Justia Civil Rights Opinion Summaries

Steven D’Braunstein was involved in a serious single-vehicle accident, resulting in his car being totaled. California Highway Patrol Officer Samantha Diaz-Durazo arrived at the scene and found D’Braunstein disoriented and in physical distress. Despite his evident symptoms, she did not call for medical assistance. Instead, she arrested him for driving under the influence of drugs and took him to jail. A nurse at the jail refused to admit D’Braunstein due to his medical condition, prompting Durazo to finally take him to the hospital, where he was diagnosed with a stroke. The delay in receiving medical treatment allegedly led to permanent injuries for D’Braunstein.The United States District Court for the Central District of California granted summary judgment in favor of Officer Durazo, holding that although she violated D’Braunstein’s Fourth Amendment rights by failing to provide reasonable medical care, she was entitled to qualified immunity. The court reasoned that the constitutional violation was not clearly established, as D’Braunstein’s injury was sustained prior to his arrest and not during the arrest process.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that a reasonable jury could find that Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, given the serious nature of the collision and his symptoms. The court further held that Durazo’s failure to provide medical care was a violation of clearly established law, which requires officers to seek medical assistance for an injured detainee or arrestee facing a substantial and obvious risk of serious harm. The case was remanded for further proceedings. View "D’Braunstein v. California Highway Patrol" on Justia Law

Two professors of Indian descent and adherents to the Hindu religion challenged California State University's (CSU) anti-discrimination and harassment policy, which included "caste" as a protected class. They argued that this inclusion stigmatized their religion and caused them to self-censor certain religious practices. They filed a lawsuit alleging violations of the Due Process Clause, Free Exercise Clause, and Establishment Clause of the U.S. Constitution, as well as equivalent claims under the California Constitution.The United States District Court for the Central District of California dismissed the professors' Equal Protection claim and the equivalent state law claim for lack of standing. The court also dismissed the Free Exercise claim for failing to state a claim without deciding on standing. The Due Process and Establishment Clause claims proceeded to a bench trial, where the court ultimately dismissed these claims as well, finding that the professors lacked sufficient injury for a pre-enforcement challenge and that the policy did not express government disapproval of Hinduism.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the professors lacked Article III standing for their Due Process claim because they failed to show that they intended to engage in any religious practice that could reasonably constitute caste discrimination or harassment. The court also found that the professors lacked standing for their Free Exercise claim, as they did not demonstrate any injury to their ability to exercise their religion. Finally, the court held that the professors lacked standing for their Establishment Clause claim, as the district court's factual finding that the policy had no hostility toward religion was not clearly erroneous. The court affirmed the judgment for the defendants and remanded for entry of judgment of dismissal without prejudice. View "Kumar v. Koester" on Justia Law

Sergeant Dan Ponder of the Riverside County Sheriff’s Department responded to a call about someone destroying property with a bat. Upon arrival, he encountered Clemente Najera-Aguirre, who matched the suspect's description. Ponder commanded Najera to drop the bat, but Najera did not comply and approached Ponder. Ponder pepper-sprayed Najera twice, but it was ineffective. Ponder then fired six shots, with the final two bullets, which were fatal, striking Najera in the back as he turned away.The plaintiffs, Najera’s children, sued Ponder and Riverside County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. The United States District Court for the Central District of California denied Ponder’s motion for summary judgment on the Fourth Amendment claim, and the Ninth Circuit affirmed this decision on interlocutory appeal. After a five-day trial, the jury found in favor of the plaintiffs, awarding $10 million in damages. Ponder’s post-trial motion for judgment as a matter of law, including a claim for qualified immunity, was denied by the district court.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that Ponder did not waive his qualified immunity defense and that the jury’s verdict established that Ponder violated Najera’s Fourth Amendment rights. The court found that Ponder’s use of deadly force was not justified as Najera posed no immediate threat to Ponder or others, and the law clearly established that such force was unlawful. The court emphasized that Ponder’s actions, including shooting Najera in the back, did not entitle him to qualified immunity. View "ESTATE OF AGUIRRE V. COUNTY OF RIVERSIDE" on Justia Law

Lars Jensen, a math professor at Truckee Meadows Community College (TMCC), voiced concerns about a policy change to the math curriculum standards. He criticized the new co-requisite policy, which placed students needing remedial instruction in college-level classes, arguing it lowered academic standards. Following his criticism, Jensen faced several adverse actions, including reprimands, negative performance reviews, and a termination hearing.The United States District Court for the District of Nevada dismissed Jensen’s claims, including First Amendment retaliation, procedural due process, and equal protection violations. The court held that Jensen’s First Amendment claim was barred by qualified immunity and that his official capacity claim was barred by sovereign immunity. The court also found that Jensen failed to identify a protected interest for his due process claim and did not allege membership in a discrete class for his equal protection claim. The court dismissed all claims with prejudice and denied leave to amend.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Jensen’s First Amendment retaliation claim. The appellate court held that Jensen’s criticism of the curriculum changes addressed a matter of public concern and was protected speech related to scholarship or teaching. The court found that the adverse actions against Jensen were motivated by his speech and that the state had not shown a substantial disruption to outweigh his First Amendment rights. The court also held that the Administrators were not entitled to qualified immunity and that Jensen’s official capacity claim for prospective relief was not barred by sovereign immunity. The court affirmed the dismissal of Jensen’s due process and equal protection claims but reversed the denial of leave to amend, remanding for further proceedings. View "JENSEN V. BROWN" on Justia Law

Triston Harris Steinman was stopped by Nevada State Trooper William Boyer for speeding. During the stop, Boyer observed an ammunition box in Steinman's car and learned that Steinman had a felony conviction. Boyer asked Steinman to exit the vehicle and sit in the patrol car while he ran a criminal history check. Steinman admitted to having ammunition but denied having firearms. Boyer eventually seized the car and obtained a search warrant, leading to the discovery of firearms, ammunition, and other contraband.The District Court for the District of Nevada suppressed the evidence, ruling that Boyer unlawfully prolonged the traffic stop without reasonable suspicion and lacked probable cause to seize the vehicle. The court also found the search warrant overbroad and invalid.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Boyer did not unlawfully prolong the stop, as his actions were within the scope of the traffic stop's mission and did not measurably extend its duration. The court also found that Boyer had reasonable suspicion of an independent offense after learning of Steinman's felony conviction. Additionally, the court ruled that Boyer had probable cause to seize the vehicle based on evidence of federal and state law violations. The court concluded that the search of the vehicle was permissible under the automobile exception to the Fourth Amendment's warrant requirement, despite the overbroad warrant. Thus, the suppression of the evidence was reversed. View "USA V. STEINMAN" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

Reed Day and Albert Jacobs, Arizona residents, wanted to ship wine directly from out-of-state retailers who do not have in-state premises in Arizona. Arizona law, however, requires retailers to have a physical presence in the state to ship wine directly to consumers. Plaintiffs filed a civil rights action under 42 U.S.C. § 1983 against Arizona state officials, claiming that this statutory scheme violates the Commerce Clause.The United States District Court for the District of Arizona granted summary judgment in favor of the state officials and the intervenor-defendant, the Wine and Spirits Wholesalers Association of Arizona. The district court found that the plaintiffs likely lacked standing and that, even if they did, the Arizona laws were not discriminatory. The court reasoned that the physical presence requirement applied equally to in-state and out-of-state retailers and was essential to Arizona’s three-tier system for alcohol distribution.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the plaintiffs had standing because the district court could grant some form of relief. However, the court found that the plaintiffs failed to show that Arizona’s physical presence requirement was discriminatory. The requirement applied even-handedly to all retailers, regardless of their state of origin, and was not so onerous as to be discriminatory. The court noted that out-of-state businesses could and did obtain retail licenses in Arizona, indicating that the laws did not have a discriminatory effect in practice. The court concluded that Arizona’s laws did not violate the dormant Commerce Clause. View "Day v. Henry" on Justia Law

Ryan Smith was shot and killed by Seattle police officers Christopher Myers and Ryan Beecroft during a response to a 911 call from Smith's girlfriend, Katy Nolan, who reported that Smith was threatening to kill both himself and her with a knife. When the officers arrived, they kicked in the door to Smith's apartment, and within 5.87 seconds, they shot Smith, who was holding a pocketknife. Smith raised his right arm across his chest and took a step forward before being shot. The officers did not issue any warnings before using deadly force.The United States District Court for the Western District of Washington denied the officers' motion for partial summary judgment based on qualified immunity. The district court found that there were factual disputes regarding whether a reasonable officer would have believed Smith posed an immediate threat and whether less drastic measures were feasible. The court concluded that the law was clearly established that officers may not use deadly force against suspects who do not pose an immediate threat.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that it had jurisdiction over the interlocutory appeal and that, viewing the evidence in the light most favorable to the plaintiffs, the officers were not entitled to qualified immunity. The court determined that a reasonable juror could conclude that Smith did not pose an immediate threat to the officers or others, and that the use of deadly force was not justified. The court emphasized that it was clearly established law that a fatal shooting under these circumstances violated the Fourth Amendment. The Ninth Circuit affirmed the district court's denial of qualified immunity. View "JOHNSON V. MYERS" on Justia Law

Dawn Lui, a longtime employee of the United States Postal Service (USPS), alleged disparate treatment, a hostile work environment, and unlawful retaliation under Title VII of the Civil Rights Act. Lui, a woman of Chinese ethnicity, claimed she was targeted with false complaints and grievances by employees at the Shelton Post Office due to her race, sex, and national origin. She was demoted from her position as Postmaster in Shelton, Washington, to a lower-paying Postmaster position in Roy, Washington, and replaced by a white man. Lui filed an informal discrimination complaint through USPS’s Equal Employment Opportunity (EEO) System and later a formal EEO complaint.The United States District Court for the Western District of Washington granted summary judgment to USPS on all of Lui’s claims. The court found that Lui failed to establish a prima facie case of discrimination, did not exhaust her administrative remedies for her hostile work environment claim, and failed to establish a causal connection for her retaliation claim.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Lui’s disparate treatment claim, holding that Lui established a prima facie case of discrimination by showing she was replaced by a white man, which gave rise to an inference of discrimination. The court also found a genuine dispute of material fact about whether the decision to demote Lui was influenced by subordinate bias.The Ninth Circuit vacated the district court’s summary judgment on Lui’s hostile work environment claim, concluding that Lui exhausted her administrative remedies and remanded the case for the district court to address the merits of this claim. However, the court affirmed the district court’s grant of summary judgment on Lui’s retaliation claim, finding that Lui failed to establish a causal connection between her protected activity and the demotion. View "LUI V. DEJOY" on Justia Law

Vietnamese refugees and residents of San Diego County, Anh Thai and Don Doan, alleged that two law enforcement officers, Dulce Sanchez and William Villasenor, violated their constitutional rights by forcibly entering their homes and interrogating them about their disability benefits. Sanchez and Villasenor were Los Angeles District Attorney’s Office investigators assigned full-time to a joint federal-state task force, the Cooperative Disability Investigations (CDI) Unit, which investigates fraud in Social Security disability benefits applications. The plaintiffs claimed that the officers displayed guns and state badges, did not seek consent for the search, and failed to have an interpreter present during the investigations.The United States District Court for the Southern District of California granted summary judgment in favor of Sanchez and Villasenor, concluding that the officers were acting under color of federal law, not state law, and therefore could not be held liable under 42 U.S.C. § 1983. The district court found that the CDI Unit was implemented under federal authority, and the officers’ day-to-day work was supervised by a federal officer, Special Agent Glenn Roberts.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that because the CDI Unit was created under federal authority and supervised by a federal officer, Sanchez and Villasenor were acting under color of federal law. The court noted that the officers’ paychecks were reimbursed by the Social Security Administration, and their investigations took place outside of Los Angeles County, further indicating their federal role. Consequently, the officers were not subject to suit under § 1983, which applies to actions under color of state law. The court affirmed the district court’s summary judgment in favor of the defendants. View "Thai v. County of Los Angeles" on Justia Law