Justia Civil Rights Opinion Summaries

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law

A personal care assistant (PCA) in a Medicaid program was investigated for submitting inaccurate records of services provided. The investigation substantiated the allegations, and a committee within the overseeing agency decided to terminate her from the program. The PCA was notified and informed of her right to appeal. An administrative law judge (ALJ) recommended adopting the committee’s determination, which the agency did. The PCA appealed to the superior court, which affirmed the agency’s decision. The PCA then appealed, raising several issues.The superior court found the PCA’s Open Meetings Act claim untimely and concluded that the Administrative Procedures Act (APA) did not apply because the sanction procedures were interpretations of existing regulations. It also determined that the PCA had no property interest in future reimbursements from the program and that her liberty interest in her reputation was not implicated. The court found substantial evidence supported the agency’s findings and the termination sanction.The Supreme Court of Alaska reviewed the case. It concluded that the PCA’s Open Meetings Act claim was untimely and that the APA did not require the Department to promulgate new regulations for the sanctions committee. The court also found that the PCA had a protected liberty interest in her reputation but determined that she received due process through the hearing before the ALJ. The court held that substantial evidence supported the Department’s findings and that the sanctions imposed were reasonable. The Supreme Court of Alaska affirmed the superior court’s decision upholding the agency’s termination of the PCA. View "Thomason v. State" on Justia Law

Nia Lucas, an African American woman with military service-related disabilities, including PTSD, depression, anxiety, panic attacks, and a traumatic brain injury, sought care at VHC for her pregnancy. Despite her complaints of pre-term contractions and pain, the Labor and Delivery Unit staff did not treat her as prescribed by her doctor. Lucas alleged that she was told her pain was not real and was only in her head. After complaining to VHC staff about racial and disability discrimination, she received a letter terminating her care, and she was subsequently dismissed from a scheduled appointment. Lucas gave birth prematurely and experienced ongoing physical and mental suffering.The United States District Court for the Eastern District of Virginia dismissed Lucas' claims of racial discrimination, disability discrimination, and retaliation under the Affordable Care Act (ACA). The court found that Lucas did not plausibly plead that she was denied treatment because of her disabilities and that her racial discrimination claim was based on a single, isolated statement. The court also concluded that the ACA did not support an independent cause of action for retaliation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Lucas' disability discrimination claim, finding that she did not allege facts connecting her disabilities to the denial of treatment or her termination. However, the court reversed the dismissal of her racial discrimination claim, holding that Lucas plausibly alleged that VHC acted with deliberate indifference to her complaints of racial discrimination. The court also held that the ACA permits retaliation claims, and Lucas plausibly pled a retaliation claim based on the temporal proximity between her complaints and her termination. The case was remanded for further proceedings consistent with this opinion. View "Lucas v. VHC Health" on Justia Law

A man named Johnathon Lerke, who was under a Murphy conservatorship, challenged his confinement in a county jail while awaiting transfer to a state hospital. Murphy conservatorships are for individuals found incompetent to stand trial and deemed a danger to others. Despite being ordered to a state hospital, Lerke was held in county jail for months due to a lack of space at the hospital. He argued that his confinement in jail was unauthorized and violated his rights.The Superior Court initially found Lerke incompetent to stand trial and ordered him to a state hospital for competency restoration. After nearly two years, the hospital reported that Lerke had not regained competence. Subsequently, a Murphy conservatorship was established, requiring his placement in a state hospital. However, due to the unavailability of space, he remained in county jail. Lerke's counsel requested his release or transfer to a local psychiatric hospital, but the court denied the request, stating that he would remain in jail until a state hospital bed became available.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court concluded that no legal authority permitted Lerke’s indefinite detention in county jail pending his transfer to the state hospital. The statutory framework requires conservatees to be placed in treatment facilities that promote their treatment and protect the public, and county jails do not meet these requirements. Although the court found Lerke’s confinement in jail unlawful, it denied habeas relief because he had already been transferred to an authorized treatment facility during the proceedings. The petition for writ of habeas corpus was denied as moot. View "In re Lerke" on Justia Law

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law

The case involves a class action lawsuit filed by transgender women prisoners in Illinois, who allege that the Illinois Department of Corrections (IDOC) has been deliberately indifferent to their gender dysphoria, a serious medical condition. The plaintiffs seek injunctive relief to ensure timely evaluations and treatments, including hormone therapy, gender-affirming surgery, and appropriate support for social transitioning.The United States District Court for the Southern District of Illinois initially issued a preliminary injunction on February 7, 2022, which was intended to address the plaintiffs' claims. The court later issued further injunctions to supplement and modify the terms. However, more than a year and a half after the preliminary injunction was issued, the district court retroactively labeled it as a permanent injunction and issued a final judgment consistent with the February 7, 2022 decision. The defendants appealed several injunctions and a finding of civil contempt by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court's attempt to retroactively transform the preliminary injunction into a permanent one was not authorized. The appellate court held that under the Prison Litigation Reform Act (PLRA), the preliminary injunction issued on February 7, 2022, expired 90 days later, on May 8, 2022. Consequently, the appellate court vacated all existing injunctions and remanded the case for further proceedings consistent with its opinion. The court also dismissed the portion of the appeal challenging the finding of contempt, as the district court had not yet imposed any sanctions, which are necessary to establish appellate jurisdiction. View "Monroe v. Bowman" on Justia Law

Charles Leonhardt, a pretrial detainee at the Big Horn County Jail, suffered from back pain and was eventually diagnosed with two lower back infections after being transported to a hospital. He sued Big Horn County Sheriff Ken Blackburn, Jail Captain Debbie Cook, unnamed detention officers, the Big Horn County Sheriff’s Office, and the Jail, alleging negligence and deliberate indifference under the Fourteenth Amendment.The District Court of Big Horn County granted summary judgment to the defendants on both claims. The court found that Sheriff Blackburn had fulfilled his duty to arrange for medical care by contracting with Midway Medical Clinic, which provided medical services to inmates. The court also determined that the actions of Sheriff Blackburn, Captain Cook, and the detention officers were reasonable and did not proximately cause Mr. Leonhardt’s injuries. Additionally, the court found no evidence of deliberate indifference to Mr. Leonhardt’s medical needs, as the defendants ensured he received timely medical care.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that there was no genuine dispute of material fact regarding the negligence claim, as the defendants acted reasonably and provided Mr. Leonhardt with access to medical care. The court also found no evidence that the defendants were aware of and disregarded an excessive risk to Mr. Leonhardt’s health, thus failing to meet the subjective component of a deliberate indifference claim. Consequently, the court affirmed the summary judgment in favor of the defendants on both the negligence and Fourteenth Amendment deliberate indifference claims. View "Leonhardt v. Big Horn County Sheriff's Office" on Justia Law

The case involves the Hawai‘i Disability Rights Center (HDRC), which represents individuals with developmental disabilities, including children with autism. HDRC alleges that the Hawai‘i Departments of Education (DOE) and Human Services (DHS) unlawfully deny students with autism access to Applied Behavioral Analysis (ABA) therapy during school hours, even when medically necessary. DOE provides ABA services only if deemed educationally relevant, and DHS does not provide ABA services during school hours, even if medically necessary and covered by Medicaid or private insurance.The United States District Court for the District of Hawaii granted summary judgment in favor of DOE and DHS, holding that HDRC's failure to exhaust administrative procedures under the Individuals with Disabilities Education Act (IDEA) was fatal to all its claims, including those under the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, and the Medicaid Act. The court concluded that HDRC, as a protection and advocacy organization, must ensure that parents of its constituents exhaust the IDEA’s administrative process.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that HDRC, as Hawai‘i’s designated protection and advocacy system, can pursue administrative remedies under the IDEA and is therefore bound by the IDEA’s administrative exhaustion requirement for its own claim. However, HDRC need not ensure that parents of individual children with autism exhaust their individual IDEA claims. The court found that HDRC did not exhaust its administrative remedies, and no exceptions to IDEA exhaustion applied.The Ninth Circuit also held that HDRC was not required to exhaust the IDEA’s administrative procedures before bringing its claims under the ADA, Section 504, and the Medicaid Act. The court concluded that HDRC’s non-IDEA claims do not allege the denial of a free appropriate public education (FAPE) and therefore do not require exhaustion under the IDEA. The court affirmed in part, reversed in part, and remanded the case. View "HAWAI'I DISABILITY RIGHTS CRT. V. KISHIMOTO" on Justia Law

A federal inmate, Dustin Rowland, developed a hernia after a pretrial detention fight. A physician deemed the hernia "reducible and stable," recommending non-surgical treatments. Rowland, desiring surgery, utilized the Bureau of Prisons' (BOP) Administrative Remedial Program, which involves a four-step grievance process. His initial requests were denied, but a later appeal led to approval for a surgical consultation. However, Rowland's final appeal was denied for procedural reasons, and he did not correct the deficiency. He eventually received surgery but filed a lawsuit claiming deliberate indifference to his medical needs, seeking damages under Bivens, injunctive relief for post-operative care, and a negligence claim under the Federal Tort Claims Act (FTCA).The United States District Court for the District of Colorado dismissed Rowland's Bivens claim, granted summary judgment against his injunctive relief claim for failure to exhaust administrative remedies, and dismissed the FTCA claim for lack of subject matter jurisdiction due to non-exhaustion. Rowland's motion for reconsideration was also denied.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, noting that Rowland's case presented a new context not covered by previous Bivens cases and that the BOP's Administrative Remedial Program provided an adequate alternative remedy. The court also upheld the summary judgment on the injunctive relief claim, as Rowland failed to exhaust administrative remedies specifically for post-operative care. Lastly, the court affirmed the dismissal of the FTCA claim, emphasizing the jurisdictional requirement of exhausting administrative remedies before filing suit. The court found no abuse of discretion in the district court's denial of Rowland's Rule 60(b) motion for reconsideration. View "Rowland v. Matevousian" on Justia Law

In 2006, an individual was convicted of first-degree sexual abuse and later subjected to civil management under New York's Mental Hygiene Law due to a "mental abnormality." Initially confined, he was released to a strict and intensive supervision and treatment (SIST) program in 2016. In 2019, he violated SIST conditions by tampering with an alcohol monitoring bracelet, leading to his temporary confinement based on a psychologist's evaluation and a probable cause finding by the court.The Supreme Court initially found probable cause to believe he was a "dangerous sex offender requiring confinement" and ordered his detention pending a final hearing. He filed a habeas corpus petition, arguing that the statutory scheme violated procedural due process by not providing an opportunity to be heard at the probable cause stage. The Supreme Court denied the petition, and the Appellate Division converted the proceeding to a declaratory judgment action, ultimately declaring the statute constitutional.The New York Court of Appeals reviewed the case and upheld the lower court's decision. The court held that the statutory scheme under Mental Hygiene Law § 10.11 (d) (4) appropriately balances individual and state interests. It concluded that the statute provides sufficient procedural safeguards, including a prompt judicial probable cause determination and a full hearing within 30 days, to mitigate the risk of erroneous confinement. The court found that the petitioner failed to demonstrate that the statute is unconstitutional either on its face or as applied to him. The order of the Appellate Division was affirmed without costs. View "People ex rel. Neville v Toulon" on Justia Law