Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the orders entered by the circuit court granting summary judgment to Defendants in the underlying action brought after investigators identified unsafe, non-sterile injection techniques, holding that the circuit court did not err.Plaintiffs, a pain management clinic and its physician, brought the underlying action alleging that the West Virginia Department of Health and Human Resources, West Virginia Bureau for Public Health, and its former Commissioner and State Health Officer (collectively, the DHHR Defendants) breached their duty of confidentiality when they issued a press release announcing that Defendants used unsafe injection practices and encouraging Plaintiffs' patients to be tested for bloodborne illnesses. Plaintiffs also sued the West Virginia Board of Ostseopathic Medicine and its executive director (together, the BOM Defendants), asserting a due process claim for failing to timely provide a hearing after their summary suspension of the physician's medical license. The circuit court concluded that the DHHR defendants were entitled to qualified immunity and that the claim against the BOM defendants was barred by res judicata. The Supreme Court affirmed, holding that there was no error in the circuit court's judgment. View "Chalifoux v. W. Va. Dep't of Health & Human Resources" on Justia Law

The court awarded Plaintiff fees after he prevailed on one of his six causes of action against his former employer ExakTime Innovations, Inc., on his complaint for disability discrimination under the Fair Employment and Housing Act (FEHA) and related causes of action. The jury awarded Plaintiff $130,088 in damages on his claim ExakTime failed to engage in a good faith interactive process with him. Plaintiff appealed from the trial court’s order awarding him $686,795.62 in attorney fees after the court applied a .4 negative multiplier to its $1,144,659.36 adjusted lodestar calculation “to account for [p]laintiff’s counsel’s . . . lack of civility throughout the entire course of this litigation.” Plaintiff contends the $457,863 reduction in attorney fees based on his counsel’s incivility must be reversed.   The Second Appellate District affirmed. The court agreed with the trial court that it may consider an attorney’s pervasive incivility in determining the reasonableness of the requested fees. A court may apply, in its discretion, a positive or negative multiplier to adjust the lodestar calculation—a reasonable rate times a reasonable number of hours—to account for various factors, including attorney skill. The court explained that the record amply supports the trial court’s finding that Plaintiff’s counsel was repeatedly, and apparently intentionally, uncivil to defense counsel—and to the court— throughout the litigation. View "Snoeck v. ExakTime Innovations" on Justia Law

Vidal-Martinez, a non-citizen, was arrested three times for operating a vehicle while intoxicated. DHS detained him and initiated deportation. Vidal-Martinez filed a habeas petition, arguing that his detention was unconstitutional because it impeded his ability to defend himself against the drunk-driving charges. ICE transferred Vidal-Martinez to county custody “until the completion of [the] criminal matter, then released to his ICE detainer.” Vidal-Martinez was convicted of DUI and sentenced to 236 days in jail. He was then returned to ICE custody. Due to a lack of evidence that he posed a flight risk or a danger to the community, the district court granted Vidal-Martinez’s habeas petition and ordered his release.Vidal-Martinez filed a FOIA request, 5 U.S.C. 552, seeking disclosure from ICE of documents related to his custody transfer. ICE produced 561 pages of responsive documents, some of which contained redactions. Vidal-Martinez challenged ICE’s redactions. ICE submitted a Vaughn index and a declaration from its FOIA officer explaining the legal justification for each redaction, citing attorney-client, work product, deliberative process privileges, and identifying information of government employees. Vidal-Martinez responded that ICE committed criminal conduct by transferring him to Indiana, so the crime-fraud exception to attorney-client privilege applied. The district court granted ICE summary judgment. The Seventh Circuit affirmed, finding no factual foundation in the record for criminal conduct or misconduct by ICE. The district court had an adequate factual basis to evaluate ICE’s withholdings. View "Vidal-Martinez v. United States Department Of Homeland Security" on Justia Law

Kari Lake and Mark Finchem (“Plaintiffs”), the Republican nominees for Governor and Secretary of State of Arizona, filed this action before the 2022 general election, contending that Arizona’s use of electronic tabulation systems violated the federal Constitution. The district court dismissed their operative first amended complaint for lack of Article III standing. Lake v. Hobbs. Plaintiffs’ candidacies failed at the polls, and their various attempts to overturn the election outcome in state court have to date been unavailing. On appeal, they no longer seek any relief concerning the 2022 election but instead seek to bar use of electronic tabulation systems in future Arizona elections.   The Ninth Circuit agreed with the district court that Plaintiffs’ “speculative allegations that voting machines may be hackable are insufficient to establish an injury in fact under Article III. The court explained that even assuming Plaintiffs could continue to claim standing as prospective voters in future elections, they had not alleged a particularized injury and therefore failed to establish the kind of injury Article III requires. None of Plaintiffs’ allegations supported a plausible inference that their individual votes in future elections will be adversely affected by the use of electronic tabulation, particularly given the robust safeguards in Arizona law, the use of paper ballots, and the post-tabulation retention of those ballots. The panel concluded that speculative allegations that voting machines may be hackable were insufficient to establish an injury, in fact, under Article III. View "KARI LAKE, ET AL V. ADRIAN FONTES, ET AL" on Justia Law

Parents Defending Education, an association of parents, brought this action to challenge a policy adopted by the Linn Mar Community School District in Iowa. The disputed policy is entitled “Administrative Regulations Regarding Transgender and Students Nonconforming to Gender Role Stereotypes.” The policy sets forth regulations for the District that “address the needs of transgender students, gender-expansive students, nonbinary, gender nonconforming students, and students questioning their gender to ensure a safe, affirming, and healthy school environment where every student can learn effectively.” The parents who seek to participate in this case are anonymous; the pleadings identify them by a letter of the alphabet. The district court determined that Parents Defending failed to establish Article III standing because the organization did not show injury, causation, or redressability on its claims.   The Eighth Circuit dismissed the appeal in part as moot and reversed on one claim. The court concluded that at least Parent G has alleged an injury in fact sufficient to confer Article III standing. Parent G asserts that her son wants to “state his belief that biological sex is immutable.” Because of the policy, however, Parent G states that her son remains silent in school “when gender identity topics arise” to avoid violating the policy. This student’s proposed activity “concerns political speech” and is “arguably affected with a constitutional interest.” Thus, Parent G has standing to bring a claim challenging the policy based on the First Amendment. Therefore, Parents Defending has standing as an association to pursue the claim on behalf of a member. View "Parents Defending Education v. LinnMar Community School Dist., et al" on Justia Law

Plaintiffs’ neighbor petitioned for a civil harassment restraining order against Plaintiffs and was granted a temporary restraining order. As a result of the TRO, Plaintiff was ordered to surrender his firearms to a California licensed firearms dealer. Certain California laws make it unlawful for any person subject to a “civil restraining order” issued by a California state court (including temporary restraining orders) to possess firearms or ammunition. Plaintiffs claim these laws violate the Second Amendment and the Due Process Clause of the United States Constitution as applied to them. Though Plaintiffs were subject to civil restraining orders when they filed their suit, the orders against them have expired, and in January 2023, a California court denied the latest request to extend them.   The Ninth Circuit dismissed Plaintiffs’ action as moot. The panel rejected Plaintiffs’ argument that, although they were no longer subject to any firearm restrictions, the case fell within the “capable of repetition, yet evading review” exception to mootness. The panel noted that this doctrine is to be used sparingly, in exceptional situations, and generally only where (1) the challenged action is in its duration too short to be fully litigated prior to cessation or expiration, and (2) there is a reasonable expectation that the same complaining party will be subject to the same action again. The panel held that this case was moot because the relevant restraining orders have expired, a three-year-long restraining order is not too brief to be litigated on the merits, and there was no reasonable expectation that Plaintiffs will be subject to the same action again View "MIRANDA WALLINGFORD, ET AL V. ROBERT BONTA, ET AL" on Justia Law

Louisiana Fair Housing Action Center (LaFHAC) sued Azalea Garden Properties, LLC (Azalea Garden), alleging that Azalea Garden discriminated on the basis of race and disability at its apartment complex in Jefferson, Louisiana, in violation of the Fair Housing Act (FHA). The district court dismissed LaFHAC’s disability claim but allowed its disparate impact race claim to proceed, subject to one caveat: The district court certified a permissive interlocutory appeal on the issue of whether the “predictably will cause” standard for FHA disparate-impact claims remains viable after Inclusive Communities Project Inc. v. Lincoln Property Co., 920 F.3d 890 (5th Cir. 2019).   The Fifth Circuit remanded the case with instructions to dismiss LaFHAC’s claims without prejudice. The court held that the district court lacked jurisdiction over this case. Along the same lines, the court wrote that it cannot consider the district court’s certified question. The court explained that LaFHAC has plausibly alleged a diversion of resources, as it shifted efforts away from planned projects like its annual conference toward counteracting Azalea Garden’s alleged discrimination. But “an organization does not automatically suffer a cognizable injury in fact by diverting resources in response to a defendant’s conduct.” The court wrote that LaFHAC failed to plead an injury because it failed to allege how its diversion of resources impaired its ability to achieve its mission. Thus, the court held that because LaFHAC has not alleged a cognizable injury, it lacks standing to bring the claims it alleges in this action. View "LA Fair Housing Action v. Azalea Garden" on Justia Law

Savion Hall, an inmate at Midland County Jail, suffered severe breathing issues that were known to prison officials. The jail contracted with Soluta, Inc., a private company, for medical services, but Soluta employees failed to provide standard medical care to Hall and fabricated his medical reports. Eventually, Hall required urgent medical attention, but when he asked Daniel Stickel, a prison guard, for help, Stickel followed set protocol: Hall was only supposed to receive “breathing treatments” every four hours; because less than four hours had elapsed since Hall’s last treatment, Stickel sent him back to his cell. Eventually, Hall was seen by a doctor, who called Emergency Medical Services (“EMS”). Hall died in the hospital. Plaintiffs, various relatives and representatives of Hall’s estate appealed the dismissal of his constitutional claims against Midland County and Stickel.   The Fifth Circuit affirmed. The court explained that municipalities such as Midland County cannot be held liable unless plaintiffs can show “(1) an official policy (or custom), of which (2) a policymaker can be charged with actual or constructive knowledge, and (3) a constitutional violation whose ‘moving force’ is that policy or custom.” The court explained that there are no allegations that anyone other than the Soluta employees was aware, or should have been aware, of the nurses’ failure to provide adequate medical care. The court reasoned that this implies that neither Soluta nor Midland County4 knew of the “policy” of failing to follow the proper medical procedures. Further, the court held that Plaintiffs have not plausibly pleaded deliberate indifference predicated on a delay in medical treatment. View "Robinson v. Midland County, Texas" on Justia Law

Plaintiff is a devout Rastafarian who vowed to “let the locks of the hair of his head grow,” a promise known as the Nazarite Vow. During his brief stint in prison, Plaintiff was primarily housed at two facilities, and each facility respected Plaintiff’s vow. With only three weeks left in his sentence—Plaintiff was transferred to RLCC. Plaintiff explained that he was a practicing Rastafarian and provided proof of past religious accommodations. And Plaintiff also handed the guard a copy of the Fifth Circuit’s decision in Ware v. Louisiana Department of Corrections. The guard threw Plaintiff’s papers in the trash and summoned RLCC’s warden. When the Warden arrived, he demanded Plaintiff hand over documentation from his sentencing judge that corroborated his religious beliefs. Guards then carried him into another room, handcuffed him to a chair, held him down, and shaved his head. Plaintiff brought claims under RLUIPA and Section 1983. He also pleaded state law claims for negligence, intentional infliction of emotional distress, and violations of the Louisiana constitution. The district court agreed with Defendants and held that those claims were moot. Plaintiff appealed.   The Fifth Circuit affirmed. The court concluded that while Sossamon I RLUIPA’s text suggests a damages remedy, recognizing as much would run afoul of the Spending Clause. Tanzin doesn’t change that—it addresses a different law that was enacted under a separate Congressional power with “concerns not relevant to [RLUIPA].” Accordingly, the court held because Sossamon I remains the law, Plaintiff cannot recover monetary damages against the defendant-officials in their individual capacities under RLUIPA. View "Landor v. Louisiana Dept of Corrections" on Justia Law

The Verona Police Department twice arrested L.B. for his connection to violent shootings. Both times, however, he was released while his charges were pending. Just five months after his second arrest, L.B. drove to Annie Walton’s house and opened fire—killing Annie Walton and injuring her grandson, Aliven Walton. Annie Walton’s wrongful death beneficiaries (collectively, Plaintiffs ) believe the City of Verona and the Verona Chief of Police, J.B. Long, are responsible for the shooting at Annie Walton’s home, so they sued under 42 U.S.C. Section 1983 and the Mississippi Tort Claims Act. At summary judgment, the district court initially dismissed all claims. But Plaintiffs filed a motion for reconsideration, and the district court reversed course—finding the City of Verona was not entitled to sovereign immunity under the Mississippi Tort Claims Act. Plaintiffs and the City of Verona subsequently filed interlocutory appeals.   The Fifth Circuit dismissed Plaintiffs appeal for lack of jurisdiction and reversed the district court’s finding against the City regarding sovereign immunity. The court explained that Long had no special duty to protect Plaintiffs besides his general duty to keep the public safe as the City’s Chief of Police. The court explained that the only evidence that demonstrates Long had knowledge of any connection between L.B. and Plaintiffs comes from Long’s investigative file, where there is a copy of a trespassing complaint that Annie filed against L.B. in 2016. Accordingly, the court held Long did not owe a duty to protect Plaintiffs from L.B.’s drive-by shooting. Thus, Plaintiffs cannot sustain their negligence claims or their MTCA claims against the City. View "Walton v. City of Verona" on Justia Law