Justia Civil Rights Opinion Summaries

Plaintiff filed suit challenging South Carolina's decision to terminate PPSAT's provider agreement because it offers abortion services. At issue was whether, and on what basis, the Medicaid Act's free-choice-of-provider provision affords a private right of action to challenge a state’s exclusion of a healthcare provider from its Medicaid roster.The Fourth Circuit affirmed the district court's grant of a preliminary injunction in favor of plaintiff and held that Congress's intent to create an individual right enforceable under 42 U.S.C. 1983 in the free-choice-provider provision is unambiguous. The court also held that a plain-language reading of the provision's mandate—that states "must" furnish Medicaid recipients the right to choose among providers "qualified to perform the service or services required"—bars states from excluding providers for reasons unrelated to professional competency. Because the individual plaintiff in this case has a private right of action to challenge South Carolina's denial of her right to the qualified and willing family-planning provider of her choice, the court agreed with the district court that she has demonstrated a substantial likelihood of success on her free-choice-of-provider claim. Furthermore, the district court did not abuse its discretion in enjoining South Carolina from terminating PPSAT's provider agreement; it was clear that plaintiff would suffer irreparable harm in the absence of a preliminary injunction; and the remaining preliminary injunction factors were satisfied. View "Planned Parenthood South Atlantic v. Baker" on Justia Law

Stewart sustained serious injuries upon crashing his car while driving under the influence. Although Stewart does not remember his time at the hospital he signed a form consenting to treatment. An emergency room doctor treated Stewart and in doing so ordered a blood draw, which confirmed that he had been drinking. The police requested and received the blood test results from the hospital’s medical staff. Stewart later sued both officers under 42 U.S.C. 1983 for violating the Fourth Amendment by obtaining his test results without a warrant and the hospital’s medical staff for violating the Health Insurance Portability and Accountability Act by disclosing the results. The Seventh Circuit affirmed summary judgment for the defendants. Indiana law requires medical staff who test a person’s blood “for diagnostic purposes” to “disclose the results of the test to a law enforcement officer who requests the … results as a part of a criminal investigation” regardless of whether the person has “consented to or otherwise authorized their release.” HIPAA does not confer individual enforcement rights—express or implied. The police officers did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. View "Stewart v. Parkview Hospital" on Justia Law

The Ninth Circuit affirmed the district court's grant of a preliminary injunction barring enforcement in several states of final federal agency rules that exempt employers with religious and moral objections from the Affordable Care Act's (ACA) requirement that group health plans cover contraceptive care without cost sharing. As a preliminary matter, the panel held that the plaintiff states had Article III standing to sue and that the appeal was not moot.The panel held that the district court did not abuse its discretion by concluding that the plaintiff states were likely to succeed on the merits of their Administrative Procedure Act (APA) claim or, at the very least, raised serious questions going to the merits. At the preliminary injunction stage, the panel held that the evidence was sufficient to hold that providing free contraceptive services was a core purpose of the Women's Health Amendment and that nothing in the statute permitted the agencies to determine exemptions from the requirement. Therefore, given the text, purpose, and history of the Women's Health Amendment, the district court did not err in concluding that the agencies likely lacked statutory authority under the ACA to issue the final rules.The panel also held that, regardless of the question of the agencies' authority under the Religious Freedom Restoration Act, the accommodation process likely did not substantially burden the exercise of religion. Furthermore, because appellants likely failed to demonstrate a substantial burden on religious exercise, there was no need to address whether the government had shown a compelling interest or whether it has adopted the least restrictive means of advancing that interest. Finally, the panel held that the district court did not abuse its discretion by concluding that the states were likely to suffer irreparable harm absent an injunction, and that the balance of equities tipped sharply in favor of the plaintiff states and that the public interest tipped in favor of granting the preliminary injunction. View "California v. The Little Sisters of the Poor" on Justia Law

Minton, a transgender man diagnosed with gender dysphoria, sued under the Unruh Civil Rights Act, Civil Code 51(b), which guarantees “full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind.” Minton’s physician, Dr. Dawson, scheduled Minton's hysterectomy at Mercy, which is part of Dignity Health. Minton told a Mercy nurse that he is transgender. The following day, Mercy notified Dawson that the procedure was canceled. Mercy’s president, Ivie, informed Dawson that she would “never” be allowed to perform Minton's hysterectomy at Mercy because it was “part of a course of treatment for gender dysphoria, as opposed to any other medical diagnosis.” At Ivie's suggestion, Dawson was able to get emergency admitting privileges at Methodist Hospital, a non-Catholic Dignity hospital about 30 minutes away. Dawson performed Minton’s hysterectomy at Methodist three days later. Dignity argued that as a Catholic hospital, Mercy is bound to follow its facially neutral “Ethical and Religious Directives for Catholic Health Care Services” issued by the U.S. Conference of Catholic Bishops, which prohibit direct sterilization and require that bodily and functional integrity be preserved. The court of appeal reversed the dismissal of Minton’s complaint. Without determining the right of Dignity to provide its services in such cases at alternative facilities, the complaint alleges that Dignity initially failed to do so and that the subsequent rectification of its denial, while likely mitigating plaintiff’s damages, did not extinguish his discrimination claim. View "Minton v. Dignity Health" on Justia Law

The Department of Justice filed suit against the State of Florida, seeking declaratory and injunctive relief under Title II of the Americans with Disabilities Act (ADA) and 28 C.F.R. 35.130(d). The Department alleged that Florida was failing to meet its obligations under Title II by unnecessarily institutionalizing hundreds of children with disabilities in nursing facilities. The Department also alleged that Florida's Medicaid policies and practices placed other children who have "medically complex" conditions, or who are "medically fragile," at risk of unnecessary institutionalization.The Eleventh Circuit held that the Attorney General has a cause of action to enforce Title II of the ADA. The court held that when Congress chose to designate the "remedies, procedures, and rights" in section 505 of the Rehabilitation Act, which in turn adopted Title VI, as the enforcement provision for Title II of the ADA, Congress created a system of federal enforcement. The court also held that the express statutory language in Title II adopts federal statutes that use a remedial structure based on investigation of complaints, compliance reviews, negotiation to achieve voluntary compliance, and ultimately enforcement through "any other means authorized by law" in the event of noncompliance. Therefore, courts have routinely concluded that Congress's decision to utilize the same enforcement mechanism for Title II as the Rehabilitation Act, and therefore Title VI, demonstrates that the Attorney General has the authority to act "by any other means authorized by law" to enforce Title II, including initiating a civil action. Accordingly, the court reversed the district court's judgment and remanded. View "United States v. State of Florida" on Justia Law

The Supreme Court answered questions certified to it by holding that a plasma collection center is a "public facility" under Tex. Hum. Res. Code (THRC) 121.002(5) and that a plasma collection center may reject a person with a disability without committing impermissible discrimination under THRC 121.003(a) when two conditions are met.Appellants were not allowed to donate plasma to CSL Plasma, Inc., a plasma collection center, and filed suit, alleging unlawful discrimination on the basis of disability. The district court granted summary judgment for CSL, concluding that the ADA did not apply and that a plasma collection center could not be considered a public facility under the THRC. The Fifth Circuit Court of Appeals certified questions to the Supreme Court as to whether the THRC governs plasma collection centers. The Supreme Court answered that a plasma collection center is a public facility under section 121.002(5) and that the center may reject a person with a disability without discriminating when (1) the center's rejection does not meet the THRC's definition of "discrimination" or satisfies an exception to the definition of "discrimination," and (2) the center establishes that allowing a person with a disability use of the public facility would pose a threat to the health or safety of others. View "Silguero v. CSL Plasma, Inc." on Justia Law

Plaintiff Elizabeth Lawson alleged she incurred damages as the result of an emergency room nurse informing a police officer that she was intoxicated, had driven to the hospital, and was intending to drive home. The trial court granted defendant Central Vermont Medical Center (CVMC) summary judgment based on its determination that nothing in the record supported an inference that the nurse’s disclosure of the information was for any reason other than her good-faith concern for plaintiff’s and the public’s safety. In this opinion, the Vermont Supreme Court recognized a common-law private right of action for damages based on a medical provider’s unjustified disclosure to third persons of information obtained during treatment. Like the trial court, however, the Supreme Court concluded CVMC was entitled to judgment as a matter of law because, viewing the material facts most favorably to plaintiff and applying the relevant law adopted here, no reasonable factfinder could have determined the disclosure was for any purpose other than to mitigate the threat of imminent and serious harm to plaintiff and the public. Accordingly, the Supreme Court affirmed the trial court’s judgment. View "Lawson v. Central Vermont Medical Center" on Justia Law

Kentucky’s “Ultrasound Informed Consent Act,” KRS 311.727, directs a doctor, before performing an abortion, to perform an ultrasound; display the ultrasound images for the patient; and explain, in the doctor’s own words, what is being depicted. There is no requirement that the patient view the images or listen to the description. The doctor also must auscultate the fetal heartbeat but may turn off the volume if the patient requests. The Act does not penalize a doctor if the patient requested that the heartbeat sound be turned off or chose not to look at the ultrasound images or if the doctor makes any other statement, including advising a patient that she need not listen to or view the disclosures, or that the patient should have an abortion. A doctor need not make any disclosures if an abortion is medically necessary or in a medical emergency. Doctors brought a First Amendment challenge. The district court permanently enjoined enforcement of the Act. The Sixth Circuit reversed, citing the Supreme Court’s 2018 decision, National Institute of Family & Life Advocates, clarifying that no heightened First Amendment scrutiny should apply to abortion-informed-consent statutes. Even though an abortion-informed-consent law compels a doctor’s disclosure of certain information, it should be upheld so long as the disclosure is truthful, non-misleading, and relevant to abortion. View "EMW Women's Surgical Center P.S.C. v. Beshear" on Justia Law

The Supreme Judicial Court affirmed the judgment of a municipal court judge civilly committing M.C. for a period of two months, holding that the record contained sufficient evidence to support M.C.’s involuntary commitment and that M.C. was not denied due process of law despite the hearing being conducted at a hospital rather than at a court house and in the absence of a complete, verbatim transcript.Although M.C. sought to have the civil commitment hearing conducted at a court house, the hearing was held at the psychiatric facility where M.C. had been temporarily committed. At the beginning of the proceeding the court-owned recording equipment malfunctioned, and then two different alternate recording devices were used to record the remainder of the hearing. The Supreme Judicial Court affirmed the judge’s decision to civilly commit M.C., holding that the available transcript provided an adequate basis for appellate review and contained sufficient evidence to support M.C.’s involuntary commitment. View "In re M.C." on Justia Law

Christopher Floeting alleged a Group Health Cooperative employee repeatedly sexually harassed him while he was seeking medical treatment. He sued Group Health for the unwelcome and offensive sexual conduct under the Washington Law Against Discrimination, which made it unlawful for any person or the person's agency or employee to commit an act of discrimination in any place of public accommodation. The trial court dismissed on summary judgment, pursuant to Group Health's argument the employment discrimination standard applied. The Court of Appeals reversed. Group Health argued the Washington Supreme Court should import workplace sexual harassment doctrines into the public accommodations context, thereby limiting its employer liability. Declining to do so, the Supreme Court affirmed the appellate court. View "Floeting v. Grp. Health Coop." on Justia Law