Justia Civil Rights Opinion Summaries

In this case, the Plaintiff, Paul Steven Wynn, had sued Rex Frederick, in his official capacity as a magistrate, and Great American Insurance Company for negligence. The Plaintiff claimed that Frederick was negligent in sending a custody order to UNC Hospitals, instead of the Sheriff's Office, resulting in a delay in the involuntary commitment of the Plaintiff's nephew, who subsequently assaulted and paralyzed the Plaintiff.The Supreme Court of North Carolina held that magistrates, as state officials, are not included in the phrase "other officers" under North Carolina General Statute § 58-76-5, which speaks to the waiving of sovereign immunity for certain officials covered by a statutory bond. The court came to this conclusion by examining the structure and history of the statute, which revealed that the statute only encompasses county officers and not state officers. As such, the court found that the statute does not waive the magistrate's sovereign immunity.Furthermore, the court held that judicial immunity applies to both official and individual capacity claims, contrary to the ruling of the Court of Appeals, which had limited the defense of judicial immunity to individual capacity claims only. The court, however, did not decide whether the magistrate's conduct in this case constituted a judicial act, as it found that the claim was independently barred by sovereign immunity. The decision of the Court of Appeals was therefore reversed. View "Wynn v. Frederick" on Justia Law

In this case, an unincorporated association, Saline Parents, and six individuals sued the Attorney General of the United States, Merrick Garland, alleging that the Department of Justice (DOJ) was unlawfully attempting to silence them and others who opposed progressive curricula and policies in public schools. This lawsuit was in response to a memorandum issued by the Attorney General, expressing concern over the increase in reported incidents of harassment, intimidation, and threats of violence against school administrators, board members, teachers, and staff. The memorandum instructed the DOJ staff to investigate the issue and discuss strategies to address it. The plaintiffs argued that their protest activities, which included constitutionally protected conduct and did not involve threats of criminal violence, had been unfairly targeted by the DOJ.The United States Court of Appeals for the District of Columbia Circuit upheld the dismissal of the case by the District Court on the grounds that the plaintiffs lacked standing to pursue this action. The court agreed with the government's argument that the plaintiffs' lawsuit was not ripe for adjudication, indicating that the plaintiffs' claims were based on hypothetical future events that may not occur. The court also found that the plaintiffs had failed to demonstrate that the government had in any way threatened imminent enforcement action against them or had labeled them in a way that impugned their reputations. The court concluded that the plaintiffs' claim was based on contingencies and speculation, making the dispute premature for judicial resolution. View "Saline Parents v. Garland" on Justia Law

In this case, the Nebraska Supreme Court affirmed a lower court's decision, finding that the Middle Republican Natural Resources District (NRD) violated the due process rights of two landowners, Merlin Brown and Uhrich & Brown Limited Partnership, by having the same attorneys act as both prosecutors and participants in the adjudicatory process of the case. The court held that such a combination of prosecutorial and adjudicatory functions in the same individuals posed an intolerably high risk of actual bias, thus, infringing on the landowners' right to a fair trial by an impartial tribunal. In this case, the NRD had accused the landowners of violating certain ground water management rules. The case was initially heard by the Board of Directors of the NRD, whose decision to impose penalties on the landowners was informed by the same attorneys who had prosecuted the case on behalf of the NRD. The landowners appealed the Board's decision under the Administrative Procedure Act (APA), leading to the district court's reversal. The NRD then appealed to the Nebraska Supreme Court, which upheld the lower court's ruling. View "Uhrich & Brown Ltd. Part. v. Middle Republican NRD" on Justia Law

In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

In this case, a prisoner named Lyle Heyward filed a complaint alleging that prison officials frustrated his attempts to celebrate Ramadan, a holy month for Muslims, in violation of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). He also alleges that officials retaliated against him for filing grievances in violation of the First Amendment. The United States Court of Appeals for the Sixth Circuit affirmed the dismissal of Heyward’s Religious Land Use and Institutionalized Persons Act (RLUIPA) claim, as RLUIPA does not permit money damages claims against state prison officials in their individual capacities, and his requests for injunctive relief were mooted by his transfer to a different prison facility.However, the court reversed the dismissal of Heyward’s First Amendment retaliation claim against Defendant Guise, finding that Heyward had adequately pleaded a retaliation claim. Specifically, Heyward alleged that after he filed a grievance against Guise, she threatened members of the Cultural Awareness Inmate Group to kick Heyward out of the organization or else the organization would be shut down. The court found these allegations sufficient to suggest that Guise's action was motivated at least in part by Heyward’s grievance-filing.The court also reversed the dismissal of Heyward’s Equal Protection Clause claim against Defendants Cooper, Smith, Davis, and Factor. Heyward alleged these officials treated members of other faith traditions differently than they treated Muslims. The court found that Heyward’s allegations of a facially discriminatory distinction between different religious groups sufficiently alleged an equal-protection violation.The case was remanded for further proceedings. View "Heyward v. Cooper" on Justia Law

In this appeal to the United States Court of Appeals for the Fourth Circuit, James Dow Vandivere challenged a district court decision denying his motion for release from civil commitment under the Adam Walsh Act. Vandivere, who had been convicted of multiple crimes involving the sexual exploitation of minors and sentenced to almost twenty years in prison, was nearing the end of his sentence when the government moved to civilly commit him. The government argued, and the district court agreed, that Vandivere remained sexually dangerous. Vandivere filed a motion for discharge and, following a hearing, the district court found he remained sexually dangerous and denied his motion. Vandivere appealed, arguing that he was wrongly forced to bear the burden of proof at the hearing and that the district court erred in determining that he remained sexually dangerous.The Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court found that under the Adam Walsh Act, the burden of proof at an Adam Walsh Act discharge hearing is on the detainee to show his recovery by a preponderance of the evidence. The court also found this allocation of burden does not violate the detainee’s due process rights. Further, the appellate court found no error in the district court's conclusion that Vandivere remained sexually dangerous, stating that the district court had appropriately considered Vandivere's behavior while in custody, his persistent cognitive distortions about sexual abuse, his refusal to participate in sex offender therapy, and his proposed release plan. View "US v. Vandivere" on Justia Law

In the State of Montana, a group of parents and the non-profit organization Stand Up Montana sued several school districts in Missoula County over the implementation of mask mandates in schools during the COVID-19 pandemic. The plaintiffs argued that the mask mandates violated their substantive due process rights. The Fourth Judicial District Court granted summary judgment in favor of the school districts, finding the mask mandates did not violate the plaintiffs' substantive due process rights. The Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court reiterated that the mask mandates did not implicate any fundamental rights under Article II of the Montana Constitution, and therefore, the rational basis test was the appropriate standard of review. Under the rational basis test, the court found that the mask mandates were rationally related to the legitimate government interest of stemming the spread of COVID-19, as the school districts had considered information and recommendations from reputable public and private health care providers and agencies, including the CDC, which all recommended universal masking. The court also affirmed the lower court's decision to grant a motion in limine to exclude testimony from the plaintiffs' hybrid witnesses, as the proffered testimony was not relevant to whether the mask policies were rationally related to stemming the spread of COVID-19. View "Stand Up Montana v. Msla Co. Schools" on Justia Law

In a dispute between the American Civil Liberties Union of New Hampshire (ACLU) and the New Hampshire Division of State Police (the Division), the Supreme Court of New Hampshire affirmed a lower court's decision permitting the ACLU's request for access to public records about a former state trooper under the Right-to-Know Law. The Division had argued that these records were exempt from disclosure under RSA 105:13-b and their release would constitute an invasion of privacy. The ACLU had requested reports, investigatory files, personnel, and disciplinary records related to adverse employment action against the former trooper.The Supreme Court ruled that the exemption cited by the Division, RSA 105:13-b, which pertains to the confidentiality of police personnel files, does not categorically prohibit disclosure of such records under the Right-to-Know Law. The court's interpretation of RSA 105:13-b is that it operates within the context of a specific criminal trial and does not prohibit disclosure in all instances or further regulate the information. Consequently, the Division's argument that the law establishes a scheme in which police personnel records may not be disclosed outside narrow exceptions was rejected.The court also found no absurdity in the coexistence of different statutory frameworks for seeking information in a police personnel file for different purposes. It ruled that the material disclosed under the Right-to-Know Law and RSA 105:13-b is tailored to the purposes of the respective laws, reflecting the different purposes served by each statutory scheme. View "American Civil Liberties Union of New Hampshire v. New Hampshire Division of State Police" on Justia Law

In the case before the United States Court of Appeals for the Ninth Circuit, a plaintiff named Robert A. Stanard, who was an inmate in the federal prison system, sued several prison officials, claiming they violated his Eighth Amendment rights by denying him treatment for Hepatitis C, and his Fifth Amendment rights by discriminating against him due to his pre-trial status. Stanard sought damages under Bivens, a precedent that allows individuals to sue federal officers for constitutional rights violations. The district court dismissed Stanard’s complaint, and he appealed.The Ninth Circuit partly affirmed and partly reversed the district court’s decision. First, the court reversed the dismissal of Stanard’s Eighth Amendment claim. The court found that his claim was not a new context for a Bivens action because it was similar to a previous case, Carlson v. Green, where the Supreme Court recognized a Bivens remedy for prison officials who were deliberately indifferent to an inmate's medical needs. The court rejected the defendants' argument that the prison officials in Stanard's case denied him care due to a Bureau of Prisons policy, while the officials in Carlson acted so inappropriately as to evidence intentional maltreatment causing death, holding that the difference in degree was not a meaningful difference that would create a new context.However, the Ninth Circuit affirmed the dismissal of Stanard’s Fifth Amendment claim. The court found that this claim did present a new Bivens context because it involved disparate treatment of pre-sentencing and post-sentencing inmates, a situation not previously addressed in Bivens cases. Given that this was a new context, the court then determined that special factors counseled against extending a Bivens remedy. Specifically, the existence of alternative remedial structures, such as the Bureau of Prisons' administrative remedy process, indicated that Congress, rather than the courts, should decide whether to create a new damages remedy. View "STANARD V. DY" on Justia Law

In the case, Maple Run Unified School District (the District) appealed a trial court order which granted the Vermont Human Rights Commission (the Commission) a motion to dismiss the District’s complaint for lack of subject-matter jurisdiction. The dispute arose from a complaint of sexual harassment filed by a student in the District. The student's mother later filed a complaint with the Commission alleging that the District failed to comply with the Vermont Public Accommodations Act (VPAA), the anti-harassment provisions in Title 16, and the school’s own policy. The Commission decided to investigate the matter. The District filed a motion with the Commission to dismiss the investigation, arguing that federal regulations preempted Title 16 and the complaint failed to state a prima facie case of discrimination under the VPAA. The Commission denied the District’s motion and decided to continue the investigation. The District then filed a Rule 75 petition in the civil division against the Commission, which the Commission moved to dismiss arguing that there was no cognizable avenue for relief under Rule 75 and the superior court lacked subject-matter jurisdiction to review the petition. The court dismissed the District’s complaint. The District appealed claiming that subject-matter jurisdiction had been established under Rule 75 via either mandamus or prohibition. The Supreme Court of Vermont held that the Commission’s determination that the complaint states a prima facie case of discrimination under the VPAA is not reviewable under Rule 75 via either mandamus or prohibition, and therefore, the superior court did not err in dismissing the District’s petition. View "Maple Run Unified School District v. Vermont Human Rights Commission" on Justia Law