Justia Civil Rights Opinion Summaries

Plaintiff pled guilty to two counts of first-degree murder in 2012 and received a life sentence at the Louisiana State Penitentiary (“LSP”). Plaintiff claims Defendants should be personally liable under 42 U.S.C. Section 1983 for his conditions of confinement from August 2012 to June 2017, which he alleges violated the Fourteenth and Eighth Amendments. On remand, the district court directed the parties to file supplemental memoranda addressing qualified immunity and prescription and referred the matter to a magistrate judge. The magistrate judge recommended dismissal for failure to state a claim. The district court adopted the magistrate judge’s recommendation and dismissed Plaintiff’s claims. Plaintiff appealed.   The Fifth Circuit affirmed. The court explained that as to the Fourteenth Amendment, the magistrate judge correctly stated that restrictive confinement, like Plaintiff’s grounds for a due process claim, only if it “imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.” Applying that standard, the judge properly considered the severity and duration of the confinement. Further, as to Plaintiff’s Eighth Amendment claim, the magistrate judge correctly stated that such a claim requires showing both that a prisoner faces conditions so dire as to deprive him of “the minimal civilized measure of life’s necessities” and that the responsible prison officials were “deliberately indifferent” to the inmate’s health or safety. Finally, the court wrote that confinement to a cell for twenty-three hours per day did not violate the Eight Amendment, where the inmate nonetheless could converse with other inmates, receive visitors, and engage in some form of exercise or other recreation. View "LaVergne v. Stutes" on Justia Law

Plaintiff is a black female educator and school administrator who works for the Brookhaven School District (the “School District”). Plaintiff sought to attend the Mississippi School Board Association Prospective Superintendent’s Leadership Academy, a training program for prospective superintendents. According to Plaintiff, the School District “established a precedent of paying for every employee’s fees after the employee was accepted to attend the program.” Plaintiff asked the Deputy Superintendent, if the School District would pay for her to attend the Leadership Academy. Once the program accepted Plaintiff, the School District’s Superintendent reneged and refused to pay for her to attend at that time. But Plaintiff’s spot was for the upcoming class, so she paid the fees herself. Plaintiff sued, alleging that the School District violated Title VII and 42 U.S.C. Section 1981 by refusing to pay for her to attend the Leadership Academy but agreeing to pay for similarly situated white males to attend. The district court dismissed Plaintiff’s claims under Federal Rule of Civil Procedure 12(c).   The Fifth Circuit reversed. The court held that Plaintiff set forth a plausible Title VII claim under Rule 12 because plausibly alleged facts that satisfy both adverse employment action prongs and the adverse employment action element was the only element in dispute. The court explained, taking Plaintiff’s allegations as true—that the School District (1) agreed to pay for similarly situated white males’ fees to attend the Leadership Academy; (2) promised to pay her fees (a promise she relied on); and (3) reneged on that promise—Plaintiff plausibly stated a Title VII disparate treatment claim. View "Harrison v. Brookhaven Sch Dist" on Justia Law

The United States commenced an investigation of Mississippi’s mental health system. This investigation was not prompted any individual instance of discrimination against a person with serious mental illness. The United States filed suit against the state of Mississippi, alleging that its entire mental health care system violated the “integration mandate” prescribed by 28 C.F.R. Section 35.130(d) and reified in the Supreme Court’s decision, Olmstead v. L.C. ex rel. Zimring. The district court conducted a trial, upheld the federal government’s theory of liability, and ordered not only sweeping modifications to the state’s system but also the indefinite appointment of a monitor who would oversee the system. Mississippi contends that (1) the federal government has not proved a cause of action for discrimination in violation of the ADA (2) the court erred in rejecting its defense that remediation would require an impermissible “fundamental alteration” of its existing programs and (3) the court’s remedial order vastly exceeds the scope of claimed liability   The Fifth Circuit reversed. The court explained that the possibility that some un-named individual with serious mental illness or all such people in Mississippi could be unjustifiably institutionalized in the future does not give rise to a cognizable claim under Title II. The court further wrote that nor does such a vague and standardless theory license courts under the ADA to rework an entire state’s mental health system. Accordingly, the court held that the government did not prove that the state of Mississippi violated Title II pursuant to the statute, regulations, or Olmstead as properly construed. View "USA v. State of Mississippi" on Justia Law

Plaintiff is a music theory professor at UNT, a leading expert on the Austrian music theorist Heinrich Schenker, the director of the Center for Schenkerian Studies, and the founder of the Journal of Schenkerian Studies. Plaintiff published an article defending Schenker against charges of racism. The Dean of the College of Music announced that the College of Music would be launching a “formal investigation into the conception and production of” the Journal’s symposium issue. After interviewing eleven individuals, the panel produced a report. The provost sent Jackson a letter instructing him to “develop of a plan to address the recommendations.” After Plaintiff submitted his plan, Board members charged the department with launching a national search for a new editor-in-chief for the Journal, who is a full-time tenured faculty member. Plaintiff sued the Board defendants, among others, alleging a First Amendment retaliation claim under 42 U.S.C. Section 1983. The district court denied the defendants’ motions to dismiss.   The Fifth Circuit affirmed. The court found that sovereign immunity does not bar Plaintiff’s First Amendment claim. Further, the court found that Plaintiff has standing to bring his First Amendment claim against the Board defendants. Accordingly, the court found that Plaintiff has “alleged an ongoing violation of federal law and seeks relief properly characterized as prospective.” Thus, at the motion to dismiss stage, sovereign immunity does not bar Plaintiff’s First Amendment claim against the Board defendants. The court also found that Plaintiff also has standing to bring his First Amendment claim. For Article III standing. View "Jackson v. Wright" on Justia Law

The Texas Department of Criminal Justice fired Plaintiff after he refused to cut his hair and beard in violation of his religious vow. Plaintiff exhausted his administrative remedies. He then filed a pro se lawsuit against TDCJ and various officers, which alleged claims of religious discrimination and failure to accommodate under Title VII of the Civil Rights Act of 1964. The district court granted summary judgment in favor of Defendants.   The Fifth Circuit, in accordance with the Supreme Court’s recent decision in Groff v. DeJoy, 143 S. Ct. 2279 (2023), reversed. The court explained that Title VII forbids religious discrimination in employment. The statute defines “religion” broadly to include “all aspects of religious observance and practice, as well as belief.” Further, the court explained that Title VII also requires employers to accommodate the religious observances or practices of applicants and employees. The court held that TDCJ breached both duties. TDCJ (A) failed to accommodate Hebrew’s religious practice and (B) discriminated against him on the basis of his religious practice   The court reasoned that the only issue is whether TDCJ has met its burden to show that granting Hebrew’s requested accommodation—to keep his hair and beard—would place an undue hardship on TDCJ. The court held that (1) TDCJ cannot meet the undue hardship standard and (2) the Department’s counterarguments are unavailing. The court noted that, in this case, TDCJ cannot hide behind its “otherwise-neutral policy.” This policy must “give way” to Plaintiff’s requested accommodation. View "Hebrew v. TDCJ" on Justia Law

Louisiana Fair Housing Action Center (LaFHAC) sued Azalea Garden Properties, LLC (Azalea Garden), alleging that Azalea Garden discriminated on the basis of race and disability at its apartment complex in Jefferson, Louisiana, in violation of the Fair Housing Act (FHA). The district court dismissed LaFHAC’s disability claim but allowed its disparate impact race claim to proceed, subject to one caveat: The district court certified a permissive interlocutory appeal on the issue of whether the “predictably will cause” standard for FHA disparate-impact claims remains viable after Inclusive Communities Project Inc. v. Lincoln Property Co., 920 F.3d 890 (5th Cir. 2019).   The Fifth Circuit remanded the case with instructions to dismiss LaFHAC’s claims without prejudice. The court held that the district court lacked jurisdiction over this case. Along the same lines, the court wrote that it cannot consider the district court’s certified question. The court explained that LaFHAC has plausibly alleged a diversion of resources, as it shifted efforts away from planned projects like its annual conference toward counteracting Azalea Garden’s alleged discrimination. But “an organization does not automatically suffer a cognizable injury in fact by diverting resources in response to a defendant’s conduct.” The court wrote that LaFHAC failed to plead an injury because it failed to allege how its diversion of resources impaired its ability to achieve its mission. Thus, the court held that because LaFHAC has not alleged a cognizable injury, it lacks standing to bring the claims it alleges in this action. View "LA Fair Housing Action v. Azalea Garden" on Justia Law

Savion Hall, an inmate at Midland County Jail, suffered severe breathing issues that were known to prison officials. The jail contracted with Soluta, Inc., a private company, for medical services, but Soluta employees failed to provide standard medical care to Hall and fabricated his medical reports. Eventually, Hall required urgent medical attention, but when he asked Daniel Stickel, a prison guard, for help, Stickel followed set protocol: Hall was only supposed to receive “breathing treatments” every four hours; because less than four hours had elapsed since Hall’s last treatment, Stickel sent him back to his cell. Eventually, Hall was seen by a doctor, who called Emergency Medical Services (“EMS”). Hall died in the hospital. Plaintiffs, various relatives and representatives of Hall’s estate appealed the dismissal of his constitutional claims against Midland County and Stickel.   The Fifth Circuit affirmed. The court explained that municipalities such as Midland County cannot be held liable unless plaintiffs can show “(1) an official policy (or custom), of which (2) a policymaker can be charged with actual or constructive knowledge, and (3) a constitutional violation whose ‘moving force’ is that policy or custom.” The court explained that there are no allegations that anyone other than the Soluta employees was aware, or should have been aware, of the nurses’ failure to provide adequate medical care. The court reasoned that this implies that neither Soluta nor Midland County4 knew of the “policy” of failing to follow the proper medical procedures. Further, the court held that Plaintiffs have not plausibly pleaded deliberate indifference predicated on a delay in medical treatment. View "Robinson v. Midland County, Texas" on Justia Law

Plaintiff is a devout Rastafarian who vowed to “let the locks of the hair of his head grow,” a promise known as the Nazarite Vow. During his brief stint in prison, Plaintiff was primarily housed at two facilities, and each facility respected Plaintiff’s vow. With only three weeks left in his sentence—Plaintiff was transferred to RLCC. Plaintiff explained that he was a practicing Rastafarian and provided proof of past religious accommodations. And Plaintiff also handed the guard a copy of the Fifth Circuit’s decision in Ware v. Louisiana Department of Corrections. The guard threw Plaintiff’s papers in the trash and summoned RLCC’s warden. When the Warden arrived, he demanded Plaintiff hand over documentation from his sentencing judge that corroborated his religious beliefs. Guards then carried him into another room, handcuffed him to a chair, held him down, and shaved his head. Plaintiff brought claims under RLUIPA and Section 1983. He also pleaded state law claims for negligence, intentional infliction of emotional distress, and violations of the Louisiana constitution. The district court agreed with Defendants and held that those claims were moot. Plaintiff appealed.   The Fifth Circuit affirmed. The court concluded that while Sossamon I RLUIPA’s text suggests a damages remedy, recognizing as much would run afoul of the Spending Clause. Tanzin doesn’t change that—it addresses a different law that was enacted under a separate Congressional power with “concerns not relevant to [RLUIPA].” Accordingly, the court held because Sossamon I remains the law, Plaintiff cannot recover monetary damages against the defendant-officials in their individual capacities under RLUIPA. View "Landor v. Louisiana Dept of Corrections" on Justia Law

The Verona Police Department twice arrested L.B. for his connection to violent shootings. Both times, however, he was released while his charges were pending. Just five months after his second arrest, L.B. drove to Annie Walton’s house and opened fire—killing Annie Walton and injuring her grandson, Aliven Walton. Annie Walton’s wrongful death beneficiaries (collectively, Plaintiffs ) believe the City of Verona and the Verona Chief of Police, J.B. Long, are responsible for the shooting at Annie Walton’s home, so they sued under 42 U.S.C. Section 1983 and the Mississippi Tort Claims Act. At summary judgment, the district court initially dismissed all claims. But Plaintiffs filed a motion for reconsideration, and the district court reversed course—finding the City of Verona was not entitled to sovereign immunity under the Mississippi Tort Claims Act. Plaintiffs and the City of Verona subsequently filed interlocutory appeals.   The Fifth Circuit dismissed Plaintiffs appeal for lack of jurisdiction and reversed the district court’s finding against the City regarding sovereign immunity. The court explained that Long had no special duty to protect Plaintiffs besides his general duty to keep the public safe as the City’s Chief of Police. The court explained that the only evidence that demonstrates Long had knowledge of any connection between L.B. and Plaintiffs comes from Long’s investigative file, where there is a copy of a trespassing complaint that Annie filed against L.B. in 2016. Accordingly, the court held Long did not owe a duty to protect Plaintiffs from L.B.’s drive-by shooting. Thus, Plaintiffs cannot sustain their negligence claims or their MTCA claims against the City. View "Walton v. City of Verona" on Justia Law

Plaintiff, formerly a patrol sergeant in the Alamo, Texas police department, brought a Section 1983 action against the City of Alamo (the “City”), former chief of police, and several other officers in connection with an alleged scheme to have Plaintiff fired and arrested on bogus charges. The district court dismissed the City and the other officers under Federal Rule of Civil Procedure 12(b)(6), then dismissed the chief of police under 12(c). Plaintiff appealed the dismissals of the chief of police and the City.   The Fifth Circuit reversed the dismissal of Plaintiff's false arrest complaint against the chief of police and affirmed the dismissal of the City. The court explained that Plaintiff’s complaint presents Defendant as the sole moving force behind a deliberate, long-term conspiracy to create and file affidavits Defendant knew to be false, with the purpose of exploiting the criminal justice system to arrest, detain, and torment Plaintiff for crimes Defendant knew he did not commit. Defendant, moreover, ordered the sham investigations that served as the basis for the false affidavits and pushed the investigations forward despite knowing Plaintiff was innocent. The court wrote that Terwilliger v. Reyna controls here. As such, the court held that Defendant’s alleged actions are relevant, like Reyna’s, for purposes of evaluating his potential Franks liability at the Rule 12 stage. Defendant was the “driving force” behind the conspiracy, and he was “continuously updated” as to the status of the investigations he had ordered, including the fact the investigations revealed no criminality or impropriety. Therefore, the court reversed the district court’s dismissal of Plaintiff’s false arrest claim against Defendant. View "Guerra v. Castillo" on Justia Law