Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's grant of summary judgment on his claims against defendants, under 42 U.S.C. 1983, for wrongful termination. The court held that UTMB was entitled to immunity from suit where plaintiff conceded that UTMB was a state agency and failed to argue that Texas had consented to suit, nor had Congress expressly waived sovereign immunity from section 1983 suits. The court also held that, putting aside plaintiff's purported property interest in his employment, plaintiff failed to identify a genuine dispute that his termination was arbitrary or capricious, or that the decision was made without professional judgment. Accordingly, the judgment of the district court was affirmed.

Plaintiffs sued law enforcement officers for excess use of force, assault and battery, and unlawful entry after the officers breached the locked door to the private bedroom of plaintiffs' 27-year-old son, Scott, to arrest him for threatening his mother. Scott attacked the officers with two knives, and in the ensuing melee, the officers shot and killed him. The court held that the officers' use of deadly force was objectively reasonable. Because the court held that Scott's Fourth Amendment right to be free from the use of excessive force was not violated, the court need not consider the issue of whether that right was clearly established. The court also affirmed the district court's grant of official immunity to the officers on plaintiffs' assault-and-battery claims; unlawful-entry claims; and warrantless arrest claims. Accordingly, the court affirmed the district court's grant of summary judgment on all claims.

Plaintiff sued defendants under Title VII, alleging claims of racial harassment and constructive discharge. Plaintiff subsequently appealed the district court's dismissal of his complaint based on a finding that plaintiff committed perjury and the district court's grant of defendants' motion for sanctions. Plaintiff argued that a less severe sanction was more appropriate and that the district court should have held an evidentiary hearing to allow plaintiff to explain his conflicting testimony. Plaintiff's counsel, who was separately sanctioned, also appealed the denial of his motion for recusal of the magistrate judge. The court held that the district court did not abuse its discretion in deciding to dismiss plaintiff's complaint with prejudice where plaintiff plainly committed perjury; plaintiff's argument that the district court failed to hold a hearing was meritless where he made no effort to explain why he and his attorney failed to show at the hearing held by the district court to address objections to the magistrate judge's report; and the district court did not abuse its discretion in denying counsel's motion for recusal where a reasonable person would not question the magistrate judge's impartiality in this case. Accordingly, the court affirmed the judgment.

Plaintiff sued the Louisiana State Board of Practical Nurse Examiners, claiming its status requirement violated the Constitution when the Board denied her a license solely on account of her immigration status. Plaintiff was an alien who had applied for permanent residence. The district court granted the Board summary judgment on all grounds. The court held that because applicants for permanent resident status did not constitute a suspect class under the Equal Protection Clause, and a rational basis supported the immigration-status requirement, the judgment was affirmed.

Plaintiffs, Mr. and Ms. Jimenez, sued the County under 42 U.S.C. 1983, alleging constitutional violations stemming from their arrests. Ms. Jimenez claimed that, because she was arrested for a minor offense, she could be strip-searched only upon reasonable suspicion that she was concealing weapons or contraband. The jury ultimately returned a verdict for Ms. Jimenez, the court entered a final judgment against the County, awarding Ms. Jimenez for past and future mental anguish, as well as punitive damages. The County appealed and a panel of the court affirmed. The court granted rehearing en banc and vacated the panel opinion. Because the County had not demonstrated reversible error in the jury instructions in this case, the court affirmed the judgment of the district court. The court reinstated Parts III, IV, and V of the panel opinion, which rejected other arguments that the County had not urged on rehearing.

Plaintiff, a group representing taxicab companies that hold only one to three permits for cabs, asserted that the city's plan to distribute new taxicab permits violated the Equal Protection Clause of the Fourteenth Amendment. The district court granted summary judgment to the city and plaintiff appealed. The court held that plaintiff had not demonstrated that the ordinance violated the Equal Protection Clause by treating taxi companies differently based on size and therefore, the court affirmed the judgment of the district court.

Plaintiff brought suit against various officials arising from his name not being placed on the 2010 primary election ballot in Houston. Plaintiff appealed the dismissal of his complaint for failure to state a claim. The court held that plaintiff's procedural due process claim was properly rejected where plaintiff had no property right to be a candidate. The court also held that plaintiff's substantive due process claim failed because there were no disputed facts regarding plaintiff's application containing an incorrect residential address where plaintiff made an oral admission that he did not live at the listed address. The court further held that plaintiff's Equal Protection claim was properly denied where the actions of the official at issue did not constitute intentional or purposeful discrimination. The court finally held that plaintiff failed to establish that Section 141.032(e) of the Texas Election Code was unconstitutional. Accordingly, because plaintiff filed his application for candidacy in the last hour of the last possible day, which limited his opportunity to refile a correct application, the court affirmed the judgment.

This case involved a claim brought under 42 U.S.C. 1981 by a terminated employee against his former union, which represented him in a grievance hearing in connection with his termination. Plaintiff alleged that defendants discriminated against him on account of his race by failing to argue during the grievance hearing that he was being terminated for a racially discriminatory reason. The court held that plaintiff failed to state a prima facie claim for racial discrimination by the union under section 1981, and therefore the district court was correct to grant defendants' motion for summary judgment.

Defendant, the Commissioner of the Mississippi Department of Corrections (MDOC), was found liable under 42 U.S.C. 1983 for violating plaintiff's constitutional rights by unlawfully incarcerating him for fifteen months beyond the expiration of his sentence. Defendant appealed the district court's denial of his motion for judgment as a matter of law, or in the alternative, motion for a new trial. The court held that because defendant was entitled to qualified immunity where no reasonable jury could have found that defendant's conduct was objectively unreasonable. Accordingly, the court reversed the judgment of the district court.

Plaintiffs, four former elementary-school students, sued the school district because school officials have, at various times and in various ways, prevented them from evangelizing while at school. At issue was whether the school principals violated clearly established law when they restricted plaintiffs from distributing written religious materials while at school. The court held that the principals were entitled to qualified immunity because clearly established law did not put the constitutionality of their actions beyond debate. Accordingly, the court reversed the judgment of the district court and remanded with an instruction to dismiss plaintiffs' claims as to the principals in their individual capacities.