Justia Civil Rights Opinion Summaries

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law

Donovan Lewis, a twenty-year-old Black man, was fatally shot by a Columbus police officer while in bed at his apartment during an attempted arrest on outstanding warrants. His estate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Columbus and the police chief, alleging that the city’s police department maintained a policy or custom of racially discriminatory policing and excessive force, which led to Lewis’s death. The complaint sought damages and permanent injunctive relief, including specific reforms to police disciplinary and employment practices that were rooted in the collective bargaining agreement (CBA) negotiated by the Fraternal Order of Police (FOP), Capitol City Lodge #9.After the estate initiated the suit, FOP moved to intervene as of right or, alternatively, permissively, arguing that the proposed reforms would violate the CBA and impact its legal obligations as the exclusive bargaining representative for Columbus police officers. The United States District Court for the Southern District of Ohio denied FOP’s motion without prejudice, finding that FOP had only a limited interest in the remedial phase and that any liability-phase interest was adequately represented by the City. The court invited FOP to renew its motion if the estate prevailed or if settlement discussions occurred.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of intervention. The Sixth Circuit held that FOP satisfied all requirements for intervention as of right under Federal Rule of Civil Procedure 24(a)(2): FOP demonstrated a substantial legal interest in the subject matter, impairment of its interests absent intervention, and that the City may not adequately represent those interests. The court concluded that FOP should be allowed to intervene in all phases of the litigation and reversed the district court’s denial of intervention. View "Estate of Lewis v. City of Columbus, Ohio" on Justia Law

A police dispatcher who worked for a Michigan city alleged that she and other female dispatchers were required to conduct searches of female arrestees, even when female officers were available, exposing them to health and safety risks. The department did not have a similar policy for male dispatchers. In 2020, the dispatcher and several colleagues filed a lawsuit alleging sex discrimination. Eleven days after filing, the dispatcher became the subject of an Internal Affairs investigation, which ultimately led to her termination for violating department policy by using a case-management system for personal reasons. She later settled with the department, resulting in her reinstatement with a demotion, suspension, and loss of promotion eligibility.Following these events, the dispatcher filed a second lawsuit in the United States District Court for the Eastern District of Michigan, claiming that the city and its police commissioner retaliated against her for exercising her First Amendment rights by filing the original lawsuit. She also brought a claim under Michigan’s Elliott-Larsen Civil Rights Act. The district court granted summary judgment to the city on the retaliation claim, finding no municipal liability, but denied summary judgment to the commissioner in his individual capacity, holding that there was a genuine issue of material fact regarding causation. The commissioner appealed, asserting qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that the dispatcher alleged legally cognizable adverse actions and that her right to be free from retaliation for protected speech was clearly established. The court affirmed the district court’s denial of qualified immunity to the commissioner and dismissed the remainder of the appeal for lack of appellate jurisdiction over factual disputes. The court declined to exercise pendent appellate jurisdiction over the state-law claims. View "DeVooght v. City of Warren" on Justia Law

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

A former correctional officer with the Michigan Department of Corrections was terminated after a coworker accused him of making harassing and inappropriate comments. The officer, after being served with a misconduct charge and attending a disciplinary conference with his union representative, was formally terminated in July 2019. He challenged his termination through arbitration, which concluded in December 2020 with a decision upholding his dismissal. Nearly three years later, he filed a federal lawsuit against two department officials, alleging violations of his constitutional rights under 42 U.S.C. § 1983, specifically focusing on procedural due process.The United States District Court for the Western District of Michigan initially dismissed the officer’s first complaint without prejudice for lack of prosecution after he failed to respond to a motion to dismiss. When he refiled a similar complaint, the district court dismissed it again, this time on the grounds that the claim was untimely under Michigan’s three-year statute of limitations for personal injury actions and that, except for his procedural due process claim, he had forfeited his other constitutional arguments. The court also found that his procedural due process claim failed to state a claim upon which relief could be granted.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the officer’s procedural due process claim accrued, at the latest, on the date of his post-termination arbitration hearing in December 2020, making his June 2024 complaint untimely. The court further held that Michigan law does not permit equitable tolling of the statute of limitations in this context and that the officer failed to plausibly allege inadequate process either before or after his termination. The Sixth Circuit affirmed the district court’s dismissal. View "Bozzo v. Nanasy" on Justia Law

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law

Five University of Kentucky football players attended a fraternity party where they were subjected to racial slurs and, in some cases, physical assault by attendees. After the incident, a fraternity member called the police and accused the players of assault and burglary, claiming they brandished weapons. Detective Cory Vinlove led the investigation and, despite evidence suggesting the players were victims, allegedly fabricated information to support criminal charges against them. The university cleared the players of wrongdoing, but Vinlove proceeded with charges, and a police press release publicized the allegations. Ultimately, a grand jury declined to indict the players, but the negative publicity had already damaged their reputations and careers.The players filed lawsuits in the United States District Court for the Eastern District of Kentucky against Vinlove, Sergeant Donnell Gordon, Police Chief Lawrence Weathers, and the Lexington-Fayette Urban County Government, asserting federal claims under 42 U.S.C. § 1983 (including malicious prosecution and fabrication of evidence) and various state-law claims. The district court consolidated the cases and granted the defendants’ motion to dismiss all claims except a state-law malicious prosecution claim against Vinlove. The court found that the plaintiffs had not alleged a deprivation of liberty under the Fourth Amendment, as required for their federal claims, and that the state-law claims were inadequately pled. The court later dismissed the remaining state-law claim for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the plaintiffs failed to allege a deprivation of liberty under the Fourth Amendment, as they were not arrested, detained, or subject to pretrial restrictions. The court also held that the press release was absolutely privileged under Kentucky law, defeating the defamation claim, and that the plaintiffs did not sufficiently allege that Gordon or Weathers initiated or continued the prosecution, defeating the state-law malicious prosecution claim. View "Adams v. Lexington-Fayette Urban County Gov't" on Justia Law

A prisoner at a Michigan correctional facility was involved in a physical altercation with another inmate, after which he was subdued and handcuffed by corrections officers. Two officers then escorted him through a hallway and into a prison yard. Upon entering the yard, the officers performed a takedown maneuver, throwing the prisoner to the ground and fracturing his foot. The prisoner claimed he did not resist or act aggressively before the takedown, while the officers asserted that he had lunged away, prompting their response. Surveillance footage captured much of the incident, but some key moments were obscured or unclear. The prisoner suffered significant injury as a result of the takedown.Following the incident, a prison misconduct hearing was held, and the hearing officer found the prisoner guilty of assaulting staff, relying heavily on the video evidence, which the prisoner was not permitted to view. The prisoner did not seek judicial review of this administrative finding. He then filed a lawsuit in the United States District Court for the Eastern District of Michigan under 42 U.S.C. § 1983, alleging excessive force in violation of the Eighth Amendment. The district court granted summary judgment to the officers, holding they were entitled to qualified immunity. The court reasoned that the hearing officer’s factual findings should have preclusive effect and that the video evidence clearly contradicted the prisoner’s account.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the hearing officer’s findings should not have preclusive effect because the prisoner lacked a full and fair opportunity to litigate the facts, particularly due to his inability to access crucial evidence. The court also found that the video evidence did not so clearly contradict the prisoner’s version as to warrant summary judgment. The court concluded that there was a genuine dispute of material fact regarding whether the officers used excessive force, and that the officers had forfeited the “clearly established” prong of their qualified immunity defense. The case was remanded for further proceedings. View "Nash v. Bryce" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law