Justia Civil Rights Opinion Summaries

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

Sean Hart and Tiffany Guzman filed a lawsuit against the City of Grand Rapids and three police officers, alleging excessive force during a 2020 Black Lives Matter demonstration. Hart and Guzman claimed that the officers used excessive force and that the City ratified this conduct. The officers sought summary judgment based on qualified immunity, and the City argued that the plaintiffs failed to establish municipal liability.The United States District Court for the Western District of Michigan granted summary judgment in favor of the City and the officers, dismissing the federal claims with prejudice and declining jurisdiction over the state claims. The plaintiffs appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment based on qualified immunity for Officer Johnson and Sergeant Bush, finding that the plaintiffs did not show that the officers violated clearly established rights. However, the court reversed the grant of summary judgment for Officer Reinink, determining that a reasonable jury could find that he used excessive force when he fired a Spede-Heat canister at Hart at close range, which could be considered deadly force. The court remanded the case for further proceedings on this claim.The court also affirmed the grant of summary judgment in favor of the City, concluding that the plaintiffs did not provide sufficient evidence to support their claim of municipal liability based on ratification of unconstitutional conduct. The plaintiffs' evidence, a spreadsheet of excessive force complaints, lacked qualitative specifics to show a pattern of inadequate investigations by the City. View "Hart v. City of Grand Rapids, Mich." on Justia Law

Michael Poffenbarger, a First Lieutenant in the Air Force Reserve, filed a lawsuit challenging the Air Force’s COVID-19 vaccine mandate, claiming it violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. He sought a religious exemption, which was denied, and subsequently refused the vaccine. As a result, he received a letter of reprimand and was placed on inactive status, losing pay and retirement points. Poffenbarger sought declaratory and injunctive relief, including restoration of lost pay and points.The United States District Court for the Southern District of Ohio initially granted a preliminary injunction preventing the Air Force from taking further punitive action against Poffenbarger. In a related case, Doster v. Kendall, the same court certified a class of affected service members and issued similar injunctions. The Sixth Circuit affirmed these injunctions, but the Supreme Court later vacated the decision on mootness grounds after Congress directed the rescission of the vaccine mandate. The district court then dismissed Poffenbarger's case as moot.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Poffenbarger’s claim for lost drill pay and retirement points was barred by federal sovereign immunity. The court explained that RFRA’s waiver of sovereign immunity does not unequivocally include claims for money damages against the federal government. Since Poffenbarger’s claim sought retrospective compensation for a previous legal wrong, it constituted money damages, which are not covered by RFRA’s waiver. Consequently, the Sixth Circuit affirmed the district court’s dismissal of the case. View "Poffenbarger v. Kendall" on Justia Law

In 2017, Gratiot County foreclosed on Donald Freed’s home due to unpaid taxes. Freed’s property, valued at $98,800, was sold for $42,000, although he owed just under $1,110. The county kept all proceeds from the sale, as Michigan’s General Property Tax Act (GPTA) did not require returning surplus proceeds to the property owner. Freed sued Gratiot County and its treasurer, Michelle Thomas, under 42 U.S.C. § 1983, claiming a violation of the Fifth and Fourteenth Amendments. Michigan intervened to defend the GPTA’s constitutionality.The United States District Court for the Eastern District of Michigan dismissed Freed’s complaint for lack of subject matter jurisdiction, citing Wayside Church v. Van Buren County. Freed appealed, and the Sixth Circuit reversed the dismissal, recognizing that the Supreme Court’s ruling in Knick v. Township of Scott partially abrogated Wayside Church. On remand, the district court granted partial summary judgment to Freed, affirming that the county had to pay Freed the difference between the foreclosure sale and his debt, but dismissed claims against Thomas due to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed Freed’s entitlement to attorneys’ fees from Gratiot County and Michigan. However, the court vacated the district court’s fee calculation and remanded for further proceedings. The Sixth Circuit held that Freed prevailed against both Gratiot County and Michigan, and Michigan’s intervention under 28 U.S.C. § 2403(b) subjected it to attorneys’ fee liability. The court found the district court’s explanation for reducing Freed’s hours and rate by 35% insufficient and required a more detailed justification for the fee award calculation. View "Freed v. Thomas" on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law

The plaintiff, Percy Brown, alleged that he was framed by University of Louisville Police Officer Jeffrey Jewell and several Louisville Metro Police Department officers for various crimes, including kidnapping, murder, rape, sodomy, and wanton endangerment, after he refused to cooperate in a check-forging investigation. Over more than ten years, the Commonwealth of Kentucky brought and dismissed numerous charges against Brown, resulting in his spending over seven years in prison. After the final indictment was dismissed, Brown filed a lawsuit.The United States District Court for the Western District of Kentucky dismissed Brown's malicious-prosecution claim related to the murder charge as barred by the statute of limitations. The court found that the claim accrued when the murder charge was dismissed on February 24, 2015, and thus was time-barred. The court also granted Jewell’s motion for judgment on the pleadings regarding Brown’s fabrication-of-evidence claim, finding it insufficiently pleaded.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of the malicious-prosecution claim, agreeing that it was time-barred. The court held that the murder charge was separable from the other charges against Brown, which were dismissed later, and thus the statute of limitations for the malicious-prosecution claim related to the murder charge began to run when that charge was dismissed. The court also found that the continuing-violation doctrine did not apply, as the last alleged unlawful act occurred more than a year before Brown filed his lawsuit. Consequently, the Sixth Circuit affirmed the district court's decision. View "Brown v. Louisville-Jefferson County Metro Government" on Justia Law

David Hieber, who led Oakland County’s Equalization Department for nearly twenty years, was terminated after an employee reported him for creating a hostile work environment. Hieber sued Oakland County and his supervisor, Kyle Jen, under 42 U.S.C. § 1983 for deprivation of pretermination and post-termination due process, political-affiliation retaliation, and age discrimination. He also brought state-law claims for defamation and age discrimination. Oakland County and Jen moved for summary judgment, which the district court granted.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of Oakland County and Jen on all claims. Hieber appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment to Oakland County and Jen, in his official capacity, on Hieber’s pretermination due-process claim, finding that there was a genuine dispute of material fact about whether Hieber received a meaningful opportunity to respond to the charges against him. The court affirmed the district court’s judgment on Hieber’s post-termination due-process claim, political-affiliation retaliation claim, age discrimination claims, and defamation claim. The court also affirmed the district court’s grant of qualified immunity to Jen in his individual capacity on the due-process claims.The main holding of the Sixth Circuit was that Hieber’s pretermination due-process rights may have been violated, warranting further proceedings on that claim. The court found that the investigatory interview and the pretermination hearing may not have provided Hieber with adequate notice of the charges and a meaningful opportunity to respond. The court remanded the case for further proceedings consistent with its opinion. View "Hieber v. Oakland County, Mich." on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law