Justia Civil Rights Opinion Summaries

In 2017, Gratiot County foreclosed on Donald Freed’s home due to unpaid taxes. Freed’s property, valued at $98,800, was sold for $42,000, although he owed just under $1,110. The county kept all proceeds from the sale, as Michigan’s General Property Tax Act (GPTA) did not require returning surplus proceeds to the property owner. Freed sued Gratiot County and its treasurer, Michelle Thomas, under 42 U.S.C. § 1983, claiming a violation of the Fifth and Fourteenth Amendments. Michigan intervened to defend the GPTA’s constitutionality.The United States District Court for the Eastern District of Michigan dismissed Freed’s complaint for lack of subject matter jurisdiction, citing Wayside Church v. Van Buren County. Freed appealed, and the Sixth Circuit reversed the dismissal, recognizing that the Supreme Court’s ruling in Knick v. Township of Scott partially abrogated Wayside Church. On remand, the district court granted partial summary judgment to Freed, affirming that the county had to pay Freed the difference between the foreclosure sale and his debt, but dismissed claims against Thomas due to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed Freed’s entitlement to attorneys’ fees from Gratiot County and Michigan. However, the court vacated the district court’s fee calculation and remanded for further proceedings. The Sixth Circuit held that Freed prevailed against both Gratiot County and Michigan, and Michigan’s intervention under 28 U.S.C. § 2403(b) subjected it to attorneys’ fee liability. The court found the district court’s explanation for reducing Freed’s hours and rate by 35% insufficient and required a more detailed justification for the fee award calculation. View "Freed v. Thomas" on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law

Three organizations, Inclusive Louisiana, Mount Triumph Baptist Church, and RISE St. James, sued St. James Parish, the Parish Council, and the Parish Planning Commission, alleging violations of their constitutional and statutory civil rights. They claimed that the Parish discriminated against them by directing hazardous industrial development towards majority-Black districts and Black churches, where their members and congregants live. They also argued that the Parish's actions desecrated and restricted access to cemeteries of their enslaved ancestors.The United States District Court for the Eastern District of Louisiana dismissed all claims. It held that the plaintiffs lacked standing for some claims and that other claims were time-barred, as they were based on the Parish's 2014 Land Use Plan. The court also dismissed claims related to religious injuries, stating that the injuries were not traceable to the Parish's actions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in dismissing the claims as time-barred, noting that the plaintiffs alleged ongoing discriminatory practices, not just a single incident. The court also found that the plaintiffs had standing to sue for property injuries and health-related injuries. Additionally, the court held that the plaintiffs had standing to pursue claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Louisiana Constitution, as their alleged injuries were traceable to the Parish's conduct.The Fifth Circuit reversed the district court's dismissal of the claims and remanded the case for further proceedings. The court emphasized that the plaintiffs had sufficiently alleged ongoing discriminatory practices and injuries that were fairly traceable to the Parish's actions. View "Inclusive Louisiana v. St. James Parish" on Justia Law

Sara Watts, an African American woman, sued her former homeowners’ association, Joggers Run Property Owners Association (HOA), alleging racial discrimination under the Fair Housing Act (FHA) and the Civil Rights Act. Watts claimed the HOA interfered with her property enjoyment through unwarranted citations, restricted access to amenities, and discriminatory treatment as a former HOA board member. She cited provisions from the FHA (42 U.S.C. §§ 3604(b), 3617) and the Civil Rights Act (42 U.S.C. §§ 1981, 1982).The United States District Court for the Southern District of Florida dismissed Watts' claims, ruling that the FHA did not cover discriminatory conduct occurring after the purchase of her home and that Watts failed to specify the contractual terms the HOA allegedly violated. The court found her allegations insufficient to support claims under the FHA and the Civil Rights Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Watts presented plausible claims under the FHA and the Civil Rights Act. It found that the FHA's language is broad and inclusive, prohibiting a wide range of discriminatory conduct related to housing. The court concluded that the HOA's actions, including restricted access to amenities and selective enforcement of rules, fell within the scope of the FHA. The court also determined that Watts sufficiently alleged intentional racial discrimination causing contractual injury under Section 1981 and that the HOA's actions violated her right to use property on an equal basis with White citizens under Section 1982.The Eleventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watts v. Joggers Run Property Owners Association, Inc." on Justia Law

The case involves BAK Realty, LLC, and Crossing Over, Inc., which operate a sober house in a three-family dwelling in Fitchburg, Massachusetts. The sober house, located in a residential B (RB) district, houses thirteen unrelated individuals recovering from addiction. The City of Fitchburg's zoning ordinances classify the sober house as a boarding house, a use not permitted in the RB district. The plaintiffs argue that the city's zoning ordinances violate the anti-disability discrimination provision of the Zoning Act, G. L. c. 40A, § 3, fourth par., which they interpret as requiring the city to treat the sober house residents as a "family" under local zoning laws.The Superior Court judge granted partial summary judgment in favor of the plaintiffs, annulling the decision of the Fitchburg Zoning Board of Appeals (board). The judge concluded that G. L. c. 40A, § 3, required the city to treat the sober house residents the same as a family or any similar-sized group of unrelated persons, whichever is more favorable. The judge ruled that the city's zoning ordinances could not be enforced against the sober house residents.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Superior Court's interpretation. The court held that G. L. c. 40A, § 3, fourth par., does not preempt municipalities from defining "family" for zoning purposes. The statute requires that disabled persons in congregate living arrangements be treated the same as either families or similar-sized groups of unrelated persons, but not necessarily both. The court found that the residents of the sober house did not meet the local definition of "family" and were treated the same as any similar group of thirteen unrelated people living together. Therefore, the court reversed the judgment of the Superior Court, upholding the board's decision that the sober house was operating as a boarding house, a use not permitted in the RB district. View "BAK Realty, LLC v. City of Fitchburg" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law

The plaintiffs, Thomas Ghelf, Tricia Hansen, Constance and Thomas Klein, Maureen Sommerfeld, and Mississippi Sports and Recreation, Inc. (MSR), own abutting properties in the Town of Wheatland, Vernon County, Wisconsin. They alleged that the Town, its officials, Vernon County, the County Treasurer, and unknown agents and employees engaged in a harassment campaign against them. This included coordinated complaints about their businesses, unlawful arrests, failures to respond to emergency services, excessive property tax assessments, a foreclosure action, and the designation of a private driveway as a public road.The United States District Court for the Western District of Wisconsin dismissed the plaintiffs' tax assessment and road claims for lack of subject matter jurisdiction, abstained from exercising jurisdiction over the foreclosure claims, and dismissed the remaining claims for failure to state a claim. The court held that the Tax Injunction Act and principles of comity barred the tax assessment and foreclosure claims. It also found that the plaintiffs' claims related to events before September 15, 2016, were time-barred by the statute of limitations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal of the tax assessment and foreclosure claims, agreeing that the Tax Injunction Act and comity principles deprived the district court of jurisdiction. The appellate court also upheld the dismissal of claims related to events before September 15, 2016, as time-barred. However, the Seventh Circuit reversed the dismissal of the plaintiffs' road claims, finding that these claims were not barred by claim or issue preclusion. The case was remanded for further proceedings on the road claims, and the court held that Town Chairman Jayne Ballwahn should not be dismissed from the suit at this stage. View "Ghelf v Town of Wheatland" on Justia Law

Eight Black homeowners in New York City sued a lending institution and affiliated entities, alleging that the lender violated federal, state, and city antidiscrimination laws. They claimed the lender made mortgage refinancing loans with high default interest rates to Black and Latino individuals in poor neighborhoods who had no income, no assets, and low credit scores but high equity in their homes, and then foreclosed on the loans when the individuals defaulted. The United States District Court for the Eastern District of New York entered a final judgment awarding four homeowners $722,044 in compensatory damages and four others nominal damages.The lender appealed, arguing that the district court erred in three ways: by finding the homeowners' claims timely under the doctrine of equitable tolling and the discovery rule of accrual, in its instructions to the jury on disparate impact and disparate treatment theories of discrimination, and in holding that a release-of-claims provision in a loan modification agreement signed by two homeowners was unenforceable as a matter of law.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the district court did not abuse its discretion in holding that the homeowners' claims were timely under the doctrine of equitable tolling. The court also found no error in the district court's instructions to the jury on disparate impact and disparate treatment theories of discrimination. Finally, the court agreed that the release-of-claims provision in the loan modification agreement was unenforceable as a matter of law. Accordingly, the Second Circuit affirmed the judgment of the district court. View "Saint-Jean v. Emigrant Mortg. Co., Inc." on Justia Law

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law