Justia Civil Rights Opinion Summaries

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law

Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, she applied for a management position but was passed over in favor of a lesbian woman. Subsequently, Ames was demoted from her role as a program administrator, and a gay man was hired to fill her previous position. Ames filed a lawsuit under Title VII, alleging discrimination based on her sexual orientation.The District Court granted summary judgment to the agency, applying the McDonnell Douglas framework for evaluating disparate-treatment claims. The court held that Ames failed to make a prima facie case of discrimination because she did not show "background circumstances" suggesting the agency discriminated against majority-group members. The Sixth Circuit affirmed, requiring Ames to meet this additional burden as a straight woman.The Supreme Court of the United States reviewed the case. The Court held that the Sixth Circuit's "background circumstances" rule, which imposes a heightened evidentiary standard on majority-group plaintiffs, is inconsistent with Title VII's text and precedents. Title VII prohibits discrimination against any individual based on protected characteristics without distinguishing between majority and minority groups. The Court vacated the judgment and remanded the case for application of the proper prima facie standard under Title VII. View "Ames v. Ohio Department of Youth Services" on Justia Law

Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

The Los Angeles County Sheriff’s Department had information that a potentially armed and dangerous parolee-at-large had been seen at a certain residence. While others searched the main house, deputies searched the property. Unbeknownst to the deputies, Mendez and Garcia were napping inside a shack where they lived. Without a search warrant and without announcing their presence, the deputies opened the shack's door. Mendez rose from the bed, holding a BB gun that he used to kill pests. The deputies shot the men multiple times. In a suit under 42 U.S.C. 1983, the court awarded nominal damages on warrantless entry and knock-and-announce claims. The court found the use of force reasonable, but cited a Ninth Circuit rule, which makes an otherwise reasonable use of force unreasonable if the officer “intentionally or recklessly provokes a violent confrontation” and “the provocation is an independent Fourth Amendment violation. The Ninth Circuit held that the officers were entitled to qualified immunity on the knock-and-announce claim; that the warrantless entry violated clearly established law; and that the provocation rule applied. The Supreme Court vacated. There is a settled, exclusive framework for analyzing whether the force used in making a seizure complies with the Fourth Amendment: “whether the totality of the circumstances justifie[s] a particular sort of search or seizure.” The provocation rule instructs courts to look back to see if a different Fourth Amendment violation was somehow tied to the eventual use of force, mistakenly and unnecessarily conflating distinct Fourth Amendment claims that should be analyzed separately. If plaintiffs cannot recover on their excessive force claim, that will not foreclose recovery for injuries proximately caused by the warrantless entry. View "County of Los Angeles v. Mendez" on Justia Law

A city is an “aggrieved person,” authorized to bring suit under the Fair Housing Act (FHA), according to the Supreme Court. The City of Miami sued Bank of America and Wells Fargo, alleging violations of the FHA prohibition of racial discrimination in connection with real-estate transactions, 42 U.S.C. 3604(b), 3605(a). The city claimed that the banks intentionally targeted predatory practices at African-American and Latino neighborhoods and residents, lending to minority borrowers on worse terms than equally creditworthy nonminority borrowers and inducing defaults by failing to extend refinancing and loan modifications to minority borrowers on fair terms, resulting in a disproportionate number of foreclosures and vacancies, impairing municipal effort to assure racial integration, diminishing property-tax revenue, and increasing demand for police, fire, and other municipal services. The Court reasoned that those claims of financial injury are “arguably within the zone of interests” the FHA protects. In remanding the case, the Court stated that the Eleventh Circuit erred in concluding that the complaints met the FHA’s proximate-cause requirement based solely on a finding that the alleged financial injuries were foreseeable results of the banks’ misconduct. Foreseeability alone does not ensure the required close connection to the prohibited conduct. Proximate cause under the FHA requires “some direct relation between the injury asserted and the injurious conduct alleged,” considering the “nature of the statutory cause of action,” and an assessment “of what is administratively possible and convenient.” View "Bank of America Corp. v. Miami" on Justia Law

Nelson, convicted of felonies and misdemeanors arising from the alleged abuse of her children, was sentenced to prison and ordered to pay $8,192.50 in court costs, fees, and restitution. Nelson’s conviction was reversed; on retrial, she was acquitted. Madden was also convicted by a Colorado jury. The court imposed a prison sentence and ordered him to pay $4,413.00 in costs, fees, and restitution. Madden’s convictions were reversed and vacated; the state did not appeal or retry the case. The Colorado Department of Corrections withheld $702.10 from Nelson’s inmate account between her conviction and acquittal. Madden paid the state $1,977.75 after his conviction. Once their convictions were invalidated, they sought refunds. The Colorado Supreme Court reasoned that Colorado’s Exoneration Act provided the exclusive authority for refunds and that neither petitioner had filed a claim under that Act; the court also upheld the constitutionality of the Act, which permits Colorado to retain conviction-related assessments until the prevailing defendant institutes a discrete civil proceeding and proves her innocence by clear and convincing evidence. The Supreme Court reversed. The Act’s scheme violates the guarantee of due process. Petitioners have an obvious interest in regaining the money. The state may not retain these funds simply because their convictions were in place when the funds were taken; once the convictions were erased, the presumption of innocence was restored. Colorado may not presume a person, adjudged guilty of no crime, guilty enough for monetary exactions. Colorado’s scheme creates an unacceptable risk of the erroneous deprivation of defendants’ property, conditioning refunds on proof of innocence by clear and convincing evidence, while defendants in petitioners’ position are presumed innocent. When the amount sought is not large, the cost of pursuing a claim under the Act would be prohibitive. Colorado has no equitable interest in withholding petitioners’ money. View "Nelson v. Colorado" on Justia Law

Moore was convicted of capital murder and sentenced to death for shooting a clerk during a robbery that occurred when Moore was 20 years old. A state habeas court determined that, under Supreme Court precedent, Moore was intellectually disabled and that his death sentence violated the Eighth Amendment. The court consulted the 11th edition of the American Association on Intellectual and Developmental Disabilities clinical manual (AAIDD–11) and the 5th edition of the Diagnostic and Statistical Manual of Mental Disorders and followed the generally accepted intellectual-disability definition, considering: intellectual-functioning deficits, adaptive deficits, and the onset of these deficits while a minor. The court credited six IQ scores, the average of which (70.66) indicated mild intellectual disability. Based on testimony from mental-health professionals, the court found significant adaptive deficits in all three skill sets (conceptual, social, and practical). The Texas Court of Criminal Appeals (CCA) declined the recommendation, concluding that the habeas court should have used standards for assessing intellectual disability contained in AAMR–9 and its requirement that adaptive deficits be “related” to intellectual-functioning deficits. The Supreme Court vacated. While precedent leaves to the states “the task of developing appropriate ways to enforce” the restriction on executing the intellectually disabled, that discretion is not “unfettered,” and must be “informed by the medical community’s diagnostic framework.” When an IQ score is close to, but above, 70, courts must account for the “standard error of measurement.” The CCA overemphasized Moore’s perceived adaptive strengths—living on the streets, mowing lawns, and playing pool for money—when the medical community focuses on adaptive deficits. The CCA stressed Moore’s improved behavior in prison; clinicians caution against reliance on adaptive strengths developed in controlled settings. The CCA concluded that Moore’s record of academic failure, with a history of childhood abuse and suffering, detracted from a determination that his intellectual and adaptive deficits were related; the medical community counts traumatic experiences as risk factors for intellectual disability. The CCA also departed from clinical practice by requiring Moore to show that his adaptive deficits were not related to “a personality disorder.” View "Moore v. Texas" on Justia Law