Justia Civil Rights Opinion Summaries

Sanjay Tripathy, a former inmate in the New York correctional system, filed a lawsuit against state prison officials. He claimed that they forced him to enroll in a sex-offender program that required him to accept responsibility for his crimes, which he argued violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment. He also claimed that he was assigned to a more intensive tier of the program in violation of his due process rights, and that he was retaliated against after he challenged the program by filing grievances and this lawsuit.The United States District Court for the Western District of New York dismissed Tripathy's claims. The court ruled that his claim for damages under RLUIPA was barred by precedent that the statute does not permit individual-capacity damages. The court also found that his demands for injunctive and declaratory relief became moot when his state convictions were vacated and he was released from prison. Regarding his constitutional claims, the court concluded that Tripathy’s free exercise claim under the First Amendment was barred by qualified immunity, that he lacked standing to seek damages for his due process claim under the Fourteenth Amendment, and that he failed to state a claim for retaliation in violation of the First Amendment.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Tripathy's claim for damages under RLUIPA was barred by precedent, that his demands for injunctive and declaratory relief were moot due to his release from prison, and that his constitutional claims were properly dismissed by the district court. View "Tripathy v. McKoy" on Justia Law

Jason Doherty, a former student at Purchase College, State University of New York, who has Asperger Syndrome, sued several administrators of the college under the Americans with Disabilities Act (ADA) for declaratory and injunctive relief and emotional distress damages. The lawsuit was initiated after the college issued no-contact orders against Doherty at the request of three other students during his freshman orientation in August 2017.The United States District Court for the Southern District of New York dismissed Doherty's claims, ruling that it lacked subject matter jurisdiction over his claims for declaratory and injunctive relief since they were moot, and that Doherty failed to state a claim for damages because emotional distress damages are not available under Title II of the ADA. The district court based its decision on the Supreme Court’s ruling in Cummings v. Premier Rehab Keller, P.L.L.C., which held that emotional distress damages are not available under the Rehabilitation Act, a law that Title II of the ADA explicitly tracks.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Doherty's claims for declaratory and injunctive relief were moot given that the no-contact orders were not disciplinary actions, were not part of his permanent record, and expired upon his graduation. The court also agreed that emotional distress damages are not available under Title II of the ADA, which explicitly tracks the remedies, procedures, and rights available under the Rehabilitation Act. Finally, the court ruled that Doherty had forfeited any claims for other damages. View "Doherty v. Bice" on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law

Elaine Bart, a former supermarket manager, brought a lawsuit against her former employer, Golub Corporation, alleging gender discrimination under Title VII and state law. She was fired for falsifying food logs, a violation she admitted to but argued was not the sole reason for her termination. Bart claimed that her supervisor made several remarks indicating that women were not fit for managerial roles, suggesting a gender bias.The United States District Court for the District of Connecticut granted summary judgment to Golub, reasoning that Bart's admission of the violation, which was the company's stated reason for her termination, resolved the pretext inquiry, defeating her claims. Bart appealed this decision.The United States Court of Appeals For the Second Circuit disagreed with the lower court's ruling. The Appeals Court held that a plaintiff need not necessarily show at the third stage of the McDonnell Douglas burden-shifting test that the employer’s stated justification for its adverse action was a pretext for discrimination. A plaintiff may also satisfy this burden by providing evidence that even if the employer had mixed motives, the plaintiff’s membership in a protected class was at least one motivating factor in the employer’s adverse action. Given Bart's testimony about her supervisor's remarks indicating gender bias, the court concluded that Bart met this burden, thus precluding summary judgment.Therefore, the Court of Appeals vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Bart v. Golub Corp." on Justia Law

The plaintiff-Appellant, Kristen King, claimed that her employer, Aramark Services Inc., subjected her to a sex-based hostile work environment, discrimination, and retaliation in violation of the New York State Human Rights Law and Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed King’s claims. However, the United States Court of Appeals for the Second Circuit affirmed the lower court’s decision on the New York State Human Rights Law claims but vacated the decision on the Title VII claims.The Court of Appeals agreed with the lower court that the impact of Aramark’s alleged discriminatory acts were only incidentally felt in New York. Regarding the Title VII hostile work environment claim, the court found that King’s termination was not only a discrete act supporting a distinct claim for damages, but also part of the pattern of discriminatory conduct that comprises her hostile environment claim. The court held that because King’s termination occurred within the limitations period, the continuing violation doctrine rendered King’s hostile work environment claim timely. Therefore, the court affirmed the lower court’s dismissal of King’s New York State Human Rights Law claims but vacated the dismissal of King’s Title VII claims and remanded the case for further proceedings on those claims. View "King v. Aramark Services Inc." on Justia Law

The United States Court of Appeals for the Second Circuit heard an appeal by Christopher Callahan against a judgment by the United States District Court for the Eastern District of New York. The district court had granted summary judgment to Suffolk County Police Officer Thomas Wilson and the County of Suffolk on claims related to the death of Callahan's brother, Kevin Callahan, which Callahan argued violated excessive force regulations under 42 U.S.C. § 1983. The appellate court ruled that the district court violated the mandate rule by not conducting a new trial as earlier instructed by the appellate court. The court found that there were disputed issues of material fact regarding Wilson's entitlement to qualified immunity, thus summary judgment was not warranted. However, the appellate court affirmed the district court's denial of Callahan's motion to amend his complaint to add a state law claim for battery. The case was remanded for a new trial. View "Callahan v. County of Suffolk" on Justia Law

John D. Whitfield's application for a job as a Youth Development Specialist with the New York City Administration for Children’s Services (ACS) was rejected. Whitfield alleged that the rejection was discriminatory and violated his First and Fourteenth Amendment rights. He initially challenged the decision in New York State Supreme Court through an Article 78 proceeding, which was dismissed. He then initiated a federal court action, which was also dismissed by the District Court on res judicata grounds. The District Court determined that the state court proceeding was a “hybrid” proceeding where Whitfield could have pursued the claims he raises in the federal action.The United States Court of Appeals for the Second Circuit disagreed, concluding that the state court adjudicated the matter as a pure Article 78 proceeding, not as a hybrid. Therefore, the state court lacked the power to award Whitfield the full scope of relief he now seeks in this action, and the District Court erred by dismissing the amended complaint on res judicata grounds. The judgment of the District Court was vacated and the case was remanded for further proceedings. View "Whitfield v. City of New York" on Justia Law

In the early morning hours of September 8, 2018, Mabior Jok was standing outside a bar in Burlington, Vermont, when Joseph Corrow, an officer of the Burlington Police Department, approached the group. The details of what happened next are fiercely disputed, but it's agreed that Corrow took Jok to the ground, resulting in Jok hitting his head, losing consciousness and being taken to the hospital. Jok was charged with disorderly conduct, but the charge was later dismissed. Subsequently, Jok brought a lawsuit against Corrow and others, alleging, among other things, that Corrow used excessive force against him in violation of his Fourth Amendment rights.Corrow moved for summary judgment on several grounds, including that he was entitled to qualified immunity. The United States District Court for the District of Vermont denied the motion, concluding that there were genuine disputes of material fact and hence, summary judgment could not be granted on the basis of qualified immunity. Corrow then filed an interlocutory appeal of the denial.The United States Court of Appeals For the Second Circuit found that Corrow failed to establish appellate jurisdiction because he continued to assert disputes of fact, and no pure question of law was presented for review. The Court concluded that it did not have jurisdiction to review the denial of qualified immunity as the denial was based on the presence of disputed material facts. Therefore, the interlocutory appeal was dismissed due to lack of appellate jurisdiction. View "Jok v. City of Burlington" on Justia Law

The plaintiff-appellant, Maurice Cotton, an inmate, filed a civil rights lawsuit against corrections officials at the Green Haven Correctional Facility. He alleged that he was wrongfully denied a transfer to another prison facility and retaliated against for filing grievances related to the transfer request. Cotton sought permission to proceed in forma pauperis (IFP), which allows indigent prisoners to pay filing fees through a structured payment plan linked to their prison accounts. The district court denied Cotton's IFP request, concluding that he had accumulated "at least three" strikes under the Prison Litigation Reform Act (PLRA) due to previous lawsuit dismissals.The United States Court of Appeals for the Second Circuit vacated and remanded the district court's decision, ruling that the district court erred in its interpretation of the three previous lawsuits. According to the appellate court, not all of Cotton's previous lawsuits counted as PLRA strikes. The court further explained that a dismissal under Heck v. Humphrey does not automatically count as a PLRA strike, arguing that the key consideration is whether the dismissal is based on the merits of the case or if it was merely a matter of timing or sequencing. Therefore, the appellate court concluded that the district court incorrectly denied Cotton's request for IFP status, warranting a remand for further proceedings. View "Cotton v. New York State Office" on Justia Law

The United States Court of Appeals for the Second Circuit reviewed a decision made by the United States District Court for the Southern District of New York. The plaintiff, Do No Harm, a membership organization, filed a suit against Pfizer Inc., alleging that a Pfizer fellowship program unlawfully excluded white and Asian-American applicants on the basis of race. The plaintiff sought a preliminary injunction, which was denied by the district court. The district court dismissed the case without prejudice because Do No Harm lacked Article III standing. The court reasoned that the organization failed to identify by name a single injured member.The Court of Appeals affirmed the district court's decision. It upheld that to establish standing under Article III, an association relying on injuries to individual members must name at least one injured member. The court also held that if a plaintiff fails to establish standing in the context of a motion for a preliminary injunction, the district court must dismiss their claims without prejudice rather than allowing the case to proceed if the plaintiff alleged sufficient facts to establish standing under the less onerous standard applicable at the pleading stage. View "Do No Harm v. Pfizer Inc." on Justia Law