Justia Civil Rights Opinion Summaries

The case concerns the parents of a pre-kindergarten student who alleged that their daughter was sexually abused by a substitute teacher at Lorena Primary School during the 2020-2021 academic year. Multiple school employees reported the teacher’s inappropriate behavior—such as allowing the child to sit on his lap, wear his clothes, and lie under a blanket with him—to the school principal, April Jewell. Despite these reports, Jewell did not investigate, warn the teacher, inform the child’s parents, or report the conduct to law enforcement. Instead, she reprimanded staff who raised concerns and reassigned a vigilant aide, which may have increased the child’s exposure to the abuser. The abuse continued throughout the school year, culminating in the teacher’s arrest, conviction, and lengthy prison sentence.The United States District Court for the Western District of Texas reviewed the parents’ claims under 42 U.S.C. § 1983, alleging violations of the child’s Fourteenth Amendment right to bodily integrity. The district court denied Jewell’s motion to dismiss based on qualified immunity, finding that the complaint sufficiently alleged that Jewell was deliberately indifferent to a known risk of sexual abuse and that her inaction caused the child’s injuries. Jewell appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed the district court’s decision. The Fifth Circuit held that the plaintiffs’ allegations, if proven, would establish that Jewell violated clearly established constitutional rights by acting with deliberate indifference to repeated reports of sexual misconduct, thereby causing the child’s injuries. The court also found that Jewell’s conduct could be considered conscience-shocking under substantive due process standards. Accordingly, the denial of qualified immunity was affirmed. View "Doe v. Jewell" on Justia Law

A white male lieutenant who had worked for the Louisiana State Police since 1995 applied for promotion to captain 31 times between 2008 and 2021 but was never selected. He alleged that, on at least two occasions, he was the most qualified candidate but was passed over in favor of non-white applicants. The two specific promotions at issue involved positions in specialized divisions where the selected candidates, both non-white, had prior experience in those divisions, while the plaintiff did not. The plaintiff claimed he had higher test scores, more time in grade, and more commendations than the selected candidates. Instead of promotion, he was offered opportunities to gain broader experience and interview advice, but he chose to retire and then filed suit alleging racial discrimination under Title VII and 42 U.S.C. § 1981, as well as constructive discharge and retaliation.The United States District Court for the Eastern District of Louisiana dismissed the § 1981, constructive discharge, and retaliation claims, finding the § 1981 claim time-barred by Louisiana’s one-year statute of limitations for such actions. After discovery, the district court granted summary judgment to the employer on the Title VII claim, holding that the plaintiff failed to rebut the employer’s legitimate, nondiscriminatory reasons for its promotion decisions—namely, the selected candidates’ relevant experience in the specific divisions. The court found no evidence that race was a motivating factor in the decisions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the district court’s rulings. The Fifth Circuit held that the plaintiff failed to present evidence sufficient to create a genuine dispute of material fact regarding pretext or mixed-motive discrimination under Title VII. The court also affirmed the dismissal of the § 1981 claim, agreeing that the one-year limitations period applied because the promotion would have created a new and distinct employment relationship. View "Stelly v. Dept of Public Safety" on Justia Law

Evan Norman visited a bar where he consumed several alcoholic drinks and fell asleep. At the request of the establishment, Deputy Ingle removed Norman and instructed him to go home, warning that he could be arrested for public intoxication. Norman repeatedly asked for the deputies’ names and badge numbers and made comments to them. As the deputies returned to the bar, Norman followed and continued to engage with them. The situation escalated when Norman reached over Deputy Sutton’s arm and pointed at Deputy Ingle, leading to physical shoving. Norman then attempted to punch Deputy Ingle and placed him in a headlock. In response, the deputies used force to subdue Norman, including multiple punches to his head. Norman was arrested and left facedown for about ten minutes while awaiting medical assistance, during which he suffered significant facial injuries.Norman filed suit in the United States District Court for the Southern District of Texas against the deputies and others, alleging excessive force, denial of medical care, failure to intervene, wrongful arrest, malicious prosecution, and First Amendment violations. The district court dismissed claims against the county and sheriff but allowed claims against the deputies to proceed. The deputies moved for summary judgment, asserting qualified immunity. The district court denied their motions, finding genuine disputes of material fact regarding the use of force, resistance, and medical care, and ruled that the deputies were not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo, considering video evidence of the incident. The court held that the video evidence resolved any material factual disputes and showed that the deputies’ actions did not violate clearly established constitutional rights. The court found the use of force reasonable under the circumstances, no denial of medical care, and no basis for failure to intervene or other claims. The Fifth Circuit reversed the district court’s judgment, holding the deputies were entitled to qualified immunity. View "Norman v. Ingle" on Justia Law

A woman was stopped by a county deputy in Texas around 2:00 AM after the officer claimed to observe multiple traffic violations, including speeding and failing to maintain a single lane. The woman, who had just left a family event with her husband, denied any wrongdoing and began recording the encounter on her phone. The officer reported smelling alcohol and observing signs of intoxication, such as slurred speech and glossy eyes. The woman refused to answer certain questions or perform field sobriety tests, leading to her arrest. Body camera footage later showed her being uncooperative and verbally abusive during the arrest and subsequent blood draw at the jail. A blood test revealed a low blood alcohol content, and the criminal charge was later dismissed for insufficient evidence.The United States District Court for the Western District of Texas granted summary judgment in favor of the county and the arresting officer on all claims. The court found that the officer was entitled to qualified immunity and that there was probable cause for the arrest based on the totality of the circumstances, including the officer’s observations and the woman’s refusal to cooperate. The court also rejected claims of First Amendment retaliation, malicious prosecution, and excessive force, as well as Monell claims against the county for alleged unconstitutional policies.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s evidentiary rulings and summary judgment de novo. The appellate court affirmed the district court’s judgment, holding that the officer had probable cause to arrest for driving while intoxicated, that the woman failed to show a constitutional violation necessary for her claims, and that the county could not be held liable under Monell without an underlying constitutional violation. The court also found no abuse of discretion in the district court’s evidentiary decisions. View "Wood v. Bexar County" on Justia Law

Texas enacted a law in 2021 requiring voters who wish to vote by mail to provide an identification number—such as a driver’s license or the last four digits of their Social Security number—on both their mail-in ballot applications and the ballots themselves. This number must match the one provided during voter registration. If the numbers do not match or are missing, the application or ballot is rejected. The law was challenged by the United States and several private plaintiffs, who argued that these requirements violate the materiality provision of the Civil Rights Act of 1964, which prohibits denying the right to vote due to errors or omissions on paperwork if those errors are not material to determining voter qualification.The United States District Court for the Western District of Texas consolidated the lawsuits and denied Texas’s motion to dismiss, finding that the plaintiffs had standing and that sovereign immunity did not bar the private plaintiffs’ claims. After discovery, the district court granted summary judgment for the plaintiffs, holding that the identification number requirement was not material to voter eligibility and enjoined Texas from enforcing the number-matching provisions.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the district court lacked jurisdiction over the private plaintiffs’ claims against the Secretary of State due to a pending appeal on sovereign immunity, but found no jurisdictional bar to reviewing the United States’ claims. The Fifth Circuit held that the identification number requirement is material to determining whether an individual is qualified to vote under Texas law, as it serves to confirm the voter’s identity and prevent fraud. The court concluded that the law complies with the materiality provision of the Civil Rights Act and reversed the district court’s judgment, rendering judgment for the defendants. View "USA v. Paxton" on Justia Law

Three registered Texas voters alleged that three local officials—a justice of the peace, a sheriff, and a constable—conspired to punish them for political reasons. The plaintiffs were arrested after reporting for jury duty, accused of falsely claiming residency in Loving County. The officials argued they were enforcing voter-eligibility rules, while the plaintiffs claimed it was retaliation to silence dissent. The plaintiffs sued under § 1983, alleging constitutional violations.The United States District Court for the Western District of Texas granted judicial and quasi-judicial immunity to the officials for some claims but denied judicial immunity for actions related to the jury proceeding. The officials appealed the denial of judicial immunity, and the plaintiffs cross-appealed the grant of immunity on other claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that presiding over the jury proceeding was a judicial act protected by absolute judicial immunity. Consequently, the court reversed the district court's denial of judicial immunity for the jury proceeding. Regarding the plaintiffs' cross-appeal, the court found it lacked jurisdiction to review those claims at this interlocutory stage and dismissed the cross-appeal.The court's main holding was that the actions of the justice of the peace in presiding over the jury proceeding were judicial in nature and thus protected by absolute judicial immunity. The court reversed the district court's decision in part and dismissed the cross-appeal for lack of jurisdiction. View "Jones v. King" on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

William Carter, a paraplegic confined to a wheelchair, was arrested for unauthorized use of 911 and spent eight days in the Shreveport City Jail. During his incarceration, Carter, who had pre-existing bedsores, did not receive adequate medical care for his wounds, which allegedly led to their infection and his subsequent hospitalization. Carter's mother, suing on his behalf, filed claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act (RA), 42 U.S.C. § 1983, and Louisiana state negligence law.The United States District Court for the Western District of Louisiana excluded the expert testimony of Dr. Joel Nitzkin before trial. After a jury trial, the court granted the defendants' Rule 50 motion for judgment as a matter of law on the ADA/RA claim, concluding that the claim was about medical treatment rather than an actionable disability claim. The jury returned a verdict for the defendants on the § 1983 and state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, holding that the ADA/RA claim amounted to a complaint about medical negligence, which is not actionable under the ADA. The court found that the failure to change Carter's bandages was a medical treatment issue, not a failure to accommodate under the ADA. Additionally, the court held that Carter's placement in a segregated cell for his safety did not constitute intentional discrimination under the ADA. The court also did not address the exclusion of Dr. Nitzkin's testimony, as it was only relevant to the ADA claims, which failed as a matter of law. The judgment of the district court was affirmed. View "Carter v. City of Shreveport" on Justia Law

M.K., a minor, enrolled in the Pearl River County School District after being homeschooled. During his sixth-grade year, he was bullied by boys in four of his classes, who called him names like "gay." In October, M.K. exposed his genitals to one of the boys in a restroom, claiming it was either accidental or an attempt to prove he was not "gay." The District suspended M.K. and required him to attend an alternative school for six weeks, which he refused, considering it akin to a prison. M.K., through his father, sued the District and others, alleging deliberate-indifference sex-discrimination under Title IX.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of the District, concluding that Title IX does not cover sexual-orientation discrimination and that the alleged behavior was not severe enough to be actionable. M.K. appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the student behavior M.K. experienced, while mean-spirited, did not meet the Supreme Court's stringent standard for "severe, pervasive, and objectively offensive" conduct required for a Title IX claim. The court emphasized that the behavior M.K. described, such as name-calling and teasing, is common in schools and does not rise to the level of actionable harassment under Title IX. The court concluded that M.K.'s experiences, though unfortunate, were not sufficient to sustain his Title IX claim against the District. View "M.K. v. Pearl River County School District" on Justia Law

In May 2018, Raynaldo Sampy Jr. was arrested by seven officers from the Lafayette Police Department after driving into an ice cooler. During the arrest, Sampy was forcibly removed from his vehicle, handcuffed, and bent over a police car. He kicked Officer Rabb while being restrained, leading to his conviction for battery of a police officer in Lafayette City Court. Sampy later filed a lawsuit under 42 U.S.C. § 1983, alleging excessive force by the officers and retaliation for his speech.The United States District Court for the Western District of Louisiana dismissed Sampy’s Fourth Amendment excessive force claim, Fourth Amendment bystander liability claim, and First Amendment retaliation claim under Heck v. Humphrey, which bars claims that would imply the invalidity of a conviction. The court did not dismiss a claim regarding a third instance of alleged excessive force, which went to trial, and the jury found for the defendants. Sampy appealed the dismissal of the initial two uses of force.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The court held that Sampy’s excessive force claims were barred by Heck because they were not temporally and conceptually distinct from his battery conviction. The court found that the facts in Sampy’s complaint were inconsistent with those adjudicated in the criminal case. The court also held that Sampy’s bystander liability and First Amendment retaliation claims were barred by Heck. Consequently, the Fifth Circuit affirmed the district court’s judgment. View "Sampy v. Rabb" on Justia Law