Justia Civil Rights Opinion Summaries

Residents of the Royal Palm Village Mobile Home Park in Haines City, Florida, sued the Park’s owners in federal court. The residents alleged that the owners had engaged in fraud by, among other things, illegally passing on costs to the residents, embellishing lot descriptions to justify increased rents, and falsely promising to upgrade roads and other common areas. The residents filed an amended complaint alleging violations of a slightly different collection of state and federal statutes: four counts under both the federal and Florida RICO statutes—as well as one under the ADA. The owners moved to dismiss. The district court dismissed the amended complaint for essentially the same reasons that it had dismissed the initial complaint. The owners now appeal the district court’s rejection of their fee requests pertaining to the first and second amended complaints. Those complaints, the owners argue, were also “to enforce” the FMHA because the residents predicated the RICO claims in those complaints on violations of the FMHA.   The Eleventh Circuit affirmed the district court’s ruling. The court explained that here the alleged FMHA violations set out in the residents’ amended complaints were not independent legal claims, but rather components of other claims (e.g., the RICO claims). The amended complaints did not seek any relief under the FMHA. Nor did they request compliance with the FMHA. Those complaints, therefore, were not “proceeding[s] to enforce provisions” of the FMHA. The district court correctly denied fees to the owners as to those complaints under Section 723.068. View "Royal Palm Village Residents, Inc., et al v. Monica Slider, et al" on Justia Law

The Supreme Court affirmed in part and reversed in part and remanded this matter for a new trial, holding that the district court erred in proceeding to a trial without a jury on Plaintiff's causes of action for breach of contract, breach of guaranty, and unjust enrichment.Plaintiff's brought this complaint against Defendants for, among other causes of action, forcible entry and detainer. The district court granted relief on the forcible entry and detainer claim, ordering restitution. After a bench trial, the district court heard the remaining causes of action and awarded damages to Plaintiff. The Supreme Court reversed in part, holding (1) Plaintiff's remaining causes of action were legal in nature, and the issues of fact that arose thereunder entitled Defendants to a jury trial unless waived; and (2) there was no waiver of Defendants' right to a jury trial. View "132 Ventures, LLC v. Active Spine Physical Therapy, LLC" on Justia Law

Detroit prohibits street vendors from selling their goods within 300 feet of sports arenas or stadiums. After the completion of Little Caesar’s Arena in 2017, the new home of the Red Wings and Pistons, Detroit refused to renew three vendor licenses for locations that fell within the 300-foot exclusion zone. The licenses had been in place since 2008. The displaced vendors sued, claiming due process violations.The Sixth Circuit affirmed summary judgment in favor of Detroit. The ordinance does not create a property interest in a vendor’s license; it never says that applicants will receive licenses for the places they choose but requires that they apply “for an approved location,” and warns that the city may “terminate[] or eliminate[]” a vendor location. Detroit retains the discretion to deny or suspend licenses to prevent a violation of the rules or to protect public safety. Even a protected property interest would not suffice to defeat Detroit’s decision. Detroit had rational reasons for denying these vendor applications: its interest in preventing congestion on its sidewalks, ensuring sidewalk safety, eliminating blight and litter, and protecting arena operators from competition. A 300-foot buffer zone around arenas is a rational way to advance Detroit’s interest in preventing congestion. View "Williams v. City of Detroit" on Justia Law

The Supreme Court affirmed in part, reversed in part, vacated in part, and remanded the grants of dismissal and summary judgment as to claims of improper actions taken by the Regional Transportation Commission of Washoe County (RTC) during the completion of a construction project on Appellants' party following condemnation proceedings, holding that the district court erred in part.Specifically, the Supreme Court held that the district court (1) did not err in dismissing Appellants' claim for waste; (2) did not err in dismissing Appellants' separate cause of action for injunctive relief; (3) did not err in granting the RTC's motion for summary judgment as to Appellants' contract-based claims; and (4) erred in granting summary judgment in favor of the RTC as to Appellants' trespass claim and their request for declaratory relief. The Court vacated the order awarding RTC attorney fees and costs because, after remand, the RTC might not be the prevailing party. View "Iliescu v. Regional Transportation Comm'n" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's denial of Defendant's motion to dismiss the criminal case against him based on an alleged violation of his statutory speedy-trial right, holding that the State did not violate Defendant's speedy-trial rights.The day before trial was set to begin, Defendant moved to dismiss the case base on an alleged violation of his statutory right to a speedy trial. The trial court denied the motion. Thereafter, Defendant entered a plea of no contest to a single felony count. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no violation of Defendant's statutory speedy-trial rights in this case. View "State v. Belville" on Justia Law

Oakland County took title to the plaintiffs’ homes under the Michigan General Property Tax Act, which (after a redemption period) required the state court to enter a foreclosure judgment that vested “absolute title” to the property in the governmental entity upon payment of the amount of the tax delinquency or “its fair market value.” The entity could then sell it at a public auction. No matter what the sale price, the property’s former owner had no right to any of the proceeds.In February 2018, under the Act, Oakland County foreclosed on Hall’s home to collect a tax delinquency of $22,642; the County then conveyed the property to the City of Southfield for that price. Southfield conveyed the property for $1 to a for-profit entity, the Southfield Neighborhood Revitalization Initiative, which later sold it for $308,000. Other plaintiffs had similar experiences.The plaintiffs brought suit under 42 U.S.C. 1983, citing the Takings Clause of the Fifth Amendment. The Sixth Circuit reversed the dismissal of the suit. The “Michigan statute is not only self-dealing: it is also an aberration from some 300 years of decisions.” The government may not decline to recognize long-established interests in property as a device to take them. The County took the property without just compensation. View "Hall v. Meisner" on Justia Law

The Watters moved into the Preserve as the only black couple in the subdivision. Kate and Ed Mamaril have each been president of the Homeowners’ Association (HOA). When the Watters began construction, Ed told them that they were not welcome. There was a dispute about the Maramils’ cats. Subsequent encounters involved shoving and racial epithets. When the Watters asked for copies of the HOA’s restrictive covenants, Marmaril, as HOA president, refused to provide copies. The Watters had disputes with the HOA concerning mailboxes, paint colors, and porch posts. The HOA has a rule against privacy fences. Watters is a veteran who was diagnosed with PTSD after being trapped in a cave, with a dog. He is unable to work because of a terminal lung condition that further exacerbates his reactivity to dogs. Watters states that his doctors advised him to get a privacy fence to mitigate his PTSD triggers. He unsuccessfully requested the privacy fence as a reasonable and necessary accommodation. A subsequent dispute involved the Watters’ plan to construct a pool.In a suit under Fair Housing Act and 42 U.S.C. 1982, the district court granted the defendants summary judgment. The Seventh Circuit vacated. The Watters can proceed with their race discrimination claim under the Act and section 1982 against the Mamarils, but not against the HOA. Without any evidence showing that the HOA knew about Watters’s PTSD, the Watters’ failure-to-accommodate claim cannot survive. View "Watters v. Homeowners Association at the Preserve at Bridgewater" on Justia Law

The Supreme Court reversed the judgment of the court of appeal holding that a sidewalk picket purporting to protest a real estate company's business practices after the company evicted two long-term residents from their home did not constitute speech in connection with a public issue under the anti-SLAPP statute's catchall provision, holding that the sidewalk protest constituted protected activity within the meaning of Cal. Code Civ. Proc. 425.16(e)(4).The court of appeal held that the sidewalk picket at issue was beyond the scope of anti-SLAPP protection because the picket did not implicate a public issue. Rather, the court of appeal concluded that the picket concerned only a private dispute between the real estate company and the two residents. The Supreme Court reversed after applying both steps of the analysis set forth in FilmOn.com Inc v. DoubleVerify Inc., 7 Cal.5th 133 (2019), holding that the sidewalk protest furthered public discussion of the public issues it implicated. View "Geiser v. Kuhns" on Justia Law

The Supreme Court reversed the the order of the trial court granting summary judgment in favor of the Gary Housing Authority and dismissing allegations that the Housing Authority's notice of its administrative taking of 624 Broadway, LLC's property was constitutionally deficient, holding that the deficient notice was not harmless.The Housing Authority only provided notice of its taking of 624 Broadway's property by publication, despite knowing how to contact the LLC. After 624 Broadway unsuccessfully requested the Housing Authority to postpone the meeting to its appraiser could assess the property 624 Broadway brought this complaint, alleging that the Housing Authority violated its federal due process rights. The trial court granted summary judgment for the Housing Authority. The Supreme Court reversed, holding (1) the Housing Authority's constitutionally deficient notice to 624 Broadway was prejudicial; and (2) 624 Broadway was entitled to a damages hearing. View "624 Broadway, LLC v. Gary Housing Authority" on Justia Law

In 2016, the Department of Housing and Urban Development promulgated a rule prohibiting the use of lit tobacco products in HUD-subsidized public housing units and their immediate surroundings. Appellants, led by New York City Citizens Lobbying Against Smoker Harassment (C.L.A.S.H.), brought an action raising a number of statutory and constitutional challenges to the Rule. The district court rejected all of C.L.A.S.H.’s claims.The D.C. Circuit affirmed, finding that the Department did not exceed its authority in passing the rule and was not arbitrary, capricious, and an abuse of discretion. The Court similarly rejected C.L.A.S.H.’s constitutional claims under the Spending Clause and the Fourth, Fifth, and Tenth Amendments. View "NYC C.L.A.S.H., Inc. v. Marcia L. Fudge" on Justia Law