Justia Civil Rights Opinion Summaries

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law

Plaintiff brought this action alleging that a correctional officer and a lieutenant at the jail in which plaintiff was detained violated plaintiff's constitutional rights by failing to protect him from being attacked by three fellow inmates. Both defendants appealed the district court's denial of their motion for summary judgment based on qualified immunity. The court concluded that the district court properly denied qualified immunity to the correctional officer where there was sufficient evidence on the present limited record from which a jury could infer that he acted with the requisite mental state for a constitutional violation. The court concluded, however, that there was no admissible evidence to establish that the lieutenant knew about a substantial risk to plaintiff's safety and, thus, the lieutenant was entitled to qualified immunity. Accordingly, the court affirmed in part and denied in part, remanding for further proceedings. View "Glaze v. Andrews, et al." on Justia Law

Plaintiff filed suit against defendant, the deputy sheriff that had arrested him, alleging excessive force and false arrest under the Fourth and Fourteenth Amendments and 42 U.S.C. 1983. The district court found that defendant had failed to meet his burden of proving probable cause and denied his motion for partial summary judgment on the false arrest claim. The court found no merit in defendant's claim that the district court effectively imposed a novel requirement that an officer may conduct a warrantless arrest for a misdemeanor offense only if that offense took place in the presence of the officer. The court reversed and remanded, concluding that defendant met his burden of showing arguable probable cause and he was, therefore, entitled to qualified immunity with respect to the false arrest claim. View "Chevallier v. Hand" on Justia Law

Plaintiffs filed these actions to enjoin enforcement of Ordinance No. 5165, which limited hiring and providing rental housing to "illegal aliens" and "unauthorized aliens," terms defined by the Ordinance. The district court severed and enjoined enforcement of certain rental provisions, concluding that they were preempted by the Immigration and Nationality Act (INA), 8 U.S.C. 1101 et seq., and violated the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq. The court concluded, inter alia, that plaintiffs have failed to establish that any of the Ordinance's rental provisions were facially preempted by federal law; the district court did not abuse its discretion in denying the Martinez Plaintiffs' motion to correct their "oversight or omission" in failing to plead a distinct FHA claim; because one of the Keller Plaintiffs had Article III standing to assert an FHA disparate impact claim, the court had jurisdiction to consider the merits of the claim; on the merits, the Keller Plaintiffs could not identify "a viable alternative means" that would not have the same "discriminatory" effect and disparate impact on the portion of unlawfully presented aliens who are Latino and, therefore, this claim must be dismissed; and the Martinez Plaintiffs failed to prove their belated claims of actual conflict. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Keller, Jr., et al. v. City of Fremont, et al." on Justia Law

A bankruptcy court ordered that the Laurel Avenue house be vacated and authorized U.S. Marshals to physically remove plaintiff, the debtor's son, from the home. On appeal, plaintiff challenged the dismissal of his suit, which alleged, inter alia, that his constitutional rights were violated when the house, its contents, and his person were searched and seized. The court found no error in the dismissal of plaintiff's 42 U.S.C. 1983 claim against the federal defendants where he did not allege a Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics action in the amended complaint, nor did he seek to amend to add the claim; plaintiff's section 1983 claim failed against the city and the city's officers where plaintiff failed to set forth sufficient facts to show a direct causal link between the city's policy or custom and the alleged violation of his constitutional rights; the district court did not err in dismissing his tort claims against the trustees under the doctrine established in Barton v. Barbour, which established that an equity receiver could not be sued without leave of the court that appointed him; and because the dismissal of plaintiff's federal claims was proper, the court found no abuse of discretion in the district court's decision to decline supplemental jurisdiction over the remaining state law claims. Accordingly, the court affirmed the judgment. View "Alexander v. Hedback, et al." on Justia Law

Plaintiff, an involuntarily committed mental patient, sued various officials alleging that a facility-wide change in policy deprived him of a previously held ability to walk unsupervised around an unsecured area of the grounds at the Center where he was committed. Where, as here, it was difficult even to characterize the claimed restriction as a bodily restraint, the balancing test of the professional-judgment standard necessarily lead the court to conclude that plaintiff's claims failed. Even if plaintiff had articulated a protected liberty interest, there was no substantive due process violation where nothing about the policy at issue shocked the conscience. Therefore, the court affirmed the district court's dismissal of plaintiff's due process claim. View "Montin v. Gibson" on Justia Law

Petitioner appealed his convictions, from four separate trials, of criminally transmitting the HIV virus in violation of Iowa Code 709C.1. On appeal, petitioner challenged the district court's denial of his 28 U.S.C. 2254 petition for habeas relief. The court concluded that the statute was not unconstitutionally vague as applied to him because he knew his HIV status to be "positive" and engaged in the type of "intimate contact" that the statute was plainly intended to prohibit; petitioner was precluded from asserting a void-for-vagueness challenge to the statute based on the hypothetical situations posed in his petitions and brief; and petitioner was precluded from asserting an overbreadth challenge to the statute because he did not raise any First Amendment concerns. Accordingly, the court affirmed the district court's denial of habeas relief. View "Musser v. Mapes" on Justia Law

Plaintiff sued the City under 42 U.S.C. 1983 after she was sexually assaulted by a City policy officer. The officer was charged with first degree sexual assault and subsequently terminated from the police force. On appeal, plaintiff challenged the district court's grant of summary judgment to the City. The court concluded that a jury could reasonably infer, based on the evidence, that the City's custom of ignoring violent misconduct and failing to supervise or discipline officers was a moving force behind the officer's assault on plaintiff. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings. View "Doe v. City of Marianna, AR" on Justia Law

Plaintiff sued her former employer and others after she was terminated, alleging federal claims of discrimination based on her gender, religion, and disability, as well as defamation under state law. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on the remaining claims that were not dismissed. The court concluded that the district court did not err in granting summary judgment on plaintiff's discrimination claims to Trumann Health where, under the McDonnell Douglas analysis, Trumann Health articulated a legitimate, nondiscriminatory reason for firing her and plaintiff did not show other similarly situated employees were more favorably treated; the district court properly granted summary judgment on plaintiff's libel claims against her co-workers; and Trumann Health could not be liable for defamation because plaintiff premised Trumann Health's liability upon the individual defendants' liability. Accordingly, the court affirmed the judgment. View "Evance v. Trumann Health Services, et al." on Justia Law