Justia Civil Rights Opinion Summaries

A sheriff’s deputy responded to a 911 call reporting a domestic dispute at a residence, with allegations that the homeowner had threatened a woman with a gun and grabbed her by the neck. Upon arrival, the deputy encountered three women and a small child outside or in the garage; none appeared injured or in distress. The homeowner stood in the garage doorway, raised his hands when ordered, and denied wrongdoing. When the deputy attempted to handcuff him, the homeowner retreated into his house, resisted being handcuffed, and a physical altercation ensued, during which the deputy punched the homeowner. The deputy ceased his efforts after being told that no gun threat had occurred.The homeowner filed suit under 42 U.S.C. § 1983 in the United States District Court for the Middle District of Tennessee, alleging unlawful entry and excessive force in violation of the Fourth Amendment. Both parties moved for summary judgment. The district court denied summary judgment to the deputy on the unlawful entry and excessive force claims, finding that material factual disputes existed as to whether exigent circumstances justified the warrantless entry and whether the force used was reasonable. The deputy appealed, asserting entitlement to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, viewing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the deputy lacked an objectively reasonable basis for believing exigent circumstances existed to justify a warrantless entry. The court further held that the right to be free from such entry and from force used to effectuate it was clearly established. Because the deputy failed to argue that his use of force was reasonable even if the entry was unlawful, the court affirmed the district court’s denial of summary judgment on both claims. View "Hoover v. Due" on Justia Law

A woman experiencing a mental health crisis called 911 and requested that police come to her home to shoot her. Three officers responded and found her holding a bat and a pickaxe. The officers maintained a distance of about fifteen feet and attempted to de-escalate the situation, with one officer assuring her that she would not be harmed. After several minutes, and following an interaction with the woman’s mother, one officer tased her, and another officer shot her multiple times as she moved in the direction of the officers. The woman survived but suffered severe injuries.The plaintiff, acting on the woman’s behalf, filed suit in the United States District Court for the Middle District of Tennessee against the two officers and the Metropolitan Government of Nashville and Davidson County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment, and also brought a negligence claim against the municipality. The officers moved to dismiss the complaint on qualified immunity grounds, and the municipality sought judgment on the pleadings. The district court granted the officers’ motion to dismiss the excessive force claims and the municipality’s motion on the negligence claim, but initially denied the municipality’s motion as to the § 1983 claim. Later, the district court granted the municipality’s motion for judgment on the pleadings on the § 1983 claim as well.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the complaint plausibly alleged that both officers violated the woman’s clearly established Fourth Amendment rights by tasing and shooting her under the circumstances described. The court also held that the district court erred in dismissing the municipal liability claim. Accordingly, the Sixth Circuit reversed the dismissal of the claims against the officers, vacated the judgment for the municipality, and remanded for further proceedings. View "Chrestman v. Metropolitan Government of Nashville and Davidson County" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

Christina Henry, a Licensed Practical Nurse at Southern Ohio Medical Center (SOMC), refused to comply with SOMC’s COVID-19 policy requiring either vaccination or weekly nasopharyngeal testing, citing religious objections. SOMC granted her a religious exemption from vaccination but denied her request for an exemption from all forms of COVID testing. Henry maintained that her religious beliefs prohibited her from undergoing any COVID test, including non-invasive methods, and proposed self-screening as an alternative. After continued refusal to test or vaccinate, SOMC placed her on unpaid leave. Henry did not request alternative testing methods during her leave and later declined to return to SOMC after the testing requirement was lifted.The United States District Court for the Southern District of Ohio granted summary judgment in favor of SOMC. The court found that Henry’s communications to SOMC indicated she sought exemption from all COVID testing, not just nasopharyngeal testing. It held that accommodating her request would impose an undue hardship on SOMC by endangering vulnerable patient populations. The court also determined that even if Henry had requested saliva testing, this would still constitute an undue hardship due to delays in obtaining test results and reduced effectiveness. Additionally, the court found that Henry failed to show SOMC’s stated reasons for placing her on unpaid leave were pretextual.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that Henry did not provide sufficient notice to SOMC of a limited objection to only certain types of testing and that either exempting her from all testing or providing saliva testing would impose an undue hardship on SOMC. The court also held that Henry failed to establish pretext in her retaliation claim. View "Henry v. Southern Ohio Medical Center" on Justia Law

Ulysses Feagin was involved in a police encounter after driving erratically, nearly causing a collision with a marked police cruiser, and subsequently leading officers on a brief pursuit. Upon stopping in a parking lot, Feagin ignored repeated commands to exit his vehicle, rolled up the windows, and appeared to reach toward the center console. When officers attempted to remove him, bullets fell from his pocket, and he physically resisted their efforts. Officer Moore deployed a taser to subdue Feagin, who was then handcuffed and placed in a police cruiser. While detained, Feagin continued to resist by kicking the cruiser’s window, prompting Moore to use pepper spray. A subsequent search of Feagin’s vehicle revealed drugs and firearms, leading to his conviction on multiple charges.The United States District Court for the Northern District of Ohio granted summary judgment to the defendants on most claims but denied it on two: Feagin’s excessive force claim related to the use of a taser and his deliberate indifference claim regarding medical care after being pepper sprayed. The district court found a genuine dispute over whether Feagin’s resistance was active or passive at the time of the tasing, but granted summary judgment on the pepper spray claim, citing Feagin’s continued resistance. The deliberate indifference claim was set for trial because defendants had not moved for summary judgment on that issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit reversed the denial of qualified immunity for the excessive force claim, holding that Officer Moore’s use of a taser was reasonable under the circumstances and did not violate clearly established law. The court dismissed the appeal regarding the deliberate indifference claim for lack of jurisdiction, as the issue had not been raised below, and remanded the case for further proceedings. View "Feagin v. Mansfield Police Dep't" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

A physician assistant employed by a Michigan hospital, later affiliated with the University of Michigan Health System, was terminated after she refused, on religious and medical grounds, to use gender identity-based pronouns or refer patients for gender reassignment procedures. The hospital had required her to complete training on serving LGBTQ+ patients, which she believed conflicted with her Christian faith and medical judgment. After seeking a religious accommodation and participating in meetings with hospital administrators, she was fired for her refusal to comply with the hospital’s requirements.She filed suit in the United States District Court for the Western District of Michigan against the hospital and several administrators, alleging violations of federal constitutional rights under 42 U.S.C. § 1983, Title VII, and Michigan law. The hospital and its administrators moved to dismiss all claims on the merits, and the district court granted the motion in part and denied it in part, allowing several of her claims to proceed. Only after this partial denial, and more than a year into the litigation, did the hospital invoke an arbitration clause from her employment agreement and move to compel arbitration. The district court granted this motion, found the arbitration clause enforceable, and dismissed the case in favor of arbitration.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the hospital had forfeited its right to arbitrate by substantially litigating the case before seeking arbitration. The Sixth Circuit held that the hospital’s conduct—seeking a complete judicial victory on the merits before invoking arbitration—was inconsistent with the right to arbitrate and constituted “default” under the Federal Arbitration Act. The court reversed the district court’s order compelling arbitration and remanded the case for further proceedings. View "Kloosterman v. Metropolitan Hospital" on Justia Law

A woman who had been living with a couple in Tennessee returned to their home to collect her belongings after being told she could no longer stay there. A dispute arose over the ownership of a car parked at the residence. The woman alleged that one of the residents, Matthew Howell, pointed a gun at her and refused to let her retrieve the car. She called 911, reporting the incident and stating that Howell was intoxicated and had threatened her. When police arrived, they spoke with the woman, who reiterated her allegations. Officers knocked on the door, and upon Howell opening it, they detected the smell of marijuana. The officers entered the home, arrested Howell for aggravated assault and resisting a frisk, and temporarily handcuffed his girlfriend, Alisha Brown, while conducting a protective sweep. The officers also allowed the woman to access the disputed car.Howell was indicted by a Tennessee grand jury for aggravated assault and resisting arrest. At trial, the jury convicted him of reckless aggravated assault, but the conviction was later amended to simple assault and ultimately reversed on double jeopardy grounds by an appellate court. Meanwhile, Howell and Brown filed a civil suit in the United States District Court for the Middle District of Tennessee, alleging Fourth Amendment violations and state tort claims against the officers and the Metropolitan Government of Nashville and Davidson County. The district court granted summary judgment to the defendants on the federal claims and declined to exercise jurisdiction over the state claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the officers were entitled to qualified immunity on all federal claims. It found that the officers’ warrantless entry was not clearly established as unconstitutional under existing precedent, that probable cause supported Howell’s arrest, and that Brown’s temporary detention did not violate clearly established law. The court also found no clearly established law prohibiting the officers’ actions regarding the disputed car and rejected the malicious prosecution claim. The court affirmed summary judgment for the officers and municipality. View "Howell v. McCormick" on Justia Law

A student, C.M., experienced repeated racial harassment by peers while attending public school in Michigan, including being subjected to racial slurs, threats, and physical assault. The harassment occurred during her sixth, seventh, and ninth grades, prompting her to transfer to another school district in her freshman year. C.M. and her parents alleged that the school district and its officials failed to adequately respond to her complaints, asserting violations of federal law (Title VI of the Civil Rights Act and the Equal Protection Clause) and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Eastern District of Michigan reviewed the case and granted summary judgment in favor of the school district and its officials. The district court found that, even when viewing the facts in the light most favorable to C.M., the school’s responses to the reported incidents did not amount to deliberate indifference under the applicable legal standards. C.M. appealed this decision to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court assumed, without deciding, that deliberate indifference claims are cognizable under Title VI for student-on-student racial harassment. Applying the deliberate indifference standard, the court held that the school’s responses to each reported incident were not clearly unreasonable and reflected good faith efforts, including investigations, disciplinary actions, and proactive measures. The court concluded that C.M. failed to establish deliberate indifference, and therefore her claims under Title VI, the Equal Protection Clause, and the Elliott-Larsen Civil Rights Act could not succeed. The judgment of the district court was affirmed. View "Malick v. Croswell-Lexington Dist. Schs." on Justia Law

Michael and Susan Mockeridge purchased a remote 40-acre property in northern Michigan, where they installed five prefabricated mini-cabins near their main cabin for family use. After neighbors became concerned that the property was being operated as a public campground, they filed complaints with local authorities. In response, three government officials—Harry Harvey, David Schmidt, and Kenneth Gibson—entered the Mockeridges’ property without a warrant or consent, inspected the mini-cabins and their surroundings, and gathered information regarding potential code violations. The officials’ entry was not via the customary driveway but through adjacent private land and dense woods, and at the time, the cabins were unoccupied.The Mockeridges subsequently received a letter from the county classifying their property as a campground and requiring licensing. After applying for permits and being told they would face penalties for prior unpermitted work, the Mockeridges filed suit in the United States District Court for the Eastern District of Michigan, alleging a violation of their Fourth Amendment rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of the Mockeridges on liability, denied qualified immunity to the officials, and found the only remaining issue was damages. The officials appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that the officials’ warrantless entry into the curtilage of the Mockeridges’ mini-cabins for the purpose of gathering information about code compliance constituted an unreasonable search under the Fourth Amendment. The court further held that the right to be free from such a warrantless search was clearly established at the time of the officials’ conduct. The court dismissed the Mockeridges’ cross-appeal and denied as moot a motion by Alcona County. View "Mockeridge v. Harvey" on Justia Law