adults. State proceedings with respect to them are closed. The Seventh Circuit affirmed the dismissal of the Milchteins’ suit as moot, rejecting arguments the district court could have entered a declaratory judgment because the Milchteins still have 12 minor children, who might precipitate the same sort of controversy. The Milchteins did not seek alteration of the state court judgment, so the Rooker-Feldman doctrine did not block this suit but it is blocked by the requirement of justiciability. The Milchteins want a federal judge to say where a state judge erred but not act on that error: “a naked request for an advisory opinion.” If Wisconsin again starts judicial proceedings concerning the Milchteins’ children, the "Younger" doctrine would require the federal tribunal to abstain. Younger abstention may be inappropriate if the very existence of state proceedings violated the First Amendment but the Milchteins do not contend that it is never permissible for a state to inquire into the welfare of a religious leader’s children. View "Milchtein v. Chisholm" on Justia Law

Plaintiffs filed suit alleging that social workers violated their constitutional rights to family unity and companionship, and as well as their small children's rights, by removing the children from home without a warrant or court order. Plaintiffs were the subject of a criminal investigation after they tried to print nude photos of their three children. Determining that the appeal was timely, the Ninth Circuit affirmed the district court's order denying plaintiffs' motion to seal the summary judgment order where the district court protected the privacy of the children, Arizona law prohibits the Department of Economic Security from releasing the files, the district court order employed clinical, anatomically correct language to briefly describe the nudity depicted in the photographs, plaintiffs did not file their complaint under seal, and plaintiffs gave public interviews where they described the photos at issue. The panel reversed the district court's order granting summary judgment in favor of the social workers based on qualified immunity, holding that the social workers did not have reasonable cause to believe the children were at risk of serious bodily harm or molestation when they removed the children from their home without judicial authorization. The panel remanded for further proceedings. View "Demaree v. Pederson" on Justia Law

Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved.The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren. View "Tyler v. Iowa Department of Revenue" on Justia Law

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