Justia Civil Rights Opinion Summaries

In this appeal, the court considered whether San Rafael's mobilehome rent regulation violated the park owners' substantive due process rights, constituted a regulatory taking under Penn Central Transportation Co. v. New York City, or ran afoul of the public use requirement of the Fifth Amendment under the standards articulated in Kelo v. City of New London. The court concluded that the district court properly rejected the City's arguments that MHC's claims were barred by the statute of limitations and precluded by res judicata, and the district court did not abuse its discretion in allowing MHC to amend its complaint. The court also concluded that the regulation did not constitute either a Penn Central or a private taking. Because the court reached the merits of the takings issue, the court need not resolve the question of ripeness. The court further concluded that the district court did not err in granting judgment on MHC's substantive due process claims; the district court did not err in submitting the breach of settlement contract claims to the jury, denying the motion for a directed verdict on that question, denying the motion for a new trial, or awarding attorneys' fees; and in its original lawsuit, MHC waived its claim for damages in order to have a bench trial on the constitutional claims. Accordingly, the court reversed the district court's holding as to the Penn Central and private takings, but affirmed the judgment in all other respects. View "MHC Limited Financing v. City of San Rafael" on Justia Law

Plaintiff appealed the district court's order granting summary judgment in favor of the County Defendants. Plaintiff claimed, among other things, that the County Defendants conspired to violate, and did violate, her Fourth and Fourteenth Amendment rights when they unlawfully searched her home pursuant to an invalid search warrant, used excessive force in the execution of that warrant, and arrested her without probable cause. Because there was probable cause to search plaintiff's residence and to arrest her, the court affirmed the district court's entry of judgment with respect to those claims. Because disputed issues of material fact remained regarding plaintiff's excessive force and conspiracy claims, however, the court reversed and remanded those claims to the district court for further proceedings. View "Cameron v. Craig" on Justia Law

Plaintiff sued several police officers and their employer, the City of Los Angeles, for false arrest, false imprisonment, and malicious prosecution. Plaintiff was charged with attempted murder and was eventually acquitted. At issue was whether plaintiff's action was barred by the doctrine of issue preclusion. The court concluded that plaintiff raised a genuine dispute as to whether an officer fabricated evidence at the preliminary hearing by falsely testifying that the victim had identified plaintiff as the shooter. That alleged fabrication plainly met the materiality threshold for defeating summary judgment on the merits. In this case, the state court never purported to find either that the officer's testimony was credible or that the victim's testimony was not. Accordingly, plaintiff was not barred by the doctrine of issue preclusion and, therefore, the court reversed and remanded. View "Wige v. City of Los Angeles" on Justia Law

AGC sought declaratory and injunctive relief against Caltrans and its officers, on the grounds that Caltrans' 2009 Disadvantaged Business Enterprise program unconstitutionally provided race- and sex-based preferences to certain groups. On appeal, AGC challenged the district court's adverse summary judgment rulings. The district court held that Caltrans' substantial statistical and anecdotal evidence provided a strong basis in evidence of discrimination against the four named groups, and that the program was narrowly tailored to benefit only those groups. The court dismissed AGC's appeal because AGC did not identify any of its members who have suffered or will suffer harm as a result of Caltrans' program, and therefore AGC had not established that it had associational standing to bring suit. View "Assoc. Gen. Contractors v. Cal. Dept. of Transp." on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against defendants alleging that he was unlawfully arrested and searched in violation of the Fourth Amendment. Plaintiff was arrested for trespass under California Penal Code 602.8 because he was standing by himself inside a playground that was surrounded by a fence that had "No Trespassing" signs posted at every entrance. The court rejected defendants' argument that the grounds for custodial arrest specified in California Penal Code 853.6(i) applied not only to misdemeanors but also to infractions. Consistent with precedent, the statute's plain language, the rule against superfluity, and other persuasive authority, the court held that California Penal Code 853.5 provided the exclusive grounds for custodial arrest of a person arrested for an infraction. Therefore, the court vacated the judgment in favor of defendants on plaintiff's state law false arrest claim and remanded for further proceedings. If there are no further issues pertaining to liability on this claim, the district court should enter judgment in favor of plaintiff and proceed to a trial on damages. The court rejected plaintiff's remaining contentions. View "Edgerly v. City and County of San Francisco, et al" on Justia Law

Defendant, a prison inmate, filed suit challenging his validation as an "associate" of the Mexican Mafia, a recognized prison gang. The court held that defendant's void-for-vagueness challenge of Cal. Code Regs. tit. 15, 3378(c)(4), an administrative regulation that guides officials in validating inmates as gang affiliates, failed because section 3378(c)(4) clearly indicated to defendant that his conduct could result in validation. Although the district court should have evaluated whether defendant was validated based on "some evidence," remand was not required to correct the error. The evidence in the record showed that prison officials relied on "some evidence" to validate defendant as an associate of the Mexican Mafia gang. Accordingly, the court affirmed the judgment of the district court. View "Castro v. Terhune, et al" on Justia Law

This dispute arose from California's implementation of a change to Medicare in 2006. The Centers argued that California mishandled the shift in payment responsibility for dual-eligibles' prescription drug costs from state Medicaid programs to the new, federal Medicare Part D Program. The Centers brought suit for declaratory and injunctive relief. Among other things, the Centers urged the federal courts to declare unlawful California's "seizure" of the Centers' Medicare Part D funds, in excess of what would be owed under the per-visit rate for the Centers' expenses. The court concluded that the Eleventh Amendment barred the Centers' claims for retroactive monetary relief; the court affirmed the district court's dismissal of the Centers' claims to the extent that they sought money damages; however, the court reversed the district court and remanded to allow the district court to assess Ex parte Young's application to the Center's remaining claims. View "North East Medical Services v. CA Dept. of Health" on Justia Law

Plaintiff brought a Title VII action against her former employer, West Coast, claiming sexual harassment and retaliatory discharge. The district court granted summary judgment to West Coast and plaintiff appealed. Because the court concluded that the evidence, viewed favorably to plaintiff, did not show sexual harassment that was sufficiently severe or pervasive to alter the terms of plaintiff's employment and subject her to an abusive environment, the court affirmed the judgment for West Coast on her sexual harassment claim. The court concluded that the evidence was sufficient to raise a material question of fact as to whether plaintiff's July 14 complaints - which the court already said could be protected activity - were a but-for cause of her termination. Therefore, the court believed that the district court erred in granting summary judgment on the retaliation claim. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Westendorf v. West Coast Contractors of NV" on Justia Law

Plaintiffs sued the City of Lancaster under 42 U.S.C. 1983 and Article I, Section 4 of the California Constitution, requesting declaratory and injunctive relief from the City's policy of permitting prayers that mention Jesus. Plaintiffs argued that both the invocation at issue and the City's prayer policy amounted to an establishment of religion. The invocation did not proselytize, advance, or disparage any faith. The court rejected plaintiffs' argument that the City, through its prayer practice, placed its official seal of approval on Christianity where the City has taken every feasible precaution to ensure its own evenhandedness. Therefore, the court held that the district court correctly determined that neither the invocation at issue nor the City's prayer policy constituted an unconstitutional establishment of religion. For the same reasons that plaintiffs' First Amendment claim failed, their state claim failed as well. Accordingly, the court affirmed the judgment. View "Rubin, et al v. City of Lancaster" on Justia Law

Plaintiff brought suit against the Chief of Police and the City under 42 U.S.C. 1983, alleging a First Amendment retaliation claim. Plaintiff, a police officer for the City, led a no-confidence vote of the police officers' union against the Chief. The Chief subsequently delayed signing an application for a certification that would have entitled plaintiff to a five percent salary increase. The district court granted summary judgment in favor of defendants, concluding that plaintiff failed to meet his burden under Garcetti v. Ceballos, to show that he undertook his act as a private citizen and not pursuant to his official duties. The court disagreed and held that plaintiff had established a prima facie case of First Amendment retaliation. Therefore, the court reversed the grant of summary judgment in favor of the Chief and remanded for further proceedings. The court affirmed the district court's grant of summary judgment to the City because plaintiff did not adduce sufficient evidence to defeat summary judgment on his Monnell claim. View "Ellins v. City of Sierra Madre, et al" on Justia Law