Justia Civil Rights Opinion Summaries

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

A professor at a public university alleged that several university administrators violated his First Amendment rights. The professor, known for his outspoken criticism of university policies and administrators on social media and in public forums, claimed that university officials attempted to silence him. He asserted that they threatened his job security, pay, research opportunities, and academic freedom, and that a university employee requested police surveillance of his speech. The professor stated that these actions caused him to self-censor, including making his social media account private and ceasing to post, out of concern for potential retaliation.The United States District Court for the Western District of Texas reviewed the case after the professor filed suit under 42 U.S.C. § 1983, alleging both retaliation for protected speech and the existence of an unwritten speech code that chilled his speech. The district court dismissed the retaliation claim, finding that the professor had not sufficiently alleged an adverse employment action, and granted summary judgment on the chilled-speech claim for the same reason. The court also dismissed the claim regarding the unwritten speech code, concluding that the professor had not adequately alleged a facial or as-applied First Amendment violation. Additionally, the court resolved two discovery disputes in favor of the university.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the professor had standing to bring his claims but could not prevail on the merits. The court determined that, under established Fifth Circuit precedent, a First Amendment retaliation claim requires an adverse employment action, which the professor did not experience. The court also found that the chilled-speech claim was not distinct from the retaliation claim and failed for the same reason. The court further held that the allegations regarding an unwritten speech code were too conclusory to state a plausible claim. The court upheld the district court’s discovery rulings, finding no abuse of discretion or prejudice. The judgment was affirmed. View "Lowery v. Mills" on Justia Law

Legacy Housing Corporation purchased several hundred vacant lots in Horseshoe Bay, Texas, intending to develop manufactured housing. The lots were subject to zoning restrictions, including a cap on speculative housing permits, contractor requirements, utility hookup fees, and setback rules. Legacy also acquired adjacent land in the city’s extraterritorial jurisdiction (ETJ) to build a road connecting the lots to a nearby highway, but this land was restricted to agricultural and residential use. Despite these limitations, Legacy constructed a road over the ETJ property, a greenbelt strip, and some development lots, advertising it as a shortcut and access to planned amenities. The City and other defendants opposed the road, citing violations of existing restrictions. Legacy alleged a conspiracy among the City, the property owners’ association (POA), and developers to prevent its development.The United States District Court for the Western District of Texas addressed multiple claims and counterclaims. It denied Legacy’s motion to dismiss the City’s counterclaims, granted the City’s motion to dismiss most claims against it, and granted summary judgment to all defendants on the remaining claims, including regulatory takings, Section 1983 violations, civil conspiracy, breach of fiduciary duty, negligence, and a strips and gores claim. Legacy’s own motion for partial summary judgment was denied, and final judgment was entered.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s rulings, with one modification. The appellate court held that Legacy’s regulatory takings claim regarding the two-permit cap was not prudentially ripe and should be dismissed without prejudice. The court otherwise affirmed summary judgment for the defendants, finding no genuine dispute of material fact and concluding that Legacy did not have property rights to build the road, nor did the defendants breach any legal duties or restrictive covenants. View "Legacy Hsing v. City of Horseshoe Bay" on Justia Law

A group of voters in Tarrant County, Texas, challenged the county’s decision to redraw the boundaries of its four commissioners precincts in 2025, a process that occurred outside the usual post-census redistricting cycle. The new map, adopted by a narrow 3–2 vote, shifted a significant number of voters—disproportionately Black, Latino, and Democratic—into precincts that would not hold commissioner elections until 2028, effectively postponing their opportunity to vote for a county commissioner by two years. The plaintiffs, who are racially diverse, argued that the redistricting was intended to harm racial minorities and Democratic voters, and that the mid-cycle timing unlawfully disenfranchised certain residents.The United States District Court for the Northern District of Texas denied the plaintiffs’ request for a preliminary injunction to block the use of the new map in the 2026 election. The district court dismissed the First Amendment claims as nonjusticiable under Supreme Court precedent, but allowed the race discrimination and vote postponement claims to proceed, ultimately finding that the plaintiffs had not shown a likelihood of success on the merits.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s denial of a preliminary injunction. The Fifth Circuit held that claims of partisan gerrymandering are nonjusticiable in federal court, even when staggered elections result in some voters’ ballots being postponed. The court further held that the plaintiffs had not demonstrated that race was a motivating factor in the adoption of the new map, applying the Arlington Heights framework and finding no clear error in the district court’s assessment of the evidence. Finally, the court concluded that postponement of voting opportunities due to redistricting in a staggered election system does not violate the Constitution, as there is no right to vote on a particular schedule. View "Jackson v. Tarrant County" on Justia Law

The plaintiff, who is civilly committed as a sexually violent predator at the Texas Civil Commitment Center, brought a pro se lawsuit under 42 U.S.C. § 1983 against the Commissioner of the Texas Department of Family Protective Services and the Executive Commissioner of the Texas Health and Human Services Commission. He alleged that these agencies failed to investigate his reports of misconduct and abuse at the facility, claiming violations of his Fourteenth Amendment rights to equal protection and due process, as well as rights under the Bill of Rights for Mental Health Patients. The plaintiff asserted that he should be able to file complaints with these agencies rather than being required to use the internal grievance procedure of the Texas Civil Commitment Office.The United States District Court for the Western District of Texas screened the complaint under 28 U.S.C. § 1915(e)(2)(B) because the plaintiff was proceeding in forma pauperis. The district court found that the plaintiff failed to state a claim for relief and that amendment would be futile, so it dismissed the complaint without prejudice. The plaintiff appealed, arguing that he had adequately stated equal protection and due process claims, that he should have been allowed to amend his complaint, and that the district court was biased.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to state an equal protection claim because he was not similarly situated to other Texas citizens and the different grievance procedures had a rational basis. The court also found no protected liberty or property interest to support a due process claim and concluded that the alleged conduct did not rise to the level of a substantive due process violation. The court further held that amendment would have been futile and found no evidence of judicial bias. The plaintiff’s motion for appointment of counsel was denied. View "Dunsmore v. Muth" on Justia Law

A black man was hired as the first black city manager of a Texas city and led several major development initiatives. His tenure became contentious, especially after two new city council members, who opposed his policies, were elected. The conflict allegedly took on a racial character, and the city manager reported race-based discrimination. Eventually, the city council voted to part ways with him “without cause,” entering into a separation agreement that included a severance payment and a non-disparagement clause. After his departure, some council members publicly criticized him and later persuaded the council to rescind the separation agreement, citing a legal opinion that it was invalid. The city demanded the return of the severance payment, prompting the former city manager to sue, alleging racial discrimination under 42 U.S.C. § 1981 and breach of contract under Texas law.The United States District Court for the Western District of Texas granted summary judgment to the plaintiff on the validity of the separation agreement and denied the city’s motions for judgment as a matter of law. The case proceeded to trial, where a jury found for the plaintiff on both claims, awarding substantial damages. The district court entered judgment accordingly, later suggesting remittitur due to statutory limits on damages for breach of contract, which the plaintiff accepted.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the plaintiff failed to establish municipal liability for racial discrimination under § 1981 and § 1983 because he could not show that a majority of the city council acted with discriminatory intent, nor could he use the “cat’s paw” theory to impute animus under Monell. However, the court affirmed the district court’s judgment that the separation agreement was valid and enforceable, and that the city breached the contract by attempting to rescind it. The court reversed the judgment on the civil rights claim, affirmed the breach of contract ruling, and remanded for consideration of attorney’s fees. View "Jones v. City of Hutto" on Justia Law

An inmate at the Louisiana State Penitentiary participated in the Angola Prison Rodeo from 1996 to 2019, selling leather belts and earning approximately $80,000. He alleged that prison officials confiscated about $16,000 of his earnings, claiming the deductions were for taxes, commissions, and maintenance fees. The inmate filed a grievance through the prison’s administrative process, arguing that the deductions were unauthorized and that he was denied a due process hearing regarding the seizure of his property. The prison denied his grievance, explaining the deductions, and the inmate exhausted his administrative remedies. He then sought relief in Louisiana state court through a petition for writ of mandamus, which remained unresolved for over a year.Subsequently, the inmate filed a pro se complaint in the United States District Court for the Middle District of Louisiana under 42 U.S.C. § 1983, alleging that various prison officials conspired to deny him due process in connection with the confiscation of his property. The defendants moved to dismiss the complaint, asserting qualified immunity and failure to state a claim. A magistrate judge recommended dismissing any standalone claims regarding the denial of the prison grievance but allowed the conspiracy and due process claims to proceed. The district court adopted this recommendation, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the defendants were entitled to qualified immunity. The court found that the inmate’s complaint did not adequately allege a pre-deprivation due process claim and that, at the time of the alleged conduct, it was not clearly established that the inmate had a protected property interest in the proceeds from the sale of crafts made and sold under prison auspices. The Fifth Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Savage v. Westcott" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

A man incarcerated in Texas state prison was classified as a member of a security threat group and placed in administrative segregation, a form of solitary confinement, for sixteen years. The only way for him to return to the general prison population was to complete a gang renunciation program, which required him to renounce his gang affiliation and participate in an interview. During the interview, he was questioned by prison and law enforcement officials about criminal activities that occurred during his incarceration. He refused to answer questions that could incriminate him, after which his application to the renunciation program was terminated for failure to cooperate. He filed grievances challenging the process, but they were denied or dismissed.He then filed suit in the United States District Court for the Western District of Texas against several prison officials, alleging violations of his Fifth, First, and Fourteenth Amendment rights. The district court initially dismissed his claims, but the United States Court of Appeals for the Fifth Circuit vacated and remanded for further proceedings. After further litigation, including the appointment of counsel and discovery, the district court again granted summary judgment for the defendants, finding no constitutional violations and holding that the officials were entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the officials were entitled to qualified immunity on the Fifth Amendment self-incrimination and First Amendment compelled speech claims because there was no clearly established law making their conduct unlawful in this context. Regarding the Fourteenth Amendment procedural due process claim, the court assumed a liberty interest but found that the periodic classification reviews provided by the prison satisfied due process requirements. The court affirmed summary judgment in favor of the defendants. View "Ballentine v. Broxton" on Justia Law

A 78-year-old inmate in a Texas men’s prison, who identifies as a transgender woman, sought sex-reassignment surgery after being diagnosed with gender dysphoria in 2013. The inmate received hormone therapy and was chemically castrated, but was ultimately denied surgery by prison medical staff. The inmate alleged that state officials discriminated by providing reconstructive vaginoplasty to female inmates while denying similar surgery to transgender inmates, claiming a violation of the Equal Protection Clause.The United States District Court for the Southern District of Texas initially denied motions to dismiss based on sovereign immunity, finding that the inmate was similarly situated to cisgender female inmates and that the claims met the requirements of the Ex parte Young exception to sovereign immunity. On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit vacated the district court’s orders, holding that the inmate had not adequately pled that any defendant was sufficiently connected to enforcement of the challenged policy. On remand, after further proceedings and discovery, the district court granted judgment on the pleadings, concluding that the defendants were either improper under Ex parte Young or that the requested relief was not permitted, and dismissed the lawsuit for lack of jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal, holding that the inmate lacked standing. The court found that the alleged injury was not fairly traceable to the defendants, as there was no evidence that any treating physician had determined the inmate was a suitable candidate for surgery or would refer the inmate for the procedure. Without such evidence, the injury could not be redressed by a favorable judicial decision against the defendants. View "Haverkamp v. Linthicum" on Justia Law