Justia Civil Rights Opinion Summaries

At the onset of the COVID-19 pandemic, the Governor of Kentucky issued orders prohibiting mass gatherings, including religious services, and closing non-life-sustaining organizations, which included religious organizations. Maryville Baptist Church held an Easter service in defiance of these orders, leading to a lawsuit against the Governor, alleging violations of the First and Fourteenth Amendments.The United States District Court for the Western District of Kentucky initially declined to issue a preliminary injunction. However, the Sixth Circuit Court of Appeals issued a partial stay, allowing outdoor worship. Subsequently, the district court granted a preliminary injunction, permitting both indoor and outdoor worship. The Governor later allowed places of worship to reopen, and the Kentucky General Assembly limited the Governor's authority to issue similar orders in the future. The underlying action was dismissed as moot, and the Church sought attorney’s fees, which the district court denied, ruling that the Church did not prevail.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court referenced the U.S. Supreme Court's decision in Lackey v. Stinnie, which held that a party who receives a preliminary injunction but whose case becomes moot before a final judgment does not qualify as a prevailing party under 42 U.S.C. § 1988. Applying this precedent, the Sixth Circuit affirmed the district court's denial of attorney’s fees, concluding that the Church's preliminary injunction did not constitute enduring judicial relief that materially altered the legal relationship between the parties. View "Maryville Baptist Church v. Beshear" on Justia Law

Alison Mayfield, who is deaf and communicates primarily through American Sign Language (ASL), was pulled over by officers from the City of Mesa’s Police Department (MPD) for suspected reckless driving. During the traffic stop and subsequent DUI processing, Mayfield requested an ASL interpreter but was not provided one. Instead, officers used a combination of written notes, lip-reading, and gestures to communicate with her. Mayfield was ultimately charged with DUI but pleaded guilty to reckless driving.The United States District Court for the District of Arizona dismissed Mayfield’s claims under Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA), holding that her claims were barred by Heck v. Humphrey and that she failed to state a claim for which relief could be granted. Mayfield appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that Mayfield’s ADA and RA claims were not barred by Heck v. Humphrey because a ruling in her favor would not necessarily imply the invalidity of her reckless driving conviction. The court found that the district court erred in considering the original DUI charges rather than the ultimate conviction for reckless driving and that the City of Mesa had not met its burden to establish the applicability of the Heck bar.On the merits, the Ninth Circuit held that the relevant question was whether the means of communication used by the officers were sufficient to allow Mayfield to effectively exchange information during the stop and arrest. The court concluded that Mayfield failed to plead sufficient facts to establish that MPD discriminated against her by not providing a reasonable accommodation. The court affirmed the district court’s dismissal of Mayfield’s complaint without leave to amend, as amendment would be futile. View "MAYFIELD V. CITY OF MESA" on Justia Law

Two minor sisters suffered severe harm while in the custody of the Department of Children and Families (DCF). In August 2015, the older sister, then twenty-two months old, manipulated a thermostat dial from her crib, causing the bedroom to overheat. This incident led to her permanent impairment and the death of another foster child. A lawsuit was filed in the Superior Court against several defendants, including four DCF employees, alleging that their failure to fulfill their duties caused the children's harm.The Superior Court denied the employees' motion for summary judgment, which argued they were entitled to qualified immunity. The employees appealed under the doctrine of present execution, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court concluded that the DCF employees did not violate the children's substantive due process rights, as their conduct was not the proximate cause of the harm suffered. The court held that the employees' omissions, such as failing to conduct more frequent home visits or investigate the presence of a potentially dangerous individual in the foster home, did not foreseeably lead to the children's injuries. Therefore, the employees were entitled to qualified immunity, and the Superior Court's denial of summary judgment was reversed. View "Gotay v. Creen" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Three Coast Guard servicemembers, Eric Jackson, Alaric Stone, and Michael Marcenelle, objected to a COVID-19 vaccination mandate issued by the Coast Guard, which operates under the Department of Homeland Security. Their requests for religious accommodations were denied, and they faced reprimands for refusing the vaccination. They filed a class action lawsuit against the Secretaries of Homeland Security and Defense, the Commandant of the Coast Guard, and the Assistant Commandant for Human Resources, alleging violations of the Religious Freedom Restoration Act, the First Amendment, and the Administrative Procedure Act. They sought declaratory and injunctive relief.The United States District Court for the Northern District of Texas dismissed the case as moot after the Department of Defense rescinded its vaccination mandate, and the Coast Guard followed suit. The Plaintiffs' motion for relief from final judgment was also denied, leading to their appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s Rule 12(b)(1) dismissal de novo. The appellate court found that the case was not moot because the Coast Guard had not issued policies protecting unvaccinated servicemembers from discrimination, unlike the Navy, which had implemented such protections. The court noted that the Plaintiffs could still face adverse actions based on their vaccination status and that a court order could provide effective relief. Consequently, the Fifth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Jackson v. Noem" on Justia Law

A citizen sought access to police use of force reports under the Iowa Open Records Act. The Des Moines Police Department requires officers to complete a report whenever force is used, detailing the incident's specifics. The reports are reviewed by supervisors and used for accountability, training, and identifying trends. In 2020, 387 use of force reports were filed, with only a few resulting in disciplinary action.The Iowa District Court for Polk County granted summary judgment in favor of the citizen, ordering the City of Des Moines to disclose the use of force reports. The court found that the reports were factual accounts of incidents and not evaluative or performance records, thus not exempt from disclosure under Iowa Code section 22.7(11). The court allowed redaction of information about officer injuries or medical treatment.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the use of force reports are not exempt from disclosure under section 22.7(11) as they are factual reports, not confidential personnel records. The court also rejected the City's argument that the reports were protected under Iowa Code section 80F.1(20), as this section pertains to statements and interviews in response to complaints, not routine use of force reports. The court noted that any specific redactions could be justified on other legal grounds if necessary. View "Harrison v. Mickey" on Justia Law

Plaintiff K.C. alleged that she was sexually abused while in foster care under the custody of the County of Merced. The abuse occurred in two separate foster homes between 1971 and 1977. K.C. claimed that she reported the abuse to her social worker, but no corrective action was taken, resulting in continued abuse. She filed a complaint citing negligent acts and omissions by the County and its employees, which she argued proximately caused her injuries.The Superior Court of Merced County sustained the County's demurrer without leave to amend, leading to the dismissal of K.C.'s complaint with prejudice. The court found that the County and its employees were protected by discretionary immunity under Government Code sections 815.2 and 820.2, which shield public employees and entities from liability for discretionary acts.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case and affirmed the lower court's judgment. The appellate court held that the social workers' decisions regarding the investigation of child abuse and the continuation of foster home placements were discretionary acts protected by immunity. The court emphasized that these decisions involved the exercise of judgment and policy considerations, which are shielded from liability to ensure that public employees can perform their duties without fear of civil suits. Consequently, the County was also immune from liability under the derivative immunity provided by Government Code section 815.2, subdivision (b). View "K.C. v. County of Merced" on Justia Law

Misty Coleman alleges that she fell and broke her ankle after slipping on a wet shower floor in a county jail. She pursued constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county, corrections officers, and medical personnel. Coleman claimed that the slippery shower violated the Due Process Clause and that a county policy or custom was behind her poor medical care. She also questioned whether the county could invoke state-law immunity from her negligence claim at the pleading stage.The United States District Court for the Southern District of Ohio dismissed all claims against all parties. The court found that Coleman failed to allege a plausible constitutional violation regarding the slippery shower and did not connect the inadequate medical care to a county policy or custom. The court also held that Ohio law granted immunity to Hamilton County on the negligence claim. The court allowed Coleman to conduct limited discovery to identify unnamed officers and nurses, but her subsequent amended complaint was dismissed as it was filed outside the statute of limitations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's dismissal, holding that Coleman’s claims accrued on the date of her accident and that her amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15. The court also found that Coleman did not meet the requirements for equitable tolling, as she did not allege facts showing that she was intentionally misled or tricked into missing the deadline. The Sixth Circuit affirmed the district court's dismissal of Coleman’s complaint. View "Coleman v. Hamilton County Bd. of County Commissioners" on Justia Law

Richard Hightower, a pretrial detainee, was attacked by his cellmate, Anthony Tyler, in a Philadelphia jail, resulting in Hightower's paralysis. Hightower was classified as a low-security risk, while Tyler was classified as a high-security risk with a history of violent behavior. Due to a mistake by a prison health services company, Tyler was placed in Hightower's intake cell instead of being transferred to a permanent cell. Tyler's aggressive behavior escalated, culminating in a violent attack on Hightower.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the City of Philadelphia and the guards. Hightower did not appeal the judgment for the guard but did appeal the judgment for the city.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Hightower failed to prove that the city caused any constitutional violation. To succeed in his Monell claim, Hightower needed to show that the city had an unconstitutional policy or custom or was deliberately indifferent to inmates' rights. The court found that the city had no policy of not separating inmates by security-risk level during intake and that the lack of a policy is not a policy. Additionally, Hightower could not show a custom that violated his rights or that the city acted with deliberate indifference. The court concluded that the risk to Hightower was not so obvious that the city could be held liable without a pattern of similar violations.The Third Circuit affirmed the District Court's summary judgment in favor of the City of Philadelphia. View "Hightower v. City of Philadelphia" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law