Justia Civil Rights Opinion Summaries

Plaintiffs filed a civil rights action against defendants seeking damages for injuries suffered as a result of their nine-month imprisonment. Plaintiffs were arrested for murder and the charges against them were eventually dropped. On appeal, plaintiffs challenged the district court's grant of summary judgment on the false arrest claim in favor of Defendants Brooks and McNeal, the grant of summary judgment on the malicious prosecution claim in favor of Brooks, and the denial of their motion for leave to amend. Because the district court did not certify as a final judgment its initial order dismissing the claims against Lamar County with prejudice, Lamar County was still a party to the suit at the time plaintiffs sought leave to amend their complaint. The district court thus abused its discretion in denying plaintiffs' motion for leave to amend. The district court did not, however, abuse its discretion when it denied plaintiffs leave to amend their complaint to add Defendant Keele to the litigation. Finally, the court affirmed the district court's orders granting summary judgment to defendants. View "Crostley, et al. v. Lamar County, TX, et al." on Justia Law

Plaintiff, currently serving life sentences in Louisiana, repeatedly sought to have his sentences commuted in order to become eligible for parole. After he was first convicted, Louisiana altered its commutation process. This appeal concerned plaintiff's complaint that the application of the new process to him violated the ex post facto provisions of the United States and Louisiana Constitutions. Because the ultimate decision of the Louisiana governor as to whether to grant or deny commutation remained entirely discretionary, plaintiff could not establish an ex post facto violation by identifying alterations to the State's commutation procedure increasing the amount of time between when commutation applications could be filed and granting the Board authority to deny a full hearing on an applicant. Accordingly, the court affirmed the judgment of the district court. View "Howard v. Blanco, et al" on Justia Law

Plaintiff brought this gender discrimination suit against LSU, alleging that the LSU Police Department violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, et seq., as well as Louisiana state employment law, La. Rev. Stat. Ann. 23:332(A)(1), 23:967, by failing to promote her to the position of Chief of Police and retaliating against her for filing complaints with the EEOC and LCHR. The court reversed the district court's grant of summary judgment in favor of LSU because plaintiff had established a prima facie case of discrimination and there was a genuine disputed issue of fact of whether LSU's alleged non-discriminatory reason for not promoting plaintiff was pretextual. Accordingly, summary judgment on the gender discrimination claim was improper. Plaintiff had also shown a conflict in substantial evidence regarding retaliation and, therefore, summary judgment was improper on that second claim. View "Haire v. Board of Supervisors of LA State University" on Justia Law

This case presented a constitutional challenge to Texas's statutory scheme, which does not allow 18- to 20-year-old adults to carry handguns in public. The court held that the state scheme withstood this challenge because the court was bound by a prior panel opinion of this court, NRA v. Bureau of Alcohol, Tobacco, Firearms, & Explosives. Because plaintiffs Jennings and Harmon were now 21, the court remanded their claims to the district court with instructions to dismiss them as moot. The court also reversed the district court's ruling that the remaining plaintiffs did not have standing to challenge Texas's general criminal provision barring persons from carrying handguns in public. Finally, with respect to the general criminal provision, the court rendered, and with respect to the licensing law the court affirmed the district court, holding that the Texas scheme did not violate the Second or the Equal Protection Clause. View "Nat'l Rifle Ass'n of America Inc, et al. v. McCraw" on Justia Law

Plaintiff brought suit against defendant, a deputy officer, following an altercation between the parties where plaintiff alleged claims of false arrest and excessive force. On appeal, defendant challenged the district court's denial of summary judgment based on qualified immunity on plaintiff's 42 U.S.C. 1983 claims and state-law official immunity on plaintiff's state-law claims. The court held that defendant was entitled to qualified immunity on plaintiff's false arrest claim because a reasonable officer at the scene would have thought that he had probable cause to arrest plaintiff, but not on plaintiff's excessive force claim. In addition, defendant was entitled to official immunity on plaintiff's state-law false arrest and imprisonment claim but not on plaintiff's state-law assault and battery claim. Accordingly, the court reversed in part and dismissed in part. View "Ramirez v. Martinez" on Justia Law

A jury found that Raytheon willfully violated the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Texas Commission on Human Rights Act (TCHRA), Tex. Lab. Code 21.001 et seq., by terminating plaintiff because of his age. Both parties appealed. The court affirmed the finding of liability; affirmed in part the award of liquidated damages, and vacated the liquidated damages award for enhanced pension because it was a future, not past loss; vacated the damages for mental anguish, rejected plaintiff's issues on cross-appeal; and remanded for reconsideration of the front pay award. View "Miller v. Raytheon Co." on Justia Law

Plaintiff, a contract FBI employee, sued the government under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq., alleging sex discrimination and retaliation. The district court dismissed for failure to state a claim under Rule 12(b)(6) and for summary judgment. The court concluded that subsection (g) created a security exemption to Title VII where access was denied to a premise where secure information was kept. Therefore, plaintiff could not be granted relief under Title VII where the government advanced numerous reasons for revocation of her access to the building where secured information was kept, all of which were related to security breaches she allegedly committed. View "Toy v. Holder, Jr." on Justia Law

Plaintiffs filed this action pursuant to 42 U.S.C. 1983 against defendants, claiming that officers violated their right to freedom from excessive force and the officers acted in furtherance of a City official policy of racial profiling and discrimination. At issue was whether the officer at issue should be granted qualified immunity for his use of force against two of the plaintiffs. The officer fired his pistol at one plaintiff three times, striking him once in the chest and causing serious injury. Because no genuine dispute of material fact existed for whether the officer at issue directed deadly force against that plaintiff and non-deadly force at another plaintiff was objectively unreasonable in the light of clearly-established law, the Rule 54(b) judgment in favor of the officer was affirmed. View "Tolan, et al v. Cotton, et al" on Justia Law

Plaintiff, a professor at LSU, appealed the district court's dismissal of his complaint for lack of subject matter jurisdiction and for failure to state a claim on which relief can be granted. Plaintiff alleged discrimination based on his race, religion, national origin, age, and gender. Although plaintiff asserted claims for injunctive and declaratory relief, he could not overcome sovereign immunity under Ex parte Young because he named only LSU, LSU Health, and the LSU Board as defendants. Therefore, the court found that sovereign immunity barred plaintiff's claims under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., and 42 U.S.C. 1983 and 1985. Plaintiff's state law claims were also barred by sovereign immunity. With regard to plaintiff's remaining claims, the court recognized that plaintiff was not required to establish a prima facie case of discrimination at the pleading stage, but the court nonetheless concluded that plaintiff had failed to state a claim for which relief could be granted. Accordingly, the court affirmed the judgment. View "Raj v. LSU, et al" on Justia Law

Plaintiff, a member of the Seventh-day Adventist faith, appealed from the district court's ruling on summary judgment that plaintiff's employer, First Student, reasonably accommodated his religion. Seventh-day Adventists observe the Sabbath from sundown Friday to sundown Saturday, and they emphasize the importance of refraining from secular work during this time. First Student terminated plaintiff for excessive absenteeism when he did not show up to work on Fridays. The court concluded that summary judgment was not appropriate at this stage of the litigation because there were genuine disputes of material fact regarding whether First Student reasonably accommodated plaintiff and whether accommodating plaintiff constituted an undue hardship on First Student. View "Antoine v. First Student, Inc." on Justia Law