Justia Civil Rights Opinion Summaries

Plaintiff, as the personal representative of Curtis Suggs, filed suit against the District, Symbral, and others, under 42 U.S.C. 1983, federal law regulating community residential facilities, and the common law. Suggs died while residing in a group home operated by Symbral, a District contractor. The District appealed the district court's grant of summary judgment to plaintiff on the section 1983 claims and negligence claims, and against Symbral and Defendants Leon and Yvonne Mohammed, as well as appealed the district court's denial of the District's post-trial motion. After reviewing the record and considering the parties' arguments, the court concluded that the district court did not err in entering summary judgment against the District on plaintiff’s section 1983 claim, and the court affirmed that portion of the decision on review. The court reversed the district court’s grant of summary judgment to plaintiff on his negligence and statutory claims, concluding that those claims are barred under D.C. Code 12-309. Because the district court abused its discretion by excluding causation evidence, the court vacated the damages and remand for reconsideration. View "Harvey v. Mohammed" on Justia Law

Plaintiff filed suit challenging the religious exemption in the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 124 Stat. 119, as an unconstitutional establishment of religion. Plaintiff also argued that the Administration’s decision to temporarily suspend enforcement of some of the Act’s requirements for a transitional period deprived him of the equal protection of the laws. The district court granted the government's motion to dismiss and held that plaintiff lacked standing to bring either claim. The court agreed with the district court that plaintiff lacks standing to assert his equal protection claim because nothing in the transitional policy requires him to buy insurance. In this case, plaintiff's inability to maintain his old plan was the independent choice of his insurer. The court concluded, however, that plaintiff did have standing to bring his Establishment Clause challenge. On the merits, the court concluded that the claim fails because the qualifications for exemption are not drawn on sectarian lines. Rather, they simply sort out which faiths have a proven track record of adequately meeting the statutory goals. Moreover, the exemption promotes the Establishment Clause’s concerns by ensuring that those without religious objections do not bear the financial risk and price of care for those who exempt themselves from the tax. As configured by this specific statutory framework, that is an objective, non-sectarian basis for cabining the exemption’s reach. View "Cutler v. HHS" on Justia Law

Plaintiffs, a group of religious non-profit organizations affiliated with the Roman Catholic Archdiocese, filed suit challenging regulations promulgated under the Patient Protection and Affordable Care Act of 2010, Pub. L. No. 111-148, 124 Stat. 119. The district court concluded that regulations promulgated under the Act that allow religious non-profit employers to opt out of providing contraceptive coverage themselves violate these religious employers’ rights under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The court concluded, however, that the challenged accommodation for religious objectors relieves, rather than imposes, any substantial burden on plaintiffs’ religious exercise, and thus does not violate the Religious Freedom Restoration Act. Accordingly, the court reversed the district court's judgment. View "Catholic Health Care Sys. v. Burwell" on Justia Law

Temporary civil commitment at New Jersey psychiatric hospitals is subject to regular review; patients have the right to counsel, to be present at the hearing, to present evidence, and to cross-examine witnesses. In a challenge to the state’s “Rennie process” for forcible medication, the Third Circuit held, in 1984, that civilly committed psychiatric patients “have a qualified constitutional right to refuse antipsychotic medication” in nonemergency situations and the process accommodated that right consistent with the Due Process Clause. A 2010 challenge alleged that the Rennie process violated the Constitution, the Americans With Disabilities Act, and the Rehabilitation Act, and demanded that the state “provide patients who refuse the non-emergency administration of psychotropic medication with meaningful due process protections—including legal counsel, notice and a hearing before a judicial decision-maker.” The state replaced the Rennie process with policies for forcible treatment in emergencies (AB 5:04A), which were not challenged, and nonemergent situations (AB 5:04B). The nonemergency policy permits longer-term forcible medication of a patient, involuntarily committed, who, as a result of a diagnosed mental illness, poses a substantial risk of serious harm to self, others, or property “within the reasonably foreseeable future” if psychotropic medication is not administered. Patients who satisfy the substantive requirements may be forcibly medicated only pursuant to procedures that stop short of prior judicial review. The Third Circuit affirmed that AB 5:04B is valid, except as to patients who have been not to require continued commitment but who remain in custody pending transfer. View "Disability Rights N.J., Inc. v. Comm'r N.J. Dep't of Human Servs." on Justia Law

Plaintiffs, the owner of a pharmacy and two individual pharmacists who have religious objections to delivering emergency contraceptives, challenged the Commission's rules requiring the timely delivery of all prescription medications by licensed pharmacies. The rules permit pharmacies to deny delivery for certain business reasons, such as fraudulent prescriptions or a customer’s inability to pay; permit a religiously objecting individual pharmacist to deny delivery, so long as another pharmacist working for the pharmacy provides timely delivery; but, unless an enumerated exemption applies, the rules require a pharmacy to deliver all prescription medications, even if the owner of the pharmacy has a religious objection. The district court held that the rules violate the Free Exercise and Equal Protection Clauses, and the court permanently enjoined enforcement of the rules. The court reversed, concluding that the rules are neutral and generally applicable and that the rules rationally further the State’s interest in patient safety. Further concluding that the rules do not infringe on a fundamental right, the court reversed the judgment. View "Stormans, Inc. v.Wiesman" on Justia Law

Plaintiffs, the owner of a pharmacy and two individual pharmacists who have religious objections to delivering emergency contraceptives, challenged the Commission's rules requiring the timely delivery of all prescription medications by licensed pharmacies. The rules permit pharmacies to deny delivery for certain business reasons, such as fraudulent prescriptions or a customer’s inability to pay; permit a religiously objecting individual pharmacist to deny delivery, so long as another pharmacist working for the pharmacy provides timely delivery; but, unless an enumerated exemption applies, the rules require a pharmacy to deliver all prescription medications, even if the owner of the pharmacy has a religious objection. The district court held that the rules violate the Free Exercise and Equal Protection Clauses, and the court permanently enjoined enforcement of the rules. The court reversed, concluding that the rules are neutral and generally applicable and that the rules rationally further the State’s interest in patient safety. Further concluding that the rules do not infringe on a fundamental right, the court reversed the judgment. View "Stormans, Inc. v.Wiesman" on Justia Law

Plaintiffs, religious organizations, filed suit under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb to 2000bb-4, challenging a requirement that they either offer their employees health insurance that covers certain contraceptive services or submit a form or notification declaring their religious opposition to that coverage. The district court enjoined the government from enforcing the requirement. The court concluded that the acts plaintiffs are required to perform do not involve providing or facilitating access to contraceptives, and plaintiffs have no right under RFRA to challenge the independent conduct of third parties. Because plaintiffs have not shown that the regulations substantially burden their religious exercise or, in University of Dallas, have not demonstrated a substantial likelihood of doing so, the court need not reach the strict-scrutiny prong or the other requirements for an injunction. Accordingly, the court reversed the judgment of the district court. View "East Texas Baptist Univ. v. Burwell" on Justia Law

Plaintiff filed suit, alleging that the DOH violated the Medicaid Act, 42 U.S.C. 1396 et seq., when it determined that guardianship fees approved by a state court could not be deducted from plaintiff’s Medicaid-required contributions to her nursing home costs. The district court dismissed the complaint based on lack of standing or, in the alternative, plaintiff failed to state a claim upon which relief could be granted. The court concluded that plaintiff did have standing where her injury was incurring debts beyond her means to the nursing facility or to her guardian. The court concluded, however, that plaintiff's claim failed on the merits because DOH was not under any unambiguous and binding obligation to allow deduction of the guardianship fees from plaintiff's net available monthly income. Accordingly, the court affirmed the judgment. View "Backer v. Shah" on Justia Law

M.K.S., who had a long history of treatment for schizophrenia and other mental health illnesses, was regularly subject to community commitments and hospitalizations. In 2013, M.K.S. stipulated to a six-month community commitment. Before the commitment was set to expire, the State filed a renewed petition for commitment. After a commitment hearing, the district court found that M.K.S. posed a danger to herself based on her recent suicidal threats and that a commitment to the Montana State Hospital was necessary to guarantee her safety. The Supreme Court affirmed based on the plain error doctrine, holding that because of a professional person’s failure to file a statutorily-required written report in M.K.S.’s civil commitment proceeding, M.K.S.’s right of due process was implicated in the proceedings. However, M.K.S. failed to demonstrate that the absence of a written report substantially impacted this right in a manner that would leave unsettled the fundamental fairness of the proceedings, compromise the integrity of the judicial process, or create a manifest miscarriage of justice. View "In re M.K.S." on Justia Law

Appellant, an intellectually disabled man, was charged with sexual battery and, in 2004, was involuntarily admitted to nonsecure residential services under Fla. Stat. 393.11. In 2011, Appellant filed suit under 42 U.S.C. 1983 and 1988 in federal district court against the Director of the Agency for Persons with Disabilities, seeking a declaratory judgment that the state’s statutory scheme for involuntarily admitting intellectually disabled persons to residential services violates the due process clause of the Fourteenth Amendment because it does not provide people who have been involuntarily admitted to nonsecure residential services with periodic review of their continued confinement by someone with authority to release them. The district court granted the Agency’s motion for summary judgment, concluding that section 393.11 is constitutional. The Eleventh Circuit Court of Appeal certified questions of law to the Supreme Court concerning the issue. The Supreme Court answered (1) “support plan” review under section 393.0651 does not require the Agency to consider the propriety of a continued involuntary admission to residential services order entered under section 393.11; and (2) the Agency is not statutorily required to petition the circuit court for the release from an involuntary admission order in cases where the Agency determines that the circumstances that led to the initial admission have changed. View "J.R. v. Palmer" on Justia Law