Justia Civil Rights Opinion Summaries

After plaintiff was shot five times during an armed confrontation with two sheriff's deputies, he filed a 42 U.S.C. 1983 action alleging that the deputies used unreasonable and excessive force in violation of the Fourth Amendment.The Fifth Circuit held that there was no error in the district court's conclusion that plaintiff failed to produce sufficient pleadings to state a Monell claim against the county. In this case, plaintiff failed to establish an official custom or policy of excessive force because the only facts he alleged with any specificity related to his shooting. The court also held that, even if the district court erred by excluding testimony from plaintiff's criminal trial, such error was harmless and the testimony's exclusion was not a basis for reversal. Finally, the court held that the deputies were entitled to qualified immunity where plaintiff failed to meet his burden of establishing a Fourth Amendment violation in the form of unreasonable and excessive force, much less a violation that every reasonable officer in Deputy Scudder's position would appreciate. Accordingly, the court affirmed the district court's judgment in all respects. View "Ratliff v. Aransas County" on Justia Law

The Fifth Circuit denied defendant's motion to change the name of his judgment of confinement to "Kathrine Nicole Jett." Plaintiff had previously come out as a transgender woman. The district court denied the motion as meritless.The court held that defendant's request to change the name on his judgment of commitment was an unauthorized motion which the district court was without jurisdiction to entertain. Therefore, the court vacated the district court's judgment. In this case, defendant's request did not fall into any of the recognized categories of postconviction motions. Furthermore, defendant's request was not authorized under 18 U.S.C. 3582(c)(2) because it was not based upon an amendment to the Sentencing Guidelines.The court also denied defendant's motion to refer to him with female instead of male pronouns. The court held that no authority supported the proposition that the court could require litigants, judges, court personnel, or anyone else to refer to gender-dysphoric litigants with pronouns matching their subjective gender identity; if a court were to compel the use of particular pronouns at the invitation of litigants, it could raise delicate questions about judicial impartiality; and ordering use of a litigant's preferred pronouns may well turn out to be more complex than at first it might appear. View "United States v. Varner" on Justia Law

The Fifth Circuit affirmed the district court's grant of Champion's motion for summary judgment on workplace-discrimination claims brought by plaintiff, an employee, who alleged that he was fired because of a diabetes-related condition. Champion claimed that plaintiff was sleeping at his desk during work hours, an immediately terminable offense.The court held that the district court did not err in finding no direct evidence of discrimination on the basis of disability. The court also agreed with the district court that the evidence suggested that plaintiff could not perform the essential functions of the job with or without an accommodation.The court also held that plaintiff's disability-based claim failed because any harassment plaintiff alleged was not severe or pervasive and did not create an abusive working environment. Furthermore, plaintiff failed to show that the harassment was based on his disability. The court held that the district court did not err in finding no failure to accommodate plaintiff's disability and no failure to engage in an interactive process. Even if plaintiff was a qualified individual, his failure-to-accommodate claim failed because he failed to carry his burden to show that he requested reasonable accommodations. The court further held that plaintiff failed to show a prima facie case of retaliation. Finally, the district court did not err by denying plaintiff's claims for damages. View "Clark v. Champion National Security, Inc." on Justia Law

Plaintiff filed suit against the fire chief and the city after he was terminated from his position as a driver/pump operator at the fire department because he objected to having TDAP vaccinations based on religious grounds. Plaintiff was given a choice between two accommodations: transfer to a code enforcement job that did not require a vaccination, or wear a respirator mask during his shifts, keep a log of his temperature, and submit to additional medical testing. When plaintiff did not accept either accommodation, he was fired by the fire chief for insubordination.The Fifth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. In regard to plaintiff's claim of retaliation in violation of Title VII and the Texas Commission on Human Rights Act (TCHRA), the court held that the city provided a reasonable accommodation by offering to transfer plaintiff to the code enforcement position in the department. In regard to plaintiff's Title VII and TCHRA retaliation claims, the court held that the city had a legitimate, non-discriminatory reason for plaintiff's termination: plaintiff's defiance of a direct order by failing to select an accommodation to the TDAP vaccine policy. In regard to plaintiff's 42 U.S.C. 1983 claims that defendants violated his First Amendment Free Exercise rights, the court held that plaintiff's right to freely exercise his religious beliefs was not burdened by the respirator requirement. View "Horvath v. City of Leander" on Justia Law

Plaintiff sought review of the district court's dismissal of her claim against the county under the Americans with Disabilities Act (ADA) and 42 U.S.C. 1983. Plaintiff's claims stemmed from the conditions of her arrest after she had undergone surgery on her right leg 24 hours beforehand.The Fifth Circuit reversed the district court's summary judgment dismissal of the ADA claim and held that a reasonable jury could find that the county intentionally denied her reasonable accommodations. In this case, the county provided plaintiff with crutches, but it denied her other accommodations, such as a wheelchair, a modified food delivery procedure, and various forms of medical care. However, the court affirmed the district court's summary judgment dismissal of plaintiff's section 1983 claim and held that she failed to show that she was subjected to an unconstitutional condition of confinement, or that the medical treatment that she received was so deficient that it amounted to deliberate indifference to a serious medical need. View "Cadena v. El Paso County" on Justia Law

In these consolidated cases, plaintiffs challenged the removal or relocation of Confederate monuments from a San Antonio park and on the University of Texas's Austin campus. The district courts dismissed plaintiffs' First Amendment claims for lack of standing and then declined to exercise supplemental jurisdiction over their state-law claims.The Fifth Circuit affirmed the district court's judgment, holding that plaintiffs have not alleged a particularized injury and therefore lack standing to bring their First Amendment claims. In this case, what plaintiffs seek was only to vindicate their own value preferences, not to redress a First Amendment injury particular to them. View "McMahon v. Fenves" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment to defendants in an action brought by plaintiff, a diabetic federal prisoner who injured his ankle while exercising, alleging that defendants were deliberately indifferent to his medical needs in violation of the Eighth Amendment's Cruel and Unusual Punishment Clause. Plaintiff also alleged a First Amendment claim, alleging retaliation for having filed grievances.The court held that there was no genuine dispute underlying defendant's deliberate indifference claim against the prison nurse where plaintiff failed to produce evidence showing that the nurse had subjective knowledge of plaintiff's exposure to harm, or denied or delayed plaintiff's medical treatment. The court also held that no reasonable jury could find that the prison supervisor denied or delayed medical treatment to plaintiff. In regard to the retaliation claim, the court held that the district court properly granted summary judgment against the nurse, because there was no genuine factual dispute as to whether the nurse's retaliatory acts -- hurried medical treatment, filing various false reports, and making adverse statements -- amounted to a cognizable retaliation claim. The court held that summary judgment on plaintiff's retaliation claim against the special investigation supervisor was also proper where plaintiff failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act. Finally, the court held that, in any event, defendants were entitled to qualified immunity. View "Petzold v. Rostollan" on Justia Law

Plaintiff, a Texas inmate, filed a 42 U.S.C. 1983 action against defendants, alleging violations of his Eighth Amendment rights, because he was housed in unconstitutional conditions and that various defendants were deliberately indifferent to his health and safety. At issue on appeal were plaintiff's individual-capacity claims.Determining that the notice of appeal was timely, the Fifth Circuit affirmed summary judgment for Defendants Riojas, Cortez, Hunter, Davidson, Swaney, Martinez, Stevens, and Henderson on plaintiff's claim related to the conditions of his cells; reversed and remanded summary judgment for Defendants Riojas, Martinez, and Ortiz on plaintiff's claim related to their failure to take him to the restroom; affirmed summary judgment for Defendant Henderson on the failure to take him to the restroom claim; affirmed summary judgment for Defendants Riojas, Martinez, and Henderson on plaintiff's claim related to their failure to treat his chest pain; affirmed summary judgment for Defendant Orr on plaintiff's claim related to Orr's failure to treat his bladder pain; and affirmed summary judgment for Defendant Stevens on plaintiff's claim that Stevens promulgated an unconstitutional policy. View "Taylor v. Stevens" on Justia Law

The Fifth Circuit granted the petition for panel rehearing and withdrew its prior opinion, substituting the following opinion.The court affirmed the district court's grant of summary judgment on plaintiff's discrimination and retaliation claims under Title VII and 42 U.S.C. 1981. The court held that plaintiff failed to present a genuine issue of material fact that her race was a motivating factor in her termination or that there was a causal connection between her EEOC complaint and the termination. In this case, plaintiff was terminated as a part of a group of layoffs designed to offset the city's budget shortfall. View "Harville v. City of Houston" on Justia Law

Plaintiffs Warren and Benfield, paramedics, filed suit against their boss, the EMS Administrator, alleging that he fired them for exercising their First Amendment free-speech and free-association rights. The district court held that defendant was entitled to qualified immunity for Benfield's free-association claim but not for Warren's or Benfield's free-speech claims.The Fifth Circuit held that Warren failed to show that defendant violated one of his constitutional rights. In this case, because Warren failed to allege the requisite causal connection between his June 2015 letter and his firing, he has not alleged an element of his First Amendment retaliatory-discharge claim. The court also held that, because defendant made no substantive argument for dismissing Benfield’s free-speech claim, the district court did not err in refusing to address the issue sua sponte. Finally, the court denied Warren's request to replead his claims. Accordingly, the court reversed the district court's denial of qualified immunity for Warren's free-speech claim and rendered judgment for defendant on that claim; affirmed the district court's judgment not to dismiss Benfield's free-speech claim; and remanded for further proceedings. View "Benfield v. Magee" on Justia Law