Justia Civil Rights Opinion Summaries

After decedent was struck and killed by a motor vehicle as he walked along a highway in the dark, plaintiffs filed a 42 U.S.C. 1983 suit against the county, the city, and law enforcement officers, alleging state law claims and constitutional claims. The district court granted summary judgment to the city and the officers, but denied summary judgment to the county and Deputy Fleming. Deputy Fleming appealed.The Eighth Circuit affirmed the district court's judgment as to the Fourth Amendment claim, holding that Deputy Fleming's seizure, detention, and transporting of the decedent at the county line for alleged vagrant-ouster purposes violated the decedent's clearly established Fourth Amendment rights. The court reversed as to the Fourteenth Amendment claim, holding that plaintiffs have not demonstrated a clearly established substantive due process right on the facts they alleged. Therefore, the court rendered judgment that Deputy Fleming was entitled to qualified immunity on the Fourteenth Amendment claim. View "Keller v. Fleming" on Justia Law

The Fifth Circuit affirmed the district court's dismissal, on summary judgment, of plaintiff's claims of interference and retaliation in violation of the Family and Medical Leave Act (FMLA). The court held that SCS had a good-faith reason for plaintiff's termination. In this case, SCS adhered to company policy in firing plaintiff after he had refused to conduct himself professionally and had delayed reporting a safety concern. View "Tatum v. Southern Company Services, Inc." on Justia Law

The Fifth Circuit held that the order committing defendant for a maximum of four months accords with due process. The court held that, even where the medical evidence indicates that the defendant's condition is permanent, temporary hospitalization bears some reasonable relation to the purpose for that confinement.In this case, defendant was charged with threatening to assault and murder two federal employees. The district court found that he lacked capacity to stand trial and ordered his temporary hospitalization to determine whether he might regain competency in the foreseeable future. The court joined its sister circuits in holding that such mandatory, limited confinement accords with due process. View "United States v. McKown" on Justia Law

The Fifth Circuit denied petitioner's motion for a stay of execution, holding that he failed to demonstrate that the circumstances justify the exercise of the court's equitable discretion. The court held that petitioner was unlikely to succeed on the merits of his claim that this case should proceed in federal court without the pressures of a state execution setting. Even even assuming arguendo he could establish a likelihood of success, the other factors also weigh in favor of the state and against a stay. The court explained that, at this point, a denial of his stay motion would not prevent him from fully and fairly litigating the merits of his Rule 60(b)(6) motion before the district court. View "Crutsinger v. Davis" on Justia Law

After plaintiff's position was eliminated, he filed a 42 U.S.C. 1983 action against the county, alleging a First Amendment retaliation claim. The Fifth Circuit affirmed the district court's denial of the county's motions for summary judgment, judgment as a matter of law, and new trial. The court held that the Rooker-Feldman doctrine was inapplicable; plaintiff's claim was not judicially estopped based on his response in his unemployment application; and plaintiff's failure to appeal the Board's decision in state court did not preclude his First Amendment claim under section 1983.The court also held that plaintiff's position was not a policymaking position, and the jury's verdict in favor of plaintiff was supported by sufficient evidence. In this case, there was evidence that at least three of the five board members had retaliatory motive, and the evidence was legally sufficient to support the jury's verdict. View "Griggs v. Chickasaw County" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment in favor of the employer on plaintiff's claims of discrimination based on age, disability, and national origin. The court held that an intake questionnaire, which does not contain a clear and concise statement of facts alleging unlawful employment practices, was insufficient to constitute a charge of discrimination. Therefore, plaintiff filed an untimely charge of discrimination which resulted in his failure to properly exhaust his administrative remedies. The court also held that equitable tolling did not apply in this case because plaintiff did not act with due diligence. View "Caycho Melgar v. T.B. Butler Publishing Co." on Justia Law

Defendant-cross claimant alleged that the city attorney violated his First Amendment right to petition for redress of grievances as well as his Fourteenth Amendment right to equal protection. The Fifth Circuit declined to reach the merits of the city attorney's qualified immunity defense to these arguments because defendant-cross claimant lacked standing to assert either. In this case, defendant-cross claimant's procedural injury did not impact any concrete interest and thus he lacked standing to claim that the city attorney violated his First Amendment right to petition. Furthermore, defendant-claimant did not encounter any barrier erected by the city attorney in the processing of the petition, and thus did not have standing to bring his equal protection claim. View "City of Hearne v. Johnson" on Justia Law

The Fifth Circuit terminated a consent decree entered in 1977, which exempts Muslim inmates from the requirement that all religious gatherings and activities in Texas state prisons attended by more than four inmates must be directly supervised by either prison staff or a prison-approved outside volunteer. The court held that the consent decree does not remain necessary to correct current and ongoing violations of the Religious Land Use and Institutionalized Persons Act, the Free Exercise Clause, or the Establishment Clause. Therefore, TDCJ's motion to vacate the consent decree should have been granted. The court vacated the award of attorneys' fees, because plaintiff and Inmate Intervenors were not prevailing parties. View "Brown v. Collier" on Justia Law

The Fifth Circuit denied the petition for rehearing en banc, granted the petition for rehearing, and withdrew its prior opinion, substituting the following opinion.The court affirmed the district court's partial grant of defendants' motion to dismiss a 42 U.S.C. 1983 action claiming that the Texas Medical Board's execution of an administrative subpoena in plaintiff's office violated the Fourth Amendment. The court held that it was clearly established at the time of this search that the medical profession as a whole is not a closely regulated industry, meaning that governmental agents violate the Constitution when they search clinics that are not pain management clinics without providing an opportunity for precompliance review. The court also held that, even assuming that pain management clinics are part of a closely regulated industry, on-demand searches of those clinics violate the constitution when the statutory scheme authorizing the search fails to provide sufficient constraints on the discretion of the inspecting officers.In this case, the unlawfulness of defendants' conduct was not clearly established at the time of the search. The court also held that the search was not pretextual; the district court did not abuse its discretion in abstaining from deciding the declaratory judgment claims; Director Robinson was not deliberately indifferent in delegating her subpoena authority in light of the fact she was acting pursuant to the regulations in the same way as her predecessors and the numerous subpoenas issued each year; and, to the extent plaintiffs sought to impose section 1983 liability on Defendants Kirby and Pease, through the subdelegation argument, that law also was not clearly established. View "Zadeh v. Robinson" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the Board and its president, alleging that defendants unlawfully deprived him of the use of several of his properties. After a jury returned a verdict for plaintiff, the district court denied the Board's motion for judgment as a matter of law or a new trial.The Fifth Circuit affirmed and held that there was legally sufficient evidence for a reasonable jury to conclude that the Board ratified the unlawful initiation of condemnation proceedings. The court rejected the Board's challenges to the jury instructions and held that, even if the instructions were erroneous, they could not have affected the outcome of the case. View "Young v. Board of Supervisors of Humphreys County" on Justia Law