Justia Civil Rights Opinion Summaries

Plaintiff filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., seeking attorneys' fees after she proved in an administrative hearing that a school district had violated her child’s right to a free appropriate public education by repeatedly placing him in isolation during school hours. The court concluded that the district court erred in applying section 1415(i)(2)(B)’s limitations period to this action for attorneys’ fees under the IDEA by a party that prevailed at the administrative level. Because the statute contains no limitations period for such actions, the district court should have borrowed one from state law. The court held that the limitations period for such an action does not begin to run until the time for seeking judicial review of the underlying administrative decision passes, and that plaintiff’s action was timely under any limitations period that could be borrowed. Accordingly, the court reversed the district court's grant of summary judgment and remanded for further proceedings. View "D.G. v. New Caney Indep. Sch. Dist." on Justia Law

Plaintiffs filed suit against defendants after their son, Quamaine Mason, was fatally shot while Officer Martin Faul was responding to a reported armed robbery. The complaint alleged Monell claims against Faul's employer, Lafayette, and Lafayette's Chief of Police, as well as claims against all three defendants under Louisiana law. The court reversed the district court's grant of summary judgment to Faul on plaintiff's Fourth Amendment and state law claims because there are material fact issues that preclude summary judgment in favor of Faul on the basis of qualified immunity. In this case, a reasonable jury could conclude that when Faul fired the final two shots, Mr. Mason would have appeared incapacitated to an objectively reasonable officer. The court otherwise affirmed the judgment. View "Mason v. City of Lafayette" on Justia Law

Three movants appealed the denial of their motion to intervene in State of Texas v. United States, where 26 states seek injunctive relief against the United States and several officials of DHS to prevent them from implementing a program entitled “Deferred Action for Parents of Americans and Lawful Permanent Residents” (DAPA). Movants are aliens who have lived in the United States for more than ten years, currently live in the Rio Grande Valley, and have minor children who are United States citizens. Movants believe that they are likely to receive grants of deferred action if DAPA goes into effect. The court reversed the district court's order denying intervention because movants satisfy the requirements for intervention by right under Federal Rule of Civil Procedure 24(a)(2). The court remanded to the district court. View "State of Texas v. United States" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging civil rights violations because the police issued an “Official Notification of Trespass Warning” prohibiting her from entering city-owned property, which was later lifted. The district court concluded that the officers were entitled to qualified immunity as to the majority of plaintiff's claims, but denied qualified immunity on the procedural due process and direct municipal liability claims. Defendants appealed the denial of qualified immunity.The court reversed and remanded, concluding that the alleged constitutional right was not clearly established at the time of the incident, so the officers are entitled to qualified immunity. View "Vincent v. City of Sulphur" on Justia Law

Plaintiffs filed suit against the school district and its employees, alleging claims related to the sexual molestation of A.W. by her teacher. The district court dismissed the claims under Rule 12(b)(6) as time-barred. At issue is the Texas statute of limitations that applies to Title IX of the Education Act of 1972, 20 U.S.C. 1681 et seq., and 42 U.S.C. 1983 claims involving sexual abuse. The court concluded that the district court did not err in finding that plaintiffs’ Title IX and section 1983 claims are time-barred because plaintiffs' claims accrued more than two years prior to their filing suit and the equitable tolling principles they have identified do not apply. Accordingly, the court affirmed the judgment and did not reach the remaining issues raised on appeal. View "King-White v. Humble Indep. Sch. Dist." on Justia Law

Plaintiffs filed suit under Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, and 42 U.S.C. 1983 against the district and two district employee, alleging discrimination based on race and a hostile educational work environment. The court applied the deliberate indifference standard for a Title VI student-on-student harassment claim and concluded that plaintiffs have raised a genuine dispute that a racially hostile environment existed. However, the court concluded that the district court did not err in granting summary judgment on the Title VI claim where plaintiffs have failed to raise a genuine dispute over whether the school district was deliberately indifferent to the harassment. Further, the court concluded that the district court did not err in granting summary judgment as to the claim against the school district and the employees under section 1983. Accordingly, the court affirmed the judgment. View "Fennell v. Marion I.S.D." on Justia Law