Justia Civil Rights Opinion Summaries

Plaintiff-Appellant Regina Daniels, a former United Parcel Service (UPS) dispatcher who worked in UPS's Kansas City, Kansas facility, brought suit against the company alleging discrimination based on her sex and age. The district court granted summary judgment in favor of UPS, and Plaintiff appealed. Upon review of the district court's decision, the Tenth Circuit concluded the district court did not err in finding: (1) most of Plaintiff's discrimination claims were untimely; and (2) the claims of discrimination and retaliation that remained failed as a matter of law. View "Daniels v. United Parcel Service, Inc." on Justia Law

Plaintiff-Appellant Frank Brown filed this action against his former employer Defendant-Appellee ScriptPro, LLC, alleging violations of the Family Medical Leave Act (FMLA), the Fair Labor Standards Act (FLSA), and Title VII of the Civil Rights Act of 1964 based on his termination in November 2008. The district court granted summary judgment in favor of ScriptPro, and Plaintiff appealed. The appellate court found that Mr. Brown did not produce sufficient evidence proving a genuine issue of fact existed to survive summary judgment. Upon review, the Tenth Circuit agreed and affirmed the trial and appellate courts' decisions. View "Brown v. ScriptPro, LLC" on Justia Law

Plaintiffs-Appellees Ann and Greg Elwell were in the process of adopting T.S., a young boy who had been in their care almost his entire life. But approximately one month after a complaint of emotional abuse of another child in the Elwells' care, state officials withdrew the license allowing the Elwells to care for T.S. and removed him from their home without any advance notice. Despite a state court's finding that the agency acted wrongfully in removing the boy, he was never returned to them. The Elwells brought suit against several state officials involved in the removal under 42 U.S.C. 1983. On a motion for summary judgment, the district court concluded that qualified immunity did not shield the state officials from liability. Upon review, the Tenth Circuit agreed with the district court that the defendants violated the Elwells' Due Process rights when they removed T.S. without notice. However, despite the Court's sympathy for the Elwells' plight, the Court concluded that this violation was not clearly established in the case law at the time of T.S.'s removal. Accordingly, the Court reversed the district court's denial of summary judgment. View "Elwell, et al v. Byers, et al" on Justia Law

The defendants in this case filed interlocutory appeals from a district order that granted a preliminary injunction in favor of plaintiff, an association of individual members of the Fundamentalist Church of Jesus Christ of Latter-Day Saints and beneficiaries of a charitable religious trust (FLDS Association). The FLDS Association alleged six claims for relief: (1) a claim for declaratory relief under 42 U.S.C. 1983 alleging deprivation of the FLDS Association's rights under the Establishment Clause and Free Exercise Clause of the United States Constitution; (2) a claim for declaratory relief under Article 1, Sections 1 and 4 of the Utah Constitution; (3) a claim for violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc; (4) a claim that Utah Code Ann. 76-7-101, which prohibits plural marriage, was unconstitutional as applied under the federal and state constitutions; (5) a claim that Utah Code Ann. sections 75-7-1001, -412(1), and -413(1)(c) were unconstitutional as applied; and (6) a claim for injunctive relief against the defendants' continuing administration of the UEP Trust. The FLDS Association also moved for a temporary restraining order and preliminary injunction against the probate court's ongoing administration of the UEP Trust. The federal suit was stayed pending the parties' settlement negotiations. After granting the defendants' motion for an emergency stay pending resolution of these appeals, the Tenth Circuit certified a question to the Utah Supreme Court regarding the preclusive effect of laches under Utah law of dismissal, of a petition for extraordinary writ. The Court received its answer from the Utah court and vacated the district court's preliminary injunction, remanding the case to dismiss the FLDS Association's claims as barred by res judicata. View "Fundamentalist Church of Jesus v. Wisan (Horne Appeal), et al" on Justia Law

Plaintiff, Rural Water District No. 2 Creek County, Oklahoma, a rural water provider covered by 7 U.S.C. 1926(b), and Defendant Glenpool Utility Services Authority, a public trust created to provide water service, and its beneficiary, Defendant City of Glenpool, entered into a Settlement Agreement under which Plaintiff agreed not to file a civil action pursuant to section 1926(b) during the term of the agreement unless Defendants defaulted on their contractual obligations. Subsequently, Plaintiff filed the civil action underlying this appeal pursuant to 42 U.S.C. 1983 alleging Defendants violated section 1926(b). The district court dismissed the action for lack of subject matter jurisdiction. The issue on appeal to the Tenth Circuit centered on whether Plaintiff’s agreement not to file a civil action against Defendants, absent default, deprived the Court of subject matter jurisdiction under 28 U.S.C. 1331, where a state court had not yet determined whether Defendants defaulted. Upon review, the Court held that such agreement did not deprive the Court of subject matter jurisdiction, and it reversed and remanded. View "Rural Wtr Dist No 2 Creek Cnty v. City of Glenpool, et al" on Justia Law

Plaintiff-Appellant Richard Kaufman brought a 42 U.S.C. 1983 action alleging that the Defendants, all Colorado police officers, had violated his constitutional rights by arresting him without probable cause. In 2009, a vehicle driven by an unnamed female driver hit an unoccupied car in a jewelry store parking lot. Someone witnessed the incident, took down the car's license plate number and reported it to the Colorado State Patrol. Officers investigating the report learned that Plaintiff owned the car and had made a purchase at the store moments before the accident. Plaintiff cited "privilege" in refusing to tell the officers the name of the female driver. Frustrated, the officers advised Plaintiff that refusing to tell them the name of the driver could end in an arrest for obstruction of justice. Plaintiff refused and he was arrested. The district court granted the Defendants' motion for summary judgment. As to a Fourth Amendment claim, the court concluded that there was no false arrest because the troopers had probable cause to believe Plaintiff's silence, accompanied by assertion of privilege, constituted a violation of the obstruction statute. The Tenth Circuit disagreed and reversed. The Defendants never contended that their encounter with Plaintiff was other than consensual; the law was well established that a citizen has no obligation to answer an officer's questions during a consensual encounter; and the Colorado Supreme Court had made it clear that the Colorado obstruction statute is not violated by mere verbal opposition to an officer's questioning. "It follows that the Defendants could not have reasonably thought that they were justified in arresting Plaintiff and their motion for summary judgment on the ground of qualified immunity should have been denied." View "Kaufman v. Higgs, et al" on Justia Law

In this litigation, Appellants (plaintiffs below) brought an action under 42 U.S.C. 1983, challenging the statutory scheme by which the state of Kansas funds its public schools. The district court dismissed their suit for lack of standing. Upon review of the matter and the applicable statutory authority, the Tenth Circuit concluded that the Appellants had standing because their alleged injury, unequal treatment by the state, would be redressed by a favorable decision. Accordingly, the Court reversed and remanded the case for further proceedings. View "Petrella, et al v. DeBacker, et al" on Justia Law

Plaintiff-Appellant Michael Storey brought civil rights claims against police officers after they arrested him at his home during an investigation of a report of a loud domestic argument. The question before the Tenth Circuit was whether the officers had probable cause to order Plaintiff to step outside his home and arrest him when he refused to do so, and if exigent circumstances or community safety concerns could support the seizure to facilitate further investigation. Upon review, the Court concluded the officers lacked probable cause and exigent circumstances to justify the arrest, and the community caretaking exception to the Fourth Amendment did not apply. The Court therefore reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Storey v. Garcia" on Justia Law

Plaintiff-Appellant Clarice Sanchez, a long-time secretarial employee of the United States Forest Service, suffered irreversible brain damage after falling at work. As a result of her injury, Sanchez lost the left half of her field of vision. She requested a hardship transfer to Albuquerque where she could better access ongoing medical treatment. After the Forest Service declined to accommodate her request, she brought suit under the Rehabilitation Act. The district court granted summary judgment in favor of the Forest Service, concluding that Plaintiff was not disabled within the meaning of the Act. Upon review, the Tenth Circuit disagreed and held that Plaintiff raised a genuine issue of material fact regarding her disability. On appeal, the Forest Service urged the Court to affirm summary judgment on an alternative ground. However, the Court declined, concluding that transfer accommodations for the purpose of medical treatment or therapy were not unreasonable per se. View "Sanchez v. Vilsack" on Justia Law

The issue before the Tenth Circuit in this case was whether the Americans with Disabilities Act created two separate-but-overlapping causes of action for employment discrimination. Plaintiff-Appellant Judy Elwell worked for Defendant-Appellee University of Oklahoma for years in an administrative role. She began to suffer from a degenerative spinal disc condition which did not prevent her from performing the essential functions of her job. Nevertheless, she sought certain accommodations from her employer. She alleged that the University refused to grant those accommodations and ultimately fired her, allegedly because of her disability. The district court dismissed Plaintiff's complaint, holding that Title II did not provide a cause of action for discrimination, and that Oklahoma did not waive its immunity from suit under the Oklahoma Anti-Discrimination Act (OADA). The Tenth Circuit affirmed: "[i]n this case, those traditional tools of statutory construction - including a close examination of the text together with a careful review of the larger statutory structure . . . persuade us that Congress has spoken and spoken clearly to the question of employment discrimination claims and placed them exclusively in Title I. . . . Because Title II does not contain an independent cause of action for employment discrimination and because Ms. Elwell [could not] carry her burden of showing a waiver of sovereign immunity that might permit her to proceed with an OADA claim, the judgment of the district court [was] affirmed." View "Elwell v. Bd. of Regents Univ. of Okla." on Justia Law