Justia Civil Rights Opinion Summaries

This case began as a dispute over the results of CM's special education evaluation under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue on appeal was: (1) the ALJ's dismissal of several of CM's claims against Lafayette prior to holding a due process hearing; and (2) the district court's dismissal of MM's, CM's parents, separate claims against the California Department of Education (CDE). The court held that the district court correctly dismissed MM's claims against Lafayette challenging the ALJ's statute of limitations ruling as being premature. The district court did not abuse its discretion in dismissing the fourth claim as duplicative and correctly held that the CDE had no authority to oversee the individual decisions of OAH's hearing officers. Accordingly, the court affirmed the judgment of the district court.

Plaintiffs brought a First Amendment and other constitutional challenges to regulations and associated guidelines that required permits for "commercial weddings" on public beaches in Hawaii. The court held that Hawaii's regulation of commercial weddings on unencumbered state beaches did not violate the First Amendment, except for a provision giving an official absolute discretion to revoke a permit at anytime and to modify it as the official deemed necessary or appropriate.

Plaintiffs, television news reporters for KPIX-TV, brought suit alleging that KPIX discriminated against them on the basis of age and gender, in violation of California law, when they were laid off. The district court granted KPIX's motion for summary judgment, dismissing all of plaintiffs' claims. The court held that, although plaintiffs established a prima facie case of discrimination, they did not present sufficient evidence of pretext to survive summary judgment. The court wrote to clarify that a plaintiff could make a prima facie case of disparate-treatment age discrimination using statistical evidence, even where that evidence did not account for defendant's legitimate nondiscriminatory reason for the discharge.

Plaintiff sued defendants under 42 U.S.C. 1983, alleging that the copying and dissemination of her son's autopsy photographs violated her Fourteenth Amendment Due Process rights. The court held that plaintiff had a constitutionally protected right to privacy over her child's death images. But, because defendant Coulter, the San Diego Deputy District Attorney, wasn't acting under color of state law when he sent the autopsy photograph to the press, that claim must be dismissed. And, because there was no "clearly established" law to inform Coulter that any of his earlier conduct was unlawful, Coulter was entitled to qualified immunity. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants.

After plaintiff was convicted for drug possession with intent to distribute, plaintiff sought the return of his property seized by the government during his arrest pursuant to Federal Rule of Criminal Procedure 41(g). Because some of plaintiff's belongings were inadvertently lost or destroyed, plaintiff sought equitable relief in the form of money damages to compensate for the missing property. The court affirmed the district court's grant of the government's motion to dismiss because sovereign immunity barred plaintiff's suit for money damages against the government.

Plaintiff appealed the dismissal of his pro se complaint under 42 U.S.C. 1983, against certain prison medical providers, alleging that the providers' delay in treating his hernia amounted to deliberate indifference to his medical needs, in violation of the Eighth Amendment. The court held that plaintiff voluntarily consented to the jurisdiction of any magistrate judge, including the one who decided his case; the allegations against Dr. Schuster could not support a deliberate indifference claim because they amount to a claim of negligence; and the allegations against Dr. Rotman were sufficient to warrant ordering him to file an answer. Accordingly, the court affirmed in part, reversed in part, and remanded in part.

Plaintiff, a 69-year-old inmate, appealed the grant of summary judgment denying his claims for violations of his rights under the Eighth Amendment. Plaintiff claimed that the doctors and wardens in the Nevada Department of Corrections were deliberately indifferent to his medical needs. The court held that the district court improperly concluded that there was a mere disagreement of medical opinion in this case and did not identify the triable issues of fact. Because plaintiff had not yet had his hip surgery, and may or may not be eligible for surgery, his claim for injunctive relief was not moot and should be addressed on remand. Accordingly, the court reversed in part, affirmed in part, and remanded in part.

Plaintiff appealed from the district court's orders granting full satisfactions of judgment as to defendants. Defendants were found to have violated plaintiff's civil rights and held liable for damages under 42 U.S.C. 1983 for alleged violations of his constitutional rights while he was held in pretrial detention in a Los Angeles jail in 1998. The court held that defendants' failure in the first appeal to challenge the district court's order that defendants were each jointly and severally liable for the fee award waived their ability to challenge that order subsequently. Therefore, the court vacated the satisfactions of judgment.

Plaintiffs, severely disabled California residents, alleged that conventional medical services, drugs, and medications have not alleviated the pain caused by their impairments. Therefore, each plaintiff has obtained a recommendation from a medical doctor to use marijuana to treat her pain. Plaintiffs obtained medical marijuana through collectives located in Costa Mesa and Lake Forest, California. These cities, however, have taken steps to close marijuana dispensing facilities operating within their boundaries. Plaintiffs brought an action in federal district court, alleging that the cities' actions violated Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that Congress has made clear that the ADA defined "illegal drug use" by reference to federal, rather than state law, and federal law did not authorize plaintiffs medical marijuana use. Therefore, the court concluded that plaintiffs' medical marijuana use was not protected by the ADA.

Plaintiff, on behalf of her son, sued defendants, including the school district, alleging 20 procedural and substantive violations of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The district court disposed of almost all of plaintiff's claims and plaintiff and defendants subsequently appealed. The court agreed with the school district that the district court erred by inferring from the IDEA a private right of action for nominal damages. The court also held that Congress has not expressed an intent to create a cause of action for monetary damages based on the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Americans with Disabilities Act, 42 U.S.C. 12101 et seq. The court reviewed plaintiff's other contentions in her cross-appeal and find them either waived or lacking merit.