Justia Civil Rights Opinion Summaries

Plaintiff filed suit under 42 U.S.C. 1983, the California Constitution, and state tort law, alleging that he was wrongfully incarcerated by LASD based on the misapplication of a felony warrant issued in 1994 for Mario L. Garcia, who has the same date of birth as plaintiff. On appeal, LASD, and former LA Sheriff Lee Baca challenged the district court’s denial of qualified immunity, absolute (quasi-judicial) immunity, and immunity under two California statutes. The court concluded that it has jurisdiction over defendants’ appeals from denial of state-law immunity because the district court’s denial determined rights collateral to those asserted in the action, and like the denial of qualified immunity, the district court’s decision is effectively unreviewable on appeal from a final judgment; LA County and LASD may only appeal denial of state-law statutory immunity; and Baca, in his individual capacity, may appeal denial of qualified immunity and of quasi-judicial immunity. The court also concluded that plaintiff has sufficiently pleaded a Fourteenth Amendment violation and he is not entitled to qualified immunity where, at the time of plaintiff's incarceration, the standards for determining whether alleged police conduct violates the Fourteenth Amendment were clearly established. In this case, although plaintiff’s arrest for driving under the influence was valid, the warrant on which he was later held matched only his first and last name and date of birth; plaintiff is nine inches taller and forty pounds heavier than the warrant subject; and, even a cursory comparison of plaintiff to the warrant subject should have led officers to question whether the person described in the warrant was plaintiff. Finally, because the facts plaintiff alleged go beyond the limits of quasi-judicial immunity, this immunity does not apply to Baca. Accordingly, the court affirmed the judgment. View "Garcia v. Cnty. of Riverside" on Justia Law

The Federation filed a class action against United, alleging that the airline’s policy of using automatic kiosks inaccessible to blind travelers violates California’s antidiscrimination laws. The district court dismissed the suit on the grounds that the Federation’s claims were expressly preempted under the Airline Deregulation Act of 1978 (ADA), 49 U.S.C. 41713, and impliedly field preempted under the Air Carrier Access Act of 1986 (ACAA), 49 U.S.C. 41705, and its implementing regulations, issued by the DOT. Under its interpretation of section 41713(b)(1) of the ADA, the court concluded that the Federation’s claims do not relate to a “service” provided by United. Moreover, the court's conclusion that United's kiosks fall outside the statutory definition of “services” is consistent with the ADA’s deregulatory purpose. Therefore, the Federation’s claims are not expressly preempted under the ADA. Absent any specific indication that Congress sought to preserve all state-law claims not expressly preempted under the ADA, the court adopted the Geier v. Am. Honda Motor Co. approach and applied ordinary implied field preemption principles to the Federation’s claims. Applying the court's precedent concerning field preemption, the court concluded that the DOT ACAA regulations covering matters other than the use of airline ticketing kiosks are not pertinent to the court's field preemption inquiry; the new regulation is pervasive and intended to occupy the field of kiosk accessibility; and DOT acted within its delegated authority in promulgating the new regulation. Therefore, the Federation’s state-law claims are impliedly field preempted under the ACAA. The court affirmed the judgment. View "Nat'l Fed. of the Blind v. United States" on Justia Law

Plaintiff was awarded nominal damages on three of his four as-applied claims in a 42 U.S.C. 1983 suit to invalidate aspects of Laguna Beach's ordinances prohibiting the use of sound-amplification devices on public sidewalks. Plaintiff then moved for attorneys' fees. The district court concluded that plaintiff was a prevailing party under 42 U.S.C. 1983, but denied attorneys' fees pursuant to Farrar v. Hobby. Farrar held that a prevailing party who seeks a large compensatory award but receives only nominal damages may not be entitled to fees. The court affirmed the district court’s order denying fees under California law. However, under federal law, the court held that because plaintiff's lawsuit achieved its future-oriented goals and plaintiff never attempted to secure compensatory damages under section 1983, the Farrar exception does not apply. Consequently, the district court erred by not considering plaintiff's entitlement to fees under the standard framework. The court vacated and remanded for further proceedings. View "Klein v. City of Laguna Beach" on Justia Law

A jury found that the City and the SMPD violated plaintiffs' constitutional rights when SMPD officers failed to disclose in seeking a warrant to search plaintiffs' home that Javier Bravo, Jr. was not living and had not been living in the home for some seven months prior to the shooting because he was incarcerated for unrelated charges. The court addressed an issue of first impression on appeal: whether in considering an award of attorney fees under 42 U.S.C. 1988, it is appropriate to take into consideration a plaintiff’s success in obtaining a settlement against another party arising out of the same facts. The court concluded that, under the facts and circumstances of this case, it was appropriate to take a settlement with the City of Santa Barbara into consideration. The court concluded that the district court's finding that plaintiffs achieved an excellent result is supported by the public benefit generated by the litigation as well as the $150,000 in damages plaintiffs obtained in the Santa Barbara settlement. Accordingly, the court affirmed the district court's fee award. However, on the same theory, the court vacated the cost award against the Santa Maria defendants and remanded for the district court to take into account the costs recovered in the Santa Barbara settlement and offset those costs against the costs to be awarded against the Santa Maria defendants. View "Bravo v. City of Santa Maria" on Justia Law

Plaintiff, a California state inmate, filed suit under 42 U.S.C. 1983 against defendant and other prison officials, alleging that they had violated the Eighth Amendment through deliberate indifference to his medical needs. The district court granted defendants' motion to dismiss because plaintiff failed to name two physicians in his grievance. The court held that a prisoner exhausts “such administrative remedies as are available,” under the Prison Litigation Reform Act of 1995 (PLRA), 42 U.S.C. 1997e, despite failing to comply with a procedural rule if prison officials ignore the procedural problem and render a decision on the merits of the grievance at each available step of the administrative process. When prison officials opt not to enforce a procedural rule but instead decide an inmate’s grievance on the merits, the purposes of the PLRA exhaustion requirement have been fully served: prison officials have had a fair opportunity to correct any claimed deprivation and an administrative record supporting the prison’s decision has been developed. In this case, plaintiff's grievance plainly put prison officials on notice of the nature of the wrong alleged in his federal suit because prison officials had full notice of the alleged deprivation and ample opportunity to resolve it. Accordingly, the court reversed and remanded for further proceedings. View "Reyes v. Smith" on Justia Law

RDN filed suit challenging the constitutionality of California Business and Professions Code Section 25503(f)–(h), which forbids manufacturers and wholesalers of alcoholic beverages from giving anything of value to retailers for advertising their alcoholic products. Sorrell v. IMS Health, Inc., requires heightened judicial scrutiny of content-based restrictions on non-misleading commercial speech regarding lawful products, rather than the intermediate scrutiny applied to section 25503 in Actmedia, Inc. v. Stroh. Accordingly, the court concluded that Actmedia is clearly irreconcilable with Sorrell. The court therefore reversed the district court's grant of summary judgment to the State and remanded on an open record for the district court to apply heightened judicial scrutiny in the first instance. View "Retail Digital Network v. Appelsmith" on Justia Law

Plaintiffs challenged the Attorney General of California’s collection of IRS Form 990 Schedule B, which contains identifying information for their major donors, arguing that the nonpublic disclosure requirement is unconstitutional as applied to them because it impermissibly burdens First Amendment rights to free speech and association by deterring individuals from financially supporting them. The district court entered preliminary injunctions preventing the Attorney General from demanding plaintiffs’ Schedule B forms pending a trial on the merits. The court concluded that an injunction properly tailored to plaintiffs’ concerns would address the risk of public disclosure by enjoining the Attorney General and her agents from making Schedule B information public, pending a decision on the merits of plaintiffs’ as-applied challenges. However, plaintiffs have not shown that they are entitled to an injunction preventing the Attorney General from demanding their Schedule B forms, enforcing that demand, and using the forms to enforce California law. Accordingly, the court vacated the injunctions with instructions to enter new orders preliminarily enjoining the Attorney General from publicly disclosing, but not from collecting, plaintiffs’ Schedule B forms. View "Americans for Prosperity Found. v. Harris" on Justia Law

Plaintiff filed suit against the University and university officials alleging violations of the First Amendment and the Due Process Clause of the Fourteenth Amendment after the University denied his application to become a student teacher. The court held that, in the context of a public university’s professional certification program, the university may evaluate the student’s speech, made in the course of the program, in determining the student’s eligibility for certification without offending the First Amendment under certain circumstances. In this case, the court concluded that the University did not violate plaintiff's First Amendment rights because its decision related directly to defined and established professional standards, was narrowly tailored to serve the University’s core mission of evaluating plaintiff’s suitability for teaching, and reflected reasonable professional judgment. Further, because the University provided adequate procedural protections in denying plaintiff’s application, neither it nor its agents violated plaintiff’s procedural due process rights. Accordingly, the court affirmed the district court's grant of summary judgment to the University. View "Oyama v. Univ. of Hawaii" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of post-conviction DNA testing under California Penal Code 1405. The court rejected plaintiff's contention that the promise held out by section 1405 is illusory and the court was unpersuaded by the statistics plaintiff cited. The court concluded that tallying the available judicial decisions does not suggest that section 1405 in practice bars access to postconviction DNA testing. The court further concluded that the reasonable probability requirement does not violate due process where plaintiff failed to show that the requirement violates any recognized principle of fundamental fairness or goes beyond what the Supreme Court approved in District Attorney’s Office for Third Judicial District v. Osborne. Moreover, the chain of custody requirement does not violate due process. The court finally concluded that the Rooker-Feldman Doctrine does not bar plaintiff's as-applied challenge because plaintiff seeks to invalidate the DNA testing statute on federal constitutional grounds. While review by someone other than the trial judge does not occur in every case, it is a categorical issue not limited to the particulars of plaintiff’s situation. The court went on to say that review of the section 1405 petition by a judge other than the trial judge does not violate due process. Accordingly, the court affirmed the district court's decision. View "Morrison v. Peterson" on Justia Law

Plaintiff filed suit under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging that his First and Fourteenth Amendment rights were violated when a correctional counselor issued plaintiff an incident report charging him with “Possession of Anything Unauthorized.” A Disciplinary Hearing Officer found that plaintiff had committed “Conduct which Interferes with the Security or Orderly Running of the Institution.” The court concluded that the district court properly granted summary judgment on plaintiff’s due process claim because, as its sister circuits have recognized, any procedural error was corrected through the administrative appeal process, and plaintiff ultimately did not lose any good time credits. Accordingly, the court affirmed the judgment. View "Frank v. Schultz" on Justia Law