Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the District of Columbia Circuit
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Plaintiff worked as a secretary for the Navy. In 2017, Plaintiff filed a charge alleging that a Navy contractor, had subjected her to a hostile work environment. In 2018, the Navy issued a final decision concluding that Plaintiff failed to prove that the contractor harassed her. On appeal, the EEOC agreed with the Navy’s conclusion, but it raised two distinct claims that Plaintiff had not charged. A motions panel denied Plaintiff’s motion in full and granted the Navy’s motion as to the first three claims.   On appeal, the relevant question was whether the employee may pursue a retaliation claim in court without first exhausting it before the Navy. The DC Circuit affirmed the order dismissing Plaintiff’s claims, holding that an employee may not pursue the relevant claim without first exhausting it before the Navy. Here, Plaintiff failed to present her retaliation-by-disclosure claim to the Navy before filing a lawsuit. The court explained that the fact that the EEOC told Plaintiff she had a right to sue does not change this analysis. The EEOC itself recognizes that an employee must describe in her charge “the action(s) or practice(s) that form the basis of the complaint.” View "Katrina Webster v. Carlos Del Toro" on Justia Law

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Appellant was working as a bus ticketing agent in Washington, D.C. when a person attempted to sneak onto a bus headed to New York without a ticket. After Appellant ordered the person off the bus the two women got into a scuffle. District of Columbia Metropolitan Police officers arrived in response to the unticketed person’s call reporting Appellant for assault.   Officers grabbed Appellant, pressed her against the wall, and then forced her to the floor and handcuffed her. The police charged her with simple assault on the person attempting to get on the bus and with assaulting a police officer while resisting arrest. Appellant subsequently sued the District of Columbia and the police officers, alleging civil rights violations during this arrest and a second arrest that occurred in April 2016. She appealed the district court’s grant of summary judgment in favor of the District and its officers.   The DC Circuit agreed in part and reversed the district court’s grant of summary judgment for the District and its officers on Appellant’s 42 U.S.C. Section 1983 wrongful arrest, common law false arrest, and respondeat superior claims. The court affirmed the district court’s grant of summary judgment as to Appellant’s other claims. The court explained that the district court erred in granting summary judgment to the District on Appellant’s wrongful arrest and common law false arrest claims because there is a genuine dispute of material fact over whether probable cause for the simple assault arrest had dissipated and required the police officers to release Appellant. View "Xingru Lin v. DC (PUBLIC)" on Justia Law

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After Appellant, a ticketing agent ordered a non-ticketed individual off of the bus, the two women got into a physical altercation. When DC Metropolitan Police officers arrived, they grabbed Appellant, pressed her against the wall, and then forced her to the floor. The police charged her with simple assault on the non-ticketed individual and with assaulting a police officer while resisting arrest.   Appellant sued the District of Columbia and the police officers, alleging civil rights violations during this arrest and a second arrest that occurred two months after the first. Appellant appealed the district court’s grant of summary judgment in favor of the District and its officers.   The DC Circuit agreed in part and reversed the district court’s grant of summary judgment for the District and its officers on Appellant’s Section 1983 wrongful arrest, common law false arrest, and respondeat superior claims. The court affirmed the district court’s grant of summary judgment as to Appellant’s other claims. The court explained that there is a genuine dispute of material fact as to whether probable cause for the simple assault charge dissipated before Appellant was handcuffed a second time and taken involuntarily to the police station. Second, there is a genuine issue of material fact as to the existence of probable cause to arrest Appellant for assaulting a police officer. View "Xingru Lin v. DC (REDACTED)" on Justia Law

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In 2016, the Department of Housing and Urban Development promulgated a rule prohibiting the use of lit tobacco products in HUD-subsidized public housing units and their immediate surroundings. Appellants, led by New York City Citizens Lobbying Against Smoker Harassment (C.L.A.S.H.), brought an action raising a number of statutory and constitutional challenges to the Rule. The district court rejected all of C.L.A.S.H.’s claims.The D.C. Circuit affirmed, finding that the Department did not exceed its authority in passing the rule and was not arbitrary, capricious, and an abuse of discretion. The Court similarly rejected C.L.A.S.H.’s constitutional claims under the Spending Clause and the Fourth, Fifth, and Tenth Amendments. View "NYC C.L.A.S.H., Inc. v. Marcia L. Fudge" on Justia Law

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The Comprehensive Merit Personnel Act (CMPA) governs collective bargaining by employees of the District of Columbia government. It allows officers of the Metropolitan Police Department, like other D.C. government employees, to unionize and engage in collective bargaining. They have done so and are represented by the plaintiff in this case, the Fraternal Order of Police, Metropolitan Police Department Labor Committee, D.C. Police Union (FOP). The police union contends that the statute violates equal protection principles, the Bill of Attainder Clause, the Contract Clause, and the Fifth Amendment Due Process Clause.   The DC Circuit rejected all the challenges concluding that the district court correctly concluded that the FOP’s constitutional claims lack merit. The FOP disputes that police accountability motivated the Council. The court explained that the legislature’s actual motive is “entirely irrelevant”; all that matters is whether there are “plausible reasons” to conclude that the statutory classification furthers a legitimate government interest.   The FOP next contends that section 116 violates the Bill of Attainder Clause. However, the court found that the union makes no serious effort to show that the Council acted beyond its discretion. And the court could discern no express or hidden intent to punish. Further, FOP contends that section 116 violates the Contract Clause. The court explained that retrospective laws violate the Contract Clause only if they “substantially” impair existing contract rights. Here, the union could not have reasonably expected to insulate itself from legal changes after the 2017 Agreement had expired by its terms. View "Fraternal Order of Police, Metropolitan Police Department Labor Committee, D.C. Police Union v. DC" on Justia Law

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The District of Columbia’s Office of the State Superintendent of Education (OSSE) regulates childcare facilities, including by setting minimum qualifications for their workers. OSSE issued a rule requiring many childcare workers to obtain an associate’s degree or its equivalent in a field related to early childhood education. Two childcare workers and a parent filed a lawsuit to challenge the new college requirements. They allege violations of their substantive due process and equal protection rights, as well as of the nondelegation doctrine.On remand, the district court dismissed, this time on the merits. In rejecting Plaintiffs’ substantive due process and equal protection claims, the court concluded that the college requirements are rational, including in the distinctions they draw between different classes of daycare workers. And in rejecting Plaintiffs’ nondelegation doctrine claim, the court held that the statute granting regulatory authority to OSSE bears an intelligible principle to guide the agency’s work.The DC Circuit affirmed. The court explained that under rational-basis review, the policy choices of the political branches are “not subject to courtroom fact-finding and may be based on rational speculation unsupported by evidence or empirical data. And here, as Plaintiffs acknowledge in their complaint, OSSE issued its regulations in part based on a report from the National Academies recommending a bachelor’s degree requirement for all educators of children ages zero to eight. Thus, the court found that a conceivably rational justification for the college requirements is readily apparent, and, in this context, that is all due process requires. View "Altagracia Sanchez v. Office of the State Superintendent of Education" on Justia Law

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The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF” or the “Bureau”) promulgated a rule classifying “bump stocks” as machine guns. The Bureau’s new rule instructed individuals with bump stocks to either destroy them, abandon them at the nearest ATF facility, or face criminal penalties. Plaintiffs initially moved for a preliminary injunction to stop the rule from taking effect, which the District Court denied, and a panel of this Court affirmed. At the merits stage, the District Court again rejected Plaintiffs’ challenges to the rule under the Chevron framework. See Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984).The central question on appeal was whether the Bureau had the statutory authority to interpret “machine gun” to include bump stocks and the DC Circuit affirmed. In employing the traditional tools of statutory interpretation, the court found that the disputed rule is consistent with the best interpretation of “machine gun” under the governing statutes. The court explained that it joins other circuits in concluding that these devices, which enable such prodigious rapid-fire capability upon a pull of the trigger, fall within the definition of “machine gun” in the National Firearms Act and Gun Control Act. View "Damien Guedes v. ATF" on Justia Law

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The United States Court of Appeals for the District of Columbia Circuit reversed the decision of the district court denying Defendant's motion to dismiss this complaint alleging, among other things, an Eighth Amendment claim of deliberate indifference to his serious medical needs or for summary judgment based on qualified immunity, holding that dismissal was warranted.While he was incarcerated in federal prison and suffering from Hepatitis C, Plaintiff applied to receive treatment with Harvoni. Dr. Jeffrey Allen, the Federal Bureau of Prisons (BOP) Medical Director, denied the request under BOP's then-operative protocol. Pursuant to later-revised protocol, Plaintiff received treatment, and his Hepatitis C was cured. Plaintiff brought this action alleging that Defendant inflicted cruel and unusual punishment upon him by failing to grant his initial treatment request. The district court denied Defendant's motion to dismiss or for summary judgment based on qualified immunity. The Court of Appeals reversed, holding that qualified immunity protected Defendant from Plaintiff's claims. View "Bernier v. Allen" on Justia Law

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Plaintiff sought numerous transfers to different units in the Office. After these requests were denied, she filed a charge of sex discrimination with the Equal Employment Opportunity Commission, contending that similarly situated male employees had been granted the transfers they requested. She filed a Title VII suit against the District in 2014 alleging unlawful sex discrimination and retaliation.   The district court, applying Brown, granted summary judgment to the District. On rehearing, Plaintiff contends that Brown is facially inconsistent with Title VII. The DC Circuit explained that without any footing in the text of Title VII or Supreme Court precedent, there is no sound basis for maintaining Brown as circuit law. The court held that an employer that transfers an employee or denies an employee’s transfer request because of the employee’s race, color, religion, sex, or national origin violates Title VII by discriminating against the employee with respect to the terms, and conditions, or privileges of employment. The court reasoned that Brown is fundamentally flawed because it “elevated policy concerns . . . over the plain statutory text.” The plain text of section 703(a)(1) contains no requirement that an employee alleging discrimination in the terms or conditions of employment make a separate showing of “objectively tangible harm.” View "Mary Chambers v. DC" on Justia Law

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The LA Times appeals the district court's denial of its motions to unseal court records relating to a search warrant allegedly executed on Senator Richard Burr in connection with an insider-trading investigation and the government's memorandum opposing its motion to unseal.The DC Circuit remanded the case to the district court to reconsider its common law analysis in light of new disclosures from a related investigation by the SEC and Senator Burr's public acknowledgment of the Justice Department's investigation, as well as precedent governing how the common law right should be balanced against competing interests. The district court shall reconsider the L.A. Times' challenge that it was fundamentally disadvantaged by the district court's decision to seal the government's opposition memorandum and attached exhibits. View "Los Angeles Times Communications LLC v. United States" on Justia Law