Justia Civil Rights Opinion Summaries

Plaintiff, a law enforcement park ranger, was transferred to a staff ranger position based on the conclusion of a medical review board constituted by the National Park Service that his uncontrolled diabetes could prevent him from safely performing his duties. Plaintiff filed suit under the Rehabilitation Act, claiming that his transfer amounted to discrimination on the basis of his alleged disability. The district court granted summary judgment for the Department and plaintiff appealed. The court held that the record supported the district court's conclusion that there was no genuine issue of material fact regarding the business necessity defense and its grant of summary judgment in favor of the Department was proper.

Plaintiff brought suit against the Board, arguing that the fee charged at the conclusion of his public intoxication and public inhabitation case violated his rights under the Sixth Amendment and Fourteenth Amendment because it discouraged public defenders from exonerating their clients. Louisiana's funding mechanism for indigent defense required indigent defendants who were found guilty, or plead nolo contendere, to pay a $35 fee at the conclusion of their cases, but it did not require defendants who were exonerated to pay the fee. The district court ruled that abstention was required under the Younger doctrine and, alternatively, that plaintiff did not state a claim for relief under the Sixth or Fourteenth Amendment. Because the court held that the district court did not err in abstaining from exercising jurisdiction over plaintiff's lawsuit, the court affirmed the judgment of the district court.

Plaintiff asserted federal claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and under 42 U.S.C. 1981, as well as a state-law claim for intentional infliction of emotional distress, asserting that his employer subjected him to racial discrimination. At the time plaintiff filed both his EEOC charge and his complaint initiating the instant case, plaintiff was a debtor in a Chapter 13 proceeding, having filed a petition for bankruptcy. The employer subsequently moved for summary judgment, arguing that plaintiff should be judicially estopped from pursuing his claims against the employer because he failed to disclose those claims to the bankruptcy court. The district court granted the motion, dismissing plaintiff's case, and plaintiff appealed. The court held that the district court did not abuse its discretion in applying judicial estoppel to plaintiff's claims after finding that plaintiff failed to create a fact issue regarding his purported inadvertence. Accordingly, the court affirmed the judgment.

Plaintiff and his mother sued the county under 42 U.S.C. 1983. Plaintiff's sister shot her husband and plaintiff, then thirteen-years-old, confessed to the murder. Plaintiff claimed that the county actors coerced a confession and plaintiff's mother claimed separation from her son while he was confessing violated her rights. The court held that, viewed under the totality of the circumstances, plaintiff's confession was voluntarily given and its introduction at trial did not offend the Fifth Amendment. Although a thirteen-year-old's separation from his mother, his desire to please adults, and his inexperience with the criminal justice system all weigh against voluntariness, his express desire to help his sister decided the issue. There was no evidence that, absent plaintiff's resolve to reduce his sister's punishment, the deputies' interrogation tactics would have produced a confession. The sister may have used her brother's love to make him lie on her behalf, but there was no evidence that the deputies knew of her plan. Looking back on his interrogation after he was released from prison, plaintiff told a national television audience, on the "Dr. Phil" show, that the deputies did not coerce him into confessing. The court rejected the remaining challenges and affirmed the district court's grant of summary judgment in favor of the county.

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings.

In this employment discrimination case, the EEOC and Thomas D. Turner (collectively, plaintiffs), appealed the district court's grant of summary judgment in favor of defendant, dismissing all plaintiffs' claims that the decisions to discipline Turner and three other African American employees for putative work-rule violations were based on race in violation of federal and state law. The court affirmed with respect to the claims based on the decisions to discipline Jesse Frank and Clarence Cargo because the court concluded that the EEOC had failed to establish a prima facie case of discrimination with regard to those decisions. However, the court reversed with respect to the claims based on the decisions to discipline Turner and Lester Thomas because the court concluded that plaintiffs have established a prima facie case of discrimination; and that defendant failed to produce admissible evidence of legitimate, nondiscriminatory reasons for those decisions. Thus, a jury question existed as to whether the decisions to discipline Turner and Thomas were impermissibly based on race.

Plaintiff, a Mississippi state prisoner, appealed from the judgment in favor of defendants in his 42 U.S.C. 1983 suit. Plaintiff alleged that his Fourth Amendment rights were violated (1) by delay in holding a probable cause determination after his arrest and (2) by his warrantless arrest. The court held that the reasons for delay could be seen as extraordinary where only a brief time passed beyond 48 hours when police resolved the uncertainties about jurisdiction and the subsequent overnight delay was the result of the magistrate's unavailability. The court also rejected plaintiff's illegal arrest claims and several other claims he raised on appeal. Accordingly, the court affirmed the judgment.

Plaintiff was dismissed from the East Baton Rouge police training program after falling asleep in class and purportedly making inappropriate sexual comments. Plaintiff subsequently demanded a name-clearing hearing from the East Baton Rouge Parish Sheriff but was denied. Plaintiff then brought federal and state law claims against the Sheriff for his failure to grant the hearing and for potentially defamatory statements made regarding plaintiff's dismissal. Because plaintiff had failed to present competent summary judgment evidence, the court affirmed the district court's grant of summary judgment in favor of the Sheriff.

Plaintiff filed an action under, inter alia, 42 U.S.C. 1983, claiming that defendants violated his Fourteenth Amendment rights to keep and bear arms, as incorporated in the Second Amendment, and to due process. The district court dismissed the action under Rule 12. The court held that plaintiff had not stated a violation of his Second Amendment right to keep and bear arms because he had not alleged that defendants prevented his "retaining or acquiring other firearms." The right protected by the Second Amendment was not a property-like right to a specific firearm, but rather a right to keep and bear arms for self-defense. The court also held that plaintiff had not stated a due-process claim where his complaint did not allege that, under Louisiana law, he sought the proper remedy for seeking the return of seized property by filing a motion under La. Rev. Stat. 15:41. In the alternative, plaintiff did not allege that due process required defendants to notify him of the procedure. Accordingly, the court affirmed the judgment.

LULAC filed suit against the City alleging that the voting method adopted by the City Charter diluted minority voting strength, in violation of Section 2 of the Voting Rights Act, 42 U.S.C. 1973. The City and LULAC settled in December 1996, and the district court entered a consent decree in accordance with the parties' settlement. At issue on appeal was whether the district court properly granted a joint motion by the City and LULAC to modify temporarily the consent decree. Because the court concluded that the district court erred in approving the temporary modification without following the procedures mandated by an earlier panel, the court vacated the district court's order and remanded for further proceedings.