Justia Civil Rights Opinion Summaries

In this case where Plaintiffs sought a declaration that the Massachusetts Constitution protects a fundamental right to physician-assisted suicide, thereby immunizing the practice from criminal prosecution, the Supreme Judicial Court held that the proposed right, as defined by Plaintiffs, was not supported in the relevant provisions of the Constitution.Plaintiffs were a licensed physician who wished to provide physician-assisted suicide and a retired physician who had been diagnosed with an incurable cancer. Plaintiffs brought a civil action seeking declaratory and injunctive relief, arguing that terminally ill patients with six months or less to live have a constitutional right to receive a prescription for lethal medication in order to bring about death in a manner and time of their choosing. The trial court granted summary judgment for Defendants. The Supreme Judicial Court affirmed, holding (1) the Massachusetts Declaration of Rights does not protect physician-assisted suicide; and (2) the law of manslaughter prohibits physician-assisted suicide without offending constitutional protections. View "Kligler v. Attorney General" on Justia Law

The Supreme Court affirmed the decision of the court of appeals that Respondent's due process rights were not violated in the proceedings which led to the trial court's conclusion that Respondent had a mental illness and was dangerous to himself, holding that there was no error.At the end of a hearing, the trial court concluded that Respondent had a mental illness and was a danger to himself and entering a thirty-day commitment order. At issue was whether the trial court, in the absence of counsel for the state, called witnesses and elicited testimony during the hearing. The Supreme Court affirmed, holding that the trial court did not violate Respondent's due process right to an impartial tribunal. View "In re J.R." on Justia Law

The Supreme Court held that the trial court did not violate Defendant's due process rights by proceeding with Defendant's involuntary commitment hearing when Defendant was not represented by counsel and that the trial court's factual findings were sufficient to support its conclusion that Defendant was dangerous to herself.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's due process rights; (2) Defendant preserved her right to challenge the trial court's incorporation of a non-testifying physician's exam report into its findings of fact, and the trial court committed harmless error by incorporating the report into its findings of fact; and (3) the court of appeals correctly held that the trial court made sufficient findings of fact based on the evidence presented by the testifying witness to support its involuntary commitment decision. View "In re R.S.H." on Justia Law

The Air Force ordered over 500,000 service members to get COVID-19 vaccinations. About 10,000 members requested religious exemptions; about 135 of these requests were granted, only to those planning to leave the service. It has granted thousands of exemptions for medical or administrative reasons. The Plaintiffs allege that the vaccine mandate substantially burdens their religious exercise in violation of the First Amendment and the Religious Freedom Restoration Act (RFRA). The district court granted a preliminary injunction that barred the Air Force from disciplining the Plaintiffs for failing to take a vaccine, then certified a class of thousands of similar service members and extended this injunction to the class.The Sixth Circuit affirmed. In opposing class-action certification, the Air Force argued that RFRA adopts an individual-by-individual approach: it must show that it has a compelling interest in requiring a “specific” individual to get vaccinated based on that person’s specific duties. In challenging the injunction, however, the Air Force failed to identify the specific duties or working conditions of any Plaintiff, citing the “general interests” underlying the mandate. The court reasoned that it could uphold the injunction based on RFRA alone but also noted common questions for the class: Does the Air Force have a uniform policy of relying on its generalized interests in the vaccine mandate to deny religious exemptions regardless of individual circumstances? Does it have a discriminatory policy of broadly denying religious exemptions but broadly granting secular ones? View "Doster v. Kendall" on Justia Law

Indiana requires abortion providers to dispose of fetal remains by either burial or cremation. Women may choose to take custody of the remains and dispose of them as they please. The Supreme Court sustained this regimen against Equal Protection challenges in 2019.This suit was filed by two women who had abortions and object to the cremation or burial of the fetal remains, which they contend implies the personhood of a pre-viability fetus, and two physicians do not want to tell patients about their statutory options. The Seventh Circuit reversed a “needlessly broad injunction” that treats the statute as invalid on its face and “effectively countermands the Supreme Court’s decision for the entire population of Indiana." The state does not require any woman who has obtained an abortion to violate any belief, religious or secular. The cremate-or-bury directive applies only to hospitals and clinics. Indiana’s statute need not imply anything about the appropriate characterization of a fetus. Nor does Indiana require any woman to speak or engage in expressive conduct. A state may require medical professionals to provide information that facilitates patients’ choices directly linked to procedures that have been or may be performed. View "Doe v. Rokita, Attorney General of Indiana" on Justia Law

In March 2020, New Jersey Governor Murphy responded to the spread of COVID-19; Executive Order 107 prohibited in-person gatherings and ordered New Jersey residents to “remain home or at their place of residence,” except for certain approved purposes, such as an “educational, political, or religious reason.” EO 107 excepted businesses deemed “essential,” including grocery and liquor stores, which could continue to welcome any number of persons (consistent with social distancing guidelines). Violations of EO 107 were subject to criminal prosecution for “disorderly conduct.” The order granted the Superintendent of the State Police, “discretion to make clarifications and issue [related] orders[.]” He exercised that power, declaring (Administrative Order 2020-4) that gatherings of 10 or fewer persons were presumptively permitted. Neither EO 107 nor AO 2020-4 contained an exception for religious worship gatherings or other First Amendment activity.Two New Jersey-based, Christian congregations, believing that the Bible requires them to gather for in-person worship services, violated the Orders and were cited. Less than a week after the filing of their complaint, challenging the Orders, Governor Murphy raised indoor gathering limits to 50 persons or 25 percent of room capacity (whichever was less), allowing outdoor religious gatherings without any gathering limits. The district court denied the congregations’ motion for a preliminary injunction. The Third Circuit dismissed an appeal as moot. View "Clark v. Governor of New Jersey" on Justia Law

The Court of Chancery dismissed for lack of subject matter jurisdiction this case brought by Plaintiffs, two religious leaders, challenging restrictions that the Governor imposed on houses of worship during the COVID-19 pandemic, holding that Plaintiffs failed to show any basis for relief.Plaintiffs asserted that they suffered harm as a result of the challenged restrictions and that the restrictions triggered, but could not survive, strict scrutiny. Plaintiffs sought as a remedy a declaration that the challenged restrictions were unconstitutional and a permanent injunction prohibiting the Governor from implementing similar restrictions in the future. The Court of Chancery granted the Governor's motion to dismiss, holding that Plaintiffs did not establish a reasonable apprehension that the Governor would engage in conduct that would warrant a permanent injunction and therefore did not make the necessary showing. View "In Re Covid-Related Restrictions On Religious Services" on Justia Law

In 2021, Tennessee enacted a statute that vaccination, masking, and quarantine decisions: “A local health entity or official, mayor, governmental entity, or school does not have the authority to quarantine a person or private business for purposes of COVID-19,” and “a school or a governing body of a school shall not require a person to wear a face mask while on school property” unless various conditions are met. Before seeking accommodation under its terms, eight minor students with disabilities filed suit, alleging that the legislation violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101m Section 504 of the Rehabilitation Act, 29 U.S.C. 794, the Equal Protection Clause, and the Supremacy Clause. The district court granted a preliminary injunction with respect to sections of the Act concerning face coverings for schools and provisions that prohibit local health officials and schools from making quarantining decisions as they relate to public schools.While acknowledging that the case is moot, the Sixth Circuit dismissed it for lack of jurisdiction. The plaintiffs’ argument that they are injured because the Act categorically violates the ADA amounts to an overly generalized grievance. They do not seek redress for a completed violation of a legal right; they seek only prospective relief to protect against future violations. Their injuries are not fairly traceable to any defendant, so no remedy applicable to those defendants (be it an injunction or a declaration) would redress the alleged injuries. View "R. K. v. Lee" on Justia Law

Plaintiffs brought various claims against Rockland County ("Rockland County Defendants") officials including a violation of the Free Exercise Clause of the First Amendment, based on orders which excluded children who were not vaccinated against measles from attending school and an emergency declaration which barred unvaccinated children, other than those with medical exemptions, from places of public assembly. The district court granted summary judgment for Rockland County Defendants.The Second Circuit reversed, finding that Plainitffs' claim raises numerous disputes—including whether there is evidence of religious animus, to whom the emergency declaration applied, and what the County’s purpose was in enacting the declaration—that prevent Defendants from prevailing on summary judgment. View "M.A. v. Rockland County Department of Health" on Justia Law

Pro se plaintiff Gary Wisner, M.D. filed a complaint alleging that defendants Dignity Health and the Dignity Health St. Joseph’s Medical Center (collectively, SJMC) falsely reported to the National Practitioner Data Bank (NPDB) that Wisner surrendered his clinical privileges while under criminal investigation for insurance fraud. The trial court granted a special motion to strike the complaint after concluding that Wisner’s claims arose from a protected activity and that Wisner failed to establish a probability of prevailing on the merits. Wisner contested both aspects of the trial court’s order, and he also argued the court erred by denying his motion to conduct limited discovery prior to the hearing on the anti-SLAPP motion. Finding no error, the Court of Appeal affirmed. View "Wisner v. Dignity Health" on Justia Law