Justia Civil Rights Opinion Summaries

Articles Posted in Government & Administrative Law
by
The Supreme Court held that Ariz. Rev. Stat. 23-1043.01(B), which limits workers' compensation claims for mental illnesses to those that arise from an "unexpected, unusual or extraordinary stress" situation, does not violate Ariz. Const. art. XVIII, 8 or equal protection guarantees under Ariz. Const. art. II, 13.Plaintiff, an officer with the Tucson Police Department, filed an industrial injury claim arising from an incident in June 2018, claiming that it exacerbated his preexisting post-traumatic stress disorder. An administrative law judge found Plaintiff's claims for mental injuries non-compensable because the June 2018 incident was not an "unexpected, unusual or extraordinary stress" situation under section 23-1043.01(B). The court of appeals affirmed the denial of benefits. The Supreme Court affirmed, holding that section 23-1043.01(B) does not unconstitutionally limit recovery for stress-related workplace injuries. View "Matthews v. Industrial Comm'n" on Justia Law

by
In late 2012, 16-year-old Shane McGuire and a group of his friends smashed pumpkins and stacked bricks on the doorstep of a home in McGuire’s neighborhood. The teens were still on the property when the homeowner, City of Pittsburgh Police Officer Colby Neidig, arrived home with his wife and children. McGuire watched the family’s reaction to the vandalism and then banged on the front door and ran away, accidentally tripping over his own brick boobytrap in the process. Neidig saw McGuire running, and gave chase, catching McGuire, knocking him to the ground and punching McGuire in the face. Neidig was not wearing his police uniform at the time, nor did he identify himself as a police officer. Neidig called 911 and restrained McGuire until Officer David Blatt, an on-duty City of Pittsburgh police officer, arrived. Two years later, McGuire filed a federal lawsuit against Neidig, Blatt, and the City of Pittsburgh, asserting excessive use of force in violation of 42 U.S.C. § 19833 and state law assault and battery claims. Ultimately, the jury returned a verdict in McGuire’s favor, finding that Neidig used unreasonable force against McGuire while acting under color of state law under Section 1983, and that Neidig was liable for McGuire’s assault and battery claims as well. The issue this case presented for the Pennsylvania Supreme Court's review involved whether the City of Pittsburgh had a statutory duty to indemnify one of its police officers for the judgment entered against him in a federal civil rights lawsuit. The Supreme Court rejected the argument that a federal jury’s finding that a police officer acted “under color of state law” for purposes of Section 19831 necessarily constituted a “judicial determination” that he also acted within the “scope of his office or duties” for purposes of the Political Subdivision Tort Claims Act. Thus, the judgment was affirmed. View "McGuire v. City of Pittsburgh" on Justia Law

by
Respondent has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. Respondent pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. Federal prisoners on the cusp of being released may be civilly committed if they are “presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk” to the person or property of others. Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner’s conduct post-release.   The Fourth Circuit held that a court must consider any terms of supervision that would govern the prisoner’s conduct post-release. Thus, because the record offers no assurances the district court appropriately considered the terms of Respondent’s supervised release before ordering him committed, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "US v. Nathaniel Williams" on Justia Law

by
The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss Plaintiff's complaint making a claim for statutory damages against the Board of County Commissioners pursuant to Mont. Code Ann. 76-3-625(1) and equal protection, takings, and due process claims under 42 U.S.C. 1983, holding that the district court erred.In granting the Board's motion to dismiss, the district court determined that Plaintiff's section 76-3-625(1) claims were barred by a thirty-day statute of limitations and its section 1983 claims failed to state a claim. The Supreme Court reversed, holding that the district court erred in (1) determining that the section 76-3-625(1) claim was subject to a thirty-day statute of limitations and was therefore time-barred; and (2) erred in concluding that Plaintiff's 42 U.S.C. 1983 claims lacked a sufficient protected property interest and were insufficiently pled to survive a motion to dismiss for failure to state a claim. View "Tai Tam, LLC v. Missoula County" on Justia Law

by
Plaintiff claimed that Defendant used excessive force while attempting an arrest on June 10, 2018, in Berdoo Canyon, which is considered BLM land. Plaintiff and her husband failed to yield to a park ranger, at which point Defendant was called to assist. As Defendant was trying to stop Plaintiff's vehicle, he fired several shots, hitting her in the hand and grazing her head.Plaintiff filed a Sec. 1983 claim against Defendant. The district court denied Defendant's motion for summary judgment related to Plaintiff's excessive force claim and Defendant appealed.On appeal, the Tenth Circuit reversed, declining to extend Bivens. The existence of alternative remedial structures is reason enough to not infer a new Bivens cause of action. Similarly, uncertainty about the potential systemwide consequences of implying a new Bivens cause of action is by itself a special factor that forecloses relief. The panel held that there was no Bivens cause of action for Plaintiff’s claim, which presented a new context. View "DENISE MEJIA V. WESLEY MILLER, ET AL" on Justia Law

by
Plaintiffs brought various claims against Rockland County ("Rockland County Defendants") officials including a violation of the Free Exercise Clause of the First Amendment, based on orders which excluded children who were not vaccinated against measles from attending school and an emergency declaration which barred unvaccinated children, other than those with medical exemptions, from places of public assembly. The district court granted summary judgment for Rockland County Defendants.The Second Circuit reversed, finding that Plainitffs' claim raises numerous disputes—including whether there is evidence of religious animus, to whom the emergency declaration applied, and what the County’s purpose was in enacting the declaration—that prevent Defendants from prevailing on summary judgment. View "M.A. v. Rockland County Department of Health" on Justia Law

by
From August 2018 through January 2019, plaintiffs were six-year-old first grade students who attended Maple Elementary School (Maple) within the Hesperia Unified School District (the District). Pedro Martinez worked at Maple as a janitor. Martinez’s position as a janitor did not require him to have any one-on-one contact with the students. Martinez engaged in a variety of activities with the students that plaintiffs characterized as “‘grooming’ activities” that were “designed to lure minor students, including [p]laintiffs, into a false sense of security around him.” Plaintiffs alleged that numerous District employees who were mandated reporters under the Child Abuse and Neglect Reporting Act (CANRA), witnessed Martinez’s behavior and did not report it to school officials or to law enforcement, in violation of the District’s policies. In January 2019, the State charged Martinez with numerous felonies involving his alleged sexual abuse of minors. In February 2019, plaintiffs filed a lawsuit against the District and Martinez, alleging numerous claims arising from Martinez’s alleged sexual abuse of plaintiffs. The trial court was persuaded by the District's argument, concluding that plaintiffs did not adequately plead a negligence cause of action against the District, because they failed to state any facts “establishing that [the] District knew of any prior acts of sexual abuse by Martinez and/or that the District had actual or constructive knowledge that Martinez was abusing [p]laintiffs so as to impose liability upon [the] District.” One month after plaintiffs sought reconsideration, the trial court entered judgment against plaintiffs. Plaintiffs argued on appeal that they were not required to plead facts demonstrating that the District had actual knowledge of past sexual abuse by Martinez, and that they otherwise pled sufficient facts to state negligence causes of action against the District. The Court of Appeal agreed with plaintiffs on all of those points. The Court disagreed with plaintiffs' contention that the trial court erred by dismissing their sex discrimination claims under Title IX and California Education Code section 220: plaintiffs’ allegations are insufficient to constitute actual notice of a violation of Title IX or Education Code section 220. The judgment of dismissal was reversed, the order sustaining the demurrer to the third amended complaint was vacated, and the trial court was directed to enter a new order sustaining the demurrer without leave to amend as to the causes of action under Title IX, Education Code section 220, and the Unruh Civil Rights Act but otherwise overruling the demurrer. View "Roe v. Hesperia Unified School Dist." on Justia Law

by
Petitioner Andrew Shouse was terminated from his employment as a captain of the Riverside County Sheriff’s Office (RCSO, the Department, or respondent), following an administrative hearing. Findings on the record reflected petitioner engaged in improper sexual relationships with subordinates under his command, misappropriated county equipment and electronic mail for his personal use, was insubordinate in violating a direct order prohibiting him from contacting any person with whom he had had a personal relationship during the pendency of the investigation, and unbecoming conduct discrediting the Sheriff’s Department. Following an administrative appeal, the findings were sustained. Petitioner petitioned for writ of mandate seeking review of his dismissal, and, upon denial of that petition, he appealed. The sole legal issue presented was whether petitioner’s rights pursuant to the Public Safety Officer’s Bill of Rights (POBRA) were violated where the investigation into his alleged improper conduct was not completed within one year of discovery. Finding no reversible error, the Court of Appeal affirmed. View "Shouse v. County of Riverside" on Justia Law

by
The Department of Alcoholic Beverage Control (Department) revoked a nightclub’s liquor license after the club’s owner, GC Brothers Entertainment LLC dba The Palms (Petitioner), failed to respond to an accusation alleging several violations of California statutes and regulations. Petitioner appealed the Department’s decision to the Alcoholic Beverage Control Appeals Board (Appeals Board), which affirmed it, and now seeks a writ of mandate directing the Department to vacate its decision.   The Second Appellate District granted the writ. The court held that the licensing scheme and strong state policy in favor of resolving cases on the merits grant an ALJ discretion to issue an OSC when he or she receives even an arguably deficient motion for relief from default. It thus runs contrary to the spirit of the licensing scheme to insist that a licensee present its complete and best case for relief within seven days of service of a notice of default. Here, the ALJ not only apparently believed he had no discretion to liberally construe Respondent’s motion for relief, but also found that Respondent’s failure to establish an irrelevant issue—proper service—constituted a failure to show good cause for relief. The ALJ’s failure to appreciate the scope of his discretion and application of an improper standard requires that we remand the matter to afford the ALJ an opportunity to exercise his discretion in the first instance and, applying the proper standard, determine whether Petitioner has shown good cause for relief from default. View "GC Brothers Entertainment v. Alcoholic Beverage Control etc." on Justia Law

by
Pursuant to Rule 8.548(b)(2) of the California Rules of Court, the Ninth Circuit requested that the Supreme Court of California decide the certified question presented below: Do non-convicted incarcerated individuals performing services in county jails for a for-profit company to supply meals within the county jails and related custody facilities have a claim for minimum wages and overtime under Section 1194 of the California Labor Code in the absence of any local ordinance prescribing or prohibiting the payment of wages for these individuals? View "ARMIDA RUELAS, ET AL V. COUNTY OF ALAMEDA, ET AL" on Justia Law