Justia Civil Rights Opinion Summaries

Plaintiffs brought an action under 42 U.S.C. 1983, seeking to prove that they were subjected to excessive force while in custody at the Sacramento County Main Jail. At issue was whether the district court erred by refusing to use certain jury instructions plaintiffs had requested. The court held that the district court prejudicially erred in refusing to instruct the jury that, for purposes of proving a Monell claim, a custom or practice could be supported by evidence of repeated constitutional violations which went uninvestigated and for which the errant municipal officers went unpunished. Therefore, the court vacated the judgment and remanded for a new trial.

Plaintiff brought a 42 U.S.C. 1983 action for damages resulting from a violent attack he allegedly suffered while he was an inmate in the Los Angeles County Jail. At issue was whether the district court properly dismissed plaintiff's supervisory liability claim for deliberate indifference against Sheriff Leroy Baca in his individual capacity under Federal Rule of Civil Procedure 12(b)(6). The court held that the Supreme Court's decision in Ashcroft v. Iqbal did not alter the substantive requirements for supervisory liability claims in an unconstitutional conditions of confinement case under the Eighth and Fourteenth Amendments where deliberate indifference was alleged. The court further held that plaintiff had sufficiently alleged under Federal Rule of Civil Procedure 8(a) a supervisory liability claim of deliberate indifference against Sheriff Baca. Accordingly, the court reversed the district court's dismissal of plaintiff's claim and remanded for further proceedings.

Plaintiff filed a lawsuit under 42 U.S.C. 1983 against defendants claiming that she had been demoted in retaliation for exercising her First Amendment rights by attending a school board meeting and sitting next to her boss, who was fired at the meeting. At issue was whether the district court properly granted defendants' motion for summary judgment holding that defendants' efficiency interests were greater than plaintiff's interest in free association. The court held that it appeared that the triggering factor in defendants' action was simply plaintiff's decision to sit next to her boss at the public school meeting, without even speaking to him. The court also held that, because defendants produced no evidence that plaintiff's association with her boss actually disrupted the office or her performance, or reasonably threatened to cause future disruption, defendants failed to show that its interests in work-place efficiency outweighed plaintiff's First Amendment interests. Accordingly, the court reversed the district court's grant of summary judgment in favor of defendants.

Appellant appealed the grant of summary judgment in his civil rights action arising from the suspension of his medical staff privileges at the University Medical Center of Southern Nevada ("UMC"), a county hospital organized under the laws of Nevada, as well as the denial of his motion for leave to file a third amended complaint asserting claims under 42 U.S.C. 1983. The principal issue on appeal was whom, if anyone, could appellant sue under 42 U.S.C. 1983 for his constitutional injury. The court held that the district court erred in determining that only the MEC, not named a party to the suit, could be liable for appellant's alleged section 1983 claims. The court also held that, because appellant alleged sufficient facts that the individually named voting members of the MEC acted under color of state law in effecting the unconstitutional deprivation of his protected property interest, amending his complaint to include reference to section 1983 would not be futile or prejudice defendants.

The California Department of Corrections and Rehabilitation ("CDCR") had a paid chaplaincy program that employed Protestant, Catholic, Jewish, Muslim, and Native American clergy. These chaplains served all inmates but other religions were also served by volunteer chaplains. A Wiccan volunteer chaplain and a small group of inmates challenged the paid chaplaincy program asserting that the Wiccan chaplain should be eligible for employment in the paid-chaplaincy program. The court held that the inmates failed to exhaust their claims or brought them in an untimely fashion and the chaplain was pursuing constitutional claims that were derivative of the inmates' claims rather than his own. Accordingly, the court held that the district court properly dismissed and granted summary judgment in favor of defendants on the Wiccan chaplains' claims because, for the most part, he lacked standing. The court agreed that the district court need not exercise jurisdiction over these derivative claims. The court also held that, although the Wiccan chaplain had standing to pursue his personal employment claims, and also constitutional claims for different treatment as a volunteer chaplain and retaliation, ultimately he could not prevail on those claims.

Appellant, director of a child development center on the Elmendorf Air Force Base, sued appellees alleging claims of discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-16, and a claim of unlawful removal from employment pursuant to 5 U.S.C. 7702. Appellant appealed from the district court's denial of summary judgment affirming a decision of the Merit Systems Protection Board ("MSPB"), which in turn upheld a decision by the United States Air Force ("Agency"), to terminate her employment after she requested 120 days leave without pay pursuant to the Family Medical Leave Act ("FMLA"), 5 U.S.C. 6382(a)(1)(D), and failed to provide the minimum information required by section 6383(b) of the FMLA. The court held that the MSPB's finding was supported by substantial evidence where appellant's WH-380 form and the two doctors' notes she submitted did not provide the minimum information required by section 6383(b). The court further held that, because appellant refused to submit the minimal mandated medical certification, she could not show any harm arising from the Agency's request for more documentation that was required by the FMLA. The court further held that the administrative law judge properly rejected appellant's argument that the Agency failed to give her adequate time to provide medical certification. The court finally held that substantial evidence supported the MSPB's finding and therefore, the Agency acted within its discretion in removing her from her position.

Plaintiffs, a class of indigent children who suffered from severe emotional and mental disabilities, sued Idaho state officials more than three decades ago, alleging that the officials were providing them with inadequate care in violation of their constitutional and statutory rights. The parties reached agreements intended to remedy deficiencies in care and those agreements were embodied in three consent decrees entered and monitored by the district court. Plaintiffs appealed the 2007 order of the district court finding that defendants had substantially complied with the remaining Action Items, which were specified in an Implementation Plan that resulted from the third consent decree, asserting that it was error for the district court to apply the standard for civil contempt in determining whether to vacate the decrees. Plaintiffs further contended that the district court committed errors in fact and law in issuing protective orders barring them from taking supplemental depositions of appellee and two non-parties. The court held that the district court's application of the contempt standard with the imposition of the burden of proof on plaintiffs was error where the district court accepted the Action Items as the entire measure of compliance with the consent decree. Accordingly, the court reversed the order of the district court. The court also held that the district court committed no errors in upholding the assertion of the deliberative process privilege to one non-party and appellee, as well as the legislative privilege to the second non-party. Accordingly, the court did not abuse its discretion in issuing the protective orders.

Plaintiffs filed a suit in federal court seeking injunctive relief against the City and County of San Francisco and its election officials (collectively, "city") alleging that when more than four candidates run for a particular office, the restricted instant runoff voting ("IRV") system precluded some groups of voters from participating to the same extent as others. At issue was whether the district court properly granted summary judgment in favor of the city where plaintiffs alleged that the restricted IRV system was unconstitutional by violating the First Amendment, the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and the Civil Rights Act, 42 U.S.C. 1983. The court held that, if the aspects of the city's restricted IRV system scheme imposed any burdens on voters' constitutional rights to vote, they were minimal at best. The court also held that the city had advanced valid, sufficiently-important interests to justify using its system. Accordingly, the court held that plaintiffs had not established that the city's chosen IRV system was unconstitutional and affirmed summary judgment in favor of the city.

Plaintiffs sued the Secretary of the Treasury and the Commissioner of the Internal Revenue Service in their official capacities under 28 U.S.C. 2201, alleging that the so-called "parsonage exemption" violated the Establishment Clause of the United States Constitution. Plaintiffs also sued the Executive Office of the California Franchise Tax Board in his official capacity under 42 U.S.C. 1983, alleging that California's parsonage exemption violated the Establishment Clause of both the United States and California Constitutions. Six days after plaintiffs filed their complaint, a minister of the gospel in the Sacramento area, who regularly claimed both the federal and state parsonage exemptions, moved to intervene as a defendant. At issue was whether an individual who claimed certain federal and state tax exemptions could intervene in an unrelated action challenging the constitutionality of those exemptions. The court held that the minister was not entitled to intervene as of right where the federal defendants adequately represented the minister's interest. The court also clarified that the independent jurisdictional grounds requirement did not apply to proposed intervenors in federal-question cases when the proposed intervenor was not raising new claims. Therefore, the court also held that the minister was not required to make any further showing that his intervention was supported by independent jurisdictional grounds where the district court's denial of permissive intervention was not an appropriate exercise in discretion because the district court did not apply the correct legal rule. Accordingly, the court vacated and remanded that portion of the district court's order so that the district court could reassess the request for permissive intervention.

Defendants appealed a denial of qualified immunity from plaintiff's 42 U.S.C. 1983 Fourth Amendment claims against them where plaintiff's claims arose out of his arrest on suspicion of smuggling methamphetamine into the Merced County Jail and out of a subsequent search of plaintiff's law office. At issue was whether defendants qualified for immunity for arresting plaintiff after receiving information about the drug smuggling from a jailhouse informant. The court held that defendants were entitled to qualified immunity where they did not violate plaintiff's constitutional rights when, after developing probable cause to arrest plaintiff, they forthrightly applied to the same judge, acting as a neutral magistrate, for a search warrant; where they executed the warrant under the supervision of a court-appointed master to ensure the integrity of plaintiff's law office and his client's files; and where defendants did not "knowingly violate the law" and they were not "plainly incompetent."