Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the District of Columbia Circuit
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Dr. Jennifer Seed, a former employee of the Environmental Protection Agency (EPA), filed a lawsuit against the EPA and the United States, alleging age discrimination. Seed claimed that she was involuntarily demoted to a junior position as older managers were replaced with younger employees. The district court granted summary judgment in favor of the EPA, concluding that Seed had not provided sufficient evidence to support her claim of age discrimination.The district court's decision was based on its finding that Seed had not provided direct evidence of discriminatory intent that would entitle her to a trial, nor had she provided indirect evidence that would give rise to an inference of discrimination. The court also found that Seed had not shown that she was treated less favorably than younger employees after her reassignment or that her treatment was based on her age.On appeal, the United States Court of Appeals for the District of Columbia Circuit dismissed Seed's appeal, ruling that the court lacked jurisdiction to address the merits of her reassignment claims because she lacked standing under Article III of the United States Constitution. The court found that Seed had not demonstrated that a favorable court decision would likely redress her claimed injuries. The court therefore remanded the case to the district court with instructions to vacate the grant of summary judgment and to dismiss the reassignment claim for lack of standing. View "Seed v. EPA" on Justia Law

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Deangelo Evans, a passenger in a car pulled over for traffic violations, was subjected to a pat-down search by the United States Park Police officers during the stop. The search revealed a firearm in his waistband, leading to his arrest and subsequent charge for being a felon in possession of a firearm. Evans moved to suppress the firearm as evidence, arguing that it was obtained through an unlawful search. The district court denied his motion, ruling that the pat-down search was justified due to the bulge in his pants that the officers believed might be a gun.The case was tried in the United States District Court for the District of Columbia, where Evans was convicted following a stipulated trial. He preserved his right to appeal the district court's denial of his motion to suppress the firearm as evidence.The case was then brought before the United States Court of Appeals for the District of Columbia Circuit. The court reviewed the district court's findings of fact for clear error. The sole issue on appeal was whether the district court erred in crediting the police officers' testimony that they initiated a Terry frisk only after they saw a bulge in Mr. Evans’s pants that they believed might be a gun. Evans argued that the officers' testimony was inconsistent and implausible. However, the appellate court found that the inconsistencies Evans identified were not so glaring that the police officers' testimony must be a fabrication. Therefore, the court affirmed the district court's decision, ruling that the protective pat-down search was justified and the firearm was admissible as evidence. View "USA v. Evans" on Justia Law

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The case involves Pablo Abreu, a student who was expelled from Howard University College of Medicine. Abreu appealed his expulsion, arguing that the university violated his rights under Title III of the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1972 by refusing to grant him additional opportunities to retake a required examination, in light of his diagnosed test-taking-anxiety disability. The district court dismissed his complaint, applying a one-year statute of limitations and ruling that his claims were time-barred.The United States Court of Appeals for the District of Columbia Circuit disagreed with the lower court's application of a one-year statute of limitations to Abreu’s ADA and Rehabilitation Act claims. The court pointed to its decision in another case, Stafford v. George Washington University, in which it concluded that a three-year statute of limitations should apply to civil rights claims under Title VI of the Civil Rights Act of 1964. Since Abreu's ADA and Rehabilitation Act claims were also civil rights claims alleging discrimination, the court ruled that the three-year statute of limitations should apply. This made Abreu’s claims timely since he filed the suit less than three years after his expulsion.The court then remanded the case back to the district court for further proceedings on the ADA and Rehabilitation Act claims. However, it affirmed the dismissal of Abreu's contractual claims, agreeing with the district court that Abreu failed to state a claim for breach of contract. View "Abreu v. Howard University" on Justia Law

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In this case, an unincorporated association, Saline Parents, and six individuals sued the Attorney General of the United States, Merrick Garland, alleging that the Department of Justice (DOJ) was unlawfully attempting to silence them and others who opposed progressive curricula and policies in public schools. This lawsuit was in response to a memorandum issued by the Attorney General, expressing concern over the increase in reported incidents of harassment, intimidation, and threats of violence against school administrators, board members, teachers, and staff. The memorandum instructed the DOJ staff to investigate the issue and discuss strategies to address it. The plaintiffs argued that their protest activities, which included constitutionally protected conduct and did not involve threats of criminal violence, had been unfairly targeted by the DOJ.The United States Court of Appeals for the District of Columbia Circuit upheld the dismissal of the case by the District Court on the grounds that the plaintiffs lacked standing to pursue this action. The court agreed with the government's argument that the plaintiffs' lawsuit was not ripe for adjudication, indicating that the plaintiffs' claims were based on hypothetical future events that may not occur. The court also found that the plaintiffs had failed to demonstrate that the government had in any way threatened imminent enforcement action against them or had labeled them in a way that impugned their reputations. The court concluded that the plaintiffs' claim was based on contingencies and speculation, making the dispute premature for judicial resolution. View "Saline Parents v. Garland" on Justia Law

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The U.S. Court of Appeals for the District of Columbia Circuit ruled on an appeal by former President Donald J. Trump regarding his claim of presidential immunity from civil damages liability related to the January 6, 2021, Capitol riot. Plaintiffs included Capitol Police officers and members of Congress who alleged that Trump, through his actions and speech, incited the riot that resulted in physical injuries and emotional distress.The court determined that, at this stage in the proceedings, Trump has not demonstrated an entitlement to presidential immunity. It distinguished between actions carried out in a president’s official capacity, which are protected by immunity, and those carried out in a private or unofficial capacity, which are not. The court rejected Trump's argument that presidential speech on matters of public concern is always an official function, stating that such speech can be either official or unofficial depending on context.The court also rejected Trump's claim that his actions leading up to and on January 6 were official because they were under his Article II duty to "take Care that the Laws be faithfully executed," stating that this claim is not independent of his ability to show that he engaged in the relevant actions in his official capacity as President rather than his unofficial capacity as a presidential candidate.The court held that Trump's actions as alleged in the complaints, if proven to be true, were carried out in his capacity as a presidential candidate, not as the sitting President. Therefore, he is subject to civil suits like any private citizen. However, the court specified that Trump must be allowed to present facts and make arguments in the district court that his actions were taken in his official capacity. View "Blassingame v. Trump" on Justia Law

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Noncitizens can qualify for employment-based U.S. visas by investing in designated commercial enterprises that create jobs in the United States. After making a qualifying investment, a noncitizen must petition the United States Citizenship and Immigration Services (USCIS) for the visa. In these two consolidated appeals, investors who have waited several years for USCIS to approve their petitions sue the agency for what they see as unreasonably delayed action in violation of the Administrative Procedure Act. The district courts in both cases granted USCIS’s motions to dismiss, holding that the investors’ allegations do not show USCIS’s delay to be unreasonable under the circumstances.   The DC Circuit affirmed. The court explained that Plaintiffs do not state a claim of unreasonable delay. The availability-screened queue is a rule of reason, and the complaints do not allege that USCIS follows a process other than its officially stated policy. Ruling in favor of Plaintiffs would require USCIS to process Plaintiffs’ petitions ahead of those of other petitioners who have been waiting as long or longer for their EB-5 petitions to be adjudicated. Congress did not set a deadline for agency action, Plaintiffs allege primarily financial harm, and the allegations do not point to government impropriety. View "Adrian Da Costa v. Immigration Investor Program Office" on Justia Law

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Plaintiff acting on behalf of her son, a student who qualifies for special education services under the Individuals with Disabilities Education Act (IDEA), appealed an order of the district court denying her motions for a temporary restraining order and a preliminary injunction pursuant to the IDEA’s “stay-put” provision. The stay-put provision provides that “during the pendency of any proceedings conducted pursuant to this section, unless the State or local educational agency and the parents otherwise agree,” a student “shall remain” in the student’s “then-current educational placement.   The DC Circuit affirmed. The court explained that Community Services for Autistic Adults and Children, a private residential treatment center in Maryland, and its affiliated school, the Community School of Maryland’s (together, CSAAC) unilateral decision to discharge Plaintiff’s son did not trigger the IDEA’s stay-put mandate because the District did not refuse to provide a similar available placement. Neither the text of Section 1415(j) nor the court’s previous decisions applying the provision impose an affirmative duty on the District to provide an alternative residential environment when a student’s then-current placement becomes unavailable for reasons outside the District’s control. The court explained that Plaintiff’s attempt to bring a substantive challenge on behalf of her son by invoking the stay-put mandate is procedurally improper because Section 1415(j) is not intended to afford parties affirmative relief, on the merits, in the form of an automatic injunction. View "Anne Davis v. DC" on Justia Law

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Thousands of protesters flooded the streets of the District to proclaim “Black Lives Matter.” Over several weeks, the protesters covered streets, sidewalks, and storefronts with paint and chalk. The markings were ubiquitous and in open violation of the District’s defacement ordinance, yet none of the protesters were arrested. During the same summer, District police officers arrested two pro-life advocates in a smaller protest for chalking “Black Pre-Born Lives Matter” on a public sidewalk. The organizers of the smaller protest, the Frederick Douglass Foundation and Students for Life of America (collectively “the Foundation”), sued. The Foundation alleged violations of the First and Fifth Amendments, conceding the defacement ordinance was facially constitutional but arguing the District’s one-sided enforcement of the ordinance was not. The district court dismissed the complaint. Concluding the First Amendment and equal protection claims were essentially the same, the district court held the Foundation had failed to adequately allege discriminatory intent, which the court considered a necessary element of both claims.   The DC Circuit affirmed the district court’s dismissal of the Foundation’s equal protection claim because the Foundation has not plausibly alleged invidious discrimination by District officials. Discriminatory motive, however, is not an element of a First Amendment free speech selective enforcement claim. The First Amendment prohibits discrimination on the basis of viewpoint irrespective of the government’s motive. The court held the Foundation has plausibly alleged the District discriminated on the basis of viewpoint in the selective enforcement of its defacement ordinance. Therefore, the court reversed the dismissal of the Foundation’s First Amendment claim and remanded for further proceedings. View "Frederick Douglass Foundation, Inc. v. DC" on Justia Law

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Plaintiff filed a Title VII action against her employer, the Federal Bureau of Investigation (“FBI” or the “Bureau”) for allegedly taking retaliatory actions against her after she reported discrimination to the Bureau’s Equal Employment Office (“EEO”). The district court granted summary judgment in favor of the FBI on several of Ramos’s allegations, finding that the FBI’s actions were not materially adverse in violation of Title VII’s antiretaliation provision. The district court also denied Plaintiff’s  motion for leave to amend her complaint to add new allegations of retaliation.   The DC Circuit reversed the district court’s grant of summary judgment with regard to the 2011 rescission of the offer to transfer to Unit 1B, but affirmed on all other grounds. The court explained that the Bureau provided a legitimate, nonretaliatory reason for the Unit Chief’s decision to make Plaintiff Backup Program Manager: concern for her well-being when she returned to work following medical leave and was still recovering from injuries. The Chief noted that the motive in looking to bring someone in was to give Plaintiff “a break” while she was on medical leave so that he would not “keep harassing her while she was on leave with work.” Then, when the Chief announced the reassignment after Plaintiff had returned from medical leave, he explained that he did not want to burden Plaintiff with a heavy workload as she was recovering from her injuries. As such, the court concluded that Plaintiff did not provide sufficient evidence for a reasonable jury to conclude that her reassignments were retaliatory. View "Laura Ramos v. Merrick Garland (PUBLIC OPINION)" on Justia Law

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The federal government funds certain expenses incurred by presidential candidates at specific times during their primary campaigns. Jill Stein, who ran for President in 2016, contends that a temporal limit on this funding unconstitutionally discriminates against minor-party candidates. Stein also contests an administrative ruling that she forfeited the right to document certain costs of winding down her campaign, which could have offset a repayment obligation that she owed the government.   The DC Circuit denied her petition. The court explained that FEC regulations required her to reassert the issue in her written submission for administrative review. Further, Stein argued that the Commission should be estopped from claiming forfeiture because its audit report stated that the winding down costs “estimated” for the period between September 2018 and July 2019 “will be compared to actual winding down costs and will be adjusted accordingly.” The court wrote that it does not read this statement to relieve Stein of her duty to address winding down costs in her request for administrative review, which was filed near the end of that period. The court explained that it recognizes that Stein could not predict the exact amount of future winding down costs. But she could have done much more to alert the FEC that she expected those costs to exceed the estimates in the audit report—and to do so by a substantial amount. View "Jill Stein v. FEC" on Justia Law