Justia Civil Rights Opinion Summaries

An Arab American faculty member began working at a university as an adjunct instructor and later held a term faculty position. In April 2017, he and another faculty member were informed that their contracts would not be renewed due to budget constraints. Around the same time, the university received a letter from an attorney alleging that the faculty member had engaged in repeated acts of sexual misconduct with a student. The university’s Title IX coordinator initiated an investigation, during which the faculty member admitted to a sexual relationship with the student but claimed it was consensual and began after she was no longer his student. The student did not participate in the investigation, and the coordinator found insufficient evidence of misconduct. The department chair and the faculty member discussed his possible reappointment as an adjunct, but after the student filed a lawsuit alleging sexual harassment and other misconduct, the university decided not to hire him as an adjunct, citing low course enrollment, his compensation request, and the lawsuit. A second investigation was launched, and this time the coordinator found, by a preponderance of the evidence, that the faculty member had sexually harassed the student. The university then deemed him ineligible for future employment.The faculty member sued the university and two former employees in the United States District Court for the Northern District of Illinois, alleging racial discrimination under 42 U.S.C. § 1981, among other claims. The district court dismissed his other claims and granted summary judgment to the university on the § 1981 claim, finding that the university had provided legitimate, nondiscriminatory reasons for its actions and that the faculty member had not shown these reasons were pretext for racial discrimination.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Seventh Circuit held that the faculty member failed to present evidence that the university’s stated reasons for its employment decisions were pretext for racial discrimination. View "Saud v DePaul University" on Justia Law

Amy Hadley’s home in South Bend, Indiana, was significantly damaged when law enforcement officers executed a search warrant in pursuit of a murder suspect they believed was inside her residence. The officers, acting on information that the suspect had accessed his Facebook account from Hadley’s IP address, obtained a warrant and forcefully entered the home, causing extensive property damage, including the use of tear gas and destruction of personal items. Hadley, who had no connection to the suspect, was denied compensation by both the City of South Bend and St. Joseph County for the $16,000 in damages.After her request for compensation was denied, Hadley filed suit in Indiana state court, seeking relief under 42 U.S.C. § 1983 for violations of her Fifth and Fourteenth Amendment rights, specifically invoking the Takings Clause. The case was removed to the United States District Court for the Northern District of Indiana, South Bend Division. The defendants moved to dismiss, arguing that Seventh Circuit precedent, particularly Johnson v. Manitowoc County, foreclosed her claim. The district court agreed and dismissed the complaint, finding that the Takings Clause did not entitle her to compensation for property damage resulting from the execution of a lawful search warrant.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that, under its precedent in Johnson v. Manitowoc County, the Fifth Amendment does not require the government to compensate property owners for damage caused by law enforcement executing a valid search warrant. The court declined to overrule Johnson and found that Hadley’s arguments did not warrant revisiting the established rule. View "Hadley v. City of South Bend" on Justia Law

Patrick Jones Jr. was hired as a probationary deputy sheriff by the Lake County Sheriff’s Office and sent to a police training academy. During his training, Jones obtained a document from his girlfriend, believing it to be a study guide, and offered to share it with classmates. The document was actually a cheat sheet for a prior version of the Illinois state law enforcement exam. After an investigation by the training institute, which concluded Jones likely did not understand the document’s true nature, the Sheriff’s Office nonetheless terminated his employment. The termination letter, authored by Undersheriff Lawrence Oliver, cited Jones’s conduct as violating the office’s code of conduct and was distributed internally and to the office’s Merit Commission. Jones later struggled to find new law enforcement employment, attributing this difficulty to the termination letter.Jones filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the termination letter was defamatory and that it deprived him of occupational liberty in violation of the Fourteenth Amendment. The district court granted summary judgment for the Sheriff’s Office and Undersheriff Oliver, finding that Jones failed to show it was virtually impossible for him to find new employment and that the statements in the letter were either true or opinion, and that Oliver was entitled to absolute immunity under Illinois law.The United States Court of Appeals for the Seventh Circuit affirmed. The court held that the Sheriff’s Office was not a proper defendant under 42 U.S.C. § 1983 because Jones did not allege a policy or custom as required for municipal liability. The court further held that Jones’s occupational liberty claim failed because there was no evidence that Undersheriff Oliver publicly disclosed the termination letter. Finally, the court held that Undersheriff Oliver was entitled to absolute immunity under Illinois law for statements made within the scope of his official duties. View "Jones v. Lake County Sheriff's Office" on Justia Law

Rodriquez D’Aundre Pam was shot and killed by Evansville police officers responding to a 911 call reporting that a man matching Pam’s description was in a backyard with a handgun, allegedly pointing it at a dog and at the caller. Officers arrived, encountered Pam on the property, and repeatedly ordered him to show his hands and get on the ground. Pam did not comply, appeared to reach for the doorknob, then moved along the house, put his hands in his pockets, and removed them when ordered. As officers continued to issue commands, Pam raised his left hand and kept his right hand at his side. Officers then fired multiple shots, killing him. A handgun was found near Pam’s body. Body camera footage captured the incident, but the video was unclear as to whether Pam was holding a gun at the moment he was shot.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the officers, finding it undisputed that Pam pointed a gun at them before they fired. Pam’s estate appealed, challenging the grant of summary judgment for Officers Offerman and McQuay.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering the evidence in the light most favorable to the estate. The court found that, while the video did not conclusively show Pam pointing a gun, the officers’ belief that Pam was threatening them with a firearm was objectively reasonable given the circumstances, including the 911 report, Pam’s actions, and the recovery of a gun. The Seventh Circuit held that the officers were entitled to qualified immunity because their perception and response did not violate clearly established law. The court affirmed the district court’s grant of summary judgment. View "Pam v. City of Evansville" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law

Chicago police officers responded to an anonymous tip alleging animal abuse at a property where Vaughn Neita kept his dog, Macy. Upon arrival, the officers found Macy tethered outside in cold weather, inside a plywood doghouse with a heater and bowls. The officers observed Macy for about twenty minutes, noting she appeared healthy and playful, but claimed her bowls were empty or contained frozen water. Neita arrived during the investigation, identified himself as Macy’s owner, and explained he had left Macy outside briefly. The officers arrested Neita for animal abuse and impounded Macy. Neita was charged in the Circuit Court of Cook County with violating two provisions of the Illinois Humane Care for Animals Act, but after a bench trial, the court found no evidence of neglect or abuse and entered a directed finding in Neita’s favor.Neita then filed a civil suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the City of Chicago and the officers, alleging false arrest, illegal search and seizure, malicious prosecution, and related claims under federal and state law. The district court dismissed some claims, including federal malicious prosecution, and later granted summary judgment to the defendants on the remaining federal claims, finding the officers had at least arguable probable cause and were entitled to qualified immunity. The court also declined to sanction the defendants for discovery delays and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s discovery rulings and dismissal of the federal malicious prosecution claim. However, it reversed the grant of summary judgment on qualified immunity, holding that genuine issues of material fact remained as to whether the officers had even arguable probable cause to arrest Neita and seize Macy. The case was remanded for further proceedings on Neita’s revived federal and state claims. View "Neita v. City of Chicago" on Justia Law

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal.After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

The plaintiff, an Illinois prisoner, was involved in a physical altercation with several correctional officers at Stateville Correctional Center. Following the incident, he was transferred to Pontiac Correctional Center, where he received medical treatment. He was issued a disciplinary ticket for a major infraction, which led to an adjustment committee hearing at Pontiac. At the hearing, he was allowed to present his side but was not permitted to call witnesses or view video evidence. The committee recommended several disciplinary measures, including three months of solitary confinement in conditions the plaintiff later described as appalling, with unsanitary and unsafe features.The plaintiff filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the disciplinary committee members and the warden violated his Fourteenth Amendment rights by imposing solitary confinement without sufficient procedural protections. The defendants moved for summary judgment, arguing that the plaintiff had not established a protected liberty interest, had not shown inadequate procedures, and that they were entitled to qualified immunity. The district court granted summary judgment for the defendants, finding that three months in segregation, even with harsh conditions, did not amount to a deprivation of a liberty interest protected by due process.On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s conclusion regarding the liberty interest, holding that the plaintiff’s evidence of three months in unusually harsh and unsanitary solitary confinement raised a genuine issue of material fact about deprivation of a protected liberty interest. However, the Seventh Circuit affirmed the judgment for the defendants, holding that they were entitled to qualified immunity because the law was not clearly established at the time of the plaintiff’s confinement. The court clarified that, going forward, short terms of solitary confinement combined with comparably harsh conditions will suffice to show a protected liberty interest requiring procedural protections. View "Jackson v. Anastacio" on Justia Law

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

A high school student sought to establish a pro-life student club at her public high school. The school promptly approved the club after she followed the required procedures, including securing a faculty sponsor and submitting a club questionnaire. The student actively promoted the club at the school’s activities fair, wearing pro-life apparel and displaying related signs. The dispute arose when the student submitted flyers containing political slogans and images for posting on school walls. Administrators instructed her to revise the flyers to comply with the school’s neutral content policy, which limited flyers to the club’s name and meeting details and excluded political content. Instead of revising the flyers, the student and her mother approached another administrator to seek approval, which led the principal to suspend the club’s status for the semester, citing concerns that the club was no longer student-led and that established procedures had been violated. The student was allowed to reapply, and the club was later reinstated.The student and her parents filed suit in the United States District Court for the Southern District of Indiana, alleging violations of the First Amendment and the Equal Access Act, claiming that the rejection of the flyers and the club’s suspension were motivated by hostility to her pro-life views. The district court granted summary judgment to the school district and officials, finding no constitutional or statutory violations.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the school’s restriction on political content in student club flyers was a reasonable, viewpoint-neutral policy related to legitimate pedagogical concerns under Hazelwood School District v. Kuhlmeier. The court also found that the temporary suspension of the club was based on neutral, conduct-related reasons and not on the student’s viewpoint. The court further held that there was no violation of the Equal Access Act and that the plaintiffs had not preserved a separate claim regarding the flyers under that statute. View "E.D. v Noblesville School District" on Justia Law