Justia Civil Rights Opinion Summaries

The State of Arizona appealed the district court's order granting a preliminary injunction to prevent a state law from taking effect that would have terminated eligibility for healthcare benefits of state employees' same-sex partners. The district court found that plaintiffs demonstrated a likelihood of success on the merits because they showed that the law adversely affected a classification of employees on the basis of sexual orientation and did not further any of the state's claimed justifiable interests. The district court also found that plaintiffs had established a likelihood of irreparable harm in the event coverage for partners ceased. The court held that the district court's findings and conclusions were supported by the record and affirmed the judgment.

Defendant pleaded guilty to conspiracy to manufacture and possess with intent to distribute methamphetamine. At issue was whether defendant was entitled, under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-2000bb-4, to use marijuana during his period of supervised release. The court held that because the government's interest in prohibiting a convicted methamphetamine dealer from using controlled substances during supervised release was compelling and because Standard Condition Number 7 was the least restrictive means of advancing that interest, the district court correctly imposed the condition.

Plaintiff and his wife filed a 42 U.S.C. 1983 action against defendants, alleging, among other things, that police officers violated their Fourth and Fourteenth Amendment rights by securing the search and arrest warrants of plaintiff's home, to search for evidence of child pornography, with an affidavit that deliberately or recklessly contained material omissions and false statements. At issue was whether the district court properly granted the officers' motion for summary judgment based on qualified immunity, concluding that the officers' conduct did not violate a clearly established constitutional right of which a reasonable officer would have known. The court held that plaintiff had made a substantial showing of the officers' deliberate falsehood or reckless disregard for the truth and had established that, but for the dishonesty, the searches and arrest would not have occurred. The court also held that the officers were not entitled to qualified immunity because plaintiff's right not to be searched and arrested as a result of judicial deception was clearly established at the time one of the officers prepared and submitted her affidavit. Accordingly, the court reversed the judgment of the district court and remanded for trial.

Plaintiffs, a class of economically vulnerable Arizonians who receive public health care benefits through the state's Medicaid agency, sued the U.S. Secretary of Health and Human Services (Secretary) and the Director of Arizona's medicaid agency (director)(collectively, defendants), alleging that the heightened mandatory co-payments violated Medicaid Act, 42 U.S.C. 1396a, cost sharing restrictions, that the waiver exceeded the Secretary's authority, and that the notices they received about the change in their health coverage was statutorily and constitutionally inadequate. The court affirmed the district court's conclusion that Medicaid cost sharing restrictions did not apply to plaintiffs and that Arizona's cost sharing did not violate the human participants statute. The court reversed the district court insofar as it determined that the Secretary's approval of Arizona's cost sharing satisfied the requirements of 42 U.S.C. 1315. The court remanded this claim with directions to vacate the Secretary's decision and remanded to the Secretary for further consideration. Finally, the court remanded plaintiffs' notice claims for further consideration in light of intervening events.

While handcuffed in the back seat of a patrol car, Everardo Torres (Everardo) was mortally mounded when a Madera City Police Officer shot him in the chest with her Glock semiautomatic pistol, believing it at the time to be her Taser M26 stun gun. Everardo's family filed this survival action under 42 U.S.C. 1983, asserting excessive force in violation of the Fourth Amendment and subsequently appealed from an adverse grant of summary judgment. The court held that, while a jury might ultimately find that the officer's mistake of weapon to have been reasonable, it was inappropriate for the district court to reach this conclusion in the face of material facts in dispute. The court held that, at this stage in the proceeding, the officer had not shown an entitlement to qualified immunity and summary judgment was therefore improperly granted.

Plaintiff and his children (plaintiffs) brought a 42 U.S.C. 1983 suit against defendants for damages resulting from plaintiff's unlawful arrest. Plaintiff was arrested as he stood outside a fair selling promotional tickets for $5 that he had received for free from a radio station. At issue was whether the district court properly granted summary judgment in favor of defendants on the grounds of qualified immunity. The court agreed with the district court that there was no probable cause to arrest plaintiff and his right to be free from unlawful arrest was violated. The court held, however, that the district court's grant of summary judgment on the grounds of qualified immunity for an unlawful arrest was reversed where all reasonably competent officers would have agreed that plaintiff was not committing a crime because there was no scalping law in Nevada; it was simply not a crime to sell tickets to a fair; plaintiff's t-shirt, which had the logo of the radio station, did not suggest fraud; and the ticket buyers were not duped by the sale. The court also held that plaintiffs' substantive due process right to family integrity was not violated where the facts of the case did not come close to rising to the level of conduct that shocked the conscience. Accordingly, the court affirmed the district court's claim on this issue.

Defendant appealed his misdemeanor convictions, after retrial, of three counts of violating 18 U.S.C. 1382. Defendant's charges arose from his protest activities on Ocean Avenue, which was a public road that crossed the Vandenberg Air Force Base (VAFB). On appeal, defendant argued that his retrial violated the proscription against double jeopardy, that there was insufficient evidence to convict, and that his conviction violated his First Amendment rights. The court found that in all three incidents, defendant was within the physical limits of the public road easement corresponding to Ocean Avenue, a fact which the government did not challenge. The court held that because the government did not have an exclusive right of possession over Ocean Avenue, defendant's presence and protest activities could not constitute violations of section 1382 under the court's precedent.

A former public high school student alleged that his history teacher violated his rights under the Establishment Clause by making comments during class that were hostile to religion in general, and to Christianity in particular. At issue was whether the teacher was entitled to qualified immunity. The court affirmed the district court's conclusion that the teacher was entitled to qualified immunity. The court also held that because it was readily apparent that the law was not clearly established at the time of the events in question, and because the court could resolve the appeal on that basis alone, the court declined to pass upon the constitutionality of the teacher's challenged statements.

Plaintiff filed a federal civil rights action against the county, alleging violation of her constitutional rights to free speech and equal protection. Plaintiff alleged that the county harassed her in retaliation of her complaints about the county's failure to enforce building and safety codes against her Malibu neighbors. At issue was whether the district court properly denied plaintiff an award of attorney's fees for her spouse's legal services. The court held that plaintiff, who was represented by her attorney-spouse in a successful civil rights action, could be awarded "a reasonable attorney's fee as part of the costs" under 42 U.S.C. 1988. Accordingly, the court vacated the portion of the district court's fee order denying plaintiff an award of attorney's fees for her spouse's services and remanded for further proceedings.

Plaintiff, a disabled individual who required the use of a motorized wheelchair to get around, filed a lawsuit against defendants, alleging that a Food 4 Less grocery store in Chula Vista, California did not comply with the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101, 12213, and certain state laws. At issue was whether the district court erred in refusing to consider the allegations in plaintiff's expert report; in granting summary judgment to defendants as to the barriers he claimed violated California's Manual on Uniform Traffic Control Devices (MUTCD), which was based on the district court's conclusion that violations of the MUTCD were not per se violations of the ADA; and in declining to exercise supplemental jurisdiction over his state claims. The court held that the district court did not err in refusing to consider the barriers that plaintiff identified only in his expert report; the district court properly granted partial summary judgment to defendants regarding those of plaintiff's allegations premised on noncompliance with the MUTCD rather than the ADA Accessibility Guidelines; and the district court did not abuse its discretion in dismissing plaintiff's state law claims with prejudice. Accordingly, the court affirmed the judgment of the district court.