Justia Civil Rights Opinion Summaries

Kate Adams, the former Chief of Police for the City of Rancho Cordova, was forced to resign over allegations that she sent racist text messages while working for the Sacramento County Sheriff’s Office. The messages, sent in 2013, included offensive images forwarded to two friends during a private conversation. Adams claimed she was merely expressing disapproval of the images. After her resignation, the messages were publicized, leading to further professional and personal repercussions for Adams.The United States District Court for the Eastern District of California dismissed Adams’s First Amendment retaliation and conspiracy claims, ruling that her speech did not address a matter of public concern. The court found that the private nature of the text messages and their content did not relate to broader societal issues or public interest.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that Adams’s private text messages, which were part of a casual conversation and not intended for public dissemination, did not constitute speech on a matter of public concern under the Pickering v. Board of Education standard. The court emphasized that the content, form, and context of the messages indicated they were of personal interest rather than public interest. Consequently, Adams’s First Amendment retaliation and conspiracy claims were dismissed, and the case was remanded for further proceedings on other unresolved claims. View "ADAMS V. COUNTY OF SACRAMENTO" on Justia Law

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

Kyle J. Rodney was convicted in Nevada state court of multiple charges, including burglary while in possession of a deadly weapon, conspiracy to commit murder, robbery with use of a deadly weapon, attempted murder with use of a deadly weapon, and battery with use of a deadly weapon resulting in substantial bodily harm. The convictions stemmed from an incident where Rodney and an accomplice attacked and severely injured Ralph Monko after Monko won a significant amount of money at a casino. Monko's injuries were severe, including head trauma and long-term physical and cognitive impairments.Rodney's convictions were affirmed by the Nevada Supreme Court. He then filed a pro se post-conviction petition for a writ of habeas corpus in state court, which was denied without the appointment of counsel or an evidentiary hearing. A second post-conviction petition was also denied on procedural grounds. Rodney subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254, raising several ineffective-assistance-of-counsel (IAC) claims. The federal district court found these claims procedurally defaulted. On appeal, the Ninth Circuit vacated and remanded for the district court to determine if the procedural default could be excused under Martinez v. Ryan, which allows for such an excuse if the IAC claims are substantial.The United States District Court for the District of Nevada, on remand, initially allowed new evidence and discovery but later ruled that it could not consider new evidence due to the Supreme Court's decision in Shinn v. Ramirez. The district court concluded that Rodney's IAC claims were not substantial based on the state-court record alone and denied relief.The Ninth Circuit Court of Appeals affirmed the district court's decision. The court held that Rodney did not fail to develop the state-court record within the meaning of 28 U.S.C. § 2254(e)(2) and that the district court erred in limiting its analysis to the state-court record. However, the Ninth Circuit found that even considering the new evidence, Rodney's IAC claims were not substantial. The court concluded that there was no reasonable probability that the outcome of Rodney's trial or sentencing would have been different but for counsel's alleged errors. Thus, the procedural default of Rodney's claims could not be excused, and the denial of his habeas petition was affirmed. View "RODNEY V. GARRETT" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

In the summer of 2020, Derrick Sanderlin attended a protest in San Jose, California, where he was struck in the groin by a 40mm foam baton round fired by Officer Michael Panighetti. Sanderlin alleged that Panighetti's use of force was retaliatory and excessive, violating his First and Fourth Amendment rights. Sanderlin claimed he was peacefully protesting and did not hear any warnings before being shot. Panighetti argued that Sanderlin was obstructing officers from targeting other individuals who posed a threat.The United States District Court for the Northern District of California denied Panighetti's motion for summary judgment, concluding that genuine disputes of material fact existed regarding whether Panighetti's actions were retaliatory and whether the force used was excessive. The court found that a jury could determine that Sanderlin was engaged in protected First Amendment activity and that Panighetti's actions were motivated by retaliatory animus. Additionally, the court held that a reasonable jury could find that Sanderlin was seized under the Fourth Amendment and that the force used was unreasonable.The United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of qualified immunity to Panighetti. The Ninth Circuit held that, viewing the evidence in the light most favorable to Sanderlin, genuine disputes of material fact existed as to whether Panighetti's use of force was retaliatory and excessive. The court concluded that it was clearly established that police officers may not use their authority to retaliate against individuals for protected speech and that the use of a 40mm foam baton round against a non-threatening individual constituted excessive force. The court also determined that subsequent legal developments did not alter the clearly established law at the time of the incident. View "SANDERLIN V. DWYER" on Justia Law

A federal inmate, Mitchell Garraway, filed a Bivens action against three prison officials, alleging they were deliberately indifferent to his safety, violating his Eighth Amendment rights. Garraway claimed that despite informing the officials of his cellmate's violent behavior and requesting a cell change, they refused, resulting in an assault by his cellmate. The officials moved for judgment on the pleadings, arguing no Bivens remedy exists for failure to protect an inmate from prisoner violence. The district court denied this motion, and after the Supreme Court's decision in Egbert v. Boule, the officials sought reconsideration, which was also denied. They then filed an interlocutory appeal.The United States District Court for the Eastern District of California initially denied the officials' motion for judgment on the pleadings, agreeing with Garraway that his case did not differ meaningfully from Farmer v. Brennan. After the Supreme Court's decision in Egbert, the officials filed a motion to reconsider, which was denied by the district court, reaffirming that Farmer remained intact post-Egbert. The officials then filed an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and dismissed the interlocutory appeal for lack of jurisdiction. The court held that district court orders extending Bivens, absent a denial of qualified immunity, are not immediately appealable under the collateral order doctrine. The court emphasized that delaying review of such orders does not threaten significant public interests and that any improper judicial intrusion into the legislative function can be effectively rectified upon review of a final judgment. The court concluded that the next logical step in the litigation would be for the federal-officer defendant to claim qualified immunity, the denial of which would be immediately appealable. View "GARRAWAY V. CIUFO" on Justia Law

A group of LGBTQ+ students sued the U.S. Department of Education, alleging that they experienced discrimination at religious colleges and universities that receive federal funding. They challenged the religious exemption to Title IX, which allows religious institutions to discriminate based on gender if it conflicts with their religious tenets. The plaintiffs claimed this exemption violated the First Amendment's Establishment Clause and the Fifth Amendment's equal protection guarantee. They also argued that the Department's 2020 amendment to Title IX regulations, which clarified that institutions do not need to submit a written statement to claim the exemption, was arbitrary and capricious under the Administrative Procedure Act (APA).The United States District Court for the District of Oregon dismissed the plaintiffs' claims. It ruled that the plaintiffs failed to state a claim that the religious exemption violated the First and Fifth Amendments. The court also found that the plaintiffs lacked standing to challenge the 2020 amendment under the APA. The court denied the plaintiffs' motion to amend their complaint, concluding that any amendment would be futile.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The Ninth Circuit held that the Title IX religious exemption does not violate the Establishment Clause under the historical practices and understanding test set forth in Kennedy v. Bremerton School District. The court found that the exemption is consistent with a long history of religious accommodations in U.S. law. The court also held that the exemption does not violate the Fifth Amendment's equal protection guarantee, as it is substantially related to the important governmental objective of accommodating religious exercise. Finally, the court agreed that the plaintiffs lacked standing to challenge the 2020 amendment, as they did not show that the rule caused them harm. The court also upheld the denial of leave to amend the complaint. View "HUNTER V. USEDU" on Justia Law

The case involves a challenge to the Hawai‘i Court Records Rules, which mandate that all medical and health records filed in any court proceeding be filed under seal without further judicial order. The plaintiff, Civil Beat Law Center for the Public Interest, argued that this rule is unconstitutionally overbroad under the First Amendment, which grants the public a presumptive right to access court records.The United States District Court for the District of Hawai‘i granted summary judgment in favor of the defendants, the Chief Court Administrators of the Hawai‘i state courts. The district court held that the public does not have a presumptive First Amendment right to access medical and health records, and even if such a right existed, requiring case-by-case litigation to unseal these records did not violate the First Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the First Amendment grants the public a presumptive right to access a substantial portion of the records sealed under Hawai‘i’s mandatory sealing provision. The court found that the state’s interest in protecting individual privacy rights does not justify the categorical sealing of all medical and health records without any case-by-case consideration. The court concluded that the mandatory sealing rule is not the least restrictive means of protecting privacy interests and that case-by-case judicial review would better balance privacy concerns with the public’s right to access.The Ninth Circuit held that the Hawai‘i Court Records Rules are unconstitutionally overbroad because they encroach on the public’s right of access to court records. The court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "CIVIL BEAT LAW CENTER FOR THE PUBLIC INTEREST, INC V. MAILE" on Justia Law