Justia Civil Rights Opinion Summaries

Birth mother N.S. (Mother) and birth father K.R. (Father) appealed a district court order that terminated their parental rights to their four-year-old twin daughters, T.R. 1 and T.R. 2. Mother also appealed the District Court’s order denying her a new trial. The issues on appeal were: (1) whether the District Court abused its discretion by terminating Mother and Father’s parental rights; (2) whether the District Court erred in finding it was in the children’s best interests to terminate those rights; (3) whether the District Court erred in finding the Department of Health and Human Services (the Department) made reasonable efforts to reunify the family; (4) whether the District Court adequately addressed the appropriateness of the treatment plans in its Findings of Fact and Conclusions of Law. Furthermore, Mother asserted that the District Court abused its discretion by denying her a new trial based on new evidence. Upon review, the Supreme Court found substantial evidence in the record to support the District Court’s findings that the conditions rendering Mother and Father unfit were unlikely to change within a reasonable time, and that it was in the best interests of the children to terminate the parental rights. "It [was] manifest on the face of the briefs and the record that there was not an abuse of discretion."

Father filed for divorce from Mother. In that proceeding, the parties contested physical and legal custody of their daughters. Prior to the merits hearing, a circuit court judge ordered preparation by court-related personnel a custody investigation report to evaluate the custodial abilities of each parent. The report was completed one week before the merits hearing, and Mother's counsel was able to review the report for only ninety minutes. As a consequence, Mother's attorney moved to exclude the report. The circuit court denied the motion. The judge then granted a divorce and awarded custody of the children to Father with visitation to Mother. The court of special appeals affirmed. At issue on appeal was whether the circuit court's unwritten policy that limits counsel of record in child custody proceedings to viewing custody investigation reports only in person in the clerk's office during normal business hours was viable. Without affirming or reversing, the Court of Appeals remanded for supplementation of the record as to the full contours of the relevant policy.

The issue before the Eleventh Circuit centered on the grant of qualified immunity to two social workers who violated clearly established federal rights during an investigation of alleged child abuse. After Plaintiff-Appellant Stephen Loftus petitioned a Florida court to help him protect his two children from his allegedly abusive former wife, social worker and Defendant-Appellee Ester Clark-Moore, investigated the safety and welfare of Loftus's children, Savonna and Dylan. In the course of her investigation, Clark-Moore allegedly interviewed Savonna without Loftus's consent, and Clark-Moore's supervisor, Myra Ferguson, allegedly twice threatened to remove both children from Loftus's care. Loftus filed a civil complaint that the social workers had violated Savonna's right to be free from unreasonable seizures and the family's right to be free from governmental interference. Upon review, the Eleventh Circuit concluded that because the social workers did not violate any clearly established federal civil rights in the investigation that Loftus had invited, it affirmed the dismissal of Loftus's complaint against them.

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees.

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims.

The Governor and Attorney General of South Dakota, along with two intervening crisis pregnancy centers and two of their personnel appealed the district court's permanent injunction barring enforcement of a South Dakota statute requiring the disclosure to patients seeking abortions of an "increased risk of suicide ideation and suicide" and the underlying grant of summary judgment in favor of Planned Parenthood of Minnesota, North Dakota, South Dakota and its medical director Dr. Carol Ball. The district court found that this advisory would unduly burden abortion rights and would violate physicians' First Amendment right to be free from compelled speech. The Eighth Circuit Court of Appeals reversed, holding that on its face, the suicide advisory presented neither an undue burden on abortion rights nor a violation of physicians' free speech rights.

A juvenile court terminated Father's parental rights to his two children. Father appealed, arguing, among other things, that the juvenile court violated his due process rights when it ordered him to provide a fingernail drug test after his termination trial. The court of appeals reversed, principally on the basis that there was no evidence in the record as to the reliability or the accuracy of the fingernail drug test, and that the record, including the fingernail test, lacked clear and convincing evidence to warrant termination of Father's parental rights. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment and order of the trial court, holding (1) the test did not violate Father's due process rights; (2) the evidence including the fingernail test was sufficient to warrant termination; and (3) termination was in the children's best interests.

Appellant Brittany Mahavier appealed orders of the circuit court granting a permanent guardianship of her son to her mother, Appellee Teresa Mahavier, and declaring the Arkansas Statutes on guardianships to be unconstitutional. Appellant stipulated below that there was sufficient evidence to establish a need for the guardianship but did not agree to the guardianship so she could maintain her constitutional challenges based on equal protection and substantive due process. The Supreme Court did not address the merits of the constitutional arguments because the Attorney General was not notified of the constitutional challenges to the guardianship statutes, as required by Ark. Code Ann. 16-111-106(b), and there was not full and complete adversarial development of the constitutional issues. Accordingly, the Court reversed and remanded for compliance with the notice requirement of section 16-111-106(b).

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit.

Respondent Robert Half International (RHI) terminated Appellant Kim Hansen's employment shortly after she returned from maternity leave and failed to reinstate her to the same or similar position. Hansen filed an action against RHI, alleging that it violated the Minnesota Parenting Leave Act (MPLA) and the Minnesota Human Rights Act (MHRA) by failing to reinstate her to her position or a comparable position after maternity leave, for retaliating against her for taking maternity leave, and for terminating her because of her sex. The district court granted summary judgment in favor of RHI. The court of appeals affirmed. The Supreme Court affirmed, holding that there were no genuine issues of material fact and that judgment was appropriate as a matter of law.