Justia Civil Rights Opinion Summaries

Plaintiff, individually and on behalf of her child, filed suit under 42 U.S.C. 1983 against the Georgia Department of Human Services, Division of Family & Children Services (DFCS), Gwinnett County DFCS, and a social worker with Gwinnett County. The social worker brought this interlocutory appeal challenging the district court's denial of summary judgment, holding that she was not entitled to qualified immunity. At issue was plaintiff's substantive due process claim that the social worker violated her liberty interests in the care, custody, and management of her minor child with respect to the social worker's actions in preparing and implementing a safety plan that allegedly prohibited plaintiff from removing her child from the paternal grandmother's care. The court concluded that, in this circumstance, it could not hold that a reasonable social worker would have been on notice that her actions violated plaintiff's substantive due process rights. Accordingly, the court reversed the denial of qualified immunity to the social worker on plaintiff's substantive due process claim and remanded for further proceedings. View "Maddox v. Stephens, et al." on Justia Law

Plaintiff filed suit against defendant, in his official capacity as the Director of the Agency for Persons with Disabilities (APD), bringing a facial challenge to the constitutionality of Florida's statutory scheme for involuntarily admitting intellectually disabled persons to residential services, Florida Statutes 393.11. The court certified questions to the Supreme Court of Florida regarding the scope of the APD's obligations under the statute. View "J.R. v. Hansen" on Justia Law

Plaintiffs, male inmates, filed suit under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc et seq., challenging an ADOC policy that forbids them from wearing their hair unshorn in accordance with the dictates of their Native American religion. The United States intervened on plaintiffs' behalf. The court affirmed the district court's judgment in favor of the ADOC because the ADOC carried its burden of demonstrating that its hair-length policy was the least restrict means of furthering its compelling governmental interests of prevention of contraband, facilitation of inmate identification, maintenance of good hygiene and health, and facilitation of prison discipline through uniformity. View "Knight, et al. v. Thompson, et al." on Justia Law

Plaintiff sued her employer, the Alabama Board of Pardons and Paroles, originally alleging federal civil rights and state age discrimination claims. The Board then removed the case to federal court, invoking the district court's subject-matter jurisdiction under 28 U.S.C. 1331. After removal, plaintiff amended her complaint alleging various federal and state law claims. The district court dismissed all of plaintiff's federal claims other than the Age Discrimination in Employment Act, 29 U.S.C. 621-634, claim for failure to state a claim. The court concluded that the Board waived its defense of immunity from litigation in federal court when it removed to federal court, but the Board did not waive its immunity from ADEA liability. Accordingly, the court affirmed the district court's judgment. View "Stroud v. McIntosh, et al." on Justia Law

Plaintiffs, the superintendent of education and her assistant superintendent, filed suit claiming that the board and its members in both their official and individual capacities terminated the superintendent and demoted the assistant superintendent in retaliation for public comments plaintiffs made about local tax policy. The court concluded that it had jurisdiction over the appeal of the denial of qualified immunity, but lacked jurisdiction over the appeal of the board and its officials. Accordingly, the court dismissed the appeal of the board and its officials for lack of jurisdiction and reversed the denial of qualified immunity for the individual members of the board. View "Leslie, et al. v. Hancock County Board of Education, et al." on Justia Law

This case stemmed from the detention and handcuffing of a nine-year-old student during her physical education class. Defendant, a Deputy Sheriff, appealed from the district court's grant of attorney's fees. The court concluded that the district court abused its discretion by awarding attorney's fees to plaintiff where plaintiff achieved a de minimus victory under the Farrar v. Hobby factors. Accordingly, the court reversed and remanded for entry of judgment in favor of defendant on his claim for attorney's fees. View "Gray v. Bostic" on Justia Law

Plaintiff, a 67-year-old man suffering from dementia and prone to disorientation and confusion, filed suit under 42 U.S.C. 1983 against defendants after he was severely beaten by his cellmate while detained at the County Jail. The court concluded that the district court did not err in granting defendants' motion for summary judgment where nothing in the record created a genuine issue of fact as to whether the prison officers were subjectively aware of a substantial risk of serious harm to plaintiff; the complaint failed to allege that the Sheriff's Department policy or custom actually caused plaintiff's injuries; and because plaintiff's principal claims fail, it followed that his wife's derivative loss of consortium claim must fail too. Accordingly, the court affirmed the judgment. View "Goodman, et al. v. Kimbrough, et al." on Justia Law

This case involved Executive Order 11-58 (EO), which mandated two types of suspicionless drug testing: random testing of all employees at state agencies within the Governor of Florida's control, and pre-employment testing of all applicants to those agencies. In this case, the district court declared the EO unconstitutional as to all current state employees. This relief swept too broadly, enjoined both constitutional and unconstitutional applications of the EO, and did so without examining the specific job categories to be tested. What the Supreme Court's case law required, in contrast, was that the trial court balance the governmental interests in a suspicionless search against each particular job category's expectation of privacy. Accordingly, the court vacated the district court's order granting summary judgment to the Union and denying summary judgment to the State. On remand, the State must meet its burden of demonstrating important special needs on a job-category-by-category basis. View "American Federation of State, County, and Municipal Emp'ees Council 79 v. Scott" on Justia Law

Plaintiff, an Orthodox Jew serving time as a prisoner of the State of Florida, filed a complaint against defendants alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq. Plaintiff claimed that defendants violated his right to practice his religion because they would not give him a strictly kosher diet. The court concluded that plaintiff's claims were not moot because Florida has not unambiguously terminated its policy which deprived plaintiff of kosher meals; while safety and cost could be compelling governmental interests, defendants have not carried their burden to show that Florida's policy in fact furthered these two interests; and defendants have not carried their burden of showing that Florida's policy of not providing kosher meals to prison inmates was the least restrictive means to further the cost and security interests they asserted. Because defendants failed to satisfy their burden at summary judgment, the court reversed the district court's grant of summary judgment to them and remanded for further proceedings. View "Rich v. Secretary, FL Dept. of Corrections, et al" on Justia Law

Plaintiff sued Coca-Cola, his employer, alleging that the psychiatric/psychological fitness-for-duty evaluation he was required to undergo violated 42 U.S.C. 12112(d)(4)(A), a provision of the Americans with Disabilities Act (ADA). The court affirmed the district court's grant of summary judgment for Coca-Cola, concluding that the evaluation was both job-related and consistent with business necessity and, therefore, permissible under the ADA. View "Owusu-Ansah v. The Coca-Cola Co." on Justia Law