Justia Civil Rights Opinion Summaries

Plaintiffs Tati Abu King and Toni Heath Johnson were unable to register to vote in Virginia due to felony convictions. King was convicted of felony drug possession in 2018, and Johnson was convicted of multiple felonies, including drug possession, in 2021. Virginia's constitution disenfranchises individuals convicted of felonies unless their civil rights are restored by the Governor or other appropriate authority. King and Johnson argued that this disenfranchisement violated the Virginia Readmission Act, a federal statute from 1870, which they claimed restricted Virginia from amending its constitution to disenfranchise individuals for crimes that were not felonies at common law in 1870.The United States District Court for the Eastern District of Virginia dismissed three of the four counts in the plaintiffs' complaint for failure to state a claim but allowed one count based on the Virginia Readmission Act to proceed. The defendants, including various state election officials and the Governor of Virginia, moved to dismiss the complaint on sovereign immunity grounds, which the district court rejected.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiffs' claim met the requirements of the Ex parte Young doctrine, which allows suits for prospective relief against state officials to prevent ongoing violations of federal law. The court affirmed the district court's decision to allow the claim to proceed against most defendants but reversed the decision regarding the Governor of Virginia and the Secretary of the Commonwealth, finding that they lacked enforcement responsibility for the challenged state action. The court concluded that the Governor and Secretary must be dismissed from the case on sovereign immunity grounds. The district court's order was thus affirmed in part and reversed in part. View "King v. Youngkin" on Justia Law

Ashleigh Gelin died by suicide in November 2013 while incarcerated at the Baltimore County Detention Center. Her parents, Edward and Deborah Gelin, sued Baltimore County and several correctional officers, alleging violations of 42 U.S.C. § 1983, the Maryland Declaration of Rights, and Maryland common law. They claimed the officers showed deliberate indifference to Ashleigh's safety and were grossly negligent.The United States District Court for the District of Maryland partially granted and partially denied the County's motion for judgment on the pleadings. The court found that the complaint did not properly allege deliberate indifference to Ashleigh's mental health needs but did plausibly allege indifference to her physical safety. The court held that the officers could not claim qualified immunity or Maryland common-law public official immunity and denied Baltimore County's claim of governmental immunity. The County's subsequent motion for reconsideration was partially addressed, but the court did not rule on whether the officers could assert public official immunity against the negligence claims.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the County's appeal was premature because the district court had not yet ruled on all issues raised in the County's motion for reconsideration. Specifically, the district court had not decided whether the officers could assert public official immunity against the negligence claims. As a result, the Fourth Circuit held the appeal in abeyance, pending the district court's resolution of the remaining issue. The court directed the parties to inform it once the district court had made a final ruling on the pending issue. View "Gelin v. Baltimore County" on Justia Law

Brandon Williams was involved in a series of interactions with Norfolk, Virginia police officers. Initially, Officer John D. McClanahan falsely charged Williams with misdemeanor trespassing and perjured himself at trial to secure a conviction. Williams appealed and used a recording to expose McClanahan's perjury, leading to the dismissal of the charge by the state appellate court. Two weeks later, Williams was hit by a speeding drunk driver, and responding officers, including McClanahan, allegedly falsified the accident report to deprive Williams of his right to sue the other driver.Williams filed a lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of retaliation for exercising his First and Sixth Amendment rights, conspiracy, and intentional infliction of emotional distress (IIED). The district court dismissed Williams' retaliation claim, finding he failed to plead an adverse action, and dismissed his conspiracy claim for lack of a constitutional violation. The court also dismissed Williams' state law IIED claims without prejudice, declining to exercise supplemental jurisdiction.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Williams adequately alleged that the officers' intentional misrepresentation on the accident report would likely deter him from recording police activity and defending himself at trial in the future. Therefore, the court reversed the district court's dismissal of his retaliation claim. The court also vacated the dismissal of his conspiracy claim, finding a plausible constitutional violation, and remanded the claim for reconsideration. Finally, the court vacated the dismissal of Williams' IIED claims and remanded them for further consideration. View "Williams v. Mitchell" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

Two plaintiffs, Smith-Phifer and Patterson, served with the Charlotte Fire Department for over twenty years and alleged racial discrimination by the department. They filed a lawsuit against the City of Charlotte, claiming violations of Title VII, 42 U.S.C. §§ 1981 & 1983, and the North Carolina Constitution. The case was initially brought in state court but was removed to federal court. Smith-Phifer and the City reached a settlement during her trial, while Patterson's case was delayed due to illness and later went to mediation.The United States District Court for the Western District of North Carolina granted Smith-Phifer and Patterson’s motions to enforce their settlement agreements. The court found that the City breached the agreements by not treating the settlement payments as pension-eligible wages under the Charlotte Firefighters Retirement Systems Act. The City appealed, arguing that the district court erred in its decision, particularly in not holding an evidentiary hearing for Patterson’s case and in its interpretation of the settlement terms regarding pension eligibility.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s order regarding Patterson, stating that an evidentiary hearing was necessary to determine whether a complete settlement agreement was reached. The court found that there were unresolved factual disputes about the terms of the agreement, particularly regarding sick leave and pension eligibility.However, the court affirmed the district court’s decision regarding Smith-Phifer. It held that the City breached the settlement agreement by failing to make the required retirement deduction from the payment to Smith-Phifer. The court concluded that the payment was “Compensation” under the Charlotte Firefighters Retirement Systems Act, which mandated the deduction. The case was remanded for further proceedings consistent with these findings. View "Smith-Phifer v. City of Charlotte" on Justia Law

Jonathan Eugene Brunson, an inmate in North Carolina, filed a § 1983 action against the North Carolina Attorney General and other state officials, seeking various forms of relief. Brunson acknowledged that he had previously filed four § 1983 suits that were dismissed under Heck v. Humphrey, which bars federal courts from entertaining § 1983 suits for damages that would undermine the legality of a conviction unless the conviction has been invalidated. Despite these dismissals, Brunson moved to proceed in forma pauperis.The United States District Court for the Eastern District of North Carolina initially granted Brunson’s request to proceed in forma pauperis but later vacated that order, citing the Prison Litigation Reform Act’s (PLRA) three-strikes rule. The district court determined that Brunson’s prior dismissals under Heck counted as strikes for failure to state a claim. Consequently, Brunson prepaid the filing fee, but his § 1983 complaint was eventually dismissed for reasons not relevant to the current appeal. Brunson then appealed and applied to proceed on appeal without prepaying fees, arguing that Heck dismissals should not count as PLRA strikes.The United States Court of Appeals for the Fourth Circuit reviewed the case to determine whether a dismissal under Heck constitutes a strike under the PLRA. The court held that a Heck dismissal is necessarily for failure to state a claim because it denies the existence of a cause of action unless the plaintiff can prove that the conviction or sentence has been invalidated. Therefore, such dismissals count as strikes under the PLRA. As Brunson had at least three prior Heck dismissals, the court denied his motion to proceed in forma pauperis on appeal. View "Brunson v. Stein" on Justia Law

In 1999, a Virginia state court jury convicted Askari Lumumba of second-degree murder and other related charges, sentencing him to fifty-eight years in prison. While serving his sentence, Lumumba engaged in communications that led to disciplinary action. He spoke on the phone about organizing inmates and sent emails discussing potential group actions within the prison. As a result, he was charged with attempting to garner support for a group demonstration, violating Disciplinary Offense Code 128, which prohibits participating in or encouraging work stoppages or group demonstrations.Lumumba's disciplinary hearing concluded with a finding of guilt, resulting in 30 days of disciplinary segregation and a loss of 180 days of good-conduct sentence credits. His appeals to the Warden and Regional Director were denied. He then petitioned for a writ of habeas corpus in the Supreme Court of Virginia, which was denied on jurisdictional grounds. Subsequently, Lumumba filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing that Offense Code 128 was void for vagueness and violated the First Amendment. The district court dismissed his petition, finding the regulation clear and reasonably related to legitimate penological interests.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Offense Code 128 is not facially unconstitutional under the First Amendment, as it reasonably relates to maintaining order and security in prisons. The court also found that the regulation is not void for vagueness, as it provides sufficient notice of prohibited conduct and does not invite arbitrary enforcement. Consequently, the Fourth Circuit affirmed the district court's dismissal of Lumumba's petition. View "Lumumba v. Kiser" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

Alexis Guerrero, a Black Dominican-American, sued Ollie’s Bargain Outlet under 42 U.S.C. § 1981 for race discrimination. Guerrero alleged that while shopping for flowerpots at an Ollie’s store in Salisbury, Maryland, an employee named Richard Murray threatened him with a knife and shouted racial slurs, preventing him from purchasing the items. Guerrero claimed that this discriminatory conduct interfered with his right to make and enforce contracts.The United States District Court for the District of Maryland granted Ollie’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The court reasoned that Guerrero failed to sufficiently allege that he was denied the opportunity to contract for goods or services that was otherwise afforded to white customers. Specifically, the court found that Guerrero did not claim that Ollie’s actually prevented him from purchasing a flowerpot and noted that he voluntarily left the store without attempting to make a purchase.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Guerrero sufficiently alleged a contractual interest by demonstrating his intent to purchase the flowerpots and that Murray’s actions, including wielding a knife and shouting racial slurs, interfered with this interest. The court found that Guerrero’s allegations were enough to show that he was denied the opportunity to contract based on his race. Consequently, the Fourth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Guerrero v. Ollie's Bargain Outlet, Inc." on Justia Law

Detective Frias of the Richmond Police Department observed an Instagram video showing known gang member J.S. and others brandishing firearms at the Belt Atlantic apartment complex. The video, posted shortly before the incident, depicted two men later identified as Anthony Cornelius Brown, Jr., and Dequane Aquil McCullers. Detectives accessed live surveillance footage showing individuals matching the video’s description at the same location. Upon arrival, the officers approached the men, who attempted to walk away. Brown and McCullers were detained and frisked, leading to the discovery of firearms.The United States District Court for the Eastern District of Virginia denied Brown and McCullers' motions to suppress the evidence of the firearms. The court found that the officers had reasonable suspicion to stop and frisk the defendants based on the video and their behavior. Brown and McCullers entered conditional guilty pleas, reserving the right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officers had reasonable suspicion to stop Brown and McCullers based on the Instagram video and their actions upon the officers' arrival. The court also found that the frisk of McCullers was justified as the officers reasonably believed he was armed. Additionally, the court ruled that the length of Brown’s detention was reasonable given the circumstances and the need to ensure officer safety. The Fourth Circuit affirmed the district court’s denial of the motions to suppress. View "US v. Brown" on Justia Law