Justia Civil Rights Opinion Summaries

Appellant, proceeding pro se and in forma pauperis, filed a lawsuit against appellees asserting claims under 42 U.S.C. 1983 and Title II of the Americans with Disabilities Act of 1990 ("ADA"), 28 U.S.C. 1915(e)(2), based in part on the allegations that he suffered from certain conditions during his incarceration and appellees failed to provide him with adequate medical care and prevented him from using the community work centers, accessing the satellite and regional prison facilities, working in the kitchen, and attending school. At issue was whether appellees were entitled to sovereign immunity for claims that they violated Title II of the ADA. As a preliminary issue, the court held that appellant had not alleged facts from which the court could reasonably infer that he suffered from a qualifying disability under the ADA and remanded the case to the district court in order to allow appellant to amend his Title II allegations where he had not had an opportunity to amend his claim after being alerted of its deficiencies.

Plaintiff filed an original petition in Texas state court alleging violations of federal law under 42 U.S.C. 1983 and 1985, violations of Texas state law under the Texas whistleblower statute, and common law defamation. At issue was whether the district court abused its discretion by failing to remand the case to Texas state court after all federal claims had been deleted and only Texas state law claims remained. The court held that the district court abused its discretion when it denied plaintiff's motion to remand where the balance of the statutory and common law factors weighed heavily in favor of remanding the pendent Texas state law claims and where Carnegie Univ. v. Cohill did not permit the court to turn any allegation of improper forum manipulation into a trump card which could defeat the heavy balance of the other relevant considerations. Therefore, the court vacated the district court's grant of summary judgment in favor of defendant on each Texas state law claim, reversed the district court's denial of plaintiff's motion to remand, and remanded the case with instructions to the district court to remand the Texas state law claims to the Texas state court from which the case was removed.

Plaintiffs, employers at a terminal for a trucking company, brought claims of race discrimination, retaliation, and hostile work environment against defendant, their employer. At issue was whether the district court properly granted summary judgment in favor of defendants and dismissed each of plaintiff's claims. The court held that summary judgment was proper where the chief district judge's opinion granting summary judgment was thorough and well-reasoned, based on evidence that plaintiffs properly presented and where the district court had no duty to "comb the entire record" for evidence.

Defendants, a husband and wife, filed a suit in federal court alleging that the U.S. Attorney for the Southern District of Mississippi ("U.S. Attorney"), who prosecuted defendants for fraud, bribery, and tax evasion charges, violated 42 U.S.C. 1983 and statutes prohibiting government officials from releasing private tax records obtained in the course of their duties when he included defendants' federal tax records obtained during a criminal investigation in the complaint he filed with the Mississippi Commission on Judicial Performance about the husband's conduct. At issue was whether prosecutorial immunity extended to a prosecutor's post-trial transfer of private federal tax records to a state ethics commission. The court held that the U.S. Attorney did not have prosecutorial immunity in this case where there was no case precedent extending immunity to post-trial conduct relating to a new action before a new tribunal and where the policies underlying prosecutorial immunity did not justify immunity in this context.