Justia Civil Rights Opinion Summaries

The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

The case involves Erie Insurance Company and its affiliates (collectively, Erie) and the Maryland Insurance Administration (MIA). In 2021, the MIA initiated two separate administrative investigations into Erie following complaints alleging racial and geographic discrimination. The first investigation broadly examined Erie’s market conduct, while the second focused on the specific allegations in the individual complaints. In 2023, the MIA issued four public determination letters stating that Erie had violated state insurance laws. These letters referenced documents obtained during the market conduct investigation, which had not yet concluded. Erie requested and was granted administrative hearings on all four determination letters.Erie then filed a lawsuit against the MIA and its commissioner in federal district court, alleging due process violations under 42 U.S.C. § 1983 and violations of Maryland state law. Erie sought a declaration that the determination letters were unlawful, an injunction preventing the defendants from disseminating the letters, and a requirement for the defendants to publicly withdraw them. The district court dismissed Erie's complaint, citing the principles of abstention outlined in Younger v. Harris, which generally discourages federal courts from interfering with ongoing state proceedings.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Erie had an adequate opportunity to raise its constitutional claims in the administrative hearings and subsequent state court review, as required for Younger abstention. The court also rejected Erie's argument that this case fell within an exception to Younger abstention due to extraordinary circumstances or unusual situations. The court concluded that Erie had not demonstrated that the MIA's actions were motivated by bias or that the administrative proceedings would not afford Erie constitutionally adequate process. View "Erie Insurance Exchange v. Maryland Insurance Administration" on Justia Law

Anthony Buntyn, an employee of a private company that transported detainees for law enforcement agencies, was charged with willfully violating the detainees' rights under the Fourteenth Amendment's due process clause due to inhumane conditions of confinement. The conditions developed while Buntyn transported the detainees in a van to various detention facilities. The government alleged that Buntyn had violated the Fourteenth Amendment's due process clause through deliberate indifference to intolerable conditions of confinement and that this indifference had resulted in bodily injury to three detainees. The jury found Buntyn guilty of depriving the detainees of humane conditions, acting willfully and with deliberate indifference, and causing bodily injury to one detainee.Buntyn appealed his conviction to the United States Court of Appeals for the Tenth Circuit, arguing that the evidence was insufficient for a finding of guilt, that the district court erred in preventing his attorney from using the term malice in closing argument, and that the court coerced the jury to reach a verdict. The Tenth Circuit rejected Buntyn's arguments and affirmed his conviction. The court found that the evidence was sufficient to support the jury's findings of inhumane conditions, deliberate indifference, and willfulness. The court also found that the district court did not err in prohibiting the use of the term malice in closing argument, and that Buntyn had waived his challenge to the district court's instruction for the jury to continue deliberating. View "United States v. Buntyn" on Justia Law

The case involves Earl Johnson, a former inmate of the Maryland Correctional Training Center, who alleged that corrections officer Chad Zimmerman sexually harassed and abused him during strip searches, in violation of his Fourth and Eighth Amendment rights. Johnson also sued Zimmerman’s supervisor, Lt. Richard Robinette, alleging supervisory and bystander liability. The district court dismissed Johnson’s claims against Robinette due to failure to exhaust administrative remedies but held that Johnson’s claims against Zimmerman were exempt from this requirement. The court also granted summary judgment to Zimmerman and Robinette on the merits of Johnson’s claims.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding that Johnson’s claims against Robinette were subject to exhaustion requirements. However, the court affirmed the district court’s decision to grant summary judgment to both defendants. The court found that the strip searches, including those involving momentary touchings of Johnson’s genitalia or buttocks, did not rise to the level of an unreasonable search under the Fourth Amendment. The court also found that Johnson failed to present sufficient evidence to prove that Zimmerman had the requisite malicious intent to sexually abuse him, sexually arouse him or himself, or otherwise gratify sexual desire. Furthermore, the court found that Johnson’s evidence fell short of establishing supervisory or bystander liability against Robinette. View "Johnson v. Robinette" on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

The plaintiff, Gary Avant, was a truck driver for Muskogee County. County officials believed that Avant was complaining to other citizens about the county’s road plan and the assignment of a county worker. Avant was subsequently fired by the county commissioner. Avant sued the commissioner under 42 U.S.C. § 1983, claiming retaliation in violation of the First Amendment. However, during the litigation, Avant denied making the statements that led to his firing. The commissioner moved for summary judgment, arguing that the perceived speech hadn’t involved a matter of public concern. The district court denied this part of the motion, and the case was remanded for the district court to develop the record.After remand, the district court again denied summary judgment, leading the commissioner to appeal again. On appeal, the commissioner argued that Avant hadn’t pleaded a claim for perceived speech and that qualified immunity applies given the lack of precedent on how to assess a public concern for perceived speech.The United States Court of Appeals for the Tenth Circuit found that it lacked jurisdiction to consider the adequacy of the pleadings. However, it did have jurisdiction over the commissioner’s argument for reversal based on the absence of a clearly established violation. The court concluded that Avant had not shown that the perceived speech involved a clearly established public concern. Therefore, the commissioner was entitled to qualified immunity, and the court reversed the denial of qualified immunity and remanded the case for the district court to grant summary judgment to the commissioner in his personal capacity on the First Amendment claim for retaliation based on perceived speech. View "Avant v. Doke" on Justia Law

The case revolves around Angela Singleton, a former employee of the Maryland Technology Development Corporation (TEDCO), who filed a lawsuit against TEDCO alleging sex- and race-based discrimination and retaliation. TEDCO, an entity created by the State of Maryland to promote economic development, argued that it was an "arm of the State" and therefore immune under the Eleventh Amendment from suits brought in federal court. Singleton countered that TEDCO was essentially a series of social impact and venture funds overseen by the corporation and did not qualify as an arm of the State.The United States District Court for the District of Maryland dismissed Singleton's complaint, agreeing with TEDCO's argument that it was indeed an arm of the State and therefore entitled to Eleventh Amendment immunity. Singleton appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that although the State of Maryland was not legally obligated to pay TEDCO's debts, it was practically responsible for the entity's solvency. The court also noted that the State exercised significant control over TEDCO, that TEDCO's concerns were statewide, and that the State treated TEDCO substantially as an agency. Therefore, the court concluded that TEDCO was an arm of the State and protected from Singleton's suit by the Eleventh Amendment. View "Singleton v. Maryland Technology and Development Corporation" on Justia Law

The case involves Travis Woods, a wheelchair user, who sued the Central New York Regional Transportation Authority and its subsidiary Centro of Oneida, Inc. (collectively, "Centro"), which operate the public bus service in Oneida County. Woods claimed that Centro violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by failing to provide wheelchair-accessible bus stops. He argued that the district court erred in granting summary judgment to Centro on his claims.The United States District Court for the Northern District of New York granted summary judgment to Centro, dismissing Woods's complaint. The court found that Centro's paratransit service and its flexible pick-up and drop-off policy were reasonable accommodations providing meaningful access to Centro’s bus service.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court found that Woods's claims under sections 12147 and 12148 of the ADA failed as a matter of law. The court concluded that Woods had not shown that the altered portions of Centro’s bus stops were inaccessible or that Centro’s bus service was not readily accessible to individuals with disabilities. The court also found that Woods had not established that any modifications to Centro’s policies, practices, or procedures were necessary to avoid discrimination or to provide program access. Therefore, the court affirmed the judgment of the district court. View "Woods v. Centro of Oneida, Inc." on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

Barbara Harrison, a severely disabled individual, challenged the Texas Health and Human Services Commission's (HHSC) decision to deny funding for medical services she claimed were necessary for her survival. Harrison lived in a group home and received nursing services funded by HHSC’s program for providing home and community-based care to people with disabilities. However, when her condition deteriorated to the point where she required 24/7 one-on-one nursing care, HHSC determined that the cost of providing Harrison’s necessary level of care exceeded the cost cap set by the program. Harrison was therefore denied program-funded nursing services, meaning her only option for receiving government-funded medical care was to move to an institutional setting.Harrison challenged HHSC’s determination in court, arguing that HHSC discriminated against her because of her disability, in violation of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, by denying her program-funded nursing services. The district court granted a preliminary injunction requiring HHSC to fund 24/7 one-on-one care for Harrison until she received a hearing on her request for general revenue funds. However, the United States Court of Appeals for the Fifth Circuit vacated the preliminary injunction and remanded for further proceedings, holding that Harrison was unlikely to succeed on her due process claim and had not demonstrated a likelihood of success on the ADA/Rehabilitation Act claims.After the case was remanded to the district court, Harrison submitted a new application to HHSC for 24-hour nursing care under the Program, the cost of which again exceeded the Cost Cap. HHSC determined that Harrison did not require 24-hour nursing care and that 5.5 hours of nursing care per day would be sufficient to meet her medical needs. The district court found that Harrison’s change in status— from receiving no Program funding to receiving some Program funding— mooted Harrison’s ADA/Rehabilitation Act claims. The court therefore dismissed them and then granted summary judgment to HHSC on Harrison’s due process claim. Harrison appealed this decision.The Fifth Circuit Court of Appeals affirmed the district court’s grant of summary judgment to HHSC on Harrison’s due process claim but reversed the district court’s dismissal of Harrison’s discrimination claims. The court found that the district court’s mootness determination was erroneous and that the factual record was still not sufficiently developed to support a judgment as to Harrison’s discrimination claims. The case was remanded for further factfinding and proceedings. View "Harrison v. Young" on Justia Law