Justia Civil Rights Opinion Summaries

A United States citizen, formerly known as Paul Anderson and now Saadiq Long, was placed on the federal government’s Terrorist Screening Dataset (commonly called the Terrorist Watchlist) and, at one point, on its No Fly List subset. After experiencing travel restrictions, employment issues, and other alleged harms, Long challenged his placement on these lists, asserting constitutional and statutory violations. He claimed that his inclusion was based on impermissible factors such as race, religion, and protected activities, and that the government’s information-sharing practices and redress procedures were unlawful. While the litigation was ongoing, Long was removed from the No Fly List, but remained on the broader Watchlist. He also alleged that his Watchlist status led to the denial of credentials necessary for his work as a truck driver.The United States District Court for the Eastern District of Virginia initially transferred some of Long’s claims to the Fourth Circuit and stayed others. After Long’s removal from the No Fly List, a prior Fourth Circuit panel found his No Fly List claims moot and remanded for the district court to determine which claims remained justiciable. On remand, the district court dismissed all of Long’s claims for lack of subject matter jurisdiction, finding that his removal from the No Fly List mooted those claims and that he lacked standing for his Watchlist-related claims, as his alleged injuries were either resolved or not sufficiently imminent.The United States Court of Appeals for the Fourth Circuit vacated the district court’s dismissal. The Fourth Circuit held that, in light of the Supreme Court’s decision in FBI v. Fikre, Long’s removal from the No Fly List did not necessarily moot his claims, as the government had not shown it could not repeat the challenged conduct. The court also found that Long had standing to challenge his Watchlist status based on the denial of transportation credentials, and remanded for the district court to consider the merits of his claims. View "Long v. Bondi" on Justia Law

Several individuals who allegedly owed debts to Kentucky public institutions—either for medical services at the University of Kentucky or for educational services at the University of Kentucky, Morehead State University, or the Kentucky Community & Technical College System—challenged the referral of their debts to the Kentucky Department of Revenue for collection. The plaintiffs argued that the statutes used to justify these referrals did not apply to their debts and that the Department unlawfully collected the debts, sometimes without prior court judgments or adequate notice. The Department used its tax collection powers, including garnishments and liens, to recover these debts, and in some cases, added interest and collection fees.In the Franklin Circuit Court, the plaintiffs sought declaratory and monetary relief, including refunds of funds collected. The Circuit Court ruled that the Department was not authorized by statute to collect these debts and held that sovereign immunity did not protect the defendants from the plaintiffs’ claims. The court also certified the medical debt case as a class action. The Court of Appeals reviewed these interlocutory appeals and held that while sovereign immunity did not bar claims for purely declaratory relief, it did bar all claims for monetary relief, including those disguised as declaratory relief.The Supreme Court of Kentucky reviewed the consolidated appeals. It held that sovereign immunity does not bar claims for purely declaratory relief or for a refund of funds that were never due to the state, nor does it bar constitutional takings claims. However, the court held that sovereign immunity does bar claims for a refund of funds that were actually due to the state, even if those funds were unlawfully or improperly collected. The court affirmed in part, reversed in part, and remanded for further proceedings to determine which funds, if any, were never due to the state and thus subject to refund. The court also found that statutory changes rendered prospective declaratory relief in the medical debt case moot, but not retrospective relief. View "LONG V. COMMONWEALTH OF KENTUCKY" on Justia Law

A man named Donald Prater, Jr. was found partially nude and behaving erratically after leaving a hospital, having previously told a deputy he had used methamphetamine and was hallucinating. Law enforcement officers from the City of Paintsville and Johnson County, along with emergency medical personnel, responded to reports of his behavior. When officers attempted to arrest Prater on a public street, he resisted and force was used, including a taser, pepper spray, and baton strikes. After being handcuffed, Prater stopped breathing and, despite immediate lifesaving efforts, died. The medical examiner found no lethal trauma and attributed the death to excited delirium syndrome, with other health factors possibly contributing.The personal representative of Prater’s estate filed a wrongful death suit in Johnson Circuit Court against various city and county entities and their employees, alleging excessive force, negligence, and wrongful death. The circuit court granted summary judgment to all defendants, finding the officers and emergency personnel were entitled to qualified official immunity, that the force used was reasonable, and that there was no evidence their actions caused Prater’s death. The court also dismissed claims against the city and county entities, including those for negligent hiring and supervision, on the basis that no underlying tort had been established.On appeal, the Kentucky Court of Appeals affirmed in part and reversed in part, holding that some claims against the city and police department for negligent hiring and supervision could proceed, and that the officers’ entitlement to qualified immunity required further factual findings. The Supreme Court of Kentucky reviewed the case and held that all defendants were properly dismissed. The Court concluded that the officers’ actions were discretionary, performed in good faith, and within the scope of their authority, entitling them to qualified official immunity. The Court reversed the Court of Appeals in part, affirmed in part, and remanded for any necessary proceedings. View "CITY OF PAINTSVILLE V. HANEY" on Justia Law

Rodney Owen Skurdal, who is not a licensed attorney, attempted to represent Ronald Trow during Trow’s initial appearance in a criminal case in Yellowstone County Justice Court. Judge Jeanne Walker, presiding over the case, ordered Skurdal to vacate the defendant’s table and did not permit him to represent Trow, as Skurdal was not a member of the bar. Trow subsequently entered a plea of not guilty, and a public defender was appointed. Skurdal then filed a lawsuit in the Thirteenth Judicial District Court for Yellowstone County against Judge Walker, later joined by Yellowstone County as a defendant, alleging violations of his and Trow’s rights and advancing various arguments, including those associated with the “Sovereign Citizen” movement.The Thirteenth Judicial District Court dismissed Skurdal’s complaint with prejudice, holding that Judge Walker and Yellowstone County were protected by absolute judicial immunity for actions taken in the course of judicial duties. The court also found that Skurdal, as a non-lawyer, had no statutory or constitutional right to represent another individual in a criminal proceeding in Montana. The court denied leave to amend the complaint, finding that any amendment would be futile due to the immunity defense.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that Montana law does not permit non-lawyers to represent others in criminal cases, and that Judge Walker’s actions were judicial acts performed within her jurisdiction, entitling her and Yellowstone County to absolute immunity from suit. The Court also concluded that the District Court did not err in denying leave to amend, as further amendment could not overcome the immunity bar. View "Skurdal v. Walker" on Justia Law

The Washington Lawyers’ Committee for Civil Rights and Urban Affairs (WLC) frequently submits Freedom of Information Act (FOIA) requests to the Bureau of Prisons (Bureau) for records to aid in representing incarcerated individuals. Frustrated by the Bureau’s delays in responding to these requests, WLC filed a lawsuit claiming the Bureau has a policy or practice of violating FOIA by not responding promptly. WLC sought an injunction to reform the Bureau’s FOIA processes to expedite record production.The United States District Court for the District of Columbia ruled that WLC had a viable policy or practice claim but granted summary judgment to the Bureau. The court credited an affidavit from the Bureau describing efforts to improve FOIA response times and found no evidence of a policy or practice of violating FOIA. WLC appealed, arguing that the Bureau’s requirement to submit individual FOIA requests for prisoners’ disciplinary and educational records, rather than using an expedited process like the one for medical records under the Privacy Act, unnecessarily increased delays.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Bureau’s practice of processing requests for individual prisoners’ records under FOIA, rather than creating a separate expedited process, does not violate FOIA. The court found that FOIA does not require the Bureau to waive its statutory entitlements under the Privacy Act for non-medical records. The court affirmed the district court’s grant of summary judgment, concluding that WLC’s claim failed as a matter of law. The court also upheld the denial of WLC’s discovery request, finding it unnecessary given the legal insufficiency of WLC’s claim. View "Washington Lawyers' Committee for Civil Rights and Urban Affairs v. Department of Justice" on Justia Law

Michael Muir, who has a congenital birth defect presenting as a hernia in his right scrotum, challenged the Transportation Security Administration’s (TSA) Final Rule authorizing the use of Advanced Imaging Technology (AIT) scanners at airport security checkpoints. Muir argued that the scanners, which use electromagnetic radiation, flag his hernia as a threat, leading to painful and potentially life-threatening pat-downs. He claimed that the Final Rule and TSA’s standard operating procedures (SOPs) are arbitrary and capricious, contrary to TSA’s statutory authority, and violate Section 504 of the Rehabilitation Act of 1973.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court found that Muir had not raised his statutory challenges during the rulemaking process, resulting in forfeiture of those claims. However, the court agreed with Muir’s Rehabilitation Act claim, noting that TSA’s failure to provide an accommodation for his disability could be a violation of the Act. The court determined that Muir had identified a reasonable accommodation—screening with a walk-through metal detector (WTMD)—and remanded the case to TSA to determine if this accommodation would impose an undue burden on the agency.The court denied Muir’s other challenges to the Final Rule and his motion to supplement the record. The court emphasized that TSA must conduct the appropriate administrative process to address the implementation of Muir’s reasonable accommodation and explore alternative accommodations if necessary. View "Muir v. Department of Homeland Security" on Justia Law

The Northwestern Illinois Area Agency on Aging (NIAAA) filed lawsuits against Paula Basta, the former Director of the Illinois Department on Aging (IDA), alleging that Basta unlawfully refused to hold hearings on three administrative petitions filed by NIAAA. These petitions concerned grievances about withheld funding and rejected service provider designations. NIAAA claimed that these actions violated their rights under the Older Americans Act (OAA) and Illinois state law.The Illinois Supreme Court ruled in favor of Basta, determining that NIAAA did not have a constitutionally protected property interest in the funding or service provider designations. Subsequently, the federal district court dismissed NIAAA’s suit, finding it time-barred and failing to state a claim. NIAAA then appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit affirmed the district court’s dismissal. The court held that NIAAA’s claims related to the denials of the Initial Petition and APS Petition were barred by the statute of limitations, as they accrued by September 2019 and were not tolled by NIAAA’s state court litigation. The court also agreed with the district court that NIAAA failed to plausibly allege a due process violation, as the Illinois Supreme Court had determined that NIAAA did not have a property interest in the funding or service provider designations.Furthermore, the Seventh Circuit found that the OAA provisions at issue did not create individual rights enforceable under 42 U.S.C. § 1983. The court concluded that the OAA’s language and context did not unambiguously confer individual rights upon NIAAA, and thus, NIAAA could not enforce these provisions through § 1983. The court affirmed the district court’s judgment in favor of Basta. View "Northwestern Illinois Area Agency on Aging v. Basta" on Justia Law

In this case, the Attorney General of New Jersey decided to supersede control of the Paterson Police Department following a fatal police shooting. The Attorney General appointed Isa M. Abbassi, a veteran NYPD officer, as the Officer in Charge (OIC) and reassigned the Paterson Police Chief, Engelbert Ribeiro, to the Police Training Commission in Trenton. Plaintiffs, including Paterson officials, challenged the Attorney General's authority to supersede the police department without local consent.The case was first brought to the Law Division, which transferred it to the Appellate Division. The Appellate Division consolidated the actions and ultimately reversed the Attorney General's decision, ruling that the Attorney General exceeded his statutory powers. The appellate court directed the defendants to reassign Ribeiro to Paterson, relinquish control of the department to city officials, and provide a report summarizing their actions and expenditures during the supersession.The New Jersey Supreme Court reviewed the case and found evidence that the Legislature intended to authorize the supersession in two statutes: Chapter 94, which facilitated the OIC's leadership, and the appropriations bill for the fiscal year ending June 30, 2024, which funded the Attorney General's operation of the department. The Court did not base its holding on other statutes or authorities cited by the defendants. The Court reversed the Appellate Division's judgment, finding that the Attorney General's supersession of the Paterson Police Department was not arbitrary, capricious, or unreasonable, and had fair support in the record. The Court did not address whether the Attorney General has general authority to supersede municipal police departments in other circumstances. View "Bulur v. The New Jersey Office of the Attorney General" on Justia Law

The case involves the National Rifle Association of America (NRA) suing Maria T. Vullo, the former Superintendent of the New York State Department of Financial Services (DFS), alleging that Vullo violated its First Amendment rights. The NRA claimed that Vullo engaged in coercive and retaliatory actions against the NRA by pressuring financial institutions and insurers to sever ties with the NRA, thereby infringing on its free speech and equal protection rights. Vullo argued that she was entitled to qualified immunity.The United States District Court for the Northern District of New York denied Vullo's motion to dismiss the NRA's First Amendment claims, finding that the NRA had sufficiently stated a claim and that Vullo was not entitled to qualified immunity at that stage. Vullo appealed the decision.The United States Court of Appeals for the Second Circuit initially reversed the district court's decision, holding that the NRA failed to state a First Amendment claim and that Vullo was entitled to qualified immunity. The NRA then petitioned the Supreme Court, which granted certiorari to address whether the NRA had stated a plausible First Amendment claim. The Supreme Court concluded that the NRA had plausibly alleged a First Amendment violation and remanded the case to the Second Circuit to reconsider the issue of qualified immunity.Upon reconsideration, the Second Circuit concluded that Vullo was entitled to qualified immunity. The court reasoned that, although the general principle that a government official cannot coerce a private party to suppress disfavored speech was well established, it was not clearly established that Vullo's conduct—regulatory actions directed at the nonexpressive conduct of third parties—constituted coercion or retaliation in violation of the First Amendment. Therefore, the court reversed the district court's denial of qualified immunity and remanded the case for the district court to enter judgment dismissing the remaining claims against Vullo. View "Nat'l Rifle Ass'n of Am. v. Vullo" on Justia Law

Jordan Watkins, while in federal custody, underwent hernia repair surgery and subsequently experienced severe pain and swelling in his groin. Medical staff at the correctional facility dismissed his symptoms as routine side effects and refused to schedule a follow-up appointment before his transfer to another facility. Watkins filed Bivens claims against the medical and correctional staff for deliberate indifference to his serious medical needs and a Federal Tort Claims Act (FTCA) claim against the United States for negligent medical treatment.The United States District Court for the Northern District of Illinois dismissed all of Watkins' claims under Rule 12(b)(6). The court held that the Supreme Court's framework for evaluating Bivens claims barred Watkins' claims and that his FTCA claim was filed too late.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Watkins' Bivens claims could proceed under the precedent set by Carlson v. Green, which allows federal prisoners to sue for damages resulting from deliberate indifference to their serious medical needs. The court found that Watkins' claims fit within the context recognized by Carlson and were not meaningfully different. The court also held that the district court's dismissal of Watkins' FTCA claim was premature. Watkins may be able to establish the requirements for equitable tolling due to extraordinary circumstances, such as disruptions caused by COVID-19, which prevented him from filing his suit on time. The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watkins v. Mohan" on Justia Law