Justia Civil Rights Opinion Summaries

Plaintiff brought suit against the church alleging that the church terminated him in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court dismissed the suit based on the ministerial exception, which barred employment-discrimination suits by ministers against their churches, pursuant to Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC. Because the court concluded that there was no genuine issue of material fact that the ministerial exception applied where plaintiff performed an important function during the church service as an accompanist, and therefore barred plaintiff's suit, the court affirmed the judgment of the district court. View "Cannata v. Catholic Diocese of Austin, et al" on Justia Law

The Church filed suit in federal district court, claiming that a now-repealed city ordinance's church-specific provisions, facially and as applied, violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., the First Amendment; the Fourteenth Amendment, and the Mississippi Constitution. The Church simultaneously filed a motion for a preliminary injunction of the challenged provisions. The court subsequently vacated the district court's order denying the Church's motion for a preliminary injunction and remanded for further proceedings. The court concluded that the issues on remand included but were not limited to: (1) whether the Church was likely to succeed on its claims challenging the validity of the newly adopted religious facilities ban; (2) whether the harm the Church would suffer absent a preliminary injunction outweighed the harm an injunction would cause the city; (3) the amount of actual damages the Church suffered on account of Sections 10.86 and 10.89 of the city's zoning ordinance, which violated RLUIPA; and (4) at the district court's discretion, whether the Church should be awarded reasonable attorneys fees as a prevailing party under 42 U.S.C. 1988(b). View "Opulent Life Church, et al v. City of Holly Springs MS, et al" on Justia Law

Plaintiff brought a Title VII sex discrimination claim against her former employer. The district court granted summary judgment for the employer on the ground that the grievance procedure established in a collective bargaining agreement (CBA) provided the exclusive remedy for plaintiff's claim. Because the CBA did not clearly and unmistakably waive a union member's right to bring a Title VII claim in a federal judicial forum, the district court erred when it concluded that the CBA required plaintiff to submit her Title VII claim to the Article 51 grievance process. Accordingly, the court vacated the district court's grant of summary judgment for the employer and remanded for further proceedings. View "Ibarra v. United Parcel Service, Inc." on Justia Law

Planned Parenthood obtained a preliminary injunction to block the enforcement of regulations which stated that health care providers participating in a Medicaid-like program must not perform or promote elective abortions. The district court preliminarily enjoined the enforcement of these regulations, reasoning that the regulations likely violated Planned Parenthood's rights to free speech and association, and denied them equal protection of the laws. The court held that the district court issued the preliminary injunction based on a wholesale assessment of the regulations' constitutionality, which gave insufficient attention to Texas' authority to subsidize speech of its choosing within its programs. Accordingly, the order of the district court granting the preliminary injunction was vacated and the case remanded for further proceedings.

Plaintiffs sued the Secretary of the Louisiana Department of Health and Hospitals, challenging the constitutionality of Louisiana's Act 490, which amended Louisiana's Outpatient Abortion Facility Licensing Law of 2001. The district court granted the Secretary's motion to dismiss, holding that the claims were not ripe. The court affirmed because plaintiffs have failed to show that hardship would result from withholding court consideration at this time.

David Scruggs pleaded guilty to a one-count superseding information charging misprision of a felony. After he was released from prison but before the conclusion of his term of supervised release, Scruggs filed a motion to vacate conviction pursuant to 28 U.S.C. 2255. After a hearing, the district court denied Scruggs's section 2255 motion and granted a certificate of appealability on three issues. The Fifth Circuit Court of Appeals affirmed, holding (1) because the information charged an offense against the laws of the United States, Scruggs's claim that, under Skilling v. United States, the district court lacked jurisdiction to accept his guilty plea was without merit; (2) Scruggs failed to prove ineffective assistance of counsel based on a conflict of interest; and (3) Scruggs failed to show that alleged governmental misconduct induced him to plea guilty.

This appeal arose out of the alleged use of excessive force in the arrest of Roger Poole following a traffic stop in Louisiana. Poole sued police officers John Stalnaker and J. Creighton, former chief of police Mike VanSant, and the City of Shreveport, seeking damages for constitutional violations under 42 U.S.C. 1983. The district court entered summary judgment in favor of Defendants. The Fifth Circuit Court of Appeals affirmed, holding (1) the district court did not err in granting Creighton and Stalnaker summary judgment on Defendant's excessive force claims based on the affirmative defense of qualified immunity; and (2) Defendant failed to meet his burden of proving genuine issues of material fact existed to preclude judgment on Defendant's claim that the City and VanSant failed to establish a policy implementing or enforcing Louisiana's policy against the use of public office for private gain.

Appellees, several individuals, claimed that the City of Galveston police used excessive force against them. Appellees filed this 42 U.S.C. 1983 against Appellants Steven LeBlanc and and Charles Wiley, former city manager and former chief of police for the City, respectively, and over a dozen individual officers. Appellees claimed that LeBlanc and Wiley were individually liable for failing to train the responding officers, especially on the appropriate use of force. Appellants moved to dismiss on qualified immunity under Fed. R. Civ. P. 12(b)(6). The district court refused to rule on Appellants' threshold qualified immunity defense, concluding it was premature to address the qualified immunity defense before general discovery. The Fifth Circuit Court of Appeals vacated the district court's order, holding that the district court abused its discretion by withholding its ruling pending general discovery and by failing to limit discovery to facts necessary to rule on Appellants' qualified immunity defense. Remanded.

Defendant was found guilty of conspiracy with intent to distribute cocaine base, conspiracy to distribute marijuana, possession with intent to distribute cocaine base, and possession of a firearm in furtherance of and in relation to a drug trafficking crime. Defendant was sentenced to a total of 420 months' imprisonment. After he exhausted his remedies on direct appeal, Defendant filed a pro se 28 U.S.C. 2255 motion, claiming that his trial counsel was ineffective. The district court denied Defendant's motion. At issue before the Fifth Circuit Court of Appeals was whether Defendant's trial counsel rendered ineffective assistance by advising him not to testify on his own behalf. The Fifth Circuit affirmed, holding that because Defendant failed to demonstrate that he was prejudiced, he did not establish a constitution violation and was not entitled to section 2255 relief.

The Fifth Circuit Court of Appeals considered these cases jointly because they raised a single issue: whether Defendants, who were convicted of possession with intent to distribute crack cocaine, among other things, were entitled to be sentenced according to the Fair Sentencing Act (FSA) when their illegal conduct preceded the FSA but their sentencing proceedings occurred post-enactment. The Fifth Circuit held that the penalties described by the FSA did not apply to federal criminal sentencing for illegal conduct that preceded the FSA's enactment, and therefore, the sentences imposed by the district courts in these cases were affirmed. However, after the Fifth Circuit issued its opinion in these consolidated cases, the Supreme Court decided Dorsey v. United States, which held, contrary to the Fifth Circuit's opinion, that the more lenient penalties of the FSA apply to offenders who committed an offense before the Act was passed but were sentenced after the Act was enacted. The Fifth Circuit, therefore, vacated and remanded these cases for resentencing consistent with the Court's holding in Dorsey.