Justia Civil Rights Opinion Summaries

The Association sued the County, alleging that the County had breached its obligation to provide certain vested healthcare benefits in perpetuity. The Association alleged that the County had implicitly promised to provide these benefits. The California Supreme Court's recent decision in Retired Employees Ass'n of Orange County, Inc. v. County of Orange (REAOC II) recognized that a county could form a contract with implied terms under specified circumstances. The court held that the district court did not err in concluding that the amended complaint failed to state a cause of action. Nevertheless, in light of REAOC II, the court could not agree with the district court's decision to deny the Association leave to amend on the ground that such amendment would be futile. Accordingly, the court vacated and remanded for further proceedings consistent with REAOC II. View "Sonoma Cnty. Ass'n of Retired Emp. v. Sonoma Cnty." on Justia Law

Respondent Robert Chaney was fired from his position and argued his termination violated the federal Family and Medical Leave Act of 1993 (FMLA). The employer, Providence Health Care d/b/a Sacred Heart Medical Center & Children's Hospital (Providence), claimed no violation of the FMLA occurred. The trial court denied motions for a directed verdict on the issue by both Chaney and Providence. Based upon undisputed facts, the Supreme Court held that the trial court erred in failing to grant Chaney's motion for a directed verdict that as a matter of law the hospital violated the FMLA. In 2005, his wife fell ill after giving birth, Chaney himself suffered a back injury, and he relied heavily on FMLA leave over the next two years. By June 2007, Chaney had used up most of his FMLA leave and had been donated leave from other employees. The record indicated that Providence administration and other staff were growing resentful that Chaney had taken so much time off. In 2007, an employee reported that Chaney appeared fatigued and incoherent. Although no claim was made that his work was compromised, Chaney was ordered to report for drug testing. The drug test was positive for methadone. Chaney had a prescription for methadone to treat back pain, but the doctor who gave the drug test noted that Chaney "[m]ay need fitness for duty evaluation or visit to his Dr. to fine tune his medication." A few months later, Chaney indicated he was prepared to return to work. The record reflected that Chaney was erroneously informed he needed Providence's permission to return to work. This violated the FMLA, under which Chaney could only be required to get authorization from his own health care provider. Chaney went to Providence's doctor, and administration told him the hospital would not allow him to return to work unless their doctor changed his recommended restriction. The hospital's doctor refused to change his recommendation. Subsequently, Chaney was fired. Providence claimed the termination was proper because Chaney failed to provide a valid fitness for work certification as required under the FMLA. View "Chaney v. Providence Health Care" on Justia Law

Quigley was 23 years old, with no known life-threatening physical conditions when he was transferred from one Michigan Department of Corrections (MDOC) facility to an MDOC guidance center, where he was under the care of CMS, a service provider with which MDOC contracted. CMS employees Dr. Thai and physician’s assistant Garver treated Quigley for moderate depression and prescribed medications. After about a month, Quigley was found dead in his cell. The medication chart confirmed that Quigley had been administered both Amitriptyline and Trazodone the previous three days. The autopsy report concluded that Quigley died of an epileptic seizure disorder. Quigley’s estate obtained affidavits from a forensic pathologist, who concluded that Quigley likely died from a fatal drug interaction between the tricyclic Amitriptyline and tetracyclic Trazodone and from a psychiatrist, who similarly concluded that the fatal drug interaction likely killed Quigley. Thai provided three medical-expert affidavits, all concluding that the best explanation for Quigley’s death is epileptic seizure. Quigley’s estate sued Thai, Garver, and CMS under 42 U.S.C. 1983. The district court denied a motion asserting qualified immunity. The Sixth Circuit affirmed, finding that there were unresolved material questions of fact concerning the cause of death. View "Quigley v. Thai" on Justia Law

After Respondent voluntarily admitted herself to the behavioral health unit of a hospital, Respondent requested to be discharged. However, the county attorney's office filed a petition requesting that Respondent be committed for further evaluation and treatment. The district court appointed a public defender to represent Respondent, and following a hearing on the petition for commitment, the court committed Respondent to the Montana State Hospital with a treatment order that included the involuntary administration of medication. The Supreme Court affirmed, holding (1) plaint error review of this issue was not warranted; and (2) Respondent was not denied the effective assistance of counsel during the hearing. View "In re J.S.W." on Justia Law

Since 2006 Ray has experienced pain in his shoulder. He contends that the pain stems from an injury and that an MRI scan would point the way toward successful treatment; Shah, Ray’s treating physician at the correctional center, believes that the pain stems from arthritis and that a scan would not help in diagnosis and treatment. The district court rejected Ray’s suit under 42 U.S.C.1983. The Seventh Circuit affirmed, noting that Ray has been examined often, x-rays have been taken, and physicians have prescribed painkillers; staff also has arranged for Ray to be assigned a lower bunk. Because Ray’s claim fails the objective component of cruel-and-unusual-punishments analysis, his contention that Dr. Shah displayed subjective antipathy is irrelevant. View "Ray v. Wexford Health Sources, Inc." on Justia Law

Devbrow entered the Indiana prison system in 2000. During intake, he told the medical staff that he had prostate problems and would need to be tested for prostate cancer within two to four years. In 2004 a test revealed an elevated PSA, but the medical staff did not order a prostate biopsy for more than a year. In a biopsy six months later, Devbrow was diagnosed with prostate cancer that had spread to his spine; treatment options were severely limited. Devbrow sued prison doctors and a nurse practitioner under 42 U.S.C. 1983 for deliberate indifference to serious medical needs in violation of the Eighth Amendment. The district court entered judgment for the defendants based on the two-year statute of limitations, construing the claim as a constitutional violation that in April 2005 when the biopsy was ordered. The Seventh Circuit reversed. The statute of limitations for a section 1983 deliberate-indifference claim does not begin to run until the plaintiff knows of his injury and its cause. Devbrow did not know of his injury when the defendants ordered a biopsy; he discovered it six months later when he learned he had cancer that might have been diagnosed and treated earlier. View "Devbrow v. Kalu" on Justia Law

USCA is a non-profit national civic league with approximately 27,000 members that devotes itself to conservative values and opposes efforts of the federal government to interfere with market processes. Some of USCA’s uninsured members object to the purchase of private health insurance because they do not believe in the effectiveness of traditional medicine, prefer alternative and integrative medicine, or prefer to focus on preventative care that is not covered by traditional health insurance policies. Two individual plaintiffs do not have, nor do they wish to acquire, health insurance, but they are not exempt from the Patient Protection and Affordable Care Act’s individual mandate, 26 U.S.C. 5000A. They challenged the mandate as violating the Commerce Clause, rights to freedom of expressive and intimate association, rights to liberty, and rights to privacy. The district court dismissed in part, without substantive analysis, holding that plaintiffs failed to satisfy the “plausibility standard” and entered summary judgment on the Commerce Clause challenge. The Sixth Circuit affirmed, stating that the Supreme Court’s opinion in National Federation of Independent Business v. Sebelius controls the outcome on the Commerce Clause count and the remaining constitutional claims were correctly dismissed for failure to state a claim. View "U.S. Citizens Ass'n v. Sebelius" on Justia Law

Stoudemire, then age 23, entered the Michigan Department of Corrections system in 2002, suffering from systemic lupus erythematosus, a chronic, painful autoimmune disease; hypercoagulapathy, a related disorder involving tendency to develop blood clots; and depression. Stoudemire bore a significant risk of experiencing kidney and liver damage, heart attacks, amputations, and chronic pain. Stoudemire’s health quickly deteriorated. She experienced a heart attack, liver failure, and life-threatening embolisms. She underwent three amputations, losing both legs below the knee. At her 2007 parole, she suffered from chronic depression, posttraumatic stress disorder, and conditions related to medications. In her suit under 42 U.S.C. 1983, the Americans with Disabilities Act, 42 U.S.C. 12132; and Michigan law, Stoudemire, alleged that she was placed in a segregation unit following her amputation that lacked accommodations for disabled persons, and was subjected to a strip search that served no legitimate purpose. The district court denied motions by the warden and an officer, seeking summary judgment on qualified immunity grounds. The Sixth Circuit vacated with respect to the warden, stating that the court did not adequately analyze deliberate indifference, but affirmed with respect to the officer, stating that the excessively invasive nature of the search outweighed any need to conduct it. View "Stoudemire v. MI Dep't of Corrs." on Justia Law

Petitioner, an inmate, submitted a petition for a writ of mandamus seeking an order directing the Director of the Department of Public Safety (DPS) to approve dental treatment, teeth cleaning, a root canal, a cavity fix, cancer treatment, and treatment for concussion for brain trauma. The Supreme Court declined to grant the requested relief, as (1) Petitioner failed to demonstrate that DPS was purposefully ignoring or failing to respond to his dental or medical needs; and (2) the documents attached to the petition demonstrated that DPS provided Petitioner medical and dental care within the purview of the State's services, apprised Petitioner of the option to seek outside care for services not covered by the State, and offered services for pain relief. View "Tierney v. Sakai " on Justia Law

Plaintiffs challenged Florida's "Patient Self-Referral Act of 1992" (the Florida Act), Fla. Stat. 456.053, which prohibited Florida physicians from referring their patients for services to business entities in which the referring physicians have a financial interest. The court concluded that the conflict preemption doctrine did not apply, and the exemptions in federal law allowing physicians serving end-stage renal disease patients to engage in self-referral did not preempt Florida's more restrict law prohibiting such conduct. The court also concluded that the Florida Act did not discriminate against interstate commerce, nor did it impose a burden on interstate commerce that was clearly excessive when compared with the law's putative local benefits. Therefore, the Florida Act did not violate the dormant Commerce Clause. Further, plaintiffs' substantive due process claim failed to survive rational basis scrutiny, and an equal protection claim would fail as well. Accordingly, the court affirmed the judgment. View "Fresenius Medical Care Holding, et al v.Tucker, et al" on Justia Law