Justia Civil Rights Opinion Summaries

In these consolidated appeals, plaintiff challenged the regulations implementing the contraceptive mandate of the Affordable Care Act, 42 U.S.C. 300gg-13(a), arguing that the regulations’ accommodation for nonprofit organizations with a religious objection to providing contraceptive coverage violates the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb, et seq. The court concluded that the regulations do not substantially burden plaintiffs' religious exercise and, alternatively, because (1) the government has compelling interests to justify the accommodation, and (2) the accommodation is the least restrictive means of furthering those interests. The court rejected EWTN’s challenges under the Establishment and Free Exercise Clauses because the accommodation is a neutral, generally applicable law that does not discriminate based on religious denomination. The court also rejected EWTN’s challenge under the Free Speech Clause because any speech restrictions that may flow from the accommodation are justified by a compelling governmental interest and are thus constitutional. View "Eternal Word Television Network v. Secretary" on Justia Law

Plaintiff filed suit against the City and its officers under 42 U.S.C.1983, federal maritime law, and state law, alleging that defendants seized his sailboat and destroyed it without justification and without notice. The district court dismissed plaintiff's claims. The court concluded that the district court should not have placed a “heightened pleading” burden on plaintiff for his section 1983 claims. The court also concluded that the district court erred to the extent that it dismissed the federal constitutional claims in Counts I, II, and V, and the maritime claims in Counts III and IV, based on the contents of the incident reports. On remand, the court instructed the district court to assess the sufficiency of the procedural due process, search and seizure, and takings claims without reliance on the disputed portions of the incident reports. The court further instructed that the district court should assume that the sailboat was not derelict, and that plaintiff was never given adequate notice that it was derelict and subject to removal and destruction. The court further concluded that the district court erred with respect to the procedural due process claim in Count I and the Fourth Amendment claim in Count II. In this case, all plaintiff needed to do to establish municipal liability was allege a policy, practice, or custom of the City which caused the seizure and destruction of his sailboat, which he did. Further, defendants cannot point to any post-Leatherman v. Tarrant Cnty. Narcotics Intelligence & Coordination Unit Supreme Court or circuit cases - and the court has not been able to locate any - holding that a complaint asserting a section 1983 municipal liability claim must, as a Rule 8(a) pleading matter, always specifically identify the municipality’s final policymaker by name. Finally, plaintiff also sufficiently stated a claim for an unconstitutional seizure under the Fourth Amendment. However, the court agreed with the district court that plaintiff failed to state a substantive due process claim. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Hoefling, Jr. v. City of Miami" on Justia Law

Plaintiffs filed suit against the officers who searched their home, the officers who arrested them, and the sheriff in charge of the jail. Plaintiffs' trailer was searched because officers believed the trailer belonged to someone else. Contraband was found in the trailer and plaintiffs were arrested. However, charges against plaintiffs were dropped after the evidence from the trailer was suppressed. They alleged violations of their federal constitutional and statutory rights, 42 U.S.C. 1983, and various claims under state law. The district court denied the officers' motion for summary judgment. The court concluded that the deputies are entitled to official immunity from the claim of trespass under Georgia law; the deputies and investigator are entitled to qualified immunity from the claim of malicious prosecution; the court joined its sister circuits and held that the exclusionary rule does not apply in a civil suit against police officers; but the sheriff is not entitled to sovereign immunity from the claim under Title II of the Disabilities Act, 42 U.S.C. 12132. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Black v. Wigington" on Justia Law

Plaintiff, the personal representative of Victor Arango and the administrator of his estate, filed suit pursuant to 42 U.S.C.1983, alleging that defendant used excessive force in the fatal shooting of Arango. Defendant appealed the district court's denial of his summary judgment motion based on qualified immunity grounds. The court held that the district court properly denied summary judgment where, taking the facts in the light most favorable to the Estate, defendant is not entitled to qualified immunity. In this case, the Estate proffered evidence that defendant fatally shot Arango in the back while Arango was compliant and non-resisting, which constitutes excessive force and violates clearly established law. Accordingly, the court affirmed the judgment. View "Perez v. Suszczynski" on Justia Law

After the City barred plaintiff from opening a tattoo establishment in the City's designated historic district, plaintiff filed suit contending that the act of tattooing is entitled to First Amendment protection and that the City's ordinance limiting the number of tattoo establishments permitted to operate in the historic district is an unconstitutional restriction on his freedom of expression. The district court granted summary judgment in favor of the City. The court agreed with the district court's conclusion that tattooing is protected artistic expression. However, the court reversed the summary judgment because the court concluded that the City has failed to show that the ordinance is a reasonable time, place, and manner restriction. In this case, aside from the City's vague statement of purpose, the City has presented insufficient evidence that it had a reasonable basis for believing that its ordinance would actually serve the significant governmental interests it propounds. View "Buehrle v. City of Key West" on Justia Law

Plaintiff filed suit against his former employer, MetLife, alleging claims of age discrimination under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623(a)(1), as well as a retirement benefits interference claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court granted summary judgment for MetLife. The court concluded that plaintiff has established a prima facie case of discrimination under the ADEA where plaintiff was replaced by someone substantially younger, plaintiff was qualified for the job for which he was discharged, and the justifications offered for plaintiff's termination were not a proper basis for rejecting plaintiff's prima facie showing. The court vacated the district court's order as to this claim and remanded for reconsideration of whether summary judgment is appropriate under the McDonnell Douglas framework. The court also concluded that the district court erred in granting judgment in favor of MetLife before deciding on the admissibility of certain declarations. Accordingly, the court vacated the grant of summary judgment as to this issue and remanded for the district court to rule on the admissibility of the declarations. View "Liebman v. MetLife Ins. Co." on Justia Law

Plaintiff filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623(a)(2), alleging that RJ Reynolds discriminated against him on the basis of his age when it rejected his application for employment. The court held that section 4(a)(2) of the ADEA authorizes disparate impact claims by applicants for employment even though the statute is unclear. The EEOC has reasonably and consistently interpreted the statute to cover such claims and the court deferred to the agency's reading of the statute. The court concluded that, in this case, plaintiff is entitled to equitable tolling of the ADEA's limitations period where plaintiff alleges that he could not have even suspected age discrimination until shortly before he filed his charge of discrimination. Accordingly, the court reversed and remanded. View "Villarreal v. R.J. Reynolds Tobacco Co." on Justia Law

Plaintiff filed suit alleging that the School Board violated his constitutional right to free speech when three of its schools removed banners for plaintiff's tutoring business from their fences. The schools removed the banners after they discovered that plaintiff's tutoring business shares a mailing address with his pornography business. The district court concluded that the schools did not remove the banners based on their content and granted summary judgment for the schools. The court affirmed on different grounds, concluding that the Free Speech Clause of the First Amendment does not protect plaintiff because the banners are “government speech.” Despite the lack of historical evidence in the record, the banners exhibit strong indicia of government endorsement and control. View "Mech v. School Bd. of Palm Beach Cnty." on Justia Law

Over 25 years ago, a representative of a class of homeless persons, filed a lawsuit against the City of Miami under 42 U.S.C. 1983. The parties subsequently entered into a settlement agreement. In this appeal, plaintiff, on behalf of a class, seeks attorney fees for opposing modifications proposed by the City of Miami to such an agreement. The court affirmed the district court's denial of fees given that modification proceedings do not trigger an award of attorneys’ fees under the agreement. In this case, the parties’ agreement limited future attorneys’ fees to enforcement proceedings. View "Peery v. City of Miami" on Justia Law

Plaintiffs filed suit challenging the facial validity of Florida's no-surcharge law under the First Amendment. Florida makes it a second-degree misdemeanor for “[a] sellor or lessor in a sales or lease transaction” to “impose a surcharge on the buyer or lessee for electing to use a credit card,” Fla. Stat. 501.0117(1)–(2), while the State expressly allows “the offering of a discount for the purpose of inducing payment by cash.” The court concluded that it must strike down section 501.0117 as an unconstitutional abridgment of free speech. The court concluded that Florida’s no-surcharge law directly targets speech to indirectly affect commercial behavior. It does so by discriminating on the basis of the speech’s content, the identity of the speaker, and the message being expressed. Because the at-best plausible justifications on which the no-surcharge law rest provide no firm anchor, the law does not pass under any level of heightened First Amendment scrutiny View "Dana's Railroad Supply v. Attorney General" on Justia Law