Justia Civil Rights Opinion Summaries

Plaintiff, a former prisoner, filed suit against four Dallas County Jail detention officers under 42 U.S.C. 1983 and state law. Plaintiff claims that the officers beat him without justification. The jury found Special Response Team Officer Erwin liable as to all claims, and awarded both compensatory and punitive damages. The court concluded that the district court did not abuse its discretion in concluding that plaintiff complied with the Prison Litigation Reform Act's (PLRA), 42 U.S.C. 1997(e)(a), exhaustion requirement; sufficient evidence supports the jury's verdict finding Erwin liable for excessive force; the court need not address Erwin’s challenges to the jury’s findings of section 1983 bystander liability or assault under state law, as Erwin’s liability for excessive force is alone sufficient to uphold the verdict; the court rejected Erwin's challenges to the jury's award of damages; and the result in this case does not reflect a miscarriage of justice and the district court acted within its discretion in denying Erwin’s new trial motion. Accordingly, the court affirmed the judgment. View "Cowart v. Erwin" on Justia Law

Five men convicted of murder and sentenced to die by lethal injection (Appellants) filed suit under 42 U.S.C. 1983, alleging constitutional violations in connection to the state's use of pentobarbital to induce death. Three of the five received stays from the Texas Court of Criminal Appeals on state habeas petitions presenting claims not at issue here. The remaining two argue that Texas is obliged by the Eighth Amendment’s prohibition on cruel and unusual punishment and the Fourteenth Amendment’s guarantee of equal protection under the law to re-test the execution drug to assure it does not present a high risk of unnecessary pain. The court concluded that appellants' claims are meritless and that they have failed to make the showing required for a stay pending appeal. Accordingly, the court denied their motion for a stay of execution. View "Wood v. Collier" on Justia Law

Members of the clergy, organizations, and other citizens of the State of Mississippi challenging HB 1523. HB 1523 declares that its aim is “to provide certain protections regarding a sincerely held religious belief or moral conviction for persons, religious organizations and private associations.” The Act enumerates the beliefs as follows: “(a) Marriage is or should be recognized as the union of one man and one woman; (b) Sexual relations are properly reserved to such a marriage; and (c) Male (man) or female (woman) refer to an individual’s immutable biological sex as objectively determined by anatomy and genetics at time of birth.” The district court determined that it should preliminarily enjoin the enactment and enforcement of HB 1523. The State moved for a stay pending appeal. The court denied the State's motion for stay pending appeal and its motion to expedite this appeal. The court granted the State’s motion to consolidate this case with 16-60478, Campaign for Southern Equality, et al v. Phil Bryant, et al. The court's decision maintains the status quo in Mississippi as it existed before the Legislature’s passage and attempted enactment of HB 1523. View "Barber v. Bryant" on Justia Law

Plaintiff, on behalf of himself and others similarly situated, filed suit against Coca-Cola, alleging claims under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that Coca-Cola owns and operates glass-front vending machines in public spaces and that those machines are not accessible to him and others who are blind. The district court dismissed the complaint, holding that Coca-Cola’s vending machines are not themselves “places of public accommodation.” Based on the unambiguous language of 42 U.S.C. 12181(7)(E), the court concluded that Coca-Cola’s vending machines are not “sales establishments” under the plain meaning of that term and therefore are not “places of public accommodation” under Title III of the ADA. Therefore, the court need not consider whether the vending machines are “facilities” under 28 C.F.R. 36.104. The court noted that its conclusion comports with the statute’s legislative history and the DOJ’s guidance. The court acknowledged the limits of its holding and noted that vending machines may very well be subject to various requirements under the ADA by virtue of their being located in a hospital or a bus station, both of which are indisputably places of public accommodation. However, plaintiff only sued Coca-Cola in this case. Accordingly, the court affirmed the judgment. View "Magee v. Coca-Cola Refreshments USA Inc." on Justia Law

Plaintiff filed suit against the school district under 42 U.S.C. 1983, alleging, inter alia, that the non-renewal of her teaching contract was in retaliation for expressing her First Amendment support for a candidate for school superintendent. The district court granted summary judgment for the school district. The court concluded that plaintiff failed to show that her protected speech was the cause of her discharge. The court also concluded that plaintiff failed to show that she was denied adequate pre-termination process under the Fourteenth Amendment. Accordingly, the court affirmed the district court's dismissal of plaintiff's First Amendment retaliation claim and procedural due process claims in all respects. View "Dearman v. Stone Cnty. Sch. Dist." on Justia Law

Plaintiff filed suit alleging that defendants violated her constitutional rights when she was required to participate in a mock performance of the Mexican Pledge of Allegiance. The district court entered summary judgment on some of plaintiff's claims and, after trial, entered judgment as a matter of law for defendants. The court concluded that, because plaintiff has graduated from high school, her only surviving claim is for nominal damages arising from the alleged violation of her rights; plaintiff failed to demonstrate the existence of an official policy or that the District had knowledge of the assignment, and thus judgment as a matter of law was proper for the District on municipal liability for any constitutional violation that may have arisen from the assignment or subsequent actions; the court's ruling also applies to the claims against the District for retaliation and violation of Equal Protection; qualified immunity was properly granted to Defendants Santos and Cavazos on the claim they violated plaintiff's First Amendment rights when they removed plaintiff from class; and, likewise, plaintiff's equal protection claim fails. Accordingly, the court affirmed the judgment. View "Brinsdon v. McAllen I.S.D." on Justia Law

Plaintiffs, eight female alien detainees, filed suit alleging claims under 42 U.S.C. 1983 and the Federal Tort Claims Act (FTCA), 28 U.S.C. 2671 et seq., as well as several state law claims, after a male CCA officer, Donald Dunn, sexually assaulted them. The court concluded that the district court did not err in dismissing plaintiffs’ Section 1983 claim against CCA and Evelyn Hernandez, the former CCA facility administrator, or in granting summary judgment for Dunn. The CCA defendants, in housing alien detainees according to ICE specifications, were performing a federal function, rather than operating the detention center under color of state law. Williamson County had almost no involvement in the detention center’s day-to-day operations. The court also concluded that summary judgment for Williamson County was proper where the county is not directly responsible for CCA’s failure to follow policy, and the county did not otherwise act with deliberate indifference in monitoring the detention center. Furthermore, plaintiffs have not plausibly asserted that ICE officials acted with deliberate indifference and the court affirmed the district court's dismissal of plaintiffs' FTCA claims against the United States. The court affirmed as to the federal claims, but reversed the dismissal of the remaining state claims and remanded. View "Doe v. United States" on Justia Law

Plaintiff, an employee of the School Board, filed suit alleging that she was sexually harassed by Timothy Graham, another board employee, in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq. The district court granted the board’s motion for summary judgment. The court concluded that there is a genuine dispute of material fact as to whether the School Board is entitled to immunity under the Ellerth/Faragher defense. Therefore, the court reversed as to this issue. In this case, the district court erred in holding that the board’s efforts to prevent sexual harassment were reasonable as a matter of law. Plaintiff produced evidence that, if believed, would show that employees at the central office were not trained on sexual harassment, were not informed of the existence of a policy, were not shown where to find it, and were not told whom to contact regarding sexual harassment. The court concluded that this would be a sufficient basis for a reasonable jury to find that the company did not take reasonable steps to prevent and remedy sexual harassment. The court also concluded that, because plaintiff did not show the existence of a genuine dispute of material fact as to whether Graham was her supervisor in the third harassment period, the district court was correct to conclude that he was not; the court rejected plaintiff's argument that using different liability standards for the distinct periods of harassment would unduly confuse the jury; and, because plaintiff does not have any properly presented and preserved argument for why the board knew or should have known about the harassment, she cannot make out a prima facie case under the standard for coworker sexual harassment. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Pullen v. Caddo Parish Sch. Bd." on Justia Law

Plaintiff was employed by Securitas, a security staffing company, and was placed as a receptionist at a company called Fidelity. Plaintiff filed suit against Securitas and Fidelity, alleging that they terminated her due to her age - she was 83-years-old. Plaintiff also alleged that Securitas terminated her in violation of Section 623(a) of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621−34, and sought liquidated damages, injunctive relief, and attorney’s fees. The court concluded that the district court erred as to the identity of the employer where Securitas has admitted that it was plaintiff's employer; there was some evidence which created a genuine dispute of material fact as to whether Securitas should have known of discrimination by Fidelity and the court reversed the grant of summary judgment as to this issue; and, depending on the outcome of the district court’s re-evaluation of whether Securitas did enough once learning Fidelity wanted plaintiff removed, the district court should also consider whether that re-evaluation affects its earlier analysis of Securitas’s decision to terminate her. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Nicholson v. Securitas Security" on Justia Law

Plaintiff, a former police officer for the town, filed suit against the town and several individual defendants, alleging that defendants violated his First Amendment rights when they terminated him for cooperating with an FBI investigation of public corruption. Plaintiff also asserted a claim under the False Claims Act, 31 U.S.C. 3730(h), alleging that he was fired in violation of the Act’s whistleblower protections. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing his First Amendment retaliation claims against all defendants and dismissing his FCA claims against the individual defendants. The town cross-appealed the denial of summary judgment with respect to the FCA claim against it. The court found that the district court erred in holding that plaintiff’s involvement in the FBI investigation was not entitled to First Amendment protection. Although the court held that plaintiff asserts a violation of his right of free speech, the court held that the right at issue was not “clearly established” at the time of his discharge. Therefore, the court affirmed the dismissal of the individual defendants on the basis of qualified immunity. However, the court reversed and vacated the grant of summary judgment for the town because plaintiff has demonstrated a viable claim of municipal liability under Monell v. Department of Social Services. The court also dismissed the town's cross-appeal for lack of appellate jurisdiction. Finally, the court affirmed the district court’s dismissal of the FCA claims against the individual defendants. View "Howell v. Town of Ball" on Justia Law