Justia Civil Rights Opinion Summaries

Two individuals active in a right-wing political organization alleged that government officials and entities in Portland, Oregon, conspired to arrest and prosecute them without probable cause in order to suppress their political speech. The plaintiffs claimed that city and county officials, various prosecutors, and a police detective orchestrated the investigation and charges after a confrontation at a bar, focusing their efforts on the plaintiffs while allegedly ignoring violent acts by left-wing activists. The plaintiffs were indicted and arrested before a planned protest, but ultimately acquitted at trial. They then sued, asserting violations of federal civil rights statutes and state tort law, including claims of conspiracy, malicious prosecution, and selective enforcement.After the plaintiffs’ acquittal, they filed their action in the United States District Court for the District of Oregon. The district court dismissed the complaint, holding that it was a “shotgun pleading” that failed to satisfy Federal Rule of Civil Procedure 8 because it lumped together claims and factual allegations without specifying which defendants were responsible for which acts. The court also ruled, in the alternative, that several defendants were immune from suit: the Multnomah County District Attorney’s Office (“MCDA”) and prosecutors in their official capacities under the Eleventh Amendment; the prosecutors in their individual capacities under absolute immunity; and the police detective for his grand jury testimony.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the complaint was properly dismissed as a shotgun pleading, but that plaintiffs must be allowed to amend. The court affirmed dismissal with prejudice of all claims against MCDA and prosecutors in their official capacities on sovereign immunity grounds, and against the prosecutors in their individual capacities to the extent their actions were prosecutorial. However, the court reversed the dismissal of claims against a deputy prosecutor for allegedly filing false affidavits, holding that such conduct is not protected by absolute immunity and is not shielded by qualified immunity if false statements were knowingly made to obtain a warrant. The court also reversed dismissal of certain state-law claims against Multnomah County and remanded for further proceedings, allowing plaintiffs to replead those claims not based on the acts of the immune parties. It affirmed immunity for the detective regarding his grand jury testimony. The disposition was affirmed in part, reversed in part, and remanded with instructions to permit amendment of the complaint. View "Gibson v. City of Portland" on Justia Law

A Nevada state prisoner claimed that, during the COVID-19 pandemic, staff at High Desert State Prison denied him outdoor exercise, even while requiring him and other inmates in his unit to work together in a prison industry warehouse. He alleged that inmates in other units were permitted outdoor yard time, and that the denial of exercise caused him physical and psychological harm. The plaintiff, housed in a protective segregation unit, asserted that these actions violated his rights under the Eighth and Fourteenth Amendments, as well as similar state constitutional provisions.After filing grievances that were denied at each level by prison officials, the inmate brought a lawsuit in the United States District Court for the District of Nevada against the warden and other prison staff under 42 U.S.C. § 1983. The district court screened the complaint and allowed certain claims, including those regarding denial of outdoor exercise and equal protection, to proceed against the warden. On summary judgment, the district court denied qualified immunity to the warden for both the Eighth Amendment and Fourteenth Amendment claims, prompting the warden to appeal.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court held that the district court correctly denied qualified immunity on the Eighth Amendment claim, finding that the right to outdoor exercise was clearly established and that there were triable issues as to whether the warden’s actions constituted deliberate indifference. However, the Ninth Circuit reversed the denial of qualified immunity on the Fourteenth Amendment claim, concluding that the plaintiff did not provide evidence that ruled out all rational justifications for the difference in yard time between his unit and others. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Cardenas-Ornelas v. Johnson" on Justia Law

The case involves the death of Ramon Timothy Lopez following an encounter with Phoenix Police Department officers. After receiving reports of erratic behavior, officers pursued Lopez in a foot chase, subdued him, and restrained him with handcuffs and a RIPP hobble device. This restraint bent Lopez’s body into a hogtied position while he was face down. Despite Lopez's distress and visible signs of medical need, officers transported him in the back of a patrol vehicle in this position. He became unresponsive during transport and was later pronounced dead at the hospital. The medical examiner attributed his death to cardiac arrest in the context of methamphetamine intoxication, heart disease, and physical restraint.Plaintiff Laura Gonzalez, Lopez’s mother, filed suit in the United States District Court for the District of Arizona against the City of Phoenix and several officers, asserting claims under federal and state law, including excessive force under the Fourth Amendment. The district court granted summary judgment in part, dismissing claims of false arrest, Monell liability, and others, but denied summary judgment on the excessive force claim related to the officers’ actions after the RIPP restraint was applied, including the transportation of Lopez in the prone, hogtied position.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of qualified immunity. The Ninth Circuit affirmed the denial, holding that a reasonable jury could find the officers’ use of the RIPP restraint and the manner of transport unreasonable and excessive, given Lopez’s lack of resistance and medical distress. The court found that precedent in the Ninth Circuit clearly established that continued use of force or refusal to alleviate its harmful effects against a helpless detainee constitutes excessive force. The case was remanded for further proceedings. View "GONZALEZ V. CITY OF PHOENIX" on Justia Law

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision.Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law

A prison inmate with a documented history of mobility impairments and medical accommodations, including the use of a wheelchair and a transportation code requiring wheelchair-accessible vehicles, was scheduled for transfer between two facilities. On the day of the transport, he arrived in his wheelchair but was not provided with an accessible van. Instead, prison officials attempted to move him onto a standard bus. The inmate protested, stating he could not board without proper accommodations, but officials treated his protest as a refusal. After a crisis negotiator was called and negotiations failed, prison staff physically moved him onto the bus, allegedly causing him injury.A magistrate judge in the United States District Court for the Western District of Washington found that there were genuine disputes of material fact regarding the officials’ awareness of the inmate’s needs, the transportation code in effect, the extent of force used, and the resulting injuries. The magistrate recommended denying summary judgment and qualified immunity for most defendants. However, the district court rejected these recommendations, granted summary judgment for the State of Washington and the individual prison officials, and found that qualified immunity shielded the officials, reasoning that the mistaken transportation code did not amount to deliberate indifference.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the district court erred in granting summary judgment because material factual disputes remained regarding whether officials had notice of the inmate’s need for accommodation and the extent of their investigation into those needs. The Ninth Circuit also found that these disputes precluded summary judgment on Eighth Amendment claims alleging deliberate indifference and excessive force, and that qualified immunity was improperly granted at this stage. The court reversed the district court’s judgment and remanded for further proceedings. View "WELDEYOHANNES V. STATE OF WASHINGTON" on Justia Law

A computer science teaching professor at a public university included a statement in his course syllabus that parodied the university’s recommended indigenous land acknowledgment. This statement, which challenged the university’s view regarding the ownership of campus land, drew complaints from students and staff, particularly those involved in diversity and indigenous advocacy. The professor refused to remove the statement when asked, prompting university administrators to replace his syllabus, publicly condemn his remarks, and encourage official complaints from students. The university then initiated a lengthy disciplinary investigation, withheld a merit pay increase during this period, issued a reprimand, and warned of potential future discipline if the professor continued similar conduct. The university’s actions were based on the disruption and distress reported by students and concerns about creating an unwelcome environment.The United States District Court for the Western District of Washington found that the professor’s speech was protected and addressed a matter of public concern. However, applying the balancing test from Pickering v. Board of Education, it granted summary judgment to the university, finding that the institution’s interest in preventing disruption and maintaining an inclusive learning environment outweighed the professor’s First Amendment rights. The district court also dismissed the professor’s facial challenges to the university’s nondiscrimination policy, interpreting it narrowly to apply only to conduct resembling unlawful discrimination, harassment, or retaliation.The United States Court of Appeals for the Ninth Circuit reversed the district court’s grant of summary judgment for the university and directed that summary judgment be entered for the professor on his First Amendment retaliation and viewpoint discrimination claims. The appellate court held that the professor’s syllabus statement was protected academic speech on a matter of public concern, and that student or community offense or discomfort could not justify university retaliation or discipline under the First Amendment. The panel also ruled that the district court improperly construed the university’s nondiscrimination policy and remanded for further proceedings on the policy’s facial constitutionality. View "REGES V. CAUCE" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

Several individuals, representing a class, challenged a health insurance company’s refusal to cover gender-affirming care for transgender individuals diagnosed with gender dysphoria. The company, acting as a third-party administrator for employer-sponsored, self-funded health plans, denied coverage for such treatments based on explicit plan exclusions requested by the employer sponsors. Some plaintiffs also alleged that they were denied coverage for treatments that would have been covered for other diagnoses, such as precocious puberty, but were denied solely because of the concurrent diagnosis of gender dysphoria.The United States District Court for the Western District of Washington certified the class and granted summary judgment in favor of the plaintiffs. The district court rejected the company’s arguments that it was not subject to Section 1557 of the Affordable Care Act because its third-party administrator activities were not federally funded, that it was merely following employer instructions under ERISA, and that it was shielded by the Religious Freedom Restoration Act (RFRA). The district court also found that the exclusions constituted sex-based discrimination under Section 1557.On appeal, the United States Court of Appeals for the Ninth Circuit agreed with the district court that the company is subject to Section 1557, that ERISA does not require administrators to enforce unlawful plan terms, and that RFRA does not provide a defense in this context. However, the Ninth Circuit held that the district court’s analysis of sex-based discrimination was undermined by the Supreme Court’s intervening decision in United States v. Skrmetti, which clarified the application of sex discrimination standards to exclusions for gender dysphoria treatment. The Ninth Circuit vacated the summary judgment and remanded the case for further proceedings to consider whether, under Skrmetti, the exclusions at issue may still constitute unlawful discrimination, particularly in cases involving pretext or proxy discrimination or where plaintiffs had other qualifying diagnoses. View "PRITCHARD V. BLUE CROSS BLUE SHIELD OF ILLINOIS" on Justia Law

A 12-year-old boy was killed by police officers during an attempt to rescue him from a neighbor who had already killed the boy’s mother and housekeeper, gravely wounded his sister, and was holding the boy hostage in a vehicle. The officers responded to multiple 911 calls, surrounded the vehicle, and attempted to negotiate with the hostage-taker, who was armed and making threats against the child’s life. After the hostage-taker was shot and killed by an officer, other officers fired additional shots, which resulted in the boy’s death.The boy’s father, siblings, and estate filed a lawsuit in the United States District Court for the District of Nevada against the city, police department, and individual officers. They alleged violations of the Fourth Amendment (excessive force), Fourteenth Amendment (substantive due process), a Monell claim for failure to train, and state law claims. The district court dismissed the federal claims with prejudice, finding that the officers had not seized the boy for Fourth Amendment purposes, had not acted with deliberate indifference or intent to harm for Fourteenth Amendment purposes, and that the Monell claim failed in the absence of a constitutional violation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the officers did not violate the boy’s Fourth Amendment rights because their actions during the active hostage situation did not constitute a seizure, and even if a violation had occurred, qualified immunity would apply as the right was not clearly established. The court also found no Fourteenth Amendment violation, as the officers’ actions did not shock the conscience or demonstrate deliberate indifference, and qualified immunity would apply. The Monell claim failed due to the absence of an underlying constitutional violation. View "HAWATMEH V. CITY OF HENDERSON" on Justia Law