Justia Civil Rights Opinion Summaries

This appeal primarily concerns a Fourteenth Amendment challenge to various sections of the Alabama Constitution that are central to the State's system of ad valorem property taxation. Plaintiffs filed suit asserting that these provisions are rooted in the State's historic racially discriminatory policies and cripple the ability of certain rural, nearly all-black public school systems in Alabama to raise revenues. Because the requested remedy would not address the alleged injury, plaintiffs lacked standing to challenge the constitutional millage cap provisions despite the district court's finding that they were enacted with discriminatory intent; plaintiffs' challenges to these provision were therefore dismissed without prejudice; plaintiffs' challenge to the State's property classification system (as set forth in Amendments 325 and 373 to Section 217) were not similarly barred, yet these claims failed because the court could not say that the district court clearly erred in finding that this system was not the product of invidious discriminatory intent; sufficient evidence also rendered permissible the district court's finding that these Amendments were financially, and not discriminatorily, motivated; under clear-error review, the court was not free to second-guess the district court's choice between two permissible views of the evidence; and, therefore, the court affirmed in part, vacated in part, and remanded with instructions to dismiss in part. View "Lynch, et al. v. State of Alabama, et al." on Justia Law

Plaintiff filed suit alleging that a corrections officer at the county jail sexually assaulted her. Officers other than the accused moved for dismissal on the basis of qualified immunity. The district court denied the motion. The court concluded that, in determining whether plaintiff alleged a constitutional violation, the district court made two related errors: it applied an incorrect legal standard and it allowed plaintiff to satisfy the standard it applied with conclusory allegations. Accordingly, the court held that plaintiff had failed to plead a constitutional violation and that the officers were therefore entitled to qualified immunity. View "Franklin v. Curry, et al." on Justia Law

Plaintiffs, daughters of the late Kenneth Weinberg, appealed the district court's grant of summary judgment to county jail officers. Kenneth, a pretrial detainee at the jail for twenty months, commenced this civil rights suit under the Due Process Clause of the Fourteenth Amendment, claiming deliberate indifference to his basic medical needs because the officers refused to provide him with batteries for his hearing aids, rendering the aids worthless and leaving him unable to hear. Kenneth also filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and a First Amendment retaliation claim against the officers for the same conduct. The court concluded that Kenneth stated a viable constitutional claim but that state law did not provide the officers with "fair warning" that their alleged conduct was unlawful. Accordingly, the officers were entitled to qualified immunity and the court affirmed the district court's grant of summary judgment in favor of the officers. View "Weinberg Gilmore, et al. v. Hodges, et al." on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law

Plaintiff filed suit against Marod to compel it to bring one of its stores into compliance with Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12181-12189. The district court dismissed the claim, concluding that plaintiff lacked standing. The court concluded that plaintiff had standing to seek injunctive relief against defendant where plaintiff has been to the store in the past, he wants to return, and his frequent trips directly past the store render it likely that he would do so were it not for the alleged ADA violations. Accordingly, the court reversed the district court's dismissal of plaintiff's claim. View "Houston v. Marod Supermarkets, Inc." on Justia Law

Plaintiff filed suit against Officer Seymour and Sergeant Parker under 42 U.S.C. 1983 for false arrest. Plaintiff was arrested in the parking lot of a bar after Officer Seymour, who was working off-duty but in full uniform, asked her to move her car before it was towed. Plaintiff responded by cursing and speaking loudly. The court affirmed the district court's denial of qualified immunity to Officer Seymour because the facts viewed in the light most favorable to plaintiff showed that Officer Seymour lacked arguable probable cause to arrest plaintiff. The court concluded, however, that the district court erred in denying qualified immunity to Sergeant Parker, who was not present during the alleged false arrest. Accordingly, the court reversed the district court's judgment in regards to Sergeant Parker. View "Wilkerson v. Seymour" on Justia Law

Plaintiff filed suit against her employer for gender discrimination, racial discrimination, and national origin discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., as well as hostile work environment, unlawful retaliation claims, and state law claims. On appeal, plaintiff challenged the district court's grant of summary judgment in the employer's favor. The court concluded that plaintiff has made out a prima facie case of employment discrimination, but it remained unclear as to whether she created a dispute of material fact regarding whether the reason the employer offered for hiring another employee over her was a pretext for discriminatory animus. Accordingly, the court vacated the district court's grant of summary judgment in favor of the employer regarding plaintiff's employment discrimination claim, remanding for further proceedings. The court affirmed in all other respects. View "Kidd v. Mando American Corp." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City and others after he was fired from the police department for violating department policies. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of defendants. The court concluded that the district court correctly concluded that plaintiff failed to establish that any of the personnel, internal affairs, or disciplinary decisions about which he complained was made by a final policy maker for the City such that municipal liability attached; plaintiff's First Amendment claims failed because he could not establish that his speech played a substantial part in the police department's decision to conduct internal affairs investigations or terminate him; and plaintiff's false arrest, imprisonment, and malicious prosecution claims also failed because he has not presented any evidence that he was arrested without probable cause and the evidence could not be read to establish that there was a causal connection between either of the individual defendants' actions and plaintiff's arrest, imprisonment, and prosecution. Accordingly, the court affirmed the grant of summary judgment to all defendants. View "Carter, Jr. v. City of Melbourne, FL, et al." on Justia Law

Plaintiff, a civil detainee at the Florida Civil Commitment Center (FCCC), was involuntarily committed pursuant to Fla. Stat. 394.910 et seq. Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, the facility director at the center, violated his expressive freedoms under the First and Fourteenth Amendments by promulgating a policy that limited all residents of the center from copying plaintiff's newsletter. In November 2010, after litigation had begun but before the district court had entered summary judgment for defendant, defendant adopted a new, different, and stricter policy. The court vacated and remanded, concluding that the district court should consider the constitutionality of the November 2010 policy along with the earlier policy in order to avoid piecemeal adjudication of the two policies. View "Pesci v. Budz" on Justia Law

This case arose when three former employees of ASU alleged that they were subjected to a hostile work environment and retaliation during their employment. ASU appealed the district court's judgment. The court concluded that the district court did not err in denying ASU's motion to sever where the district court had broad discretion to deny the severance in the interest of judicial economy; the court did not have jurisdiction to hear ASU's appeal of the district court's denial of its Rule 50(b) and 59(b) motion where ASU had not filed a notice of appeal with the district court clerk; and the district court did not abuse its discretion in awarding front pay. Accordingly, the court affirmed in part and dismissed in part. View "Weatherly, et al. v. Alabama State University" on Justia Law