Justia Civil Rights Opinion Summaries

Plaintiff sued Luminant, his employer, alleging several unlawful employment practices. The jury agreed with plaintiff that plaintiff's complaints motivated Luminant's decision to discipline him. The jury also found, however, that Luminant proved, by a preponderance of the evidence, that it would have made the "same decision" irrespective of his complaints. The district court entered judgment in Luminant's favor and taxed all costs against plaintiff. Plaintiff moved to retax costs and sought an award of attorney's fees. The court held that 42 U.S.C. 2000e-5(g)(2)(B)(i) authorized cost-and-fee-shifting only for violations of section 2000e-2(m). Retaliation did not violate section 2000e-2(m). Consequently, the district court correctly decided that section 2000e-5(g)(2)(B)(i) did not authorize cost-and-fee-shifting. Accordingly, the court affirmed the judgment of the district court. View "Carter v. Luminant Power Services Co." on Justia Law

Plaintiff, a Texas state prisoner of Muslim faith, filed a pro se complaint against TDCJ pursuant to the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-5, and 42 U.S.C. 1983. Plaintiff claimed that TDCJ violated RLUIPA and his constitutional rights by prohibiting him from wearing a beard and from wearing a white head covering, known as a Kufi, to and from worship services. The district court granted declaratory and injunctive relief in favor of plaintiff to the extent that TDCJ's policy prohibited him from wearing a quarter-inch beard. TDCJ appealed. As a preliminary matter, the court held that the district court did not violate Federal Rule of Civil Procedure 52(a)(1), which required that the district court find the facts specially and state its conclusions of law separately. On the merits, the court held that TDCJ had not satisfied its burden of showing that the no-beard policy was the least restrictive means of furthering the compelling interests of controlling costs and in security by promoting easy identification of inmates. Accordingly, the court affirmed the judgment of the district court. View "Garner v. Kennedy, et al." on Justia Law

Plaintiff, arguing pro se, appealed the district court's summary judgment on his racial discrimination claims against Huntington. The court granted Huntington's motion to summarily dismiss the appeal because plaintiff's appellate brief failed reasonably to comply with Federal Rule of Appellate Procedure 28, which required a statement of issues presented for review. View "Davison v. Huntington Ingalls, Inc." on Justia Law

Plaintiff appealed from the district court's dismissal of her civil rights action against the District. Plaintiff sought review of her claim under section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, for the District's alleged gross mismanagement of her Individualized Education Program (IEP) and failure to reasonably accommodate her disabilities. Because plaintiff plausibly stated that the District acted with gross misjudgment in failing to further modify her IEP, the court reversed and remanded for further proceedings. Because plaintiff appealed only the dismissal of her Rehabilitation Act claim, the court did not address the district court's rulings as to the other claims. View "Stewart v. Waco Indep. Sch. Dist." on Justia Law

Plaintiff brought suit against a law enforcement officer, the City of Amarillo, and other defendants, alleging that the officer had wrongfully arrested him two years earlier. On appeal, plaintiff challenged the district court's dismissal of his suit because he failed to show good cause for the delay in perfection of service. Because the district court's warning of dismissal and grant of extensions accompanied by generous allotments of time did not influence plaintiff to effect service properly, the court could not say that the district court abused its discretion in dismissing plaintiff's claim. View "Thrasher v. Amarillo Police Dept, et al" on Justia Law

Plaintiff appealed the district court's sua sponte dismissal of his civil rights complaint as frivolous and for failure to state a claim upon which relief could be granted. The court held that the district court abused its discretion in dismissing the claim against one corrections officer at the initial screening stage and before the filing of any responsive pleadings. The district court did not err in dismissing plaintiff's denial of medical care claim where the officers did not show deliberate indifference regarding plaintiff's denial of medical treatment and because the officers took plaintiff to see a V.A. hospital physician after the incident at issue and transported him subsequently to the prison medical department for treatment. In regards to the claim regarding plaintiff's injury in the van, the issue was moot. As for the denial of medical care claim, allowing plaintiff to amend his complaint would have been futile and the district court did not err in declining to provide leave to file an amended complaint. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Rogers v. Boatright, et al" on Justia Law

Defendant was found not guilty of second degree murder by reason of insanity and was committed to the Attorney General's custody under 18 U.S.C. 4243(e). Defendant was subsequently found to no longer be a substantial risk to others if he followed a strict treatment regimen and was conditionally released. The district court then later found that defendant failed to comply with the conditions of his release and that he posed a substantial risk of bodily injury to others. Consequently, the district court revoked the release and placed him back into the custody of the Attorney General. The court held that the district court did not abuse its discretion in not calling for a competency hearing; defendant failed to raise a valid Sixth Amendment complaint and the district court did not abuse its discretion in refusing to replace counsel; and the district court committed no error in its finding underlying the conclusion to revoke the conditional release. Accordingly, the court affirmed the order. View "United States v. Mitchell" on Justia Law

Defendants Mathew Dean Moore and Melvin Williams, former New Orleans Police Officers (NOPD), appealed their convictions and sentences arising from an incident that resulted in the death of an individual. The court concluded that a jury could reasonably conclude from the evidence that the individual's death was proximately caused by and the foreseeable result of being kicked in the chest by Williams; the district court did not err by basing Williams' sentence on the base offense of voluntary manslaughter; the evidence was sufficient to sustain Moore's conviction for aiding and abetting the submission of a false incident report and by obstructing a federal investigation through the submission of a false NOPD incident report and aiding and abetting each other; the evidence was sufficient to sustain Moore's conviction for making false, material statements to the FBI; and the district court did not err in determining Moore's sentence. Accordingly, the court affirmed the convictions and sentences. View "United States v. Moore, et al" on Justia Law

Plaintiff, a former TDCJ employee, appealed the district court's grant of summary judgment for TDCJ on her Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a)(1)(D), claims. Plaintiff's allergic reaction to the use of scented candles and wall plug-ins around her work area was the basis of her ADA claim. The court held that plaintiff did not suffer from a disability within the meaning and coverage of the ADA. Further, there was no dispute that TDCJ did not receive plaintiff's FMLA certification before the deadline. Accordingly, the court affirmed the judgment. View "Milton v. Texas Dept. of Criminal Justice" on Justia Law

Mariner's Cove Townhomes Association appealed the district court's grant of summary judgment on the pleadings for the United States. The district court held that the Association was not entitled to just compensation for the diminution of its assessment base resulting from the government's condemnation of fourteen properties in the Mariner's Cove Development. The court found that the Association's right to collect assessments was a property interest, but the loss of the Association's assessment base was incidental to the condemnation and was barred by the consequential loss rule. Accordingly, the court held that the loss of the Association's right to collect assessments on those properties was not compensable under the Takings Clause of the Fifth Amendment. View "United States v. Land" on Justia Law