Justia Civil Rights Opinion Summaries

In the case before the United States Court of Appeals for the Eighth Circuit, One Love Housing, LLC, a company that operates a residential sober living home in Anoka, Minnesota, sued the City of Anoka for refusing to grant a waiver from the city's zoning regulations. The regulations permit only a single family or a group of not more than four unrelated persons to reside together in the area where the sober home is located. One Love wanted to accommodate seven unrelated recovering addicts in the home. One Love and two residents of the home alleged that the city violated the Americans with Disabilities Act and the Fair Housing Act by refusing to grant this waiver.The district court granted One Love summary judgment on its claim that the city failed to reasonably accommodate the sober home's request. The court ordered the city to grant the waiver for One Love to house seven unrelated individuals recovering from substance abuse. The city appealed this decision.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision and remanded the case for further proceedings. The appellate court held that the district court erred by considering evidence that was not presented to the city council when it denied One Love's request for a waiver. The appellate court also found that the district court erred in granting summary judgment to One Love because there was a genuine dispute over whether the requested accommodation was reasonable and necessary. The court stated that the financial viability of One Love's sober home is relevant only if One Love can prove that the service it offers provides a therapeutic benefit that is necessary for people recovering from alcohol or drug abuse to successfully live in a residential neighborhood without relapsing. The court concluded that there are genuine issues of disputed fact on these issues. The court also declined to rule on One Love's disparate treatment and disparate impact claims, leaving those for the district court to address on remand. View "One Love Housing, LLC v. City of Anoka, MN" on Justia Law

The case revolves around two developers, SAS Associates 1, LLC and Military 1121, LLC, who filed a complaint against the City Council of Chesapeake, Virginia, alleging that their equal protection rights were violated when their rezoning applications were denied by the council. The developers owned several parcels of land in Chesapeake and sought to combine them to create a 90-acre development involving housing units, commercial space, and a conservation district. Their plans required rezoning, which was denied by the Council citing community opposition and the ability to develop under existing zoning classifications. The developers filed a complaint alleging that their application was denied even though similar applications from other developers were approved, and the council's reasons for denial were irrational and arbitrary.The United States Court of Appeals for the Fourth Circuit upheld the district court’s decision to dismiss the developers' claim. The Court of Appeals found that the developers failed to demonstrate that they were treated differently from others who were similarly situated and that the unequal treatment was the result of discriminatory animus. Furthermore, the court highlighted that zoning decisions are primarily the responsibility of local governments and that the Developers did not provide any valid comparators to support their claim of discriminatory treatment. The court noted the lack of any evidence to infer discriminatory intent on the part of the City Council members and ruled that the Developers' disagreement with the Council's decision does not render the Council's judgment call pretextual. The court affirmed the judgment of the district court dismissing the complaint. View "SAS Associates v. City Council of Chesapeake" on Justia Law

In this case, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the park's policy that required all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, four Latino families, argued that this policy violated the Fair Housing Act (FHA) because it disproportionately ousted Latinos from the park. The district court initially granted summary judgment in favor of the park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.However, the United States Court of Appeals for the Fourth Circuit reversed the district court's judgment. The court of appeals found that the district court had misunderstood the federal anti-harboring statute. The court of appeals noted that the statute requires more than simply entering into a lease agreement with an undocumented immigrant to be in violation. Rather, a person must knowingly or recklessly conceal, harbor, or shield undocumented immigrants from detection. The court of appeals concluded that the park's policy of verifying tenants' legal status did not serve the park's stated interest of avoiding liability under the anti-harboring statute. Consequently, the park had not met its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims under the FHA. As such, the court of appeals reversed the grant of summary judgment for the park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In a case brought before the United States Court of Appeals for the Fourth Circuit, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the Park's policy requiring all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, noncitizen Latino families, argued that this policy disproportionately ousted Latinos from the Park and therefore violated the Fair Housing Act (FHA). The district court initially granted summary judgment in favor of the Park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.On appeal, the Fourth Circuit reversed the district court's decision. The court determined that the anti-harboring statute did not plausibly put the Park at risk for prosecution simply for leasing to families with undocumented immigrants. Furthermore, the court found that the Park's policy did not serve a valid interest in any realistic way to avoid liability under the anti-harboring statute. Therefore, the Park did not meet its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. Given these findings, the Court of Appeals did not need to reach the third step to determine whether a less discriminatory alternative was available. As such, the court reversed the grant of summary judgment for the Park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In this case, Nagla Abdelhalim, an Egyptian immigrant and a Muslim woman, filed suit against her neighbors Aaron and Dinara Lewis and Andrew and Roxana McDevitt, alleging that they violated the Fair Housing Act by engaging in a year-long campaign of harassment against her in an attempt to drive her out of the neighborhood because of her race, national origin, and religion. The dispute began when Abdelhalim started a short-term rental business, renting out her basement on platforms such as Airbnb, which violated a local ordinance at the time and was disapproved by her neighbors. The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants, concluding that Abdelhalim had not produced evidence of intentional discrimination based on a protected ground.On appeal, the United States Court of Appeals for the Fourth Circuit considered only whether the district court erred in granting the defendants' motions for attorneys’ fees. The Fourth Circuit ruled that the district court had applied the wrong legal standard and thus abused its discretion in granting attorneys’ fees to the defendants. The court noted that while a plaintiff’s failure to prevail is a factor to consider, it alone cannot be the basis for concluding that a claim was without foundation. The court found that Abdelhalim had provided sufficient evidence to support her belief that the defendants intended to discriminate against her based on her race, religion, or national origin. Thus, her claims were not without foundation, and the award of attorneys' fees to the defendants was vacated. View "Abdelhalim v. Lewis" on Justia Law

In the case before the United States Court of Appeals for the Second Circuit, Ateres Bais Yaakov Academy of Rockland (ABY) sued the Town of Clarkstown, George Hoehmann, CUPON Inc., and Citizens United to Protect Our Neighborhoods of Greater Nanuet Inc. ABY, a religious educational institution, planned to purchase property in Clarkstown, New York, to establish an Orthodox Jewish school. It alleged that the Defendants manipulated an ostensibly neutral building permit application and zoning appeals process to block this construction. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that ABY's religious discrimination and civil rights claims were not ripe as it had not received a final decision from the town’s Zoning Board of Appeals (ZBA) and that the lost-contract injury underpinning ABY’s tortious interference claim was not traceable to the Town Defendants.In this appeal, the Second Circuit disagreed with the district court. The Second Circuit found that the ZBA's refusal to adjudicate ABY's appeal of its permit application constituted a final decision for ripeness purposes. The court also determined that ABY had plausibly alleged a causal connection between the Town Defendants’ actions and the injuries resulting from ABY's lost contract with Grace Church. Therefore, the Second Circuit reversed the district court's judgment and remanded the case for further proceedings. View "Ateres Bais Yaakov Academy of Rockland v. Town of Clarkstoawn" on Justia Law

In 1882-1883, the Railway acquired property and constructed the now-abandoned railroad line. In 2008, the Railway filed a notice of exemption from formal abandonment proceedings with the Surface Transportation Board (STB). The Illinois Department of Natural Resources showed interest in railbanking and interim trail use under the 1983 National Trails System Act Amendments, 16 U.S.C. 1247(d). The STB issued a Notice of Interim Trail Use (NITU). The owners of property adjoining the railroad line sued, alleging takings by operation of the Trails Act with respect to 51 parcels; 22 parcels were conveyed by instruments including the words “right of way” (ROW Agreements); three were conveyed by instruments including the words “for railroad purposes” (Purpose Agreements); and three are those for which no instruments were produced.The Claims Court granted the government summary judgment, finding that the Railway held the ROW Agreement and Purpose Agreement parcels in fee simple and that the owners failed to show that they had cognizable property interests in the non-instrument parcels. The Federal Circuit reversed. The court rejected the government’s argument that using the term “right of way” in the ROW Agreements referred to the land conveyed, not a limitation on the interest conveyed. For the Purpose Agreements, the Claims Court mistakenly relied on cases discussing deeds that did not include an expression of purpose in the granting clause. Illinois law indicates that the Railway obtained, at most, an easement over the non-instrument parcels. View "Barlow v. United States" on Justia Law

The Supreme Court affirmed the determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" on Justia Law

Michigan’s Uniform Unclaimed Property Act (UUPA) allows the state to take custody—not ownership—of unclaimed property “in trust for the benefit of the rightful owner” After publishing required notices, the state sells or liquidates the unclaimed property within three years of receiving it, unless the owner brings a valid claim, then deposits the proceeds into its general fund, subtracting reasonable administration costs; the owner can no longer reclaim his property, but can still recover the “net proceeds” from its sale. UUPA apermits owners to recover the interest earned on their property and post-liquidation interest if the property accrued interest before the state took custody of it.Two companies delivered O’Connor’s properties—checks collectively worth no more than $350— to the state after he failed to claim them. The state liquidated them. O’Connor filed a claim for compensation. Michigan reimbursed O’Connor for the value of his property, but not any post-liquidation interest. O’Connor alleges that neither the state nor the third-party holders provided him with the statutorily required notices. O’Connor sued Michigan under the Fifth Amendment; Michigan’s Treasurer, and the Administrative Manager of the Unclaimed Property Program, under 42 U.S.C. 1983. The Sixth Circuit held that the officials are entitled to qualified immunity on O’Connor’s taking claims but not his due process claims. The district court correctly dismissed O’Connor’s claims against the state but should not have dismissed them with prejudice. View "O'Connor v. Eubanks" on Justia Law

Willow purchased a house that needed repairs. Bids for the work exceeded $100,000. Renovations began in 2017 but soon halted. After several years passed, with the house remaining empty, the Village proposed its demolition as a nuisance. The Village published notice, posted notices on the house, and mailed notice to Willow, which concedes having actual knowledge of the impending demolition. Willow did not respond until the week scheduled for the demolition when its lawyer proposed a meeting. The parcel was sold at auction to satisfy the Village’s lien for demolition expenses.Willow sued under 42 U.S.C. 1983, claiming a taking without compensation. The Seventh Circuit affirmed summary judgment for the Village. Demolition of a dilapidated structure that constitutes a public nuisance is not problematic under the Due Process Clause and does not require compensation. The protection that the federal Constitution offers to property owners is notice and an opportunity for a hearing. The Village gave such a notice to Willow, which did not ask for a hearing. Illinois law offers procedures that are constitutionally adequate; someone wanting to stop a demolition need only file suit in state court, which automatically blocks action until the judge decides whether the building meets the statutory criteria for demolition. The district court was not required to decide a state law inverse-condemnation claim. View "Willow Way, LLC v. Village of Lyons, Illinois" on Justia Law