Justia Civil Rights Opinion Summaries

Plaintiffs challenged the constitutionality of the ban on compensation for human organs in the National Organ Transplant Act, 42 U.S.C. 274e, as applied to bone marrow transplants. Plaintiffs sought declaratory and injunctive relief to allow harvesting of hematopoietic stem cells which would be extracted by peripheral blood stem cell apheresis (the same technique sometimes used to collect plasma or platelets). The court concluded that Congress made a distinction between body material that was compensable and body material that was not. The distinction had a rational basis, so the prohibition on compensation for bone marrow donations by the aspiration method did not violate the Equal Protection Clause. The court also concluded that when the peripheral blood stem cell apheresis method of bone marrow transplantation was used, it was not a transfer of a "human organ" or a "subpart thereof" as defined by the statue and regulation, so the statue did not criminalize compensating the donor. Therefore, the court need not decide whether prohibiting compensation for such donations would be unconstitutional.

Defendant appealed the district court's preliminary injunction precluding enforcement of California Welfare and Institutions Code 14105.191(f), which amended California's Medicaid Plan and set provider reimbursement rates for the 2009-2010 rate year, and for each year thereafter. Plaintiffs challenged the law under 42 U.S.C 1983 and the Supremacy Clause because the State did not obtain federal approval of its State Plan Amendment (SPA) prior to implementing the rate changes. The court vacated the preliminary injunction and held that plaintiffs have not shown that they have an unambiguously conferred right to bring a section 1983 claim.

The State of Arizona appealed the district court's order granting a preliminary injunction to prevent a state law from taking effect that would have terminated eligibility for healthcare benefits of state employees' same-sex partners. The district court found that plaintiffs demonstrated a likelihood of success on the merits because they showed that the law adversely affected a classification of employees on the basis of sexual orientation and did not further any of the state's claimed justifiable interests. The district court also found that plaintiffs had established a likelihood of irreparable harm in the event coverage for partners ceased. The court held that the district court's findings and conclusions were supported by the record and affirmed the judgment.

Plaintiffs, a class of economically vulnerable Arizonians who receive public health care benefits through the state's Medicaid agency, sued the U.S. Secretary of Health and Human Services (Secretary) and the Director of Arizona's medicaid agency (director)(collectively, defendants), alleging that the heightened mandatory co-payments violated Medicaid Act, 42 U.S.C. 1396a, cost sharing restrictions, that the waiver exceeded the Secretary's authority, and that the notices they received about the change in their health coverage was statutorily and constitutionally inadequate. The court affirmed the district court's conclusion that Medicaid cost sharing restrictions did not apply to plaintiffs and that Arizona's cost sharing did not violate the human participants statute. The court reversed the district court insofar as it determined that the Secretary's approval of Arizona's cost sharing satisfied the requirements of 42 U.S.C. 1315. The court remanded this claim with directions to vacate the Secretary's decision and remanded to the Secretary for further consideration. Finally, the court remanded plaintiffs' notice claims for further consideration in light of intervening events.

Plaintiffs brought this action challenging the constitutionality of the Patient Protection and Affordable Care Act, Pub. L. 111-148, 124 Stat. 119, amended by Health Care and Education Reconciliation Act of 2010 (HCERA), Pub. L. No. 111-152, 124 Stat. 1029 (Act). The government subsequently appealed the district court's ruling that the individual mandate was unconstitutional and the district court's severability holding. The state plaintiffs cross-appealed the district court's ruling on their Medicaid expansion claim. The court held that the Act's Medicaid expansion was constitutional. The court also held that the individual mandate was enacted as a regulatory penalty, not a revenue-raising tax, and could not be sustained as an exercise of Congress's power under the Taxing and Spending Clause; the individual mandate exceeded Congress's enumerated commerce power and was unconstitutional; and the individual mandate, however, could be severed from the remainder of the Act's myriad of reforms. Accordingly, the court affirmed in part and reversed in part the judgment of the district court.

Wisconsin inmates challenged the state's Inmate Sex Change Prevention Act, Wis. Stat. 302.386(5m), which prevents the state Department of Corrections from providing transgender inmates with certain medical treatments. The district court ruled in favor of the inmates. The Seventh Circuit affirmed, noting the medical consequences and concluding that the policy violated the Eighth Amendment.

This case arose when Pauline Thomas brought her daughter, Jane Doe and four of her grandchildren, including John Doe and R.N.T. to the Emergency Room at the Hennepin County Medical Center and reported her concerns that Jane Doe might have been sexually abused by R.N.T. Appellants brought suit against appellees claiming that the 72-hour hold placed on John Doe, the internal examination of Jane Doe, and the examination of John Doe violated the children's rights under the Fourth Amendment and that the seizure and search of both children violated the Fourteenth Amendment rights of all appellants. At issue was whether the district court properly granted summary judgment in favor of appellees and denied appellants' motion for partial summary judgment on their claims under 42 U.S.C. 1983. The court rejected appellants' contention that appellees failed to move for summary judgment on all of appellants' claims; that the district court ignored questions of material fact; and that the district court at times used the wrong legal standards when analyzing the facts. The court also held that because it affirmed the district court's adverse grant of summary judgment against appellants, the court did not reach the denial of appellants' partial motion for summary judgment.

An inmate of the Maine corrections system, sought a civil rights remedy (42 U.S.C. 1983) for alleged denial of adequate medical care for human immunodeficiency virus (HIV) by healthcare professionals at a jail and the state prison. The district court entered summary judgment for the defendants. The First Circuit affirmed with respect to the contractor that provides care, stating that the evidence could not establish Eighth Amendment violations, but reversed with respect to a physicians' assistant. Although the contractor acknowledged that its care "fell short of the mark," carelessness or inadvertence falls short of the Eighth Amendment standard of deliberate indifference. There was a material dispute about deliberate indifference by the physicians' assistant, who had a financial interest in limiting care and a disciplinary history.

Plaintiffs-Appellants Dwayne and Debbie Bonney appeal the lower courtâs decision granting summary judgment to Defendant-Appellee Stephens Memorial Hospital. The Court vacated the decision on the state law claims, and remanded the case back to the lower court for further proceedings. Plaintiffs drove themselves to the hospital after a violent assault that took place at their home. A hospital security guard overheard the Plaintiffsâ discussion with nursing staff, and said that he was going to call the police. Despite the Plaintiffsâ protest, the guard made the call, and disclosed all information he overheard. Based on this information, police obtained a warrant to search the Plaintiffs' home, found evidence of marijuana cultivation, leading to the Plaintiffsâ subsequent indictment and conviction on drug trafficking charges. Citing a violation of state and federal law for unauthorized disclosure of health care information, the Plaintiffs brought suit seeking damages from the hospital and the unnamed guard. On appeal, the Court found that the lower court erred in dismissing the Plaintiffsâ state claims under summary judgment: â30-A.M.R.S. § 287 does not shield health care providers for the unauthorized reporting of confidential health care information when the reporting involved is not related to an examination of a victim performed to obtain evidence for the prosecution.â The Court upheld dismissal of the Plaintiffsâ claims under the Health Insurance Portability and Accountability Act (HIPPA) finding the law authorizes no private cause of action.