Justia Civil Rights Opinion Summaries

The case involves Robert Paul Rundo and Robert Boman, who were charged with conspiracy to violate the Anti-Riot Act and with substantively violating the Act. The indictment alleges that Rundo is a founding member of the "Rise Above Movement" (RAM), a militant white supremacist group. Rundo and Boman, along with other RAM members, attended several political rallies where they violently attacked counter-protesters. The indictment details their involvement in rallies in Huntington Beach, Berkeley, San Bernardino, and Charlottesville, where they engaged in organized violence and later boasted about their actions online.The United States District Court for the Central District of California initially dismissed the indictment, finding the Anti-Riot Act unconstitutional due to facial overbreadth under the First Amendment. The Ninth Circuit reversed this decision, holding that the Act was not facially overbroad except for certain severable portions. On remand, the district court dismissed the indictment again, this time based on a claim of selective prosecution. The district court concluded that the government selectively prosecuted RAM members while ignoring the violence of Antifa and related far-left groups, suggesting that the prosecution was based on the offensive nature of RAM's speech.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 Rundo did not meet his burden to demonstrate that similarly situated individuals were not prosecuted and that his prosecution was based on an impermissible motive. The court found that the district court erred by comparing collective conduct to individual conduct and by holding that individual Antifa members were similarly situated to Rundo. The Ninth Circuit also held that Rundo failed to show that his prosecution was based on an impermissible motive, noting that timing and other factors cited by the district court were insufficient. The court reinstated the indictment and remanded the case for trial. View "USA V. RUNDO" on Justia Law

Vincent Bell, a pretrial detainee with an amputated right leg, alleged that deputies used excessive force during a cell extraction and transfer at the San Francisco Jail. Bell claimed that Sergeant Yvette Williams did not provide him with a wheelchair or other mobility device, forcing him to hop on one leg until he fell. Deputies then carried him by his arms and leg, causing him pain and minor injuries. Bell sued under the Fourteenth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act.The United States District Court for the Northern District of California held a jury trial. The jury found in favor of Bell on his excessive force claim against Williams and his ADA and Rehabilitation Act claims against the City and County of San Francisco. However, the jury did not find that Williams caused Bell physical or emotional harm. The jury awarded Bell $504,000 in compensatory damages against the City but not against Williams. The district court denied the defendants' post-trial motion for judgment as a matter of law or a new trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the jury's verdict on Bell's Fourteenth Amendment excessive force claim and his ADA and Rehabilitation Act claims, finding substantial evidence supported these claims. However, the court reversed the district court's decision on Bell's Monell theory of liability, concluding that Bell did not present substantial evidence showing that the City's training was the product of deliberate indifference to a known risk. The court also vacated the jury's compensatory damages award, deeming it grossly excessive, and remanded for a remittitur or a new trial on damages. View "BELL V. WILLIAMS" on Justia Law

Zachary Rosenbaum was arrested by San Jose police officers, during which a police dog allegedly bit him for over twenty seconds after he had surrendered and lay prone on his stomach with his arms outstretched. Rosenbaum sued the City of San Jose and the officers involved under 42 U.S.C. § 1983, claiming excessive force in violation of the Fourth Amendment. He alleged that the prolonged dog bite caused severe lacerations and permanent nerve damage to his arm.The United States District Court for the Northern District of California denied the defendants' motion for summary judgment based on qualified immunity. The defendants appealed, arguing that the bodycam video contradicted Rosenbaum's allegations. However, the district court found that the video did not contradict Rosenbaum's claims and that whether the officers acted reasonably was a triable question for the jury.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's denial of qualified immunity. The Ninth Circuit held that the bodycam video generally supported Rosenbaum's allegations and that a reasonable jury could find that the officers used excessive force. The court noted that it was clearly established in the Ninth Circuit that officers violate the Fourth Amendment when they allow a police dog to continue biting a suspect who has fully surrendered and is under officer control. Therefore, the court concluded that the officers were not entitled to qualified immunity and affirmed the district court's decision. View "Rosenbaum v. City of San Jose" on Justia Law

Rosa Cuevas was a passenger in a car driven by Quinntin Castro, who led police on a high-speed chase. After getting stuck in mud, Castro continued trying to flee. Police officers surrounded the car, broke the window, and sent a police dog inside. Castro shot and killed the dog and injured an officer. The officers returned fire, aiming at Castro but accidentally hitting Cuevas multiple times. Castro was ultimately killed, and Cuevas survived with severe injuries. Cuevas sued the City of Tulare and the involved officers under 42 U.S.C. § 1983 and California law, alleging excessive force.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Cuevas was not seized for Fourth Amendment purposes and, alternatively, that even if she were seized, the officers were entitled to qualified immunity because it was not clearly established that their use of force was excessive. The court declined to exercise supplemental jurisdiction over the state law claims and the defendants' counterclaims.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Cuevas was indeed seized under clearly established Fourth Amendment law. However, it was not clearly established that the force used by the officers was excessive. The court found that none of the cases cited by Cuevas clearly established that officers violated her rights when they shot her while defensively returning fire during an active shooting. The court also noted that in excessive-force cases where police officers face a threat, the obviousness principle will rarely be available as an end-run to the requirement that law must be clearly established. Therefore, the officers were entitled to qualified immunity. View "Cuevas v. City of Tulare" on Justia Law

The case involves Delaney Marks, who was convicted of murder and sentenced to death in California in 1994. Marks appealed his conviction, arguing that he was incompetent to stand trial and that he is intellectually disabled, making him ineligible for the death penalty. The United States Court of Appeals for the Ninth Circuit affirmed in part and vacated in part the district court’s judgment denying Marks's federal habeas petition.Marks's claim that he was incompetent to stand trial was denied. The court found that although Marks presented substantial evidence of incompetence, there was a reasonable basis in the record for the California Supreme Court to deny this claim.However, the court held that the district court erred by denying relief on Marks's claim that he is intellectually disabled and thus ineligible for the death penalty. Marks had shown that the California Supreme Court’s rejection of this claim was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding.The court also held that the district court properly denied relief on Marks's claim that the judge adjudicating his Atkins claim was biased against him. The California Supreme Court reasonably could have concluded that the judge did not display a deep-seated favoritism or antagonism that would make fair judgment impossible.The court affirmed the district court's denial of relief on Marks's claims of ineffective assistance of counsel. The California Supreme Court reasonably could have concluded that a second competency hearing would have reached the same conclusion as a jury which had already found Marks competent.In sum, the court vacated the district court’s denial of Marks’s Atkins claim and remanded for de novo review of that claim. The court otherwise affirmed the district court's decision. View "Marks v. Davis" on Justia Law

The case involves Dr. Firdos Sheikh, who brought Fourth and Fifth Amendment claims against former special agents with the Department of Homeland Security Investigations (HSI). Dr. Sheikh alleged that the agents fabricated evidence in a search warrant affidavit and submitted misleading reports to prosecutors, leading to her arrest and criminal prosecution.Previously, the district court dismissed Dr. Sheikh's claims. The court applied the two-step framework from Ziglar v. Abbasi to determine whether implied causes of action existed. The court held that Dr. Sheikh's claims presented a new context as they differed from cases where the Supreme Court implied a damages action. The court also found that several special factors indicated that the Judiciary was arguably less equipped than Congress to weigh the costs and benefits of allowing a damages action to proceed.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court agreed that Dr. Sheikh's claims presented a new context under Bivens and that special factors counseled hesitation in extending an implied cause of action. The court noted that the claims risked intrusion into the Executive Branch's prosecutorial decision-making process, were leveled against agents of HSI who investigate immigration and cross-border criminal activity, and alternative remedial structures existed. View "Sheikh v. Department of Homeland Security" on Justia Law

The plaintiff, Purushothaman Rajaram, a naturalized U.S. citizen, alleged that Meta Platforms, Inc., refused to hire him because it preferred to hire noncitizens holding H1B visas, to whom it could pay lower wages. Rajaram claimed that this constituted employment discrimination under 42 U.S.C. § 1981, which prohibits discrimination in hiring against U.S. citizens based on their citizenship.The district court dismissed Rajaram's complaint, ruling that section 1981 does not prohibit discrimination based on U.S. citizenship. Rajaram appealed this decision to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit disagreed with the district court's interpretation of section 1981. The appellate court held that the statutory text of section 1981 prohibits employers from discriminating against U.S. citizens. The court reasoned that an employer that discriminates against U.S. citizens gives one class of people—noncitizens—a greater right to make contracts than U.S. citizens. This interpretation, the court held, is consistent with the plain language of the statute, which guarantees that all persons shall have the same right to make and enforce contracts as is enjoyed by white citizens.The Ninth Circuit reversed the district court's dismissal of Rajaram's employment discrimination action and remanded the case for further proceedings. The court concluded that section 1981 does prohibit discrimination in hiring against U.S. citizens on the basis of their citizenship. View "RAJARAM V. META PLATFORMS, INC." on Justia Law

The case involves Jeremy and Kristy Morris, who sued the West Hayden Estates First Addition Homeowners Association (HOA) under the Fair Housing Act. The Morrises alleged that the HOA discriminated against them based on religion by attempting to prevent them from conducting a Christmas program. The jury ruled in favor of the Morrises, awarding them compensatory and punitive damages. However, the district court granted judgment as a matter of law to the HOA, alternatively granted a new trial, and issued a permanent injunction against future productions of the Christmas program that violate the HOA’s covenants, conditions, restrictions, and easements.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s judgment. The appellate court held that the district court properly granted judgment as a matter of law to the HOA as to the Morrises’ disparate treatment claim under 42 U.S.C. § 3604(b) because they did not show that they were adversely affected by the HOA’s actions. However, the court reversed the district court's judgment as a matter of law on the Morrises’ claim that the HOA interfered with their right to purchase and enjoy their home free from discrimination, in violation of 42 U.S.C. § 3617. The court affirmed the district court’s grant of a new trial to the HOA as to the § 3617 claim and vacated the district court’s grant of an injunction to the HOA. The case was remanded for further proceedings. View "MORRIS V. WEST HAYDEN ESTATES FIRST ADDITION HOMEOWNERS ASSOCIATION, INC." on Justia Law

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

In March 2020, Idaho enacted the Fairness in Women’s Sports Act, a law that categorically bans transgender women and girls from participating in women's student athletics. The Act also provides a sex dispute verification process, which allows any individual to dispute the sex of any student athlete participating in female athletics in the State of Idaho and require her to undergo intrusive medical procedures to verify her sex. Lindsay Hecox, a transgender woman who wished to try out for the Boise State University women’s track and cross-country teams, and Jane Doe, a cisgender woman who played on high school varsity teams and feared that her sex would be disputed under the Act due to her masculine presentation, filed a lawsuit against the Act.The United States District Court for the District of Idaho granted a preliminary injunction against the Act, holding that it likely violated the Equal Protection Clause of the Fourteenth Amendment. The court found that the Act subjects only students who wish to participate in female athletic competitions to an intrusive sex verification process and categorically bans transgender girls and women at all levels from competing on female teams. The court also found that the State of Idaho failed to provide any evidence demonstrating that the Act is substantially related to its asserted interests in sex equality and opportunity for women athletes.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision, holding that the Act likely violates the Equal Protection Clause. The court found that the Act discriminates on the basis of transgender status and sex, and that it is not substantially related to its stated goals of equal participation and opportunities for women athletes. The court remanded the case to the district court to reconsider the appropriate scope of injunctive relief. View "Hecox v. Little" on Justia Law