Justia Civil Rights Opinion Summaries

North Carolina's House Bill 289 authorized the state's Division of Motor Vehicles to issue, among other specialty license plates, a "Choose Life" plate. However, this law authorized no pro-choice specialty license plate. North Carolina vehicle owners who wanted a pro-choice specialty plate, along with the ACLU, filed suit challenging the statute. North Carolina argued that it could so discriminate because specialty plate messages constituted pure government speech free from First Amendment viewpoint-neutrality constraints. The court concluded that, because the specialty plate speech at issue implicated private speech rights and was not pure government speech, North Carolina's authorizing a "Choose Life" plate while refusing to authorize a pro-choice plate constituted viewpoint discrimination in violation of the First Amendment. Accordingly, the court affirmed the district court's grant of summary judgment and a permanent injunction in favor of the vehicle owners and the ACLU. View "American Civil Liberties Union v. Tata" on Justia Law

Plaintiff, a state prisoner housed at Red Onion State Prison (ROSP), filed suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000 cc et seq., and 42 U.S.C. 1983, challenging ROSP's 2010 Ramadan policy. ROSP had devised a new eligibility policy for 2010 where, in addition to signing up to participate in Ramadan, inmates had to provide some physical indicia of Islamic faith. The court vacated the district court's summary judgment order granting defendants qualified immunity on plaintiff's claims for monetary relief where defendants have failed to establish as a matter of law that the 2010 Ramadan policy, as applied to plaintiff, did not violate his First Amendment rights and where their alleged actions violated plaintiff's clearly established rights; vacated the district court's decision that the prison's abandonment of the policy mooted the claims for equitable relief where defendants failed to meet their "heavy burden" of establishing that it was "absolutely clear" that the 2010 Ramadan policy would not be reinstated; and remanded for further proceedings. View "Wall v. Wade" on Justia Law

Plaintiff, an employee of MTA for four decades, filed suit against MTA alleging various forms of discrimination after her position was terminated due to budget cuts. The court concluded that, because summary judgment was granted before plaintiff had a chance to discover facts essential to her claim, and she alleged discrimination occurring before any legislative activity, the district court's Rule 56(d) denial was an abuse of discretion. The court concluded, however, that the district court's dismissal of plaintiff's age discrimination and disability discrimination claims were barred by sovereign immunity. Accordingly, the court affirmed in part, reversed in part, and remanded. View "McCray v. Maryland Dep't of Transp." on Justia Law

Plaintiff filed suit against Altarum, alleging that Altarum discriminated against him by wrongfully discharging him on account of disability and that Altarum failed to accommodate his disability. Plaintiff was terminated after he injured his legs on a subway platform and was on short-term disability benefits. On appeal, plaintiff challenged the district court's dismissal of his wrongful-discharge claim. The court concluded that, under the Americans with Disabilities Act Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553, and its implementing regulations, an impairment is not categorically excluded from being a disability simply because it is temporary. In this instance, the impairment alleged by plaintiff fell comfortably within the amended Acts' expanded definition of disability. Therefore, the court reversed and remanded for further proceedings. View "Summers v. Altarum Institute, Corp." on Justia Law

Plaintiffs filed a putative class action suit challenging the legality of the toll charged by the MWAA for use of the Dules Toll Road. The district court dismissed the complaint on numerous grounds. The court concluded that plaintiffs' claims were barred neither by the standing requirement of Article III nor the prudential restrictions the court has recognized on its own judicial power; under the Elizabeth River Crossings OpCo, LLC v. Meeks framework, the tolls charged for passage on the Dules Toll Road are user fees, not taxes, under Virginia law; and therefore, their collection by the MWAA did not run afoul of the Virginia Constitution and did not violate the due process rights of motorists. Accordingly, the court affirmed the district court's dismissal of plaintiffs' complaint. View "Corr v. Metropolitan Washington" on Justia Law

Plaintiffs filed a class action challenging the constitutionality of the issuance and form of automated speeding citations issued under Maryland's speed camera program. The court found that the notice and hearing afforded by Maryland's speed camera statute satisfied due process where notice sent by first-class mail was reasonably calculated to provide actual notice of the speeding violation and civil penalties; the availability of a trial in state court, upon plaintiffs' election, provided adequate opportunity to be heard on any objections prior to the imposition of the statutory penalties; and any flaws in the citation or enforcement process could have been challenged in the state courts and plaintiffs failed to do so. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the towns. View "Snider Int'l Corp. v. Town of Forest Heights, MD" on Justia Law

After individuals associated with Occupy Columbia were removed by law enforcement from a 24-hour per day protest on the grounds of the South Carolina State House, Occupy Columbia filed suit against defendants, including the Governor, seeking injunctive relief and damages under 42 U.S.C. 1983, the South Carolina Constitution, and South Carolina's common law. The court granted in part and denied in part. On appeal, defendants sought review of the district court's denial of qualified immunity to defendants. The court affirmed, concluding that Occupy Columbia has alleged a violation of a clearly established First Amendment right - the right to protest on State House grounds after 6:00 p.m. in the absence of a valid time, place, and manner restriction. View "Occupy Columbia v. Haley" on Justia Law

Plaintiff filed suit against defendant under, inter alia, 42 U.S.C. 1983 for violation of plaintiff's Fourth Amendment rights after defendant, a deputy sheriff, arrested plaintiff for withholding information about possibly rabid animals. On appeal, defendant challenged the judgment of damages plus attorney's fees entered against her in the section 1983 proceeding. The court concluded that, by securing a warrant that lacked adequate evidentiary support, defendant infringed plaintiff's Fourth Amendment right to be free from capricious arrest and this constitutional right was clearly established. Therefore, defendant could not shield herself from damages liability by invoking qualified immunity. Because the district court overstated plaintiff's degree of success, it erred in not making an attorney's fee award that would properly reflect her success in this case. Accordingly, the court affirmed the verdict of damages but vacated the attorney's fee award, remanding for an award of $100,000, exclusive of costs. View "McAfee v. Boczar" on Justia Law

Plaintiff filed suit against officers under 42 U.S.C. 1983, as well as state law claims, after plaintiff was shot by the officers. Plaintiff, after hearing sounds of unknown persons outside his home, opened the front door carrying a shotgun and was shot by the officers. The court concluded that it had jurisdiction under the collateral order doctrine. The district court did not err in denying the officers qualified immunity from plaintiff's excessive force claims under section 1983 where a reasonable officer would not have had probable cause to feel threatened by plaintiff's actions and the constitutional right at issue - the right to be free from deadly force when posing no threat - was clearly established at the time the officers shot plaintiff. Accordingly, the court affirmed the district court's judgment as to the section 1983 claims. The court also affirmed the district court's denial of public officers' immunity with respect to plaintiff's state law tort claims. View "Cooper, Sr. v. Sheehan" on Justia Law

Plaintiff, a state prisoner, filed suit challenging the constitutionality of 42 U.S.C. 1997e(d)(2), a part of the Prison Litigation Reform Act of 1995 (PLRA), as violating his right to equal protection of the laws under the Fifth Amendment's Due Process Clause. Plaintiff challenged a provision that caps the attorneys' fee award that a successful prisoner litigant could recover from the government in a civil rights action at 150 percent of the value of the prisoner's monetary judgment. The court declined to apply heightened equal protection scrutiny in this case and joined its sister circuits in concluding that section 1997e(d)(2) was constitutional. Congress's goals in enacting section 1997e(d)(2) included reducing marginal or frivolous prisoner civil rights lawsuits and protecting the public fisc. Such goals were legitimate and Congress acted rationally in adopting the provision. Accordingly, the court affirmed the judgment of the district court. View "Wilkins v. Gaddy" on Justia Law