Justia Civil Rights Opinion Summaries

This case arose from a dispute over which California government entity would be responsible for funding the education of K.G. pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). The School District contended that the district court erred in granting K.G. relief from its original judgment denying attorneys' fees. The court concluded that the district court did not apply the incorrect legal rule in evaluating whether to grant relief pursuant to Rule 60(b)(1) where the district court's determination that K.G.'s delay in pursuing Rule 60(b) relief was understandable in light of the original attorney's poor mental and physical health; K.G. was the prevailing party entitled to attorney fees because K.G.'s prayer was answered in full when the ALJ designated the School District as the responsible agency and granted K.G.'s requested relief; K.G. qualified as a prevailing party under the IDEA, and this victory was not trivial or merely technical; but it was not clear from the district court's award that it took into account forgoing considerations in reducing the fees originally requested. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Irvine Unified School District v. K.G." on Justia Law

The court filed an amended opinion reversing in part and affirming in part the denial of habeas relief, and order denying a petition for rehearing en banc. Petitioner, convicted of two counts of murder and sentenced to death, appealed the district court's denial of his 28 U.S.C. 2254 habeas corpus petition. The court concluded that the relevant state court decision, relating to petitioner's claims regarding (1) the use of a leg brace as a security measure during trial; (2) the use of dual juries; (3) juror bias; (4) counsel's performance during the plea process; and (5) counsel's performance during the penalty phase, was not contrary to, nor an unreasonable application of, clearly established federal law or based on an unreasonable determination of the facts before that court. The court concluded, however, that the Arizona Supreme Court applied a "causal nexus” test, whereby not all mitigating evidence was considered under Lockett v. Ohio, Eddings v. Oklahoma, and their progeny. Consequently, this decision was contrary to established federal law and the court reversed, remanding with instructions to grant the petition with respect to petitioner's sentence. View "Hedlund v. Ryan" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging claims arising out of injuries he sustained while he was housed in the county jail. On appeal, the county and Conmed, a private contractor, challenged the district court's denial of their motion to dismiss the complaint as time-barred. Plaintiff argued that the applicable statute of limitations was tolled under RCW 4.96.020. The court held that RCW 4.96.020 is a special statute of limitations as opposed to a typical tolling provision, and thus it is not applicable to claims filed under section 1983. Therefore, the court found that plaintiff filed his federal complaint after the applicable three-year statute of limitations had expired, and that his section 1983 claims were thus time-barred. Accordingly, the court reversed the district court's order and remanded with instructions to dismiss the section 1983 claims. View "Boston v. Kitsap County" on Justia Law

Plaintiff, a 53-year-old garbage truck driver, filed suit against USA Waste, his employer of 32 years, alleging wrongful termination based on age discrimination and retaliation. The district court granted summary judgment for USA Waste. The court held that the district court erred by granting summary judgment in favor of USA Waste because plaintiff established a prima facie case under both his age discrimination and retaliation theories, and USA Waste failed to introduce any evidence that it had a legitimate reason for firing him. In this case, the Immigration Reform and Control Act of 1986 (IRCA), Pub.L. 99-603, 100 Stat. 3359, did not require proof of employment eligibility from plaintiff, and USA Waste could not make plaintiff's reinstatement contingent on verification of his immigration status because doing so would violate California public policy. Furthermore, plaintiff's use of an attorney was activity protected by California public policy, USA Waste fired plaintiff because he was represented by his attorney at the Settlement Agreement negotiations, and the district court erred by holding that USA Waste provided a legitimate reason for firing plaintiff. Therefore, the court concluded that USA Waste failed to meet its burden as to plaintiff's claim based on retaliation discrimination. The court also held that the district court did not abuse its discretion when it denied plaintiff's oral request for leave to amend the complaint eight months after the filing deadline. Accordingly, the court reversed and remanded for further proceedings. View "Santillan v. USA Waste of California" on Justia Law

Plaintiffs, parents of a student at the District, filed suit alleging claims that the District violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Plaintiffs argued that the district court misapplied the statute of limitations in 20 U.S.C. 1415(f)(3)(C) to their claims that the District failed to identify their child's disability or assess him for autism in 2006 and 2007. The court concluded, as a question of first impression, that the IDEA's statute of limitations requires courts to bar only claims brought more than two years after the parents or local educational agency "knew or should have known" about the actions forming the basis of the complaint. In this case, the district court barred all claims "occurring" more than two years before plaintiffs filed their due process complaint. Therefore, the court remanded so that the district court could determine when plaintiffs knew or should have known about the actions forming the basis of their complaint. View "Avila v. Spokane School District 81" on Justia Law

Plaintiff, a tattoo artist and long-time resident of Long Beach, filed suit against the City, alleging that the City's zoning ordinances violated the First Amendment by unreasonably restricting his ability to open and operate a tattoo shop in Long Beach. The district court entered judgment for the City. The court concluded that the district court inaccurately narrowed plaintiff's claims in its order by framing plaintiff's challenge as only to the conditional use permit (CUP) requirement, when plaintiff also challenged the location restrictions on tattoo shops; ignoring plaintiff's claim that the CUP process vests unbridled discretion in the City; and stating that plaintiff's claim only concerned his desire to open a shop at 316 Elm Street in the East Village Arts District, when this was just one of three locations that plaintiff initially identified in his letter to the City. The court held that plaintiff has standing to bring a facial first amendment challenge to the City's zoning ordinances where he was not required to first apply for, and then be denied, a CUP to bring this claim under a permitting system that allegedly gives City officials unfettered discretion over protected activity; plaintiff has standing to bring an as-applied First Amendment challenge to the City's zoning ordinances where it appeared likely that the City would take action against plaintiff if he opened a tattoo shop without a CUP; plaintiff raised a cognizable claim that the City's zoning ordinances constituted an unlawful prior restraint on speech; and plaintiff raised a cognizable claim that the City's ordinances constituted unlawful time, place, or manner restrictions on speech. Accordingly, the court reversed and remanded for further proceedings. View "Real v. City of Long Beach" on Justia Law

Petitioner, convicted of ten different state criminal charges, appealed the district court's interlocutory orders requiring an Arizona state corrections official to reimburse petitioner for deposition expenses incurred in his pending habeas proceeding under 28 U.S.C. 2254. Determining that it had interlocutory jurisdiction under the collateral order doctrine, the court concluded that the district court could not order a state to reimburse an indigent habeas petitioner for deposition expenses in a section 2254 habeas proceeding when, as here, the state did not request the deposition. Accordingly, the court reversed the relevant orders and remanded for further proceedings to determine whether petitioner could obtain reimbursement under the Criminal Justice Act (CJA), 18 U.S.C. 3006A, from the federal government. View "Copeland v. Ryan" on Justia Law

M.C. filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A), alleging that the district violated the IDEA by (1) failing to adequately document the services provided by a teacher of the visually impaired (TVI), (2) failing to specify the assistive technology (AT) devices provided, and (3) failing to file a response to the due process complaint. The court concluded that the district's failure to adequately document the TVI services and AT devices offered to M.C. violated the IDEA and denied M.C. a free appropriate public education (FAPE); these procedural violations deprived M.C.'s mother of her right to participate in the individualized education program (IEP) process and made it impossible for her to enforce the IEP and evaluate whether the services M.C. received were adequate; and, at the very least, plaintiffs were entitled to have the district draft a proper IEP and receive compensatory education he would have occupied but for the school's violations of the IDEA. Accordingly, the court reversed the judgment and remanded. View "M.C. v. Antelope Valley Union High School District" on Justia Law

The court published an order previously denying the government's motion for a stay of a restraining order pending appeal. The order became moot when this court granted the government's unopposed motion to dismiss its underlying appeal. No party has moved to vacate the published order. The court voted to determine whether it should grant en banc reconsideration in order to vacate the published order denying the stay, and the matter failed to receive a majority of the votes in favor of en banc reconsideration. Therefore, vacatur of the stay was denied. Judge Reinhardt concurred. Judge Bybee, with whom Judges Kozinski, Callahan, Bea, and Ikuta joined, dissented. View "Washington v. Trump" on Justia Law

After plaintiff was acquitted of murder, she filed suit against Detective Karen Thompson and Doe Defendants under 42 U.S.C. 1983, alleging that Thompson violated her constitutional rights to compulsory process and a fair trial by intimidating and attempting to dissuade a key witness from testifying on behalf of the defense, and that Thompson and Doe Defendants conspired to violate her civil rights by orchestrating criminal charges against the key witness. The district court dismissed for failure to state a claim. The court held that plaintiff adequately alleged misconduct by Thompson that rises to the level of substantial interference with a defense witness in contravention of the Compulsory Process Clause of the Sixth Amendment and the Due Process Clause of the Fourteenth Amendment; plaintiff pleaded a sufficient causal connection between Thompson's misconduct and the witness's unavailability; the fact that plaintiff was eventually acquitted does not render the witness's testimony immaterial, nor does it bar plaintiff's section 1983 action stemming from violations of her rights during the underlying criminal investigation and prosecution; the witness's testimony was material to plaintiff's defense because evidence of third-party culpability would have cast some doubt on the government's evidence at plaintiff's trial; and, likewise, plaintiff sufficiently alleged a plausible claim for civil conspiracy. Accordingly, the court reversed and remanded. View "Park v. Thompson" on Justia Law