Justia Civil Rights Opinion Summaries

Plaintiff filed suit against MTBank, alleging violations of various state and federal statues by not allowing her to work remotely when she became pregnant. The magistrate judge ruled as a matter of law against plaintiff on a number of claims and the jury found for MTBank on the remaining claims. The court held that the district court abused its discretion in admitting evidence of the reinstatement offer because the offer was, as a matter of law, not unconditional; the district court erred in sua sponte disqualifying the attorneys for both parties, because the disqualification depended on the erroneous admission of evidence relating to the reinstatement offer; the jury instructions were not erroneous; and the court lacked jurisdiction over plaintiff's challenge to the district court's New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., ruling. Accordingly, the court vacated in part in regard to the jury's verdict and the disqualification order, dismissed in part in regard to claims under the NYSHRL, and remanded for further proceedings. View "Jia Sheng v. MTBank Corp." on Justia Law

Appellees, three married female couples, filed suit against Appellant, the director of the Arkansas Department of Health, seeking a declaration that the refusal to issue birth certificates with the names of both spouses of the birth certificates of their respective minor children violated their equal protection and due process rights. Appellees also sought an order requiring Appellant to issue corrected birth certificates. The circuit court ordered Appellant to issue three amended birth certificates naming both spouses. The Supreme Court reversed, holding (1) the circuit court erred in finding that the case was controlled by Smith v. Wright; and (2) the circuit court erred in finding that Ark. Code Ann. 20-18-401(e) and (f) and Ark. Code Ann. 20-18-406(a)(2) facially violated Appellees’ rights to due process and equal protection. View "Smith v. Pavan" on Justia Law

The district court terminated Father’s parental rights with respect to his child, making the child legally available for adoption by her stepfather. Father appealed the termination order. The court of appeals certified the case for transfer to the Supreme Court. At issue before the Supreme Court were Father’s claim of ineffective assistance of counsel and claims to the right to counsel under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and under the due process clause of the Utah Constitution. The Supreme Court reversed, holding that Father had a federal due process right to counsel in the district court proceedings and that that right was erroneously denied in violation of Father’s federal due process rights. View "In re K.A.S." on Justia Law

Mother’s parental rights to her daughter were terminated. During the termination proceedings at the juvenile court, Mother was unrepresented by counsel. At the end of the proceeding, the juvenile court found by clear and convincing evidence that Mother was unfit as a parent and that it was in the best interests of the child to be placed with Adoptive Parents. Mother appealed, challenging on multiple constitutional grounds Utah Code 78A-6-1111(2), the statutory scheme that provides appointed counsel for indigent parents in state-initiated parental termination proceedings while denying such counsel for indigent parents in privately initiated proceedings. The Supreme Court reversed in part, holding (1) section 78A-6-1111(2) is not facially unconstitutional; but (2) the court erred in relying on the statute to deny Mother’s request for counsel without considering Mother’s circumstances and due process rights. View "In re E.K.S." on Justia Law

The Commissioner of Children and Families (Petitioner) filed petitions to terminate the parental rights of Mother and Father (together, Respondents) to their two minor children. The trial court granted the petitions. Respondents appealed, claiming that the trial court erred in finding that Petitioner made reasonable efforts to reunify Respondents with their children and that Respondents were unable to unwilling to benefit from reunification efforts. The Supreme Court affirmed, holding (1) a finding that no reunification efforts were required is an independent basis upon which the trial court could have terminated the parental rights of Respondents; and (2) Respondents’ appeals would be moot because they did not timely appeal from that finding, but such a result would violate Respondents’ due process rights under the circumstances of this case. Remanded for a new trial. View "In re Egypt E." on Justia Law

Father and Mother divorced in 2011. In 2013, the district court ordered Father to pay additional child support for failing to previously pay child support. In 2014, Mother filed a motion to modify custody and enforce the 2013 order. After a hearing, at which Father represented himself, the district court awarded Mother primary physical custody of the child. The district court then held Father in contempt of court for failing to pay child support. The court sentenced Father to a total of eighty days in jail and stayed the contempt sentence on the condition that Father “follow the Orders of the Court.” The Supreme Court affirmed in part and reversed in part, holding (1) a contempt order that does not contain a purge clause is criminal in nature, and because the district court’s contempt order did not contain a purge clause, the district court violated Appellant’s constitutional rights by imposing a criminal sentence without providing Appellant with counsel; and (2) the district court abused its discretion by basing its decision to modify custody on Appellant’s failure to comply with a court order and by failing to consider and set forth its findings as to the Nev. Rev. Stat. 125.480(4) factors for determining the child’s best interest. View "Lewis v. Lewis" on Justia Law

Plaintiff, formerly employed at UICSM as a physician assistant, filed suit alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. The district court granted summary judgment to UICSM. The court noted that 29 C.F.R. 825.311(a) inarguably permitted UICMS to contact plaintiff to inquire about her "status and intent to return to work." The court concluded that UICMS was entitled to summary judgment on plaintiff's interference claim where plaintiff has not presented evidence that UICMS's requests for her to work from home when she had a broken foot were a condition of her employment nor that her compliance with them was anything but voluntary. The evidence does not permit a reasonable jury to find that UICMS interfered with plaintiff's right to FMLA leave. In regard to plaintiff's discrimination claim, the court concluded that the sequence of events alone does not give rise to a causal link between UICMS's alleged discriminatory motive and its decision not to renew plaintiff's contract strong enough to permit her to forgo the burden-shifting framework; applying the McDonnell Douglas framework, the court concluded that UICMS has proffered plaintiff's tardy charting as a nondiscriminatory justification for deciding not to renew her contract; and plaintiff has not created a dispute as to pretext. Accordingly, the court affirmed the judgment. View "Massey-Diez v. UICMS" on Justia Law

Kody Brown, Meri Brown, Janelle Brown, Christine Brown, and Robyn Sullivan (“the Browns”) form a “plural family.” Kody Brown is legally married to Meri Brown and “spiritually married” to the other three women, whom he calls “sister wives.” When the family became the subject of a TLC reality television show in 2010, the Lehi Police Department opened an investigation of the Browns for violating Utah’s bigamy statute, Utah Code Annotated section 76-7-101. The Browns then filed a 42 U.S.C. 1983 action in federal district court against the Governor and Attorney General of the State of Utah and the Utah County Attorney. Claiming the Statute infringed their First and Fourteenth Amendment rights, the Browns sought declaratory relief and a permanent injunction enjoining enforcement of the Statute against them. The Tenth Circuit concluded after review of this matter that the district court erred by proceeding to the merits: "[f]ollowing adoption of the [Utah County Attorney’s Office] UCAO Policy, the Browns’ suit ceased to qualify as an Article III case or controversy. Their suit was moot before the district court awarded them relief, and the court therefore lacked jurisdiction to decide the Browns’ claims." View "Brown v. Buhman" on Justia Law

Petitioners, a group of individuals and advocacy groups, filed a petition challenging the constitutionality of Article 68 of the Civil Code of Puerto Rico and other laws of the Commonwealth that prohibit same-sex couples from marrying. After the lower court dismissed Petitioners’ claims, the United States Supreme Court decided Obergefell v. Hodges. All parties subsequently agreed that the Commonwealth’s ban on same-sex marriage was unconstitutional. The First Circuit agreed and vacated the judgment. On remand, however, the district court did not enter judgment in favor of Petitioners but, instead, issued a memorandum concluding that the Commonwealth’s ban was not unconstitutional because the “right to same-sex marriage” had not been determined to apply in Puerto Rico. Petitioners requested a writ of mandamus requiring the district court to enter judgment in their favor striking down the ban as unconstitutional. Respondents moved for leave to join in Petitioners’ request. The First Circuit granted Petitioners’ petition for writ of mandamus and Respondents’ motion to join in the petition, holding that the district court erred in ruling that the ban is not unconstitutional and directly contradicted the First Circuit’s mandate and compounded its error by failing to enter a final judgment to enable an appeal in ordinary course. View "In re Conde-Vidal" on Justia Law

In In re P.M., the Supreme Court concluded that, in government-initiated parental rights termination proceedings, the statutory right of indigent parents to counsel endures until all appeals are exhausted. In this case, the trial court terminated the parental rights of C.S.F. The court of appeals affirmed. Acting pro se and outside the time for filing a petition for review, C.S.F. filed a motion in the Supreme Court seeking an extension of time and a hand-written indigency affidavit. The Supreme Court referred the case to the trial court for appointment of counsel to represent C.S.F. in the Supreme Court, holding that C.S.F. should be able to pursue any argument regarding her case with the assistance of new counsel. View "C.S.F. v. Dep’t of Family & Protective Servs." on Justia Law