Justia Civil Rights Opinion Summaries

Plaintiff claimed that because of circumstances beyond his control, he did not receive notice of the district court’s judgment for over 90 days after it was entered, and he filed a notice of appeal shortly after he did receive notice. In response, the Fourth Circuit found his notice of appeal untimely, but the court construed the notice as a timely motion to reopen the appeal period pursuant to Federal Rule of Appellate Procedure 4(a)(6), which implements an exception found in 28 U.S.C. Section 2107(c), and remanded the case to the district court. The district court then entered an order under Rule 4(a)(6), reopening the time for noticing an appeal for 14 days from the date of its order. Plaintiff, however, failed to file a notice of appeal within the window so provided.   The Fourth Circuit dismissed his appeal. The court explained that Section 2107(c) of Title 28, which is the statute prescribing the timing requirements for filing appeals in civil actions, provides that a would-be appellant who does not receive timely notice of a judgment and thereafter fails to file a timely notice of appeal may nonetheless request — not more than 180 days after the judgment is entered — that the district court exercise its discretion to reopen the time for appeal by providing a new 14-day window within which to file a notice of appeal. Compliance with this narrow supplemental opportunity for filing a timely notice of appeal is especially significant because the times specified by statute for filing appeals in civil actions are jurisdictional. View "Donte Parrish v. US" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Puerto Rico Highways and Transportation Authority (PRHTA) and its executive directors (collectively, Appellees) and dismissing this complaint brought by sixty-nine current and former employees of the PRHTA (collectively, Appellants), holding that the district court did not err or abuse its discretion.Appellants brought this action challenging the PRHTA's decision no longer to give effect to a regulation providing Appellants with additional compensation. Specifically, Appellants claimed that the decision was contrary to P.R. Act No. 66-2014, giving rise to violations of the Contracts Clause and Due Process Clause. The district court granted summary judgment for the PRHTA on the federal constitutional claims and declined to exercise supplemental jurisdiction over Appellants' claims under Puerto Rico law. The First Circuit affirmed, holding that the district court (1) did not err in concluding that Appellants could not establish their federal constitutional claims; and (2) did not abuse its discretion in declining to exercise jurisdiction over Appellants' remaining Puerto Rico law claims. View "Vazquez-Velazquez v. P.R. Highway & Transportation Authority" on Justia Law

The Supreme Court vacated the judgment of the court of appeals determining that the Mill Creek Metropolitan Park District Board of Commissioners failed to comply with Ohio Rev. Code 1545.11 when it initiated appropriation proceedings to take private property owed by Landowner, holding that the trial court's orders denying Landowner's motions for summary judgment were not final, appealable orders.The Park District initiated appropriation proceedings against Landowner. Landowner answered by denying the necessity of the appropriation and the Park District's authority to appropriate the property. The trial court denied Landowner's motions for summary judgment. The court of appeals reversed and remanded with instructions to enter summary judgment for Landowner. The Supreme Court vacated the court of appeals' judgment, holding that the court erred in determining that the trial court's orders denying Landowner's motions for summary judgment were final, appealable orders. View "Mill Creek Metropolitan Park District Bd. of Commissioners v. Less" on Justia Law

While Respondent was employed as a truck driver at Greatwide Dedicated Transport II, LLC (“Greatwide”), he witnessed certain drivers receive additional driving assignments in violation of 49 C.F.R. Section 395.3, which regulates the maximum driving time for property-carrying vehicles. After collecting evidence related to the violations, Respondent submitted anonymous letters to management reporting his findings. Soon thereafter, Respondent revealed to management personnel that he was the author of the letters. The following month, Respondent was assigned to deliver two trailers filled with merchandise to two Nordstrom store locations in Manhattan, New York and Paramus, New Jersey. However, when Respondent returned from this assignment, he was suspended for—what Greatwide claimed to be—violations of company policy. Greatwide subsequently terminated and dismissed Respondent without a more explicit explanation. Respondent promptly filed a whistleblower complaint with the U.S. Department of Labor’s (“DOL”) Occupational Safety and Health Administration (“OSHA”). Following several lengthy delays, the Administrative Law Judge (“ALJ”) ruled in Respondent’s favor, ordering Greatwide to pay both back pay and emotional distress damages. The Administrative Review Board (“ARB”) affirmed.   The Fourth Circuit affirmed. The court concluded that substantial evidence supports the ARB’s conclusion that Respondent engaged in protected activity, that his activity was a contributing factor in his termination, and that Greatwide failed to prove by clear and convincing evidence that Respondent would have been terminated absent his protected conduct. Nor was Greatwide prejudiced by the proceeding’s delays. Finally, the court declined to enforce the alleged settlement agreement because the company failed to challenge the ALJ’s decision before the ARB. View "Greatwide Dedicated Transport II, LLC v. United States Department of Labor" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing the appeal brought by the Commission on Human Rights and Opportunities in this housing discrimination case, holding that this Court was compelled to affirm.For several years, Richard Cantillon harassed his neighbor, Kelly Howard, by making obscene gestures, calling her racial epithets, and physically menacing Howard. Howard eventually filed a neighbor versus neighbor claim with the Commission on Human Rights and Opportunities, alleging that Cantillon had violated her civil rights on account of her race. Cantillon defaulted, and the referee awarded Plaintiff $15,000 in damages. The Commission appealed the award as insufficient, but neither Howard nor Cantillon participated in the appeal. The trial court dismissed the appeal, concluding that there was no legal basis for it to second-guess the amount of the award. The court of appeals affirmed. The Supreme Court affirmed, holding that the appellate court appropriately resolved the Commission's claims under the circumstances of this case. View "Comm'n on Human Rights & Opportunities v. Cantillon" on Justia Law

In the winter of 2020, the Secretary of Health and Human Services (HHS) determined that the threat posed by the novel SARS-CoV-2 virus constituted a public health emergency. The CDC published the rule at issue—the Requirement for Persons to Wear Masks While on Conveyances and at Transportation Hubs, 86 Fed. Reg. 8025-01 (Feb. 3, 2021) (“Mandate”). Plaintiffs initiated this litigation, arguing that the Mandate was unlawful under the Administrative Procedure Act, 5 USC Section 706(2) (APA), and unconstitutional under non-delegation and separation-of-powers tenets.   The Eleventh Circuit vacated the district court’s judgment and instructed the district court to dismiss the case as moot. The court explained that it found Plaintiffs’ contention that there is a reasonable expectation that the CDC will issue another nationwide mask mandate for all conveyances and transportation hubs to be speculative. Conjectures of future harms like these do not establish a reasonable expectation that a mask mandate from the CDC will reissue. Further, the court reasoned that there is no “reasonable expectation or a demonstrated probability that the same controversy will recur involving the same complaining party.” View "Health Freedom Defense Fund, et al v. President of the United States, et al" on Justia Law

Appellants in these tandem appeals are each a parent of a disabled child. Arguing that his or her child was entitled to benefits under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. Section 1415(i), each parent brought an administrative action against his or her local education agency and prevailed. Subsequently, each parent brought a federal action for attorneys’ fees pursuant to 20 U.S.C. Section 1415(i)(3)(B). In each case, the district court awarded less attorneys’ fees than the parent requested, and the parents appealed.   The Second Circuit reversed the district court’s denial of travel-related fees in No. 21-1961 and remanded for further proceedings. The court otherwise affirmed the judgments of the district courts. The court found that it was persuaded that there was no abuse of discretion in the district court’s calculation of reasonable attorneys’ fees in each case. Further, the court wrote that the district courts that declined to award prejudgment interest did not abuse their discretion because “delays in payment” may be remedied by “application of current rather than historic hourly rates.” However, the court held that the district court abused its discretion when it denied any travel-related fees to M.D.’s counsel. A district court may permissibly adjust excessive travel costs. But the district court could not “eliminate all of the hours submitted by [CLF] as travel time” by denying travel-related fees altogether. View "H.C. v. NYC DOE, et al." on Justia Law

Two Texas employers: Braidwood Management, Inc. (“Braidwood”) and Bear Creek Bible Church (“Bear Creek”), filed suit, as per their closely held religious beliefs, asserting that Title VII, as interpreted in the EEOC’s guidance and Bostock, prevents them from operating their places of employment in a way compatible with their Christian beliefs. Plaintiffs have implicitly asserted that they will not alter or discontinue their employment practices. all parties admitted in district court that numerous policies promulgated by plaintiffs (such as those about dress codes and segregating bathroom usage by solely biological sex) already clearly violate EEOC guidance. Both plaintiffs also contend that they are focused on individuals’ behavior, not their asserted identity.   The Fifth Circuit affirmed the district court’s conclusion that plaintiffs’ claims are justiciable; reversed the class certifications; affirmed the judgment against Bear Creek; affirmed the ruling that Braidwood is statutorily entitled to a Title VII exemption; vacated the judgment that Braidwood is constitutionally entitled to a Title VII exemption; and vacated the judgment regarding the scope-of-Title-VII claims as a matter of law. The court reasoned that under the facts presented, it cannot determine a more appropriate, limited class definition for any of the classes presented here. Accordingly, the court held that both Braidwood and Bear Creek have standing and bring individual claims. Further, the court explained that the EEOC failed to show a compelling interest in denying Braidwood, individually, an exemption. The agency does not even attempt to argue the point outside of gesturing to a generalized interest in prohibiting all forms of sex discrimination in every potential case. View "Braidwood Management v. EEOC" on Justia Law

Plaintiff-appellant Sharhea Wise worked as a mail carrier for the United States Postal Service. When she got pregnant, she asked to avoid handling heavy items. The Postal Service agreed to provide help when items were too heavy, but Wise needed to tell someone when she needed help. On two occasions, Wise allegedly had to handle items that were too heavy. Both times, she blamed the Postal Service for failing to accommodate her need for help. The Postal Service argued in response that Wise hadn’t asked for help. Days after Wise allegedly had to handle the heavy items, she walked off the job and the Postal Service fired her. Wise claimed retaliation, attributing the firing to her requests for help. The Postal Service denied retaliation, explaining that it had fired Wise because she walked off the job. Wise characterized this explanation as pretextual. The district court granted summary judgment to the Postal Service, and Wise challenged the rulings. The Tenth Circuit agreed with her challenge on the failure-to-accommodate claim. "On this claim, a reasonable factfinder could find that the Postal Service had failed to accommodate Ms. Wise’s need to avoid handling heavy items." But the Court agreed with the grant of summary judgment on the retaliation claim because: (1) the Postal Service presented a neutral, nonretaliatory explanation for the firing; and (2) Wise lacked evidence of pretext. View "Wise v. DeJoy" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had not been lawfully arrested without a warrant and thus reversing the decisions of the West Virginia Division of Motor Vehicles (DMV) to revoke Defendant's driver's license, holding that the circuit court did not err.A law enforcement officer arrested Defendant in his home without a warrant for a misdemeanor committed elsewhere. Rhe officer articulated no urgent need to arrest Defendant and admitted that he could have obtained a warrant from an impartial magistrate. The DMV applied evidence suggesting that Defendant might have driven while intoxicated from the scene of the misdemeanor to his home in three separate decisions revoking Defendant's driver's license. The circuit court reversed the revocation decisions, concluding that they were clearly wrong in light of the now-repealed W. Va. Code 17C-5A-2(f)(2). The Supreme Court affirmed, holding that the circuit court did not err in concluding that the DMV's suspension orders were founded upon an unlawful arrest. View "Frazier v. Briscoe" on Justia Law