Justia Civil Rights Opinion Summaries

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

In 1997, after his third DWI arrest, Scheffler’s driving privileges were cancelled. Scheffler successfully completed a one-year abstinence-only program, and in 1998, was issued a driver’s license with the restriction that he abstain from use of alcohol. After a 1999 cancellation of his license, Scheffler was completed a three-year rehabilitation program and received a restricted license in 2002. In 2010, Scheffler was arrested for DWI and, to obtain a new restricted license, had to either complete a six-year rehabilitation program or submit to an Ignition Interlock Program. Scheffler sued, claiming Americans with Disability Act violations based on perceived alcoholism. The district court dismissed. The Eighth Circuit affirmed. ADA defines a disabled person as having a physical or mental impairment that substantially limits one or more major life activities, having a record of such an impairment, or being regarded as having such an impairment, 42 U.S.C. 12102(1). Alcoholism may qualify when it limits a major life activity. Scheffler did not claim to actually be an alcoholic or that alcoholism limits a major life activity. DWI does not, alone, establish that he is an alcoholic. There was no allegation that Scheffler has ever been diagnosed as an alcoholic or that Scheffler suffers from a substantial limitation to a major life activity. View "Scheffler v. Dohman" on Justia Law

Concerned by Plaintiff’s “increasingly threatening” Facebook posts, two Marine veterans who had served with Plaintiff contacted the FBI. After interviewing Plaintiff, two FBI agents consulted with Michael Campbell, a local mental health evaluator, as to whether they should detain Plaintiff for a mental health evaluation. Campbell recommended that Plaintiff be detained. After interviewing Plaintiff, Campbell petitioned for and received a temporary detention order from a magistrate judge. Plaintiff was taken to a hospital, where he was involuntarily admitted for treatment for seven days. Following his release, Plaintiff filed suit under 42 U.S.C. 1983, seeking damages and injunctive relief against Campbell for violating his Fourth Amendment and First Amendment rights. The district court granted summary judgment to Campbell on the basis of qualified immunity. The Fourth Circuit affirmed, holding (1) Campbell did not violate Plaintiff’s Fourth Amendment rights based on existing precedent; (2) Plaintiff did not make out a First Amendment violation; and (3) injunctive relief was not appropriate on this record. View "Raub v. Campbell" on Justia Law

Nurse Dalton was terminated from her supervisory position at the ManorCare skilled nursing facility. Dalton alleged interference with her statutory rights under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601, and discrimination based on her Chronic Kidney Disease disability in violation of the Iowa Civil Rights Act, Iowa Code Ch. 216, and the Americans with Disabilities Act, 42 U.S.C. 12101. ManorCare claimed that nurses that Dalton supervised had complained about her job performance and that Dalton had received a Third/Final Written Warning for violating Major/Type B Work Rules, citing inappropriate negative comments about her work at the nurses’ station, where patients could overhear; failure to notify staff members she had cancelled a meeting; and taking an extended lunch break and failing to attend patient care conferences. There were also problems with attendance and late reports. Dalton understood that any further performance-related issue could result in termination. The district court dismissed all claims. The Eighth Circuit affirmed. Dalton’s termination was the end of an on-going, unrelated disciplinary process. View "Dalton v. Manor Care of West Des Moines, LLC" on Justia Law

Petitioners were residents of a state hospital and involuntary participants in the Kansas Sexual Predator Treatment program at the hospital. Petitioners filed petitions for habeas corpus relief challenging the Program’s implementation of a new administrative grievance procedure. The district court summarily denied the petitions and assessed the costs of filing the action against each petitioner. The Court of Appeals affirmed the dismissal of the petitions but reversed the assignment of costs to Petitioners. The Supreme Court affirmed, holding that, whenever a person civilly committed files a habeas petition relating to his or her commitment, the costs shall be assessed to the counties in which the petitioners were determined to be sexually violent predators. View "Merryfield v. Sullivan" on Justia Law

The State of Tennessee operated the Arlington Developmental Center, an institutional home for people with mental disabilities. In 1992, the United States sued Tennessee under the Civil Rights of Institutionalized Persons Act alleging that, among other things, Tennessee had failed to provide Arlington’s residents with adequate food, medical care, supervision, and shelter. After a trial on the merits, the district court found that Arlington’s conditions violated the due-process rights of its residents. The court ordered the State to submit a plan to improve conditions there. Since then, People First of Tennessee has presented 19 applications for attorneys’ fees to the district court. Tennessee consented to pay every dollar of fees requested in the first 18 applications filed by intervenors-appellees People First of Tennessee (a total of about $3.6 million, including over $400,000 for the period at issue here). But the State objected to People First’s 19th application, which for the most part sought fees for a contempt motion that the district court had stricken from the docket and that People First never renewed. The 19th application also sought fees for hours that People First’s attorneys had chosen to spend monitoring the State’s compliance with the consent decree, even though the State had already paid $10.6 million in fees to a monitor whom the court had appointed for that same purpose. Despite those circumstances, the district court awarded People First $557,711.37 pursuant to the application, holding that People First had been a “prevailing party” with respect to its contempt motion. The State appealed the district court's award. After review, the Sixth Circuit disagreed with the district court's judgment, reversed and remanded. View "United States v. Tennessee" on Justia Law