Justia Civil Rights Opinion Summaries

Plaintiff brought a 42 U.S.C. 1983 suit against officials from the California State Prison, alleging constitutional violations relating to his six-day placement on contraband watch. Plaintiff was placed on contraband watch after three unlabeled bottles found in his prison cell tested positive for methamphetamine. The district court granted defendants' motion for summary judgment in part but denied summary judgment with respect to plaintiff's Eighth Amendment and due process claims against Defendant Mandeville and Rosario. The court held that both Defendant Mandeville and Rosario were entitled to qualified immunity because the law at the time plaintiff was on contraband watch did not clearly establish that their actions were unconstitutional. View "Chappell v. Mandeville, et al" on Justia Law

Plaintiff alleged that defendants, correctional officers at the prison where he was incarcerated at the time of the alleged occurrence, violated his Eighth Amendment rights by spraying him with an excessive quantity of pepper spray. Plaintiff also alleged that his Fourteenth Amendment rights were disregarded when the officers denied him a vegetarian breakfast. The court held that the district court failed to draw all inferences in plaintiff's favor when resolving the issue of qualified immunity in a summary judgment and therefore, the court reversed and remanded on plaintiff's Eighth Amendment claim. The court affirmed the district court's grant of summary judgment on the Equal Protection challenge where plaintiff failed to raise a triable issue of fact with respect to whether the officers intentionally refused to provide him with a religious breakfast tray while providing the same to other inmates who were similarly situated. View "Furnace v. Sullivan, et al" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of her former employer, Montblanc, and its President and CEO, Jan-Patrick Schmitz. The court concluded that Montblanc demonstrated that plaintiff could not perform the essential functions of store manager by offering her admissions that her disability prevented her from performing any work and plaintiff, in response, offered no submission establishing a triable issue of fact. Therefore, summary judgment on plaintiff's disability discrimination claim under the California Fair Employment and Housing Act (FEHA), Cal. Gov't Code 12940(a), was proper. Because plaintiff pointed to no evidence that would raise a triable issue of whether Montblanc's true reason for terminating her employment was discriminatory, the court affirmed summary judgment on the retaliation claim under section 12940(h). Further, Schmitz's conduct during a store visit did not constitute harassment under section 12940(j). Finally, plaintiff's claim of intentional infliction of emotion distress failed where Schmitz's conduct could not be characterized as exceeding all bounds of that tolerated in a civilized community and plaintiff's alleged emotional distress was not "severe." Accordingly, the court affirmed the dismissal of all of plaintiff's claims.View "Lawler v. Mountblanc North America, LLC, et al" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action claiming that defendants were deliberately indifferent to his medical needs related to dental care. On appeal, defendant challenged the district court's judgment as a matter of law in favor of Dr. Dillard and Dr. Fitter and judgment following a jury verdict in favor of Dr. Brooks. At issue was whether the district court erred when it instructed the jury on the question of whether Dr. Brooks could be held responsible for failing to provide services when he lacked resources. The court held that the principle contained in the instructions given in this case was a proper one where the instruction took into account the duties, discretion, and means available. The instruction, in effect, stated that if Dr. Brooks could not "render or cause to be rendered" the needed services because of a lack of resources that he could not cure, he also could not individually be liable. Accordingly, the court affirmed the judgment. View "Peralta v. Dillard, et al" on Justia Law

Plaintiff was convicted of four counts of first-degree murder and sentenced to death in 1995. Plaintiff filed suit in federal district court in California challenging a state court's denial of his request to obtain additional DNA testing pursuant to a state statute. Plaintiff alleged that he was the target of a conspiracy involving members of the county sheriff's department and others. The district court dismissed on the basis that it lacked subject matter jurisdiction under the Rooker-Feldman doctrine. Under that doctrine, the federal courts lacked subject matter jurisdiction over his first claim, which sought federal relief from the state court's determination in the DNA proceeding, and over his second and third claims, which were inextricably intertwined with the first. Therefore, the court agreed with the district court that his complaint was properly dismissed. The court also held that the district court did not err in implicitly denying plaintiff's request to amend his complaint. View "Cooper v. Ramos, et al" on Justia Law

In the four cases giving rise to these eleven consolidated appeals, the Secretary of the Department of Health and Human Services (HHS) and the Director of the California Department of Health Care Services (DHCS), appealed the district court's grant of preliminary injunctions to plaintiffs, various providers and beneficiaries of California's Medicaid program (Medi-Cal). At issue was the implementation of Medi-Cal reimbursement rate reductions. The court held that Orthopaedic Hospital v. Belshe did not control the outcome in these cases because it did not consider the key issue here - the Secretary's interpretation of 42 U.S.C. 1396a(a)(30)(A); the Secretary's approval of California's requested reimbursement rates were entitled to Chevron deference; and the Secretary's approval complied with the Administrative Procedures Act, 5 U.S.C. 500 et seq. The court further held that plaintiffs were unlikely to succeed on the merits on their Supremacy Clause claims against the Director because the Secretary had reasonably determined that the State's reimbursement rates complied with section 30(A). The court finally held that none of the plaintiffs had a viable takings claim because Medicaid, as a voluntary program, did not create property rights. View "Managed Pharmacy Care, et al v. Sebelius, et al" on Justia Law

Plaintiff filed an action in district court under 42 U.S.C. 1983, alleging that her Fourth Amendment rights had been violated by an officer's warrantless entry into her front yard and sought damages for her injuries. Plaintiff sustained serious injuries as a result of the officer's act of kicking down the front gate of her yard while in pursuit of a suspect who had committed at most a misdemeanor offense. The district court found that the officer was entitled to qualified immunity and granted his motion for summary judgment. The court held, however, that the law at the time of the incident would have placed a reasonable officer on notice that his warrantless entry into the curtilage of a home constituted an unconstitutional search, which could not be excused under the exigency or emergency exception to the warrant requirement. Therefore, the officer was not entitled to qualified immunity and the court reversed the judgment of the district court. View "Sims v. Stanton" on Justia Law

Plaintiff, a state prisoner, asserted that denials by prison officials of his request for a conjugal visit with his wife violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., and the First Amendment, by interfering with his practice of a tenet of his Islamic faith requiring him to marry, consummate his marriage, and father children. The court held that because plaintiff's claim was based on an independently wrongful, discrete act in 2008, which was the denial of his request for conjugal visits with his second wife, his claims were not time-barred, notwithstanding the denial, pursuant to the same regulation, of his prior requests for conjugal visits with his first wife in 2002. View "Pouncil v. Tilton, et al" on Justia Law

In this prisoner civil rights action filed pursuant to 42 U.S.C. 1983, plaintiff appealed from the dismissal with prejudice of his first amended complaint for deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Plaintiff alleged that defendants violated his rights by failing to comply with his medical "chrono," which required him to be housed in a ground floor cell and that defendants failed to provide him with an interpreter at medical appointments. The court held that the district court erred by refusing to consider arguments that plaintiff raised for the first time in his objections to a magistrate judge's findings and recommendations on defendants' motion to dismiss; concluding that defendant failed to exhaust his administrative remedies; and dismissing his complaint on the ground that he failed to state a claim upon which relief could be granted. Further, the district court erred by failing to provide notice pursuant to Rand v. Rowland. Accordingly, the court vacated and remanded. View "Akhtar v. J. Mesa, et al" on Justia Law

Plaintiffs, Yellow Page Companies, challenged the validity of Seattle's imposition of substantial conditions and costs on the distribution of yellow page phone directories (Ordinance 123427). The district court rejected plaintiffs' challenges and granted summary judgment in favor of the City, allowing the Ordinance to stand. The court concluded that, although portions of the directories were obviously commercial in nature, the books contained more than that, and the court concluded that the directories were entitled to the full protection of the First Amendment. As a result, when the court evaluated the Ordinance under strict scrutiny, the Ordinance did not pass strict scrutiny because it was not the least restrictive means available to further the government's interest. Accordingly, the court reversed the district court's entry of summary judgment in favor of the City and remanded for the entry of judgment in favor of plaintiffs. View "Dex Media West, Inc., et al v. City of Seattle, et al" on Justia Law