Justia Civil Rights Opinion Summaries

The circuit court ruled Enoch Oliver could proceed to trial with his malicious-prosecution claim against University of Mississippi Medical Center (UMMC) and two of its law-enforcement officers, Syrone McBeath and David Stewart. Oliver was charged with three misdemeanors: disorderly conduct for failure to comply with the commands of a police officer, resisting arrest, and carrying a concealed weapon. A nol-pros order was signed by the trial court and charges were ultimately dropped against Oliver. Oliver sued civilly, and UMMC, McBeath, and Stewart were served with process; several other officers were not. UMMC, McBeath, and Stewart filed a motion to dismiss, which was joined by the unserved defendants, who specially appeared. The served defendants argued Oliver’s claims were governed by the Mississippi Tort Claims Act (MTCA) and its one-year statute of limitations. The lone exception was the malicious prosecution of the felony claim, because the one-year statute of limitations did not begin to run until that charge was nol-prossed. The unserved defendants’ motion was granted, leaving the remaining claim against the served defendants as the malicious-prosecution claim based on the felony charge. Three-and-a-half years later, UMMC, McBeath, and Stewart filed a motion for summary judgment. UMMC argued, as a state agency, it had not waived sovereign immunity for a malice-based claim; McBeath and Stewart argued Oliver lacked proof they maliciously prosecuted him. Alternatively, all defendants cited the MTCA’s police-protection and discretionary-function immunity. The circuit court denied the defendants’ motion. UMMC, McBeath, and Stewart filed this interlocutory appeal, claiming they were entitled to summary judgment. The Mississippi Supreme Court determined as a matter of law, malice-based torts did not fall under the Mississippi Tort Claims Act’s sovereign-immunity waiver. So Oliver had no malicious-prosecution claim against UMMC or its employees in their official capacity. Oliver also brought malicious-prosecution claims against the UMMC officers in their individual capacity, but the record showed Oliver failed to put forth any evidence the officers acted with malice or lacked probable cause. The Court thus reversed the circuit court’s denial of summary judgment and rendered a final judgment in defendants’ favor. View "University of Mississippi Medical Center v. Oliver" on Justia Law

The failure of Terry Scott and Damon Fleming to appeal the denial of their respective grievances against the Kentucky State Police (KSP) by the Personnel Cabinet precluded their subsequent action filed in the circuit court. The trial court dismissed most of Scott’s and Fleming’s claims but nevertheless permitted the case to go forward. After a trial, the court held that Scott and Fleming had met their burden of showing a prima facie case of an equal protection violation, entitling them to equitable relief. The court of appeals affirmed, thus rejecting KSP’s argument that Scott and Fleming had failed to exhaust their administrative remedies. The Supreme Court reversed, holding that Scott’s and Fleming’s failure to exhaust administrative remedies barred their direct action in the circuit court. View "Kentucky State Police v. Scott" on Justia Law

Kolton deposited money into an interest-bearing bank account in Illinois. Years passed without activity in the account, so the bank transferred Kolton’s money to the state as the Disposition of Unclaimed Property Act requires. The Act is not an escheat statute; it gives Illinois custody, not ownership, of “presumed abandoned” property. Most such property gets invested, with any income that accrues earmarked for Illinois’s pensioners. Owners may file a claim for return of their property, but the Act limits the Treasurer to returning the amount received into custody. Kolton brought a purported class action under 42 U.S.C. 1983, claiming violation of the Takings Clause, which protects the time value of money just as much as it does money itself. The judge dismissed for want of subject-matter jurisdiction, stating that under the Supreme Court’s “Williamson” holding, a plaintiff usually must try to obtain compensation under state law before litigating a takings suit. Kolton filed neither a claim with the Treasurer nor a lawsuit in state court seeking just compensation. The Seventh Circuit vacated, noting that Section 1983 does not create a cause of action against the state and the Treasurer, personally, did not deprive Kolton of his money. Williamson was not concerned with jurisdiction. View "Kolton v. Frerichs" on Justia Law

The Supreme Court affirmed the circuit court judgments denying two employers’ requests for permanent writs of mandamus against the Missouri Commission on Human Rights (MCHR). The circuit court rejected Employers’ arguments that the MCHR was required to first determine whether Employers’ employees’ complaints of discrimination were timely filed with the MCHR before the MCHR had authority to issue the employees a right-to-sue letter. The Supreme Court held (1) Mo. Rev. Stat. 213.111.1 requires the MCHR to issue a right-to-sue letter and terminate all proceedings related to a complaint if 180 days have elapsed and the employee has made written request for a right-to-sue letter; and (2) because that is what occurred in both of these cases, the MCHR was required to issue the right-to-sue letters, and the circuit court properly refused to issue writs directing the MCHR to perform an act the MHRA prohibits. View "State ex rel. Tivol Plaza, Inc. v. Missouri Commission on Human Rights" on Justia Law

Vanderklok wanted to fly from Philadelphia to Miami, to run a half-marathon. In his carry-on luggage, he had a heart monitor and watch stored inside a piece of PVC pipe, capped on both ends. During screening at the airport security checkpoint, the pipe and electronics prompted secondary screening, supervised by Transportation Security Administration (TSA) employee Kieser. According to Vanderklok, Kieser was disrespectful, so Vanderklok stated an intent to file a complaint against him. Vanderklok claims that Kieser, in retaliation, called the Philadelphia police and falsely reported that Vanderklok had threatened to bring a bomb to the airport. Vanderklok was arrested. He was acquitted because Kieser’s testimony about Vanderklok’s behavior did not match airport surveillance footage. Vanderklok sued. The district court concluded that Kieser lacked qualified immunity as to Vanderklok’s First Amendment claim and that a reasonable jury could find in Vanderklok’s favor as to his Fourth Amendment claim. The Third Circuit vacated. Because Kieser sought and was denied summary judgment on the merits of Vanderklok’s Fourth Amendment claim, rather than on the basis of qualified immunity, that claim cannot be reviewed on interlocutory appeal. The court concluded that no First Amendment claim against a TSA employee for retaliatory prosecution even exists in the context of airport security screenings. View "Vanderklok v. United States" on Justia Law

Plaintiffs, African-Americans, worked for Union Pacific as “Signal Helpers,” an entry‐level job. After a probationary period, both became eligible for promotion. Union Pacific did not respond to their requests to take a required test, then eliminated the Signal Helper position in their zones. Both were terminated. They filed charges with the EEOC. After receiving notification from the EEOC, Union Pacific provided some information but failed to respond to a request for company-wide information, despite issuance of a subpoena. The EEOC issued right‐to‐sue letters, 42 U.S.C. 2000e‐5(f)(1). Plaintiffs sued. The district court granted Union Pacific summary judgment. The Seventh Circuit affirmed. While that action was pending, the EEOC issued Union Pacific a second request for information, served a second subpoena, and brought an enforcement action. The district court denied Union Pacific’s motion to dismiss, rejecting its arguments that the EEOC lost its investigatory authority either after the issuance of a right to sue notice or when Union Pacific obtained a judgment. The Seventh Circuit affirmed, noting a split in the Circuits. Given the EEOC’s broad role in preventing employment discrimination, including its independent authority to investigate charges of discrimination, especially at a company‐wide level, neither the issuance of a right‐to‐sue letter nor the entry of judgment in a lawsuit brought by individuals bars the EEOC from continuing its own investigation. View "Equal Employment Opportunity Commission v. Union Pacific Railroad Co." on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing this action brought by the Board of Commissioners of Union County (Union County) seeking a declaratory judgment and an injunction against the Commissioner of the Indiana Department of Transportation and the Department itself (collectively, INDOT). In the action, Union County alleged that INDOT was negligent in its highway repair efforts, causing damage to the septic systems of three landowners in Union County. The trial court granted INDOT's motion to dismiss, concluding that Union County did not have standing to sue INDOT for injury done to its residents. The Supreme Court affirmed, holding that the trial court did not err in dismissing the action because Union County failed to plead any viable theory of standing to support its alleged cause of action. View "Board of Commissioners of Union County v. McGuinness" on Justia Law

In 2011, Plaintiffs, former arbitrators for the Illinois Workers’ Compensation Commission, brought a due process action challenging the implementation of a workers’ compensation reform statute that terminated their six‐year appointments under prior law. The district court granted summary judgment for defendants. The Seventh Circuit affirmed, concluding that plaintiffs failed to demonstrate a clearly established right that was violated. While that suit was pending, the Illinois governor declined to reappoint Plaintiffs, which ended their employment. Two years later, Plaintiffs filed suit against the governor and his advisors, alleging retaliation for filing the prior suit and that the retaliation violated the First Amendment. The district court dismissed plaintiffs’ First Amendment claims, holding that the Due Process Suit was not protected speech. The Seventh Circuit affirmed, declining decide whether the Due Process Suit was speech on a matter of public concern as is required for a government employee to show retaliation in violation of the First Amendment. Plaintiffs’ claims fail because Plaintiffs were policymakers who could be not reappointed for engaging in “speech on a matter of public concern in a manner that is critical of superiors or their stated policies.” View "Hagan v. Quinn" on Justia Law

When a state fails to protect a foster child from harm, the foster child can sue the state under the special-relationship doctrine, pursuant to 42 U.S.C. 1983. The special-relationship doctrine provides an exception to the general rule that states aren’t liable for harm caused by private actors. This case is about the geographical reach of the special-relationship doctrine: whether the special relationship (and its accompanying duty to protect)—crosses state lines. James Dahn, a foster child, sued two Colorado social workers responsible for investigating reports that he was being abused, along with others involved with his adoption. Dahn had been in Oklahoma’s custody until, with Oklahoma’s approval, a Colorado-based private adoption agency placed him for adoption with a foster father in Colorado. The foster father physically abused Dahn before and after adopting him. The private adoption agency was responsible for monitoring Dahn’s placement. Together with Colorado, it recommended approval of his adoption by the abusive foster father. Dahn eventually escaped his abusive foster father by running away. Dahn then sued the private adoption agency, its employees, and the Colorado caseworkers who were assigned to investigate reports of abuse from officials at Dahn’s public school. The district court dismissed all of Dahn’s claims except a section 1983 claim against the two Colorado caseworkers and two state-law claims against the agency and its employees, concluding the special-relationship doctrine allowed Dahn to move forward with the 1983 claim, and it exercised supplemental jurisdiction over the remaining state-law claims. The Colorado caseworkers appealed. Though the Tenth Circuit condemned their efforts to protect the vulnerable child, the Court concluded, under the controlling precedents, that the Colorado caseworkers were entitled to qualified immunity, and reversed. View "Dahn v. Amedei" on Justia Law

The notice of termination itself constitutes an adverse employment action, even when the employer later rescinds the termination. The Second Circuit held that plaintiff's notice of termination in this case was itself an adverse employment action, despite its later revocation; likewise, the court saw no reason to construe plaintiff's Family Medical Leave Act (FMLA) claim differently from her Title VII claim with respect to whether the rescission of a notice of termination given to a pregnant employee establishes as a matter of law that the notice may not constitute an adverse employment action; the facts alleged were insufficient to establish constructive discharge nor a hostile work environment; plaintiff's retaliation claim was properly dismissed; and because plaintiff did state a plausible claim of discriminatory termination, and interference with her FMLA rights, the district court should reconsider on remand its decision to decline to exercise supplemental jurisdiction over the state and city law claims. Accordingly, the court vacated in part and remanded, and affirmed in all other respects. View "Shultz v. Shearith" on Justia Law