Justia Civil Rights Opinion Summaries

After a car accident involving David Fraley and Timothy Oeding, Oeding’s insurer (“Auto-Owners”) placed an investigative hold on Fraley’s truck for several months. Fraley filed a negligence action against Oeding’s estate, Oeding’s employer (“J&R”), and Auto-Owners, alleging, among other things, that Auto-Owners’ investigatory hold caused Fraley intangible economic loss due to the loss of use of the truck. The trial court dismissed the complaint, holding (1) the court could not exercise personal jurisdiction over Oeding and J&R solely because their insurer did business in Ohio, and (2) Fraley was not entitled to maintain a direct action against Auto-Owners because he had not obtained a judgment against Auto-Owners’ insureds. The court of appeals reversed, concluding that the trial court erred in its determination that it lacked personal jurisdiction over Oeding and J&R because Auto-Owners’ investigatory hold and its communication with Fraley brought Auto-Owners, and by extension J&R and Oeding, within Ohio’s long-arm statute. The Supreme Court reversed, holding that an Ohio court may not impute an insurance company’s conduct to its nonresident insured for purposes of establishing personal jurisdiction over the insured. View "Fraley v. Estate of Oeding" on Justia Law

Wourms, age 16, was killed in a crash; he was driving erratically when an officer, warned by a 911 call from Wourms’ mother that her son was drunk and “going crazy,” turned on his emergency lights to signal him to pull over. Wourms increased his speed to about 80 mph in an area posted for 25 mph. His father sued under 42 U.S.C. 1983, arguing that the crash was caused by the police car intentionally ramming Wourms’s car, resulting in an unconstitutional seizure of his person and property. The officer denied that his car touched Wourms’s car. The district court entered summary judgment, finding the evidence insufficient for a reasonable jury to find that the cars had collided. The Seventh Circuit affirmed, noting that without a collision, Wourms was entirely responsible; the police officer had every legal right to signal Wourms to pull over. Even ramming a recklessly driven car to induce the driver to stop or cause the car to crash, need not be unreasonable. In this case, however, there were no marks on the police car that matched marks on Wourms’s car, no debris on the road where Wourms started to swerve, and no skid marks from the police car. Witness testimony indicated that the police could not have caught Wourms in time to hit his car before the crash.View "Wourms v. Fields" on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law

Respondents, the City and County of Honolulu and certain individuals, banned Petitioners, two stagehands, from working at certain City-owned facilities based on Petitioners' involvement in a charitable concert featuring the City's mayor. After a jury-waived trial, the circuit court entered judgment in favor of Respondents on all claims, including Petitioners' claims that the ban was unconstitutional. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments, holding that the City's ban interfered with Petitioners' liberty interests under the Hawaii Constitution and that the City failed to satisfy due process by instituting the ban without giving Petitioners notice and an opportunity to be heard. Remanded. View "Minton v. Quintal" on Justia Law

Plaintiffs are the writer and publisher of a book entitled "Where's the Birth Certificate? The Case that Barack Obama is not Eligible to Be President." A journalist published an article on Esquire's Political Blog entitled "BREAKING: Jerome Corsi's Birther Book Pulled from Shelves!" Soon after the blog was published, Esquire published an update on the blog stating that "for those who didn't figure it out," the article was "satire." Plaintiffs filed suit against Esquire for, inter alia, violation of the D.C. Anti-Strategic Lawsuits Against Public Participation (Anti-SLAPP) Act, D.C. Code 16-5501 et seq., and the Lanham Act, 15 U.S.C. 1125(a)(1)(A) and (B). The court held that the complaint was properly dismissed under Rule 12(b)(6) for failure to state a claim because the blog post was fully protected political satire and the update and the journalist's statements were protected opinion. Further, the complaint failed to state a claim for violation of the Lanham Act. Accordingly, the court affirmed the district court's dismissal of the complaint. View "Farah, et al. v. Esquire Magazine, et al." on Justia Law

In 2009, GameStop, Inc., which operated retail stores that sold video games and video gaming software, hired Petitioner as an assistant manager. When she began her employment, Petitioner received a store associate handbook. In a document included with the handbook was an arbitration agreement. Petitioner signed and dated an acknowledgment of the handbook and rules including arbitration. In 2011, Petitioner sued GameStop and some of its managers (collectively, GameStop) for wrongful discharge, sexual harassment, and intentional infliction of emotional distress, among other causes of action. The circuit court dismissed the complaint pending Petitioner's submission of her claims to final and binding arbitration. Petitioner appealed, arguing that she did not enter into a valid arbitration with GameStop or, in the alternative, the arbitration agreement was unconscionable and unenforceable. The Supreme Court affirmed, holding (1) Petitioner and GameStop entered into a valid agreement to arbitrate Petitioner's claims; and (2) the arbitration agreement was neither procedurally nor substantively unconscionable. View "New v. GameStop, Inc." on Justia Law

Appellant, the same-sex partner of a highway patrolman who was killed in the line of duty, applied for survivor benefits under Mo. Rev. Stat. 104.140.3, which provides survivor benefits to the surviving spouse of a highway patrol employee who is killed in the line of duty. The Missouri Department of Transportation and Highway Patrol Employees' Retirement System denied Appellant's application. Appellant argued before the circuit court that the survivor benefits statute violated his equal protection rights by excluding him from survivor benefits because of his sexual orientation and violated the constitutional proscription against special laws. The circuit court affirmed the administrative decision. The Supreme Court affirmed, holding (1) Appellant was not eligible for survivor benefits because he was not married to the patrolman; and (2) the survivor benefits statute is constitutional and is not a special law. View "Glossip v. Mo. Dep't of Transp. & Highway Patrol Employees' Ret. Sys." on Justia Law

Plaintiff filed suit against Kmart Corporation and Sears Holdings Corporation (collectively, Kmart), bringing a federal claim of racial discrimination under 42 U.S.C. 1981 and a pendent state law claim of negligent infliction of emotional distress. Plaintiff, an African-American woman, alleged that a white Kmart sales clerk insulted her with racial slurs and comments while she was placing items on hold in a layaway transaction. The district court dismissed the federal claim for failure to state a claim under section 1981 and dismissed without prejudice the state law claim. Plaintiff appealed the dismissal of her section 1981 claim. The First Circuit Court of Appeals affirmed, holding that Plaintiff failed to make out a section 1981 claim where her only allegation of harm she suffered was from the sales clerk's utterances, and nothing more. View "Hammond v. Kmart Corp." on Justia Law

Bovee contends that his sister, Broom, violated the due process clause when, in her role as guidance counselor at his children’s school, she criticized his parenting methods and called him a “bad father.” Bovee claims that this alienated his children’s affections, violating his fundamental liberty interest in familial relations. The district court dismissed for lack of subject matter jurisdiction. The Seventh Circuit held that the dismissal should have been on the merits. “The suit is about words, and only words.” Bovee’s lawyer conceded that Broom has not taken any official act adverse to his interests. Defamation, words not accompanied by any other official action, does not violate the due process clause. View "Bovee v. Broom" on Justia Law

Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law