Justia Civil Rights Opinion Summaries

Plaintiff, who has difficulty walking because of certain health problems, alleged that United did not provide her with adequate assistance moving through the airport on two airplane trips and that she suffered physical and emotional injuries as a result. The court held that the Air Carrier Access Act (ACAA), 49 U.S.C. 40101 et seq., and its implementing regulations preempted state and territorial standards of care with respect to the circumstances which airlines must provide assistance to passengers with disabilities in moving through the airport. The ACAA did not, however, preempt any state remedies that could be available when airlines violated those standards. The court also held that the ACAA and its implementing regulations did not preempt state-law personal injury claims involving how airline agents interact with passengers with disabilities who requested assistance in moving through the airport. Finally, the court held that a terminal used for transportation by aircraft was excluded from definition as a Title III-covered place of public accommodation under the Americans with Disabilities Act (ADA), 42 U.S.C. 12181 et seq. Accordingly, the court affirmed in part, reversed in part, and remanded in part. View "Gilstrap v. United Air Lines, Inc." on Justia Law

Plaintiffs brought suit pursuant to 42 U.S.C. 1983, alleging that defendants enforced two local ordinances in violation of the Eighth Amendment. On appeal, plaintiffs challenged the district court's order granting summary judgment to defendants. The court reversed the dismissal of plaintiffs' claims for retrospective relief because those claims were not barred by the Rooker-Feldman doctrine; the court reversed the dismissal of plaintiffs' claims for prospective relief because those claims have not been mooted by defendants' voluntary conduct; the court did not reach the merits of plaintiffs' Eighth Amendment challenges; and the court held that jurisdiction existed as to plaintiffs' Eighth Amendment claims and remanded for a consideration of the merits in the first instance. View "Bell, et al v. City of Boise, et al" on Justia Law

Plaintiffs brought a pre-enforcement action under 42 U.S.C. 1983 against defendant, the California Secretary of State. At issue were the California Elections Code sections 8066 and 8451, which mandated that circulators shall be voters in the district or political subdivision in which the candidate was to be voted on and shall serve only in that district or political subdivision. Plaintiffs alleged that the residency requirement violated the First and Fourteenth Amendments and sought to enjoin its enforcement. The court reversed and remanded the district court's dismissal of the complaint on the ground that plaintiffs lacked standing, holding that plaintiffs have alleged a sufficient injury-in-fact to meet constitutional standing requirements. In light of plaintiffs' concrete plan and defendant's specific threat of enforcement, the court concluded that plaintiffs have met the constitutional "case or controversy" requirement. View "Libertarian Party Los Angeles, et al v. Bowen" on Justia Law

This case involved two provisions in Arizona's Senate Bill 1070, which makes it unlawful for a motor vehicle occupant to hire or attempt to hire a person for work at another location from a stopped care that impedes traffic, or for a person to be hired in such a manner. At issue was whether these provisions violated the First Amendment by restricting and penalizing commercial speech for day laborers and for those who hire them. The court held that the district court correctly determined that, though Arizona had a significant government interest in promoting traffic safety, the day labor provisions failed Central Hudson Gas & Electric Corp. v. Public Service Commission of New York's requirement that restrictions on commercial speech be no more extensive than necessary to serve that interest. The district court did not abuse its discretion in concluding that plaintiffs were likely to succeed on the merits and that the other requirements for a preliminary injunction were satisfied. Therefore, the court affirmed the preliminary injunction barring enforcement of the day labor provisions. View "Valle del Sol, et al v. State of Arizona, et al" on Justia Law

The Association sued the County, alleging that the County had breached its obligation to provide certain vested healthcare benefits in perpetuity. The Association alleged that the County had implicitly promised to provide these benefits. The California Supreme Court's recent decision in Retired Employees Ass'n of Orange County, Inc. v. County of Orange (REAOC II) recognized that a county could form a contract with implied terms under specified circumstances. The court held that the district court did not err in concluding that the amended complaint failed to state a cause of action. Nevertheless, in light of REAOC II, the court could not agree with the district court's decision to deny the Association leave to amend on the ground that such amendment would be futile. Accordingly, the court vacated and remanded for further proceedings consistent with REAOC II. View "Sonoma Cnty. Ass'n of Retired Emp. v. Sonoma Cnty." on Justia Law

The CDCR, in an effort to meet the religious exercise needs of prison inmates, maintained paid full-time and part-time chaplain positions of five faiths: Catholic, Jewish, Muslim, Native American, and Protestant (the Policy). Plaintiffs claimed, under 42 U.S.C. 1983, that various entities and individuals violated their federal and state constitutional rights by refusing to hire a paid full-time Wiccan chaplain and by failing to apply neutral criteria in determining whether paid chaplaincy positions were necessary to meet the religious exercise needs of inmates adhering to religions outside the five faiths. Because plaintiffs sufficiently pleaded facts supporting a plausible claim under the Establishment Clause and the California State Constitution, the court reversed and remanded both claims to the district court for further proceedings. The court affirmed the district court's dismissal of plaintiffs' remaining claims. View "Hartmann, et al v. California Dept. of Corrections, et al" on Justia Law

This case stemmed from plaintiffs' complaint asserting state and federal causes of action against eight defendants. At issue on appeal was the district court's award of attorney's fees and costs to Plaintiff Joseph Padgett. The court vacated the district court's award of costs and attorney's fees because the district court provided no explanation of how it calculated them. The court remanded to the district court for an explanation of how it used the lodestar method to reduce Padgett's fees and how it calculated Padgett's reduced costs. For the same reason, the district court erred in failing to explain why it denied costs to the prevailing defendants. While the district court had discretion to depart from Federal Rule of Civil Procedure 54(d) in appropriate cases, the court could not review its unexplained order for abuse of discretion. Accordingly, the court vacated and remanded. View "Padgett, et al v. Loventhal, et al" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of the City and two of its police officers, in his 42 U.S.C. 1983 action. Plaintiff alleged, inter alia, that the police officers retaliated against him for exercising his First Amendment right to freedom of speech after he was cited for a noise violation. The court held that plaintiff had put forth facts sufficient to allege a violation of his clearly established First Amendment right to be free from police action motivated by retaliatory animus, even if probable cause existed for that action. Therefore, the officers were not entitled to qualified immunity and plaintiff's claims should proceed to trial. View "Ford v. City of Yakima, et al" on Justia Law

Good News appealed from the district court's determination on remand from the Ninth Circuit that the Town's ordinance restricting the size, duration, and location of temporary directional signs did not discriminate between different forms of noncommercial speech in an unconstitutional manner. In Reed v. Town of Gilbert, the court held that the ordinance was not a content-based regulation and was a reasonable time, place, and manner restriction. Accepting the court's opinion in Reed as law of the case, the court concluded that the Sign Code was constitutional because the different treatment of types of noncommercial temporary signs were not content-based as that term was defined in Reed, and the restrictions were tailored to serve significant government interests. Good News' other challenges did not merit relief. Further, the court determined that the amendments to the Sign Code made by the Town during the pendency of the appeal did not moot this case and that Good News could file a new action in the district court should it wish to challenge the new provisions of the Sign Code. View "Reed, et al v. Town of Gilbert, Arizona, et al" on Justia Law

Plaintiffs, Filipino World War II veterans and their widows, contended that their Fifth Amendment rights to due process and equal protection were violated by a statute establishing the Filipino Veterans Equity Compensation Fund (FVEC) and by the VA's administration of it, resulting in their lack of payment. The district court dismissed the claims with prejudice on the pleadings for lack of subject matter jurisdiction and for failure to state a claim. The court held that the Veterans' Judicial Review Act, Pub. L. No. 100-687, div. A, 102 Stat. 4105, barred review of plaintiffs' due-process claim and the district court's dismissal of the claim was appropriate. Because plaintiffs' complaint did not challenge a new classification established by the American Recovery and Reinvestment Act, Pub. L. No. 111-5, 1002(i), 123 Stat. at 202, and did not allege any plausible facts suggesting that the classification in 38 U.S.C. 107 was created for a discriminatory purpose, the court held that the district court did not err when it dismissed the equal-protection claim under Rule 12(b)(6). View "Recinto, et al v. The U.S. Dept. of Veterans Affairs, et al" on Justia Law