Justia Civil Rights Opinion Summaries

Defendant, a mobility‐impaired inmate who suffers from cerebral palsy and scoliosis, filed suit against DOCCS under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act (RA), 29 U.S.C. 794, seeking declaratory and injunctive relief allowing him to use his motorized wheelchair within DOCCS facilities. The court held that the district court erred by granting summary judgment in favor of DOCCS because there is a genuine dispute of material fact as to whether the mobility assistance program provides plaintiff meaningful access to DOCCS services and as to whether allowing him the use of his motorized wheelchair would unduly burden DOCCS. The court also held that DOCCS’s blanket ban on motorized wheelchairs - without an individualized inquiry into the risks of allowing a mobility‐impaired inmate to use his or her motorized wheelchair - violates the ADA and the RA. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings. View "Wright v. New York State Dep’t of Corr." on Justia Law

Plaintiff filed suit against Officer Priatno and Gammone under 42 U.S.C. 1983, alleging that the officers violated his Eighth Amendment rights when they brutally beat him for talking back to another officer when he was an inmate at Downstate Correctional Facility. At issue is whether plaintiff exhausted all available administrative remedies prior to filing suit in the district court, as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). The court concluded that the prison's grievance process was not available to plaintiff because the applicable grievance procedures are “so opaque” and confusing that they were, “practically speaking, incapable of use.” Because plaintiff satisfied the PLRA's exhaustion requirement, the court reversed and remanded. View "Williams v. Correction Officer Priatno" on Justia Law

Plaintiff filed suit against NYCHA, alleging that its decision not to hire her as a bricklayer was sex-based and thus violated Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; the New York State Human Rights Law (NYSHRL); and the New York City Human Rights Law (NYCHRL). The district court granted summary judgment to NYCHA as to the Title VII and NYSHRL claims. The district court declined to exercise supplemental jurisdiction over the NYCHRL claim and dismissed it without prejudice. The court concluded that the district court erred when it failed to view plaintiff’s evidence as a whole and instead set aside each piece of evidence after deeming it insufficient to create a triable issue of fact that NYCHA’s refusal to hire her was based in part on the fact that she is female. In this case, plaintiff has proffered evidence that - when viewed as a whole - is sufficient to permit a rational finder of fact to infer that NYCHA’s decision not to hire her was more likely than not motivated in part by sex-based discrimination. Accordingly, the court vacated and remanded for further proceedings. View "Walsh v. NYCHA" on Justia Law

Plaintiffs filed suit against the Town alleging claims under the Fair Housing Act (FHA), Title VIII of the Civil Rights Act of 1968, as amended 42 U.S.C. 3601 et seq. Plaintiff obtained limited variances from a land-use regulation prohibiting accessory structures on the lot of their newly purchased home, allowing plaintiffs to install a fence, pool, and deck designed to accommodate their son's disability. The Town Board’s resolutions allowing the variances required removal of the structures when, inter alia, the disabled child’s residency in the house terminated (Restoration Provision). The district court dismissed the complaint under FRCP 12(b)(6). The district court determined that it did not need to reach the issue of whether the Restoration Provisions were reasonable under the FHA because plaintiffs’ complaint did not allege facts sufficient to show either an intent to discriminate or to constitute disparate impact discrimination. The court concluded, however, that the reasonableness of the Town’s accommodations is in issue. The reasonableness issue here cannot be determined on the pleadings because the relevant factors are numerous and balancing them requires a full evidentiary record. Therefore, the court vacated the district court's dismissal as to this issue. The court affirmed as to the dismissal of plaintiffs' retaliation claim where the Restoration Provisions on their face simply restore the requirements applicable to all such properties in the area once the needs of plaintiff's disabled child are not an issue. View "Austin v. Town of Farmington" on Justia Law

Plaintiff filed suit asserting claims for violation of his First Amendment rights under Bivens v. Six Unknown Named Agents, and for false imprisonment and negligence under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b), 2671–2680. Plaintiff alleged that he was placed in solitary confinement in retaliation for publishing an on-line article. The court concluded that, in light of the different interests at stake, the court's case law establishing a prisoner’s right to file a lawsuit or grievance does not clearly establish a prisoner’s right to publish an article under a byline. Therefore, the court held that Defendant Rivers, a BOP employee, is entitled to qualified immunity from the Bivens claim and did not reach the question of whether Rivers violated plaintiff's First Amendment rights. The court also concluded that the district court correctly dismissed plaintiff’s negligence claim on the ground that it lacks a private analogue. Accordingly, the court affirmed the judgment. View "McGowan v. United States" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and state law for false arrest, excessive force, assault, failure to intervene, and unlawful entry. The district court granted summary judgment as to the claims of unlawful entry and the other claims were tried to a jury. After a verdict in favor of plaintiff on the remaining counts, the district court granted judgment for defendants under Fed. R. Civ. Pro. 50(b). The court agreed with the district court's disposition of plaintiff’s false arrest claims. Because the trial record establishes that a reasonable law enforcement officer could have concluded that there existed probable cause to arrest plaintiff, defendants can claim the protection of qualified immunity. The court concluded that the force used in effecting plaintiff’s arrest was reasonable as a matter of law, and found no error in the district court’s dismissal of unnamed defendants or discovery rulings. Therefore, the court affirmed the judgment insofar as it disposed of plaintiff’s claims for false arrest, excessive force, and assault, dismissed unnamed defendants, and refused to permit further discovery. However, the district court erred in concluding, as a matter of law, that defendants had no realistic opportunity to intervene in an alleged assault on plaintiff by an unidentified police officer and that plaintiff lacked a legitimate expectation of privacy in his mother’s apartment. Accordingly, the court vacated the judgment in regard to the failure-to-intervene and unlawful-entry claims and remanded for further proceedings. View "Figueroa v. Mazza et al." on Justia Law

Defendants appealed the district court's denial of their motion for judgment as a matter of law (JMOL) under Federal Rule of Civil Procedure 50, or alternatively for a new trial under Rule 59, or relief from the judgment under Rule 60(b)(6) on plaintiff's New York State Human Rights Law (NYSHRL) claim. Plaintiff, diagnosed with cancer, cross-appealed the dismissal of her New York City Human Rights Law (NYCHRL) claim. Plaintiff and her husband cross-appealed the dismissal of their Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 116(a), claims. The court held that, because plaintiff did not request a reasonable accommodation prior to her termination, the district court erred in denying defendants’ Rule 50 motion. Therefore, the court reversed that decision and vacated the jury award on the NYSHRL claim. However, the court affirmed the district court's dismissal of plaintiff's NYCHRL claim for lack of subject matter jurisdiction and denial of the COBRA claims on the merits. View "Vangas v. Montefiore Med. Ctr." on Justia Law

Defendant, the former New York State Governor, launched the Sexually Violent Predator Initiative, which provided for the involuntary civil commitment at state psychiatric facilities of some ʺsexually violent predatorsʺ (SVPs) nearing the date of their release from incarceration or supervision. Plaintiffs, six individuals who were civilly committed to a psychiatric hospital, filed suit asserting claims under the Fourth Amendment, the substantive and procedural components of the Fourteenth Amendmentʹs Due Process Clause, the Fourteenth Amendmentʹs Equal Protection Clause, and several provisions of New York state law. The district court concluded that defendants were not entitled to qualified immunity as a matter of law, which the court affirmed on interlocutory appeal. Many of the claims were thereafter dismissed by the district court on judgments as a matter of law, while the remainder were tried to a jury. The jury found one defendant liable for procedural due‐process violations, and awarded each plaintiff one dollar in nominal damages against that defendant. On appeal, plaintiffs Warren and Brooks challenged the district courtʹs (1) jury instruction on personal involvement; (2) denial of judgment as a matter of law on procedural due‐process liability; (3) denial of judgment as a matter of law on plaintiffsʹ entitlement to actual, compensatory damages; (4) entry of judgment for the defendants on the plaintiffsʹ false‐imprisonment claims on the grounds that these claims were duplicative; and (5) limitations on depositions, and several other evidentiary decisions. The court concluded that plaintiffs' arguments lack merit and affirmed the judgment of the district court. View "Warren v. Pataki" on Justia Law

Plaintiff, an inmate at the Attica Correctional Facility, filed suit under 42 U.S.C. 1983, alleging that while he was incarcerated at Attica, defendant corrections officers Dennis Fleckenstein and Chester Kosmowski subjected him to cruel and unusual punishment by depriving him of meals and defendant Fleckenstein physically assaulted him in violation of his Eighth Amendment rights. At trial, the jury found that both defendants violated plaintiff's constitutional right to nutritionally adequate food and awarded him nominal and punitive damages. On appeal, defendants challenged the district court's admission of a prison monitoring report conducted by a private, nonprofit corporation. The court concluded that the report is hearsay that does not fall within the Business Records Exception nor the Public Records Exception. Furthermore, the report was inadmissible because it further contains hearsay in the form of statements from inmates complaining about abuse at Attica. Because admission of the report was not harmless error, the district court abused its discretion in admitting it. Accordingly, the court vacated and remanded for further proceedings. View "Abascal v. Fleckenstein" on Justia Law

Plaintiff, a corrections officer at the Ulster County Jail, filed suit against the County and its officials, alleging that the denial of her request for an accommodation under the County's light duty policy amounted to pregnancy discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., as amended by the Pregnancy Discrimination Act of 1978, 42 U.S.C. 2000e(k). The district court dismissed plaintiff's claim against the County and former Sheriff VanBlarcum. The district court granted defendants’ motion for judgment as a matter of law at the close of plaintiff’s direct case, reasoning that the policy could not be discriminatory because it was facially neutral with respect to pregnancy. While this appeal was pending, the Supreme Court decided Young v. United Parcel Service, Inc., which held that an employer’s facially neutral accommodation policy gives rise to an inference of pregnancy discrimination if it imposes a significant burden on pregnant employees that is not justified by the employer’s non‐discriminatory explanation. In this case, the court concluded that plaintiff has presented sufficient evidence to support a pregnancy discrimination claim under Young and therefore vacated the judgment in part and remanded with instructions to conduct a new trial. The court also vacated the post judgment orders and remanded for further proceedings. View "Legg v. Ulster Cnty." on Justia Law