Justia Civil Rights Opinion Summaries

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

The court agreed to rehear this case en banc to clarify under what circumstances the exhaustion requirement of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(l), barred non-IDEA federal or state law claims. Plaintiff, on behalf of herself and her son, appealed the district court's grant of summary judgment to defendants where the district court dismissed her claims for lack of subject matter jurisdiction because plaintiff did not initially seek relief in a due process hearing and therefore, failed to comply with one of the exhaustion-of-remedies requirement of the IDEA. The court held that the IDEA's exhaustion requirement was not jurisdictional and that plaintiff's non-IDEA federal and state-law claims were not subject to the IDEA's exhaustion requirement. Therefore, the court reversed the judgment.

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

The District of Columbia filed this suit to recover its attorneys' fees from a lawyer who brought an administrative complaint against the District on behalf of a student with special educational needs under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). At issue was whether the District was a "prevailing party" under the IDEA in this suit. The court held that the facts in this case followed closely in the wake of the court's precedent in District of Columbia v. Straus where that court held that the district was not a "prevailing party" where its own change of position was what had mooted the dispute, causing the case to be dismissed. Therefore, the court held that the District, in this case, was not a "prevailing party" where the District of Columbia Public Schools (DCPS) authorized an independent comprehensive psychological evaluation for the student, which mooted the only issue before the hearing officer. Accordingly, the district court's grant of summary judgment ordering the lawyer to pay attorneys' fees was reversed.

Appellants, on behalf of their disabled daughter, appealed the district court's finding that the Fort Osage R-1 School District ("school district") offered the daughter a free appropriate public education ("FAPE") within the meaning of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, et seq., for the 2006-2007 school year. Appellants sought reimbursement for their costs of placing their daughter at a private facility during the school year. The court held that the district court did not err in concluding that the school district offered the daughter a FAPE and that the Individualized Education Plan put forward by the school district did not suffer from any procedural error. Accordingly, the court affirmed the judgment of the district court.

Plaintiff received disability insurance benefits under the Social Security Act 42 U.S.C. 301 et seq., between September 1994 and March 2004. After an investigation, the Social Security Administration ("SSA") notified plaintiff that she was ineligible for disability benefits because her employment income had exceeded SSA limits and determined that she was required to repay more than $60,000 in over paid benefits. At issue was whether the district court properly entered judgment for the SSA and denied plaintiff's waiver of over payment recovery and affirmed the ALJ's conclusion that it lacked authority to consider plaintiff's new argument contesting the amount of the overpayment itself. The court held that plaintiff failed to meet the administrative exhaustion requirement because she did not timely challenge her overpayment. Accordingly, since no final decision was made, the district court lacked jurisdiction under 42 U.S.C. 405(g) to consider plaintiff's challenge to the overpayment. The court also held that plaintiff was not entitled to a waiver of overpayment recovery because substantial evidence showed that she was not without fault in causing the overpayment and that the ALJ properly found that plaintiff knew or should have known that her work information was material because of her agreement to report such work in her benefit applications. Accordingly, the court affirmed the judgment of the district court.

Claimant appealed the district court's judgment upholding the Commissioner of Social Security's denial of her application for disability insurance. Appellant raised several issues of error on appeal. The court held that a certain physician's post-hearing letter did not contain any additional information and was not relied upon in the decision making process, and its receipt did not violate claimant's due process rights; that the ALJ did not err in finding claimant retained the residual functional capacity to perform certain kinds of low-stress work; that there was no error in the decision not to order a consultative examination regarding claimant's mental impairments; and that a hypothetical question posed to the Vocation Expert adequately addressed impairments supported by the record. Accordingly, the court affirmed the judgment where substantial evidence on the record as a whole supported the ALJ's decision.

Plaintiffs, a class of indigent children who suffered from severe emotional and mental disabilities, sued Idaho state officials more than three decades ago, alleging that the officials were providing them with inadequate care in violation of their constitutional and statutory rights. The parties reached agreements intended to remedy deficiencies in care and those agreements were embodied in three consent decrees entered and monitored by the district court. Plaintiffs appealed the 2007 order of the district court finding that defendants had substantially complied with the remaining Action Items, which were specified in an Implementation Plan that resulted from the third consent decree, asserting that it was error for the district court to apply the standard for civil contempt in determining whether to vacate the decrees. Plaintiffs further contended that the district court committed errors in fact and law in issuing protective orders barring them from taking supplemental depositions of appellee and two non-parties. The court held that the district court's application of the contempt standard with the imposition of the burden of proof on plaintiffs was error where the district court accepted the Action Items as the entire measure of compliance with the consent decree. Accordingly, the court reversed the order of the district court. The court also held that the district court committed no errors in upholding the assertion of the deliberative process privilege to one non-party and appellee, as well as the legislative privilege to the second non-party. Accordingly, the court did not abuse its discretion in issuing the protective orders.

The Nebraska Department of Health and Human Services (DHSS) determined that Darline Liddell-Toney was required to participate in a self-sufficiency program in order to receive benefits under the Welfare Reform Act, despite her documented disability. The district court affirmed the DHSSâ determination. Ms. Liddell-Toney appealed, arguing that the district court erred in finding that the DHSS provided sufficient evidence to prove she was not entitled to an exemption from participating in the program. The Supreme Court found that the evidence clearly indicated that Ms. Liddell-Toney was prevented from working for a substantial period due to her disability. The Court held that the district court erred when it affirmed DHSSâs determination that Ms. Liddell-Toney did not qualify for an exemption from participating in the self-sufficiency program. The Court reversed the judgment of the district court, and remanded the case for further proceedings.

Plaintiff-Appellant Jessica Cohon sought funding through New Mexicoâs Medicaid program. She qualified for the âMi Via Waiverâ program, and submitted budget requests which were partly granted, partly denied. After an unsuccessful administrative appeal, she filed suit, alleging that the administration of the Mi Via Waiver program discriminated against severely disabled persons like herself. The State moved to dismiss Plaintiffâs complaint, arguing that not only was it the wrong entity being sued, but that Plaintiff had no statutory basis to support her suit. The district court dismissed Plaintiffâs claims based on federal law, but remanded her state-law claims to the administrative agency for further proceedings. Plaintiff appealed the dismissal of her federal law claims to the Tenth Circuit. Upon review, the Tenth Circuit found Plaintiffâs federal claims âinsufficient in substance,â and affirmed the judgment of the district court that dismissed her claims.