Justia Civil Rights Opinion Summaries

In 2002, Plaintiffs commenced a proposed class action civil rights suit against the County of Rensselaer. The County invoked Selective Insurance Company’s duty to provide a defense under the policies that the company sold to the County. Selective agreed to defend the County in the action, subject to the insurance policy limits and the deductible. Selective’s counsel and the County agreed to settle the actions for $1,000 per plaintiff, determined to be slightly more than 800 individuals in total, with attorney fees also being recoverable. Selective abided by the terms of the settlement. The County, however, refused to pay Selective more than a single deductible payment. Selective then commenced this action for money damages, arguing that each class member was subject to a separate deductible. Supreme Court concluded that a separate deductible payment applied to each class member and that all legal fees should be allocated to one policy. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the class action suit did not constitute one occurrence under the relevant policies’ definition of “occurrence” and that the attorney’s fees generated in defending that suit were properly allocated to the named plaintiff. View "Selective Ins. Co. of Am. v. County of Rensselaer" on Justia Law

The Departments of Health and Human Services (HHS), Labor (DOL), and Treasury appealed a preliminary injunction that enjoins the government from enforcing the contraceptive mandate provisions of the Patient Protection and Affordable Care Act (ACA), 42 U.S.C. 300gg-13(a)(4), and its implementing regulations against nonprofit religious organizations that offer healthcare coverage to their employees. The district court’s order also enjoined the government from enforcing the challenged provisions against “any insurance provider (including insurance issuers and third-party administrators) offering health insurance to” the organizations. The Eighth Circuit affirmed, stating that by coercing the organizations to participate in the contraceptive mandate and accommodation process under threat ofsevere monetary penalty, the government has substantially burdened their exercise of religion. Even assuming that the government’s interests in safeguarding public health and ensuring equal access to health care for women are compelling,the contraceptive mandate and accommodation process likely are not the least restrictive means of furthering those interests. View "Dordt College v. Burwell" on Justia Law

Religious, not-for-profit organizations challenged the “contraceptive mandate” of the Patient Protection and Affordable Care Act of 2010 (ACA), 42 U.S.C. 300gg-13(a)(4), arguing that the ACA’s accommodations for religious organizations impose a substantial burden on their free exercise of religion, and that the ACA and accompanying regulations are not the least restrictive means of furthering a compelling government interest, in violation of the plaintiffs’ rights under the Religious Freedom Restoration Act of 1993 (RFRA), 42 U.S.C. 2000bb. The district court entered a preliminary injunction. The Seventh Circuit reversed, stating: It is the operation of federal law, not any actions that the plaintiffs must take, that causes the provisions of services that the plaintiffs find morally objectionable. The accommodation has the legal effect of removing from objectors any connection to the provision of contraceptive services. View "Grace Schools v. Burwell" on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Appellees in these consolidated appeals challenged under the Religious Freedom Restoration Act (RFRA) the requirement under the Patient Protection and Affordable Care Act (ACA) that contraceptive coverage be provided to their plan participants and beneficiaries. Appellees included a nonprofit institution of higher learning established by the Reformed Presbyterian Church and certain Catholic Dioceses and nonprofit organizations affiliated with the Catholic Church. Because they provided coverage to the Catholic nonprofits, the Dioceses, which were otherwise exempt, were required to comply with the contraceptive coverage requirement as to the nonprofits. The nonprofit appellees were eligible for an accommodation to the contraceptive coverage requirement, under which the contraceptive services will be independently provided by an insurance issuer or third-party administrator once the appellees advise that they will not pay for those services. Appellees argued that the accommodation places a substantial burden on their religious exercise because it forces them to facilitate the provision of insurance coverage for contraceptive services and has the impermissible effect of dividing the Catholic Church. The district courts granted Appellees’ motions for a preliminary injunction. The Third Circuit reversed, concluding that the accommodation places no substantial burden on Appellees, and therefore, Appellees did not show a likelihood of success on the merits of their RFRA claim. View "Geneva College v. Sec’y U.S. Dep’t of Health & Human Servs." on Justia Law

Plaintiffs filed suit against Deputy Arnold and Sheriff Graves, alleging violations of federal and state law after Arnold fatally shot their father while responding to a 911 call that the father was threatening to commit suicide. Plaintiffs also filed suit against ReliaStar to recover $179,000 they allege ReliaStar owes them under the father's accidental death policy. The district court granted Arnold and Grave's motions for summary judgment and granted ReliaStar's motion for summary judgment. The court held that Arnold did not violate the father's Fourth Amendment rights when he entered the father's home without a warrant because he had an objectively reasonable belief that the father would imminently seriously injure himself, and the district court did not err in granting Arnold's motion for summary judgment on the warrantless entry claim because Arnold is entitled to qualified immunity; Arnold is entitled to qualified immunity because he did not violate the father's constitutional right to be free from excessive force; the district court did not err in granting summary judgment for Arnold on the assault and battery claims, the false imprisonment claims, and the intentional infliction of emotional distress claim; the district court correctly granted Graves's motion for summary judgment; and the district court did not err in granting summary judgment for ReliaStar where the record was replete with factual evidence that ReliaStar relied on in determining that the father's death was not accidental, demonstrating that ReliaStar could have reached its determination without resorting to the conflict of interest at issue. Accordingly, the court affirmed the judgment of the district court.View "Rice, et al. v. Reliastar Life Ins. Co." on Justia Law

Annex, Stuart Lind, and Tom Janas filed suit challenging HHS' contraceptive mandate under the Religioous Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1(a). Lind, a controlling shareholder of Annex, opposed insurance coverage of contraceptives for Annex's employees. The district court denied Annex and Lind's motion for a preliminary injunction respecting the contraceptive mandate's enforcement. The court concluded that Janas lacks standing to appeal because he did not join the preliminary injunction motion which forms the basis of the appeal; the mandate does not apply to Annex because Annex has fewer than fifty full-time employees and has no government-imposed obligation to offer health insurance of any kind; the only alleged injury is that independent third parties - private health insurance companies not involved in this case - are unable to sell Annex a health insurance plan that excludes healthcare inconsistent with Lind's religious relief; and, ultimately, it is unclear whether Annex's alleged injury is caused by the government defendants and redressable by the federal courts. Accordingly, the court vacated the district court's denial and remanded for the district court to conduct more fact-finding to determine whether subject matter jurisdiction exists. View "Annex Medical, Inc., et al. v. Sebelius, et al." on Justia Law

The Alaska Workers' Compensation Board denied a death benefit claim filed by the decedent's same-sex partner because the death benefit statute grants benefits only to a worker’s "widow or widower" as defined by statute. The Board construed these terms by applying the Marriage Amendment to the Alaska Constitution, which defined marriage as "only between one man and one woman," thus excluding a decedent's same-sex partner. Because this exclusion lacked a fair and substantial relationship to the purpose of the statute, the Supreme Court concluded that this restriction on the statutory definition of "widow" violated the surviving partner's right to equal protection under the law. View "Harris v. Millennium Hotel" on Justia Law

In 2004 Fox was charged with the sexual assault and murder of his three-year-old daughter. Detectives coerced a confession and delayed testing of DNA evidence, leaving Fox imprisoned for eight months, separated from his wife and son. His defense finally obtained the DNA evidence and had it tested at a private lab; the results excluded Fox and charges were dropped. Fox sued under 42 U.S.C. 1983 and state law alleging due process violations, malicious prosecution and intentional infliction of emotional distress. A St. Paul policy required the insurer to defend the detectives to its policy limit, $1 million. Will County also had excess liability policies for $5 million from AAIC (secondary) and Essex (tertiary). Under AAIC’s policy it was not required to assume “settlement or defense” until the underlying policy had been exhausted. None of the policies covered punitive damages. The detectives were represented by a firm retained by St. Paul. The jury awarded $15.5 million, including $6.2 million in punitive damages. Offers to settle for less, before and after the verdict, were rejected. St. Paul exhausted its policy limit; AAIC assumed the defense. The detectives assigned to the Foxes any claims against the insurers in exchange for a covenant not to seek punitive damages from the detectives’ personal assets. The Seventh Circuit upheld $8,166,000 of the damages awarded, including $3.4 million in punitive damages. Fox sought a declaratory judgment that AAIC breached its good faith duties to reasonably settle the claims and inform the detectives of their conflicts of interest. The district court dismissed, reasoning that AAIC, as excess insurer, never had any control over the defense before judgment and therefore had no duty to settle the claims or alert the detectives to any potential conflicts of interest. The Seventh Circuit affirmed View "Fox v. Am. Alt. Ins. Corp." on Justia Law

Department of Health and Human Services (HHS) regulations implementing the 2010 Patient Protection and Affordable Care Act (ACA) require that employers’ group health plans furnish preventive care and screenings for women without cost sharing requirements, 42 U.S.C. 300gg–13(a)(4). Nonexempt employers must provide coverage for 20 FDA-approved contraceptive methods, including four that may have the effect of preventing a fertilized egg from developing. Religious employers, such as churches, are exempt from the contraceptive mandate. HHS has effectively exempted religious nonprofit organizations; an insurer must exclude contraceptive coverage from such an employer’s plan and provide participants with separate payments for contraceptive services. Closely held for-profit corporations sought an injunction under the 1993 Religious Freedom Restoration Act (RFRA), which prohibits the government from substantially burdening a person’s exercise of religion even by a rule of general applicability unless it demonstrates that imposing the burden is the least restrictive means of furthering a compelling governmental interest, 42 U.S.C. 2000bb–1(a), (b). As amended by the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), RFRA covers “any exercise of religion, whether or not compelled by, or central to, a system of religious belief.” The Third Circuit held that a for-profit corporation could not “engage in religious exercise” under RFRA and that the mandate imposed no requirements on corporate owners in their personal capacity. The Tenth Circuit held that the businesses are “persons” under RFRA; that the contraceptive mandate substantially burdened their religious exercise; and that HHS had not demonstrated that the mandate was the “least restrictive means” of furthering a compelling governmental interest.The Supreme Court ruled in favor of the businesses, holding that RFRA applies to regulations that govern the activities of closely held for-profit corporations. The Court declined to “leave merchants with a difficult choice” of giving up the right to seek judicial protection of their religious liberty or forgoing the benefits of operating as corporations. Nothing in RFRA suggests intent to depart from the Dictionary Act definition of “person,” which includes corporations, 1 U.S.C.1; no definition of “person” includes natural persons and nonprofit corporations, but excludes for-profit corporations. “Any suggestion that for-profit corporations are incapable of exercising religion because their purpose is simply to make money flies in the face of modern corporate law.” The Court rejected arguments based on the difficulty of ascertaining the “beliefs” of large, publicly traded corporations and that the mandate itself requires only insurance coverage. If the plaintiff companies refuse to provide contraceptive coverage, they face severe economic consequences; the government failed to show that the contraceptive mandate is the least restrictive means of furthering a compelling interest in guaranteeing cost-free access to the four challenged contraceptive methods. The government could assume the cost of providing the four contraceptives or could extend the accommodation already established for religious nonprofit organizations. The Court noted that its decision concerns only the contraceptive mandate, not all insurance-coverage mandates, e.g., for vaccinations or blood transfusions. View "Burwell v. Hobby Lobby Stores, Inc." on Justia Law