Justia Civil Rights Opinion Summaries

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. As a condition of receiving federal funds, Congress required states to limit eligibility for federal benefits, such as Medicaid, to citizens and certain aliens. Plaintiffs filed suit claiming that Basic Health Hawai'i violated the Equal Protection Clause of the Fourteenth Amendment because it provided less health coverage to nonimmigrant aliens residing in Hawai'i (COFA Residents) than the health coverage that Hawai'i provided to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid. The court concluded that Congress has plenary power to regulate immigration and the conditions on which aliens remain in the United States, and Congress has authorized states to do exactly what Hawai'i had done here - determine the eligibility for, and terms of, state benefits for aliens in a narrow third category, with regard to whom Congress expressly gave states limited discretion. Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents. Accordingly, the court vacated the district court's grant of a preliminary injunction preventing Hawai'i from reducing state-paid health benefits for COFA Residents because Hawai'i is not obligated to backfill the loss of federal funds with state funds and its decision not to do so was subject to rational-basis review. View "Korab v. Fink" on Justia Law

Planned Parenthood filed suit against the State for declaratory judgment and to enjoin provisions of 2013 Texas House Bill No. 2 (H.B. 2). H.B. 2 pertains to the regulation of surgical abortions and abortion-inducing drugs. Two provisions of H.B.2 were at issue: first, the requirement that a physician performing or inducing an abortion have admitting privileges at a hospital no more than thirty miles from the location where the abortion is provided; and second, the limitations on the use of abortion-inducing drugs to a protocol authorized by the FDA. The district court held that parts of both provisions were unconstitutional and granted, in substantial part, the requested injunctive relief. A motions panel of this court granted a stay pending appeal, and the Supreme Court upheld the stay. As a preliminary matter, the court concluded that the physician-plaintiffs had standing on behalf of their patients, as well as standing to assert their own rights. The court concluded that the district court applied the wrong legal standards under rational basis review and erred in finding that the admitting-privileges requirement amounts to an undue burden for a large fraction of women that it affects. The court also concluded that the district court erred in holding that H.B. 2's rejection of the off-label protocol from fifty to sixty-three days LMP (last menstrual period) facially imposes an undue burden on the abortion rights of certain women. Accordingly, the court reversed and rendered judgment for the State, except that the admitting privileges requirement may not be enforced against abortion providers who timely applied for admitting privileges under the statute but are awaiting a response from the hospital. View "Planned Parenthood, et al. v. Abbott, et al." on Justia Law

In 2008, Shields, an Illinois prisoner was lifting weights and ruptured the pectoralis tendon in his left shoulder. Although he received some medical attention, he did not receive the prompt surgery needed for effective treatment. Due to oversights and delays by those responsible for his medical care, too much time passed for surgery to do any good. He has serious and permanent impairment that could have been avoided. After his release from prison, Shields filed suit under 42 U.S.C. 1983, alleging that several defendants were deliberately indifferent to his serious medical needs and violated his rights under the Eighth Amendment to the Constitution. The district court granted summary judgment in favor of the defendants. The Seventh Circuit affirmed, reasoning that Shields was the victim not of any one person’s deliberate indifference, but of a system of medical care that diffused responsibility for his care to the point that no single individual was responsible for seeing that he timely received the care he needed. As a result, no one person can be held liable for any constitutional violation. Shields’ efforts to rely on state medical malpractice law against certain private defendants also failed. View "Shields v. IL Dep't of Corrs." on Justia Law

Plaintiffs filed suit against the Secretary of Health and Human Services (HHS) and the Commissioner of the Social Security Administration (SSA) raising constitutional challenges to the Patient Protection and Affordable Care Act (ACA), Pub. L. No 111-148, 124 Stat. 119; raising statutory challenges to actions of HHS and the Commissioner relating to the implementation of the ACA and prior Medical legislation; and attacking the failure of defendants to render an "accounting" that would alter the American people to the insolvency towards which Medicare and Social Security programs were heading. On appeal, plaintiffs challenged the district court's dismissal of their claims. The court rejected plaintiffs' claims that 26 U.S.C. 5000A, which was sustained as a valid exercise of the taxing power, violated the Fifth Amendment's prohibition of the taking of private property without just compensation and violated the origination clause. The court concluded that plaintiffs' substantive attack on the Social Security Program Operations Manual System (POMS) provisions was clearly foreclosed by its decision in Hall v. Sebelius, holding that the statutory text establishing Medicare Part A precludes any option not to be entitled to benefits. The court rejected plaintiffs' second statutory claim attacking an interim final rule. Finally, the court concluded that plaintiffs failed to provide a legal argument for their claims against the Commissioner and Secretary, and therefore, the court lacked jurisdiction over plaintiffs' claim to an "accounting." Accordingly, the court affirmed the judgment of the district court. View "Assoc. Amer. Physicians, et al. v. Sebelius, et al." on Justia Law

In 2006 Buechel was incarcerated at FCI-Greenville federal correctional institution, where he contracted Methicillin-Resistant Staphylococcus aureus, (MRSA), a staph infection resistant to certain antibiotics. Buechel was hospitalized for more than 40 days and was left with serious and permanent damage to his heart and lungs. He sued under the Federal Tort Claims Act, 28 U.S.C. 1346(b), alleging that his injuries were caused by the prison’s negligence. The district court issued a pretrial order that limited Buechel’s negligence claim to a theory that he contracted MRSA from contact with one fellow inmate, in the prison laundry in July 2006, or more generally as a result of sloppy procedures in handling infected prison laundry. After a bench trial, the court held that Buechel had not proved that he contracted MRSA from either the inmate or the laundry procedures and entered judgment in favor of the government. The Seventh Circuit affirmed the finding that Buechel failed to prove that he contracted MRSA from the inmate or as a result of inadequate laundry procedures, but vacated and remanded for consideration of a broader theory. Buechel’s administrative claim and complaint presented a broader theory that the prison was negligent more generally in its failure to adhere to its MRSA-containment policies.View "Buechel v. United States" on Justia Law

James, a 60-year old with a lengthy criminal record and a history of psychiatric hospitalizations, has been held involuntarily at the Chester Mental Health Center since 2003, under successive involuntary commitment orders entered after he had reached the mandatory parole date on his criminal sentences. As the most recent order was about to expire, the Chester facility filed a petition under the Mental Health Code (405 ILCS 5/3-813) alleging that James continued to be subject to involuntary admission, with certificates from a psychiatrist and a psychologist, stating that James was “[a] person with mental illness who, because of his illness is reasonably expected to inflict serious physical harm upon himself or another in the near future … is unable to provide for his basic physical needs so as to guard himself from serious harm.” The petition was filed on April 29, 2010. The court set the matter for May 5, 2010. James’s attorney appeared on that date and obtained an order for independent evaluation. The independent doctor was prepared to testify that James should remain at Chester; on May 19 James’s attorney advised the court that his client had elected to have a jury. James agreed to wait unit the first available jury date in August. At trial on August 23, James expressed surprise that he had a court date and stated that he was not feeling any better. The jury returned a unanimous verdict that James was subject to involuntary admission. The appellate court held that under these particular circumstances, the delay between the jury request and the actual hearing was significant enough to be prejudicial to the patient and reversed. The Illinois Supreme Court reversed, stating that, given all of his circumstances, the delay following James’s request for a jury trial did not cause him any prejudice.View "In re James W." on Justia Law

The City appealed the district court's grant of plaintiffs' motion for a preliminary injunction enjoining Local Law 17. Local Law 17, inter alia, requires pregnancy services centers to make certain disclosures regarding the services that the centers provide. The court concluded that the law was not impermissibly vague; plaintiffs failed to demonstrate a likelihood of success on the merits with respect to one of the challenged disclosures, which requires pregnancy services centers to disclose if they have a licensed medical provider on staff; plaintiffs have demonstrated a likelihood of success on the merits with respect to other provisions challenged by plaintiffs that require other forms of disclosure and impermissibly compel speech; and because the provisions are severable, the court severed the enjoined provisions from the rest of Local Law 17. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "The Evergreen Association, Inc v. City of New York" on Justia Law

In 2013, the Governor of Wisconsin signed into law a statute that prohibits a doctor, under threat of heavy penalties, from performing an abortion unless he has admitting privileges at a hospital no more than 30 miles from the clinic in which the abortion is performed. Wis. Stat. 253.095(2). Planned Parenthood and others challenged the law under 42 U.S.C. 1983. The district court entered a preliminary injunction against enforcement of the law. The Seventh Circuit affirmed. The court noted that the seven doctors affected by the law had applied for, but after five months, had not been granted, admitting privileges; that all Wisconsin abortion clinics already have transfer agreements with local hospitals to facilitate transfer of clinic patients to the hospital emergency room. A hospital emergency room is obliged to admit and to treat a patient requiring emergency care even if the patient is uninsured, 42 U.S.C. 1395dd(b)(1). Had enforcement of the law, with its one-weekend deadline for compliance, not been stayed, two of the state’s four abortion clinics would have had to shut down and a third clinic would have lost the services of half its doctors. View "Planned Parenthood of WI v. Van Hollen" on Justia Law

A six-person jury found Milwaukee County met its burden to involuntarily commit Appellant for mental illness treatment under Wis. Stat. 51.20, and the circuit court entered an order that committed Appellant for a period no longer than six months. Appellant appealed, arguing that the six-person non-unanimous jury available to her under section 51.20 violated equal protection guarantees. Specifically, Appellant argued that her equal protection rights were violated because only a six-person jury with a five/six determination is available to those subject to involuntary commitment under Chapter 51 when compared to the twelve-person jury with a requirement of unanimity for individuals subject to involuntary civil commitment proceedings under Chapter 980. The Supreme Court affirmed, holding that the differences in the jury provisions for initial commitment hearings under Chapter 51 and Chapter 980 do not violate Appellant's constitutional right to equal protection. View "Milwaukee County v. Mary F.-R." on Justia Law

Plaintiff, her husband, and their jointly owned company filed suit under 42 U.S.C. 1983 against two employees of the Department (Hansen and Watkins), alleging violations of their due process rights. Plaintiffs argued, inter alia, that the Department failed to provide plaintiff with actual notice of her placement on the disqualification list and deprived all the plaintiffs of due process. The court could find no authority or "general constitutional rule" requiring Hansen and Watkins to provide plaintiff final oral notice or request written confirmation of her termination in addition to the notice and opportunity for hearing they had already provided. Therefore, the court concluded that placing plaintiff on the disqualification list was not a deprivation of due process rights. Accordingly, Hansen and Watkins were entitled to qualified immunity on the individual capacity claims against them. Plaintiff's remaining claim was without merit. The court affirmed the judgment of the district court. View "Foster, et al. v. MO Dept. of Health and Senior Servs., et al." on Justia Law