Justia Civil Rights Opinion Summaries

Seattle Pacific University (SPU), a religious institution, filed a lawsuit against the Washington Attorney General, alleging First Amendment violations arising from the Attorney General's investigation into the university's employment policies and history under the Washington Law Against Discrimination (WLAD). SPU prohibits employees from engaging in same-sex intercourse and marriage. After receiving complaints, the Attorney General requested documents related to SPU's employment policies, employee complaints, and job descriptions. SPU sought to enjoin the investigation and any future enforcement of WLAD.The district court dismissed the suit, citing lack of redressability and Younger abstention. The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that SPU failed to allege a cognizable injury for its retrospective claims, as the Attorney General's request for documents carried no penalties for non-compliance. However, the court found that SPU had standing for its prospective pre-enforcement injury claims, as SPU intended to continue employment practices arguably proscribed by WLAD, the Attorney General had not disavowed its intent to investigate and enforce WLAD against SPU, and SPU's injury was redressable. The court also held that Younger abstention was not warranted as there were no ongoing enforcement actions or any court judgment. The case was remanded to the district court to consider prudential ripeness. View "SEATTLE PACIFIC UNIVERSITY V. FERGUSON" on Justia Law

The case involves Rosalina Calonge, who sued Officer Edward Carboni and the City of San Jose under 42 U.S.C. § 1983, alleging that Officer Carboni used excessive deadly force when he shot and killed her son, Francis Calonge. The incident occurred when police officers responded to 911 calls reporting a man with a gun. They located Francis Calonge, who had what appeared to be a gun in his waistband. Officer Carboni shot and killed Calonge after following him for about a minute as he walked down a street.The United States District Court for the Northern District of California granted summary judgment in favor of Officer Carboni, ruling that he was entitled to qualified immunity because the plaintiff had failed to identify specific caselaw clearly establishing that Officer Carboni’s conduct violated the Fourth Amendment.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court found that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could decide that Officer Carboni violated Calonge’s Fourth Amendment right to be free from excessive force. The court also concluded that the relevant law was clearly established at the time, so Officer Carboni was not entitled to qualified immunity. The court resolved three disputed facts in the plaintiff’s favor for purposes of the appeal: Calonge was not drawing his gun or making a threatening gesture when Officer Carboni shot him; there were no bystanders in Calonge’s vicinity when he was shot; and officers did not instruct Calonge to get on the ground or otherwise stop. The court held that the totality of the circumstances did not justify deadly force. View "CALONGE V. CITY OF SAN JOSE" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law

The case revolves around Elizabeth Carley, an inmate in the custody of the Nevada Department of Corrections (NDOC), who filed a suit against Dr. Romeo Aranas, the former Medical Director of NDOC. Carley alleged that Dr. Aranas was deliberately indifferent to her medical needs when he denied her request for certain Hepatitis C (HCV) treatment. The district court denied Dr. Aranas' motion for summary judgment, concluding that he was not entitled to qualified immunity at that time.Previously, the district court had concluded that there was a genuine dispute of material fact as to whether Dr. Aranas was deliberately indifferent to Carley's serious medical needs. However, it did not proceed to the second step of the qualified immunity inquiry, which was whether the violation was clearly established at the time of the violation.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Dr. Aranas was entitled to qualified immunity because no clearly established law rendered the HCV policies unconstitutional at the time of the alleged violation. The court concluded that no decision of the Supreme Court, this court, or a “consensus of courts” would have put Dr. Aranas on notice that the relevant inmate treatment prioritization schemes violated the Eighth Amendment during his time as the NDOC Medical Director. Therefore, the court reversed the district court’s order and remanded with instructions to grant summary judgment for Dr. Aranas. View "CARLEY V. ARANAS" on Justia Law

A class of indigent criminal defendants in Oregon, who were incarcerated and awaiting trial without legal representation, filed a federal habeas corpus petition. They argued that the state's failure to provide them with counsel violated their Sixth Amendment rights. The district court issued a preliminary injunction requiring that counsel be provided within seven days of the initial appearance, and if this did not occur, the defendants must be released from custody subject to reasonable conditions imposed by Oregon Circuit Court judges.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the district court did not abuse its discretion in concluding that the petitioners were likely to succeed on the merits of their Sixth Amendment claim. The court reasoned that without counsel, the petitioners could not understand, prepare for, or progress to critical stages of their cases. The court also held that the district court did not abuse its discretion in concluding that the petitioners were suffering and would continue to suffer irreparable harm. The court found that the public has an interest in a functioning criminal justice system and the protection of fundamental rights. View "Betschart v. Washington County Circuit Court Judges" on Justia Law

The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

The case involves a challenge to the constitutionality of private prisons in Arizona. The plaintiffs, the Arizona State Conference of the National Association for the Advancement of Colored People (NAACP) and two former prisoners, argued that private prisons, driven by profit, compromise safety and security and reduce programming and services. They also claimed that private prisons have a financial incentive to keep prisoners incarcerated longer by manipulating disciplinary proceedings.The United States District Court for the District of Arizona dismissed the case, leading to an appeal to the United States Court of Appeals for the Ninth Circuit. The district court held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights, the Thirteenth Amendment, the Eighth Amendment, and the Fourteenth Amendment's Equal Protection and Due Process Clauses.The Ninth Circuit affirmed the district court's decision. The court found that the NAACP had standing to bring the suit. However, it held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights. The court also found that the Thirteenth Amendment does not prohibit incarceration in a private prison, and that the plaintiffs failed to plausibly allege that confinement in a private prison violates the Eighth Amendment. Finally, the court held that the Fourteenth Amendment's Due Process and Equal Protection Clauses do not prohibit incarceration in a private prison. View "NIELSEN V. THORNELL" on Justia Law

The plaintiff, Ronald Hittle, was the Fire Chief for the City of Stockton, California. He alleged that he was terminated from his position due to his religion, specifically his attendance at a religious leadership event. The City of Stockton, former City Manager Robert Deis, and former Deputy City Manager Laurie Montes were named as defendants. The City had hired an independent investigator, Trudy Largent, to investigate various allegations of misconduct against Hittle. Largent's report sustained almost all of the allegations, including Hittle's use of city time and a city vehicle to attend a religious event, his failure to properly report his time off, potential favoritism of certain Fire Department employees based on a financial conflict of interest not disclosed to the City, and endorsement of a private consultant's business in violation of City policy.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. The court also found that Hittle failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that employment discrimination claims under Title VII and the California Fair Employment and Housing Act are analyzed under the McDonnell Douglas burden-shifting framework. The court concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants. The court found that the district court's grant of summary judgment in the defendants' favor was appropriate where the defendants' legitimate, non-discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual. View "HITTLE V. CITY OF STOCKTON" on Justia Law

Five registered gun owners in California challenged a state law, Assembly Bill 173 (AB 173), which permits the California Department of Justice (DOJ) to share information from its databases about firearm and ammunition purchasers and concealed carry weapon (CCW) permit holders with accredited research institutions. The plaintiffs argued that the law violated their right to informational privacy under the Fourteenth Amendment, their Second Amendment right to keep and bear arms, and the federal Privacy Act.The district court dismissed the case, finding that the plaintiffs failed to state a claim for violation of the right to informational privacy. The court reasoned that the personal information in the DOJ's databases was not highly sensitive or intimate and that the plaintiffs had no reasonable expectation that such information would never be disclosed. The court also found that AB 173 did not restrict conduct protected by the Second Amendment, as it did not impede the plaintiffs' ability to purchase, keep, carry, or use firearms. The court further held that AB 173 was not unconstitutionally retroactive, as it did not attach new legal consequences to past conduct. Finally, the court rejected the plaintiffs' claim that the Privacy Act preempted two California statutes relating to CCW permit applications, as neither statute required the disclosure of social security numbers.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision, agreeing with its findings and reasoning. The court held that the plaintiffs failed to state a claim for violation of the right to informational privacy, the Second Amendment, or the Privacy Act. View "JANE DOE V. BONTA" on Justia Law

Diamond S.J. Enterprise, Inc., which operates a nightclub in San Jose, California, had its license suspended for thirty days by the city following a shooting outside the club. The city held an administrative hearing and found that Diamond had operated its venue in a way that caused the shooting and created a public nuisance, violating San Jose's entertainment business licensing provisions. Diamond filed a complaint in federal court, alleging First Amendment and due process violations.The case was first heard in the United States District Court for the Northern District of California, which dismissed Diamond's claims and granted summary judgment for the City of San Jose. The district court ruled that the challenged provisions did not implicate First Amendment rights and that the city had satisfied due process requirements.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's decision, holding that Diamond's facial attack on the city's public entertainment business licensing provisions failed because the provisions did not give city officials unbridled discretion that created a risk of censorship. The court also held that Diamond failed to state a procedural due process claim, as the licensing scheme provided Diamond with notice, an opportunity to be heard, the ability to present and respond to evidence, and a pre-deprivation appeal, followed by post-deprivation review by the California Superior Court. View "Diamond S.J. Enterprise, Inc. v. City of San Jose" on Justia Law