Justia Civil Rights Opinion Summaries

The Utah Department of Transportation (UDOT) owned a piece of property on land adjacent to property owned by Plaintiff. Plaintiff filed a condemnation action, asserting a right to condemn a portion of UDOT's parcel to construct an access road to the development Plaintiff planned to build on its property. The district court granted summary judgment for UDOT, finding that the two parties' uses were incompatible because the detention pond on UDOT's property left no room for Schroeder's proposed road. Plaintiff appealed, challenging the district court's invocation of the more necessary public use doctrine and its refusal to allow an exception under the doctrine of compatible uses. The Supreme Court affirmed, holding that, absent any basis for a compatible use exception in this case, UDOT was entitled to judgment as a matter of law. View "Schroeder Invs., L.C. v. Edwards" on Justia Law

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law

The City of Baltimore initiated a condemnation action to acquire an old theater once used as a vaudeville venue. The theater's owner (Owner) contested the action, arguing that the City had no right to condemn the property. Six weeks before trial, Owner filed an emergency motion demanding a postponement and an order requiring the City to pay to move all the junk out of the theater prior to trial so the jury would not view the property in its existing condition. The trial court denied the motion and the jury viewed the theater as is. The court of special appeals ruled that the trial court did not abuse its discretion in denying Owner's motion. The Court of Appeals affirmed, holding that Owner was not entitled to a payment in advance of trial, and Owner suffered no prejudice from the denial beyond what it brought upon itself. View "A&E North, LLC v. Mayor & City Council of Baltimore" on Justia Law

Plaintiff applied for a special permit to open an adult entertainment establishment within an industrial district. By the terms of a City ordinance, adult entertainment was forbidden on sites within an industrial district. The City denied Plaintiff's application. The Zoning Board of Appeals denied Plaintiff's appeal for variances from the ordinances. At issue on appeal was whether the City's zoning ordinances violated the First Amendment by preventing Plaintiff from opening his adult entertainment establishment on land zoned industrial without providing an adequate opportunity elsewhere. The federal district court entered summary judgment for the City. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in calculating the land available to Plaintiff for adult use; and (2) the available land provided Plaintiff a reasonable opportunity to open an adult business. View "Lund v. Fall River, Mass." on Justia Law

In this appeal, the court considered whether San Rafael's mobilehome rent regulation violated the park owners' substantive due process rights, constituted a regulatory taking under Penn Central Transportation Co. v. New York City, or ran afoul of the public use requirement of the Fifth Amendment under the standards articulated in Kelo v. City of New London. The court concluded that the district court properly rejected the City's arguments that MHC's claims were barred by the statute of limitations and precluded by res judicata, and the district court did not abuse its discretion in allowing MHC to amend its complaint. The court also concluded that the regulation did not constitute either a Penn Central or a private taking. Because the court reached the merits of the takings issue, the court need not resolve the question of ripeness. The court further concluded that the district court did not err in granting judgment on MHC's substantive due process claims; the district court did not err in submitting the breach of settlement contract claims to the jury, denying the motion for a directed verdict on that question, denying the motion for a new trial, or awarding attorneys' fees; and in its original lawsuit, MHC waived its claim for damages in order to have a bench trial on the constitutional claims. Accordingly, the court reversed the district court's holding as to the Penn Central and private takings, but affirmed the judgment in all other respects. View "MHC Limited Financing v. City of San Rafael" on Justia Law

This action arose out of Plaintiffs' alleged breach of a conservation restriction appurtenant to their Hudson, Massachusetts home. Plaintiffs and members of the Hudson Conservation Commission clashed over Plaintiffs' compliance efforts. In the meantime, a Hudson Police captain filed charges against Plaintiff for criminal harassment and threat to commit a crime based on Plaintiff's alleged misconduct to his neighbors. All charges were later dropped against Plaintiff. Plaintiffs subsequently filed a 42 U.S.C. 1983 suit against the Town of Hudson, the Commission, and several state and local officials, alleging that Commission members, an administrator, and a building inspector violated the equal protection clause by selectively enforcing local laws against them and that the conduct of town officials and other defendants were so outrageous as to constitute substantive due process violations. The district court dismissed the suit. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' complaint did not plead facts sufficient to support any of their federal claims. View "Freeman v. Town of Hudson" on Justia Law

Appellants in this case were rental property owners in the City of La Vista. Appellant sought a declaration that the City's ordinance establishing a rental housing licensing and inspection program was unconstitutional. Appellants claimed that the ordinance's application to rental property residences only, and not to owner-occupied residences, was an arbitrary and unreasonable classification that violated Nebraska's constitutional prohibition against special legislation. The district court entered summary judgment for the City. The Supreme Court affirmed, holding that the City's ordinance did not violate the prohibition against special legislation, as (1) the distinction between rental property residences and owner-occupied residences presented a real difference in circumstances; and (2) the City's regulation of rental properties was reasonably related to its legitimate goal of maintaining safe rental housing and livable neighborhoods. View "D-CO, Inc. v. City of La Vista" on Justia Law

This case involved an inverse-condemnation dispute over ten acres. At issue was who had title to the parcel: the Texas Department of Transportation (TxDOT), the City of Edinburg (City), or API Pipe Supply and Paisano Service Company (collectively, API). In 2003, the trial court awarded the City a "fee title" to the property subject to a drainage easement granted to TxDOT. In 2004, the trial court entered a judgment purporting to render the 2003 judgment null and void. API claimed the judgment gave API fee-simple ownership, subject to a drainage easement granted to the City, and, via subsequent conveyance, to TxDOT. In 2005, TxDOT began its drainage project. API, relying on the 2004 judgment, brought a takings claim for the value of the removed soil. The trial court held in favor of API, and the court of appeals affirmed. The Supreme Court reversed and dismissed the suit, holding (1) the 2004 judgment was void and therefore could not supersede the valid 2003 judgment; (2) API was statutorily ineligible for "innocent purchaser" status, and equitable estoppel was inapplicable against the government in this case; and (3) because API held no interest in the land, API's takings claim failed. View "Dep't of Transp. v. A.P.I. Pipe & Supply, LLC" on Justia Law

Appellant rented second-floor office space and owned one of the upper-floor residential units in the Baxter Hotel. In 2008, the Baxter Homeowners Association (BHA) restricted access to the hotel's elevator by only permitting unit owners and their tenants to access the elevator via swipe key cards. After Appellant filed a complaint with the Montana Human Rights Bureau (Bureau), the BHA board installed a time clock system that would keep the elevator unlocked during business hours and locked at night. Appellant subsequently moved his law office out of the building. Ultimately, a hearing officer with the Bureau concluded that BHA violated Mont. Code Ann. 49-2-304(1)(a) when it failed to provide a reasonable alteration to the elevator to permit disabled persons to have unfettered access to the second floor business offices in the hotel during business hours, awarded $6,000 in damages to Appellant, and denied both parties' requests for attorneys' fees. The Human Rights Commission affirmed. The district court reversed. The Supreme Court affirmed, holding that Appellant did not possess proper standing to file a complaint of discrimination on behalf of his unidentified and potential clients. View "Baxter Homeowners Ass'n, Inc. v. Angel" on Justia Law

Complainants were disabled residents of a condominium. Complainants filed a complaint against the condominium's board of directors (the Condo) and their property management company, alleging that the Condo had discriminated against them by refusing to grant a reasonable accommodation for their disabilities. Specifically, Complainants alleged that the Condo refused to provide keys to the side and back doors to their building. The Office of Administrative Hearings ruled that Complainants had not proven that giving them the keys to the side and back doors was necessary and reasonable. The Appeal Board of the Commission on Human Relations (Board) disagreed and determined that the Condo (1) was required to prove that giving Complainants keys was an unreasonable financial burden, and (2) failed to establish that giving Complainants keys presented an undue burden. The circuit court reversed. The court of special appeals vacated the circuit court's decision. The Court of Appeals affirmed, holding (1) the Condo was required to prove that providing keys to Complainants was unreasonable in light of the costs attendant in doing so; and (2) the Board properly performed the requisite balancing test when it concluded the Condo unreasonably denied Complainants' requests to be given the disputed keys. View " Cameron Grove Condo. Bd. of Dirs. v. Comm'n on Human Relations" on Justia Law