Justia Civil Rights Opinion Summaries

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress concerning a traffic stop in Kittery, Maine because the police had reasonable suspicion to justify the investigative stop as of 1:55 a.m. and the seizure was not unreasonably long; and (2) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was reasonable suspicion to justify the detention. View "United States v. Ramdihall" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was no unlawful seizure, and therefore, the evidence Defendant sought to suppress did not constitute the fruits of an unlawful seizure; and (2) the district court did not err in concluding that the warrantless swiping of credit cards from in the trunk of a rental car through a card reader was constitutional. View "United States v. Hillaire" on Justia Law

First Circuit rejects civil rights claims relating to retention of property in car towed for an evidentiary search.Chelmsford police located Denault’s 2000 Nissan parked in Testa’s Lowell driveway. Denault, the suspect in a crime, was in custody. Testa was the mother of Denault's children. The officers had Denault's car towed and secured a warrant. Days later, they executed the warrant; having determined that the car did not contain evidence, they released it to Christopher's Towing. The officers had no contact with Denault. They did not supply, and Christopher's Towing did not request, Denault’s contact information. Testa repeatedly tried to recover the car and her belongings, particularly child booster seats. Testa claims that officers refused to discuss returning the car or its contents unless Testa agreed to be questioned in connection with the Denault investigation; they never informed her that they had released the car. Three months later, Denault's mother showed Tesla a Notice of Abandoned Vehicle sent to Denault's last known address, indicating a lien of $4797.82 for towing, storage, and processing. Neither Testa nor Denault could pay. They sued under 42 U.S.C. 1983 and the Massachusetts Civil Rights Act. They ultimately prevailed on a common-law conversion claim against one officer for $2225. The First Circuit affirmed, noting the “confusing” record and that the plaintiffs had waived claims relating to the initial seizure. View "Denault v. Ahern" on Justia Law

A plaintiff may not bring claims for damages under 42 U.S.C. 1981 against state actors, including defendants sued in their official capacities as government officials.The First Circuit affirmed the district court’s dismissal of Plaintiff's section 1981 claims against employees of the City of Boston. Plaintiff, who represented the estate of her late father, challenged her father’s termination from his employment with the Department of Public Works. The district court dismissed the section 1981 claims, concluding that section 1981 provides no implied private right of action for damages against state actors. The First Circuit affirmed, holding that Jett v. Dallas Independent School District compelled the result reached by the district court. View "Buntin v. City of Boston" on Justia Law

While they were investigating a suspected drug-trafficking operation, federal DEA agents made a warrantless entry into an apartment that, as it turned out, served as a stash house for a second, more substantial, drug-trafficking operation. Defendant, a participant in the second drug-trafficking operation, was charged with conspiring to possess with intent to distribute and to distribute one kilogram or more of heroin. Defendant moved to suppress the evidence gathered from the apartment. The district court denied the motion, concluding that probable cause and exigent circumstances justified the warrantless entry. The First Circuit affirmed, holding that the record supported the district court’s determination that the combination of probable cause and exigent circumstances justified the DEA agents’ warrantless entry into the apartment. View "United States v. Almonte-Baez" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment in favor of her former employer, AstraZeneca Pharmaceutical LP, on Plaintiff’s claims that AstraZeneca violated the Americans with Disabilities Act (ADA) and several provisions of Puerto Rico law. Plaintiff attempted to persuade the First Circuit that there existed several material factual disputes in this case. The First Circuit affirmed the summary judgment, holding (1) AstraZeneca was entitled to summary judgment on both Plaintiff’s ADA disability discrimination claim and her ADA retaliation claim; and (2) Plaintiff failed to shoulder her burden to proceed to trial on her claims sounding in Puerto Rico law. View "Delgado-Echevarria v. AstraZeneca Pharmaceutical LP" on Justia Law