Justia Civil Rights Opinion Summaries

Plaintiffs Russell and Mary Ann Rueger and John Moyers appealed a trial courts grant of summary judgment in favor of Defendants Natural Resources Board and the District #9 Environmental Commission of Vermont. The matter arose from an Access to Public Records Act request. The court concluded that certain records held by Defendants reflected deliberations of an agency acting in a quasi-judicial role, and those were exempt from disclosure. Plaintiffs argued on appeal that the court erred in interpreting the Act. Upon review, the Supreme Court agreed with the trial court that the documents in question fell within the plain language of the Act, and were indeed exempt. Accordingly, the Court affirmed the grant of summary judgment in favor of Defendants.

The United States sued defendants, alleging they engaged in a pattern or practice of sex discrimination in the rental of housing. After a jury found for defendants, the district court granted in part defendants' motion for costs and attorneys' fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412, and the government subsequently appealed. In this case, the government brought a single pattern or practice claim. The court held that the district court should have made a single determination about whether the government's suit, as a whole, was substantially justified. The district court improperly considered the case as consisting of ten individual victims' claims for separate assessment, rather than a single pattern or practice claim. Consequently, this error required reversal.

The Rochester International Joint Zoning Board enacted a zoning ordinance that increased the size of a runway safety zone and changed the restrictions within the safety zone to allow fewer types of uses of land within the zone. The safety zone extended over property owned by Leon and Judith DeCook. The DeCooks brought an inverse condemnation action, alleging that the Board's decision constituted a taking for which the DeCooks were entitled to compensation. The district court first concluded there was no taking, and upon remand, again concluded that the Board's actions did not constitute a taking. The DeCooks appealed another time, and the Supreme Court ultimately held the ordinance constituted a taking of the DeCooks' property. The DeCooks subsequently moved for an award of attorney fees incurred during the appeals. The Supreme Court granted the motion, as the Cooks prevailed and were entitled under Minn. Stat. 117.045 to an award of reasonable costs and expenses, including attorney fees, incurred on appeal.

The City filed a complaint in eminent domain against Zara Thomas, trustee of two revocable trusts, and a motion for an order of immediate possession, seeking to procure a portion of Thomas's property for the purpose of constructing a bike trail. The circuit court granted the City's motion for order of immediate possession, and the City commenced construction on Thomas's property. Thomas appealed. The Supreme Court dismissed the appeal without prejudice, holding that the order did not conclude the parties' rights as to the subject matter in controversy, and therefore, was not a final and appealable order, as the circuit court had not yet addressed the issue of Thomas's right to just compensation and the amount of damages.

Plaintiffs sued Roommate.com in federal court, alleging that the website's questions requiring disclosure of sex, sexual orientation and familial status, and its sorting, steering and matching of users based on those characteristics violated the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., and the California Fair Employment and Housing Act (FEHA), Cal. Gov't Code 12955. Because precluding individuals from selecting roommates based on their sex, sexual orientation and familial status raised substantial constitutional concerns, the court interpreted the FHA and the FEHA as not applying to the shared living units. Therefore, the court held that Roommate.com's prompting, sorting and publishing of information to facilitate roommate selection was not forbidden by the FHA or the FEHA. Accordingly, the court vacated the district court's judgment and remanded for entry of judgment for defendant. Because plaintiffs were no longer prevailing, the court vacated the district court's order for attorney's fees and dismissed the cross-appeal on attorney's fees as moot.

Plaintiffs appealed from the district court's dismissal of their complaint against government officials and a group of telecommunications companies. Plaintiffs challenged section 802 of the Foreign Intelligence Surveillance Act (FISA), 50 U.S.C. 1885a, as an unconstitutional taking under the Fifth Amendment. Section 802 allowed the U.S. Attorney General to certify that a telecommunications company provided assistance at the behest of the government in connection with investigation of terrorism, thereby triggering immunity on the theory that application of section 802 required dismissal of plaintiffs' case and negated the cause of action under various federal statutes. The court held that the district court correctly dismissed plaintiffs' complaint for lack of jurisdiction where plaintiffs demanded no monetary damages. Consequently, the court need not reach the merits of the Takings Clause claim.

Plaintiff sued defendant, a general improvement district, arguing that defendant's policy of only allowing people who own or rent real property within defendant's 1968 boundaries to access beaches that it owned and operated was unconstitutional under the First Amendment and the Equal Protection Clause of the Fourteenth Amendment. The district court granted defendant's motion for summary judgment. The court held that the beaches were not a traditional public forum, and that plaintiff's exclusion from beaches did not violate either his First Amendment or Fourteenth Amendment rights. Accordingly, the court affirmed the judgment of the district court.

After the fiscal court voted to discontinue maintenance on a county road, Appellant, who owned property and lived on the road, erected a locked gate blocking the road and provided a key to each property owner on the road. Appellees, a non-profit association known as Preserve Rural Roads of Madison County, filed suit against Appellant to force him to remove the gates. The circuit court granted Appellees' motion for summary judgment, finding that Appellees had standing and that Appellant was without legal right or ownership to prohibit others from using the road. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Rural Roads had associational standing in this matter; (2) the discontinuance of maintenance on the county road did not affect any public easement rights; and (3) the lower courts' decisions in this case, holding that the county road is a public road and that Appellant could not block the road with gates, did not constitute an unlawful taking of Appellant's land.

Plaintiff entered into a lease with the housing authority in 2007 as "Resident" and named her two sons as "Household Members." The lease provided that certain criminal activities could lead to immediate eviction. Plaintiff received a notice to vacate a few weeks later, after a visit by her daughter led to a gunfight in the parking lot. While plaintiff's challenge was pending, second and third notices issued. Police had been called to her apartment and determined that plaintiff had stabbed her husband, who was living at the apartment and was high on cocaine. Officers found joints on the counter. Plaintiff vacated. The district court granted summary judgment in favor of the defendants on federal claims and declined to exercise jurisdiction over state law claims. The Seventh Circuit affirmed. The case is moot because plaintiff never contested the second and third notices and, therefore, cannot be restored to the apartment; there was evidence that she lied on her application and was never eligible for tenancy. She incurred no expenses and state court proceedings provided all the process that was due. The court rejected a claim of emotional distress and a claim that the complex constituted segregated housing.

The Township proposed redevelopment that would eliminate 327-329 existing homes in a neighborhood, occupied predominantly by low-income minority residents, and replace them with more expensive housing, unaffordable to current residents. About half of the existing brick row houses, built in the 1950s, were owner-occupied. A 2000 report described the area as characterized by blight, excess land coverage, poor land use, and excess crime; the Township began to acquire properties. By 2008, 75 homes had been destroyed and 148 had been acquired and left vacant. By 2009, 110 more homes were destroyed, causing noise, vibration, dust, and debris. Residents alleged violations of the Fair Housing Act (42 U.S.C. 3604(a)); the Civil Rights Act of 1866 (42 U.S.C. 1982) ; and the Equal Protection Clause. The district court granted summary judgment to the Township. The Third Circuit reversed. Drawing all reasonable inferences in favor of the residents, the evidence was sufficient to establish a prima facie case of disparate impact under the FHA. The court must ask whether the Township's legitimate objectives could have been achieved in a less discriminatory way. Contrasting statements about the cost and feasibility of an alternative relying on rehabilitation, create genuine issues of material fact.