Justia Civil Rights Opinion Summaries

Plaintiffs, Medicaid recipients who unsuccessfully sought coverage for prescription drugs, filed suit contending that the District and its officials unlawfully failed to afford them notice of their entitlement to a hearing before denying their prescription drug claims. The court affirmed the district court's dismissal of plaintiffs' claims under Title XIX of the Social Security Act, 42 U.S.C. 1396 et seq., and rejected plaintiffs’ argument that Title XIX’s notice regulations are triggered whenever there has been a denial of a claim for prescription drug coverage at the point-of-sale. However, the court reversed the district court's dismissal of the due process claims because the prescription drug coverage sought by plaintiffs qualifies as a property interest protected by the Fifth Amendment; plaintiffs adequately alleged that Xerox, a private company, determined their eligibility for benefits while acting as an agent of the District; and the court remanded the case to permit the district court to conduct an inquiry in the first instance into what process is due. The court also remanded to the district court to reconsider its jurisdiction over the D.C. -law claims in light of the court's partial reversal. View "NB v. District of Columbia" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983 against DSS to enforce the Food Stamp Act's, 7 U.S.C. 2020(e)(3) and (9), time limits for awarding food stamp benefits. The district court certified a class consisting of all past, current, and future Connecticut food stamp applicants whose applications are not processed in a timely manner and the district court issued a preliminary injunction requiring DSS to process food stamp applications within the statutory deadlines. The court concluded that plaintiff can maintain a private lawsuit under 42 U.S.C. 1983 to enforce the statutory time limits in section 2020(e)(3) and (9). The court also concluded that federal regulations do not excuse DSS from processing food stamp applications within the statutory time limits. Accordingly, the court affirmed the judgment. View "Briggs v. Bremby" on Justia Law

The federal government provides low-income housing tax credits that are distributed to developers by state agencies, including the Texas Department of Housing and Community Affairs. The Inclusive Communities Project (ICP), which assists low-income families in obtaining affordable housing, brought a disparate-impact claim under Fair Housing Act sections 804(a) and 805(a), alleging that allocation of too many credits to housing in predominantly black inner-city areas and too few in predominantly white suburban neighborhoods resulted in continued segregated housing patterns. Relying on statistical evidence, the district court ruled in favor of ICP. While appeal was pending, HUD issued a regulation interpreting the FHA to encompass disparate-impact liability and establishing a burden-shifting framework. The Fifth Circuit held that disparate-impact claims are cognizable under the FHA, but reversed, concluding that the court had improperly required proof of less discriminatory alternatives. The Supreme Court affirmed and remanded. Disparate-impact claims are cognizable under the FHA. The Court noted that the statute shifts emphasis from an actor’s intent to the consequences of his actions. Disparate-impact liability must be limited so that regulated entities can make practical business choices that sustain the free-enterprise system. Before rejecting a business justification—or a governmental entity’s public interest—a court must determine that a plaintiff has shown “an available alternative . . . that has less disparate impact and serves the [entity’s] legitimate needs.” A disparate-impact claim relying on a statistical disparity must fail if the plaintiff cannot point to a policy causing that disparity. Policies, governmental or private, are not contrary to the disparate-impact requirement unless they are “artificial, arbitrary, and unnecessary barriers.” When courts find disparate impact liability, their remedial orders must be consistent with the Constitution and should concentrate on eliminating the offending practice. Orders that impose racial targets or quotas might raise difficult constitutional questions. View "Texas Dep't of Hous, & Cmity Affairs v. Inclusive Communities Project, Inc." on Justia Law

Plaintiffs, parents of a disabled student, filed suit under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. 1400 et seq., seeking reimbursement by the DOE for the costs of attending a private program. The hearing officer denied the request for reimbursement, concluding that it was untimely under Haw. Rev. Stat. 302A-443(a). The district court held, however, that the student's placement by the parents was “bilateral,” not “unilateral,” so that the parents’ request was not untimely, and concluded that the parents were entitled to reimbursement. The court agreed and concluded that the student's family is entitled to reimbursement for the 2010–11 school year because the DOE tacitly consented to his enrollment at the private school program by failing to provide an alternative. The court also affirmed the district court's fee award. View "Sam K. v. Hawaii Dept. of Educ." on Justia Law

Robinson worked for Concentra as a medical assistant from 2003 until she was terminated in 2010. Robinson applied for Social Security disability benefits four days after being terminated, claiming that she had multiple sclerosis that rendered her unable to work. The initial application was denied. An ALJ reversed, summarizing Robinson’s statements that: she must use a cane to walk because of leg numbness; she has poor vision; her hands frequently cramp and she has difficulty holding objects; and she needs help with all household chores. Robinson then filed suit against Concentra under Title VII, 42 U.S.C. 1981, and the Family and Medical Leave Act, claiming that she had been terminated on the basis of her race and color and in retaliation for filing a complaint with the EEOC and taking FMLA leave and that Concentra had interfered with her ability to take FMLA leave. The court entered summary judgment, finding that Robinson was estopped from showing that she was qualified for her position when she was terminated in September 2010, because she received disability benefits based on her statement that she was fully disabled as of June 2010. The Second Circuit affirmed, noting that Robinson failed to “proffer a sufficient explanation” for the contradictory statements. View "Robinson v. Concentra Health Servs.,Inc." on Justia Law

This action began in 1993 when Plaintiffs, representatives of a class of over 1.5 million Texas children eligible for Medicaid’s Early and Periodic Screening, Diagnosis, and Treatment program ("EPSDT"), sued various Texas state officials under 42 U.S.C. 1983 for violations of federal Medicaid law in the state’s implementation of the Program. The parties concluded a consent decree in 1996 in which Defendants promised to implement a number of changes, among which was a training program for participating health care providers. A few years later, after little progress had been made, the district court found Defendants in violation of the Decree. The Fifth Circuit reversed solely on Defendants' challenge to the Decree's validity under the Eleventh Amendment. In 2007, the parties agreed on a corrective action order to resolve Plaintiffs’ concerns with one part of the Decree. Defendants, believing their obligations to be satisfied, moved to dissolve that order and the associated Decree provisions under Rule 60(b)(5). The district court granted their motion. Plaintiffs appealed the district court’s termination of several provisions of the Decree decree and the dissolution of a related corrective action order pursuant to the first clause of Federal Rule of Civil Procedure 60(b)(5), that the judgment has been “satisfied, released, or discharged.” Finding no reversible error, the Fifth Circuit affirmed. View "Frew v. Suehs" on Justia Law

Plaintiff-appellant Alphonso Myers was injured on the job. He received social security benefits due to his inability to work. While claiming benefits, he applied for a job as an armed guard with defendant-appellee Knight Protective Service. On his job application, plaintiff made no mention of his prior injury. Supervisors at Knight noticed that plaintiff appeared to be in pain. Plaintiff then admitted that he had undergone a series of surgeries from the prior workplace injury. Concerned that this pain might interfere with his duties as an armed guard, Knight required plaintiff to submit to a physical exam before resuming his duties as a guard. Plaintiff waited months for the exam - long enough that plaintiff considered the delay as an effective termination from his job. Plaintiff then filed suit, arguing that he had been discriminated against on the basis of his race and disability. The district court granted summary judgment to Knight, and plaintiff appealed. Finding no reversible error, the Tenth Circuit affirmed the district court's judgment.View "Myers v. Knight Protective Service" on Justia Law

After his employment with the town was terminated, the plaintiff sought benefits under the Illinois Unemployment Insurance Act. The town opposed his claim, arguing that he was ineligible for unemployment benefits because he had constructively resigned “without good cause” by failing to obtain a commercial driver’s license within one year of starting work, a condition of his employment. The department agreed with the town. The plaintiff unsuccessfully appealed. He then sued in federal court under 42 U.S.C. 1983, claiming that he was fired in violation of his rights to due process of law and freedom of speech. The district court dismissed the claim as barred by collateral estoppel. The Seventh Circuit reversed, reasoning that the Illinois statute, 820 ILCS 405/1900(B), denies collateral estoppel effect to rulings in unemployment insurance proceedings. View "Council v. Village of Dolton" on Justia Law

The Board challenged the district court's decision to award O.L.'s parents reimbursement for one-on-one instruction outside the school setting as well as some of their attorney's fees. The parents cross-appealed the district court's decision not to award O.L. compensatory education. The court concluded that the parents were eligible for reimbursement; the district court was right to find that the alternative program was proper under the standard set forth in Bd. of Educ. of Hendrick Hudson Centr. Sch. Dist., Westchester Cnty. v. Rowley; even if the alternative program has its shortcomings, it was reasonably calculated to permit the child to obtain some educational benefit; the district court's reimbursement award was appropriate; the district court did not abuse its discretion when it took the quality of the chosen alternative into consideration; it was clear on the record that the district court properly weighed the evidence and did not abuse its considerable discretion when it denied the request for compensatory education; and there was no need to reverse the attorney's fee award since the court affirmed the district court's decision in all respects. View "R.L., et al. v. Miami-Dade Cty. Sch. Bd." on Justia Law

In 1997, in response to Congress’s enactment of the Personal Responsibility and Work Opportunity Reconciliation Act, which narrowed the eligibility of non-citizens for Medicaid and other federal benefits, the state of Maine extended state-funded medical assistance benefits to certain legal aliens rendered ineligible for Medicaid. In 2011, the Maine Legislature terminated these benefits. Appellants moved for a preliminary injunction against enforcement of the 2011 legislation, alleging that the state violated their equal protection rights by providing state-funded medical assistance benefits to United States citizens while denying those benefits to similarly situated non-citizens due solely to their alienage. The district court denied Appellants’ motion for a preliminary injunction. The First Circuit Court of Appeals affirmed the district court’s denial of a preliminary injunction, holding that Appellants’ equal protection claim failed on the merits because the state of Maine was not obligated to extend equivalent state-funded benefits to Appellants in the first place, and therefore, the termination of those benefits did not violate the Equal Protection Clause. View "Bruns v. Mayhew" on Justia Law