Justia Civil Rights Opinion Summaries

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

The California Supreme Court held that limiting marriage to opposite-sex couples violated the California Constitution; state voters then passed a ballot initiative, Proposition 8, amending the state constitution to define marriage as a union between a man and a woman. Same-sex couples who wished to marry filed suit in federal court, challenging Proposition 8. State officials refused to defend the law, so the district court allowed the initiative’s official proponents to intervene, declared Proposition 8 unconstitutional, and enjoined its enforcement. State officials declined to appeal. The intervenors appealed. The Ninth Circuit certified a question, which the California Supreme Court answered: official proponents of a ballot initiative have authority to assert the state’s interest to defend the constitutionality of the initiative when public officials refuse to do so. The Ninth Circuit concluded that petitioners had standing and affirmed. The Supreme Court vacated and remanded, holding that the intervenors did not have standing to appeal. Article III of the Constitution confines the power of federal courts to deciding actual “Cases” or “Controversies.” A litigant must demonstrate a personal and tangible harm throughout all stages of litigation. The intervenors had standing to initiate this case against the California officials responsible for enforcing Proposition 8, but once the district court issued its order, they no longer had any injury to redress and state officials chose not to appeal. The intervenors had not been ordered to do or refrain from doing anything. Their “generalized grievance” is insufficient to confer standing. The fact that a state thinks a private party should have standing to seek relief for a generalized grievance cannot override settled law to the contrary. View "Hollingsworth v. Perry" on Justia Law

Petitioners petitioned to be appointed permanent guardians of their elderly uncle, Thomas Lankford. The district court dismissed the guardianship petition after finding Petitioners were not qualified to serve as guardians because their potential to inherit from Lankford created a disqualifying conflict of interest. Petitioners appealed, asserting (1) the district court erred in finding a conflict of interest, and (2) in the alternative, the guardianship conflict waiver statute, which allows a court of waive conflicts but limits that authority to conflicts of a spouse, adult child, parent, or sibling of a ward, violated their due process and equal protection rights. The Supreme Court affirmed, holding (1) the district court did not err in finding a conflict of interest; and (2) Petitioners' constitutional claims were not properly before the Court. View "Utley v. Lankford" on Justia Law

After Father tested positive three times for marijuana use in violation of conditions of probation, the Department of Health and Human Resources removed Father's son, T.B., from Father's care. Father was incarcerated for a third time during a reunification period with T.B., and the Department subsequently filed a petition to terminate Father's parental rights. Father moved for substitution of court-appointed counsel, which the district court denied on the grounds that the trial was to start in two days. After a three-week continuance, the trial was held, and the court terminated Father's parental rights. Father appealed, contending that he was denied due process when the district court did not, on its own initiative, inform him that he could proceed without counsel after denying his motion to dismiss his current counsel or his implicit motion to appoint new counsel. The Supreme Court affirmed, holding that, under the circumstances of this case, the trial court did not err in its judgment. View "In re T.B." on Justia Law

Arizona House Bill 2036 (H.B. 2036), enacted in April 2012, forbids, except in a medical emergency, abortion of a fetus determined to be of a gestational age of at least twenty weeks. Arizona law separately prohibited abortions after fetal viability unless necessary to preserve the pregnant woman's life or health. The challenged provision at issue, Section 7 of H.B. 2036, extended the abortion ban earlier in pregnancy, to the period between twenty weeks gestation and fetal viability. Under controlling Supreme Court precedent, the court concluded that Arizona could not deprive a woman of the choice to terminate her pregnancy at any point prior to viability. Section 7 effects such a deprivation, by prohibiting abortion from twenty weeks gestational age through fetal viability. The twenty-week law was therefore unconstitutional under an unbroken stream of Supreme Court authority, beginning with Roe v. Wade and ending with Gonzales v. Carhart. Accordingly, the court reversed the district court's denial of declaratory and injunctive relief. View "Isaacson v. Horne" on Justia Law

Melissa and Heather Gartner were a married lesbian couple. Heather conceived a child using an anonymous sperm donor. The child was born during the spouses' marriage. The Gartners requested a birth certificate recognizing both Heather and Melissa as the child's parents. The Department of Public Health refused to place the name of the nonbirthing spouse in a lesbian marriage on the birth certificate without the spouse first adopting the child. The district court ordered the Department to issue the Gartners a birth certificate listing both spouses as parents but did not require the Department to extend the same practice to other married lesbian couples. The Supreme Court affirmed as modified, holding (1) Iowa Code 144.13(2), Iowa's presumption of parentage statute, violates the equal protection clause of the Iowa Constitution because it allows for only "the name of the husband" to appear on the birth certificate; and (2) accordingly, the Department must presumptively list on a child's birth certificate the nonbirthing spouse in a lesbian marriage when the child was born to one of the spouses during their marriage. View "Gartner v. Iowa Dep't of Pub. Health" on Justia Law

Defendant brought her seven-week-old son, John Doe, to a medical center for injuries. A jury later convicted Defendant of assault on a minor and aggravated assault. The district court ordered a change in parenting arrangements for John Doe as part of the criminal sentence despite pending dependency and neglect proceedings. As part of Defendant's sentence, the district court ordered Defendant to pay fees, costs, and surcharges without recording findings regarding Defendant's financial situation. The Supreme Court affirmed, holding (1) because Defendant had regained custody of John Doe through the civil proceeding, her claim regarding the imposition of a condition concerning the temporary custody of John Doe was moot; however, the statement in the court's written judgment that the father should be presumed to have custody of John Doe should not have been included in the criminal sentence; and (2) the district court acted within its discretion in imposing fees. View "State v. MacDonald" on Justia Law

After an adjudicatory hearing in this abuse and neglect case, Appellant was found to have neglected her three children. Appellant appealed, arguing that she was denied fundamental due process rights because the trial court declined to grant a motion to dismiss or to strike witnesses after claimed discovery violations by the State and because the evidence was insufficient to support a finding of neglect. The Supreme Court affirmed, holding (1) the trial judge did not abuse his discretion in dealing with the claimed discovery violations; (2) Appellant received due process; and (3) the evidence was sufficient to support a finding of neglect. View "DL v. State, Dep't of Family Servs." on Justia Law

Plaintiff filed a complaint that her former employer discriminated against her after she became pregnant. At issue was whether direct estoppel barred a claim of pregnancy discrimination under state law when a jury found at trial that plaintiff suffered no adverse employment action regarding her claim of retaliation for exercising her right to maternity leave under federal law. The court concluded that the jury verdict against plaintiff's claim of retaliation estopped plaintiff from relitigating the common issue of whether she suffered an adverse employment action. Accordingly, the court affirmed the grant of summary judgment against plaintiff's claim of pregnancy discrimination. View "DuChateau v. Camp, Dresser & McKee, Inc." on Justia Law

After Mother gave birth to an infant alone at home, Boyfriend took Mother and the infant to the hospital. Medical staff noticed puncture wounds on the infant's back and notified the authorities. An ensuing investigation resulted in the removal of the infant from Mother's care. The county prosecutor subsequently petitioned the trial court for subpoenas to compel Mother and Boyfriend to give testimony relating to the home birth of the infant. The trial court issued the subpoenas. Before Mother and Boyfriend testified, their attorney moved to quash the subpoenas pursuant to their rights against self-incrimination. The court granted the motion. The trial court then granted the prosecutor's petition for use immunity. The Supreme Court reversed, holding (1) the prosecutor was not authorized to request a grant of use immunity; and (2) where, as here, no charges have been filed and no grand jury has been convened, a prosecutor may subpoena witnesses pursuant to Ind. Code 33-39-1-4, but if those witnesses invoke their constitutional right against self-incrimination, the prosecutor cannot petition the court to grant them use immunity and compel them to testify without first filing charges or convening a grand jury. View "In re Prosecutor's Subpoena re S.H." on Justia Law