Justia Civil Rights Opinion Summaries

In 2019, Morgan began employment as Disciplinary Counsel for the Board of Professional Responsibility of the Supreme Court of Tennessee. During a disciplinary proceeding, Manookian, whose law license had been suspended, moved to disqualify Morgan as the Board’s counsel, claiming that Morgan was “an anti-Muslim bigot.” Manookian’s filing attached tweets posted by Morgan from 2015-2016 that allegedly demonstrated Morgan’s bias toward Muslims. Manookian is not Muslim but claimed that his wife was Muslim and that his children were being raised in a Muslim household. Morgan responded that the tweets were political in nature and related to the 2015–2016 presidential campaign; he disavowed any knowledge of the religious faith and practices of Manookian’s family. The Board moved for Morgan to withdraw as Board counsel in the appeal, which the court allowed. A week later, Garrett, the Board’s Chief Disciplinary Counsel, told Morgan that his employment would be terminated. Several months later, Garrett notified Morgan that the Board had opened a disciplinary file against him. The matter was later dismissed.The Sixth Circuit affirmed the dismissal of Morgan’s 42 U.S.C. 1983 claims against the Board for lack of subject-matter jurisdiction based on Eleventh Amendment sovereign immunity but reversed the dismissal of the claim for damages against Garrett based on absolute quasi-judicial immunity. Extending judicial immunity here would extend its reach to areas previously denied— administrative acts like hiring and firing employees. View "Morgan v. Board of Professional Responsibility of the Supreme Court of Tennessee" on Justia Law

Harris went to the store, argued with a clerk, left the store, and entered the laundromat next door where his friend, Henderson, worked. Harris asserts that while he was between the buildings, the clerk came out, pointed a gun, and taunted him with racial slurs. Following Harris’s 911 call, four officers arrived. As shown on bodycams, they expressed disbelief in Harris’s report. The store clerk denied having a gun. The store had at least three surveillance cameras but the officers watched footage from only the front door, although Harris had reported that the incident occurred near the back door. Harris wanted to move forward with his report, believing the footage would corroborate his account. The officers indicated that the video revealed Harris had lied and arrested Harris. No officer took Henderson’s statement. Detective Busch reviewed the police report and passed it to the prosecutor for charging.Harris spent 18 days in jail before being released on bond. Weeks later, the state dropped Harris’s false felony report charge; the store clerks failed to appear. Harris sued the City of Saginaw, the officers, and Busch. The Sixth Circuit affirmed the denial of qualified immunity summary judgment to the officers, the grant of qualified immunity to Busch, and the dismissal of Harris’s failure-to-train and failure-to-supervise claims against the city. There is a genuine dispute of material fact regarding whether the officers arrested Harris without probable cause. View "Harris v. City of Saginaw, Michigan" on Justia Law

M.Q., a student attending public school in Knox County, Tennessee, was diagnosed with autism. M.Q. is largely nonverbal and has developmental delays in communication skills, social/emotional behavior, and pre-vocational skills. A suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400, Section 504 of the Rehabilitation Act, 29 U.S.C. 794; and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, alleged that M.Q. was improperly excluded from the general education classroom setting and placed him in a self-contained classroom for students with disabilities for nearly all his kindergarten academic instruction.The district court held that this placement violated the IDEA but rejected claims that also it also violated Section 504 and the ADA. The Sixth Circuit affirmed. The district court correctly found that the district complied with the statutory requirements with respect to including a general education teacher on M.Q.’s individual education plan (IEP) team— albeit under their most literal interpretation. The IEP cannot stand because it placed M.Q. in a more restrictive educational setting than his disability required. View "Knox County, Tennessee v. M.Q." on Justia Law

Moss purchased cocaine from a DEA informant and was charged with possession with intent to deliver 1,000 or more grams of cocaine and possession of a firearm during the commission of a felony. Moss’s first attorney moved for an entrapment hearing. Steingold then began representing Moss. At the entrapment hearing, 10 days later, Steingold attested to minimal pre-trial preparation. Moss was the only witness he presented. Steingold requested a continuance to contact witnesses he learned about during Moss’s direct and cross-examination. The court permitted Steingold to contact one witness but denied a continuance. The prosecution presented five witnesses and multiple exhibits. The court denied Moss’s motion to dismiss based on entrapment.At trial, Steingold waived his opening argument, presented no witnesses, and stipulated to the admission of the transcript from the entrapment hearing as substantive evidence. For one of the government’s two witnesses, Steingold did not object during his testimony or conduct any cross-examination. Steingold waived his closing argument. On appeal, Moss unsuccessfully argued that Steingold provided constitutionally ineffective assistance by waiving Moss’s right to a jury trial and stipulating to the admission of the evidence from the entrapment hearing.The Sixth Circuit reversed the district court’s order of habeas relief. The state court’s denial of Moss’s ineffective assistance claims under Strickland was not contrary to nor an unreasonable application of clearly established federal law. View "Moss v. Miniard" on Justia Law

Smucker’s is a federal contractor that supplies food items to the federal government. In 2021, by Executive Order, President Biden directed all federal contractors to “ensure that all [their] employees [were] fully vaccinated for COVID-19,” unless such employees were “legally entitled” to health or religious accommodations. The order made contractors “responsible for considering, and dispositioning, such requests for accommodations.” In September 2021, Smucker’s notified its U.S. employees that it would “ask and expect” them to “be fully vaccinated.” A month later, in the face of “deadlines in the federal order,” Smucker’s announced a formal vaccine mandate with exemptions based on “sincerely held religious beliefs.”The plaintiffs unsuccessfully sought religious exemptions, then sued Smucker's under the First Amendment's free-exercise guarantee. The Sixth Circuit affirmed the dismissal of the suit. When Smucker’s denied the exemption requests, it was not a state actor. Smucker’s does not perform a traditional, exclusive public function; it has not acted jointly with the government or entwined itself with it; and the government did not compel it to deny anyone an exemption. That Smucker’s acted in compliance with federal law and that Smucker’s served as a federal contractor, do not by themselves make the company a government actor. View "Ciraci v. J.M. Smucker Co." on Justia Law

Based on nominations, UC awarded “triumph cords” to graduating students who had overcome adversity. UC did not vet the nominees and unintentionally awarded a cord to a convicted sex offender. Goldblum, UC’s Title IX coordinator, told her supervisor, Marshall, that she would investigate how UC evaluated admissions applications from convicted sex offenders and address the controversy in the student newspaper. Goldblum forwarded a letter to Marshall, who ordered Goldblum not to submit anything until Marshall coordinated with other University officials. The administration had authorized Dean Petren to address the controversy. Marshall told Goldblum that Petren would issue UC’s response. Marshall also identified problems with the letter’s content. Goldblum texted Marshall that she intended to submit the letter and accept “any repercussions.” Marshall texted: “Please do not send.” Goldblum sent the letter, which was never published. Marshall reported Goldblum’s insubordination. During an investigation, UC discovered additional infractions: Goldblum repeatedly ignored Title IX complaints, criticized her colleagues in front of her staff, and missed reporting deadlines. UC allowed Goldblum to resign in lieu of termination.Goldblum sued UC for unlawful termination under Title VII and Title IX. The Sixth Circuit affirmed the dismissal of the claims. UC had legitimate nonretaliatory reasons to fire Goldblum, who has not produced “sufficient evidence from which a jury could reasonably reject” UC’s proffered reasons. Her letter was not “protected activity.” No reasonable juror could conclude that UC’s work-performance rationale was not based in fact. View "Goldblum v. University of Cincinnati" on Justia Law

Jane, a sophomore, reported to Oberlin College’s Title IX office (20 U.S.C. 1681–1688) that she believed her sexual encounters with Doe amounted to sexual misconduct. The office did not inform Doe of the allegations for several weeks and did not investigate. According to Doe, the delay resulted in a failure to preserve exculpatory security-camera footage. Doe alleges that the dearth of information provided to him led him to hire a private investigator. Doe believed that Jane had spoken to other students about the matter and requested that Oberlin protect his privacy. Doe was told that Jane had requested an informal resolution but was later told that Jane had decided to pursue a formal resolution. Doe asserted a retaliation complaint, claiming that the change was prompted by his complaint that Jane was slandering him. Oberlin then provided Doe with the requested reports and complaints.Doe sought a temporary restraining order weeks after learning of Roe’s complaint, before any formal hearing process began, alleging violations of federal due process, Title IX, and state tort laws. Oberlin subsequently officially concluded that Doe had not violated the Sexual Misconduct Policy. The district court dismissed the due process claim with prejudice and dismissed the remaining claims without prejudice. The Sixth Circuit affirmed in part. Although the district court did not follow the appropriate process for an on-the-merits, sua sponte dismissal of Doe’s due process claim, Oberlin is not a state actor subject to federal due process requirements. The court remanded in part; the court was correct to dismiss the remaining claims for lack of ripeness, but subsequent factual developments have ripened the claims. View "Doe v. Oberlin College" on Justia Law

Waide encountered the Lexington police after a shed fire occurred on the property next to his. Although no one suspected Waide of being involved with the fire and there was no evidence of arson, the fire investigator noticed surveillance cameras attached to Waide’s duplex residence and asked Waide to turn over his DVR. When Waide declined, the investigator obtained a warrant to enter Waide’s apartment and retrieve the DVR. When six officers arrived at Waide’s duplex to execute that warrant, their threatened entry and questions about whether Waide had drugs on the premises caused Waide to admit that his apartment contained a small amount of marijuana. This confession led to the issuance of two subsequent warrants to search both units of Waide’s duplex for narcotics–the other unit was occupied by Waide’s mother. The searches yielded a firearm plus large quantities of drugs and money.After the district court denied Waide’s motions to suppress evidence, he entered into a conditional guilty plea to the offense of possessing cocaine and heroin with the intent to distribute the drugs and to possessing a firearm in furtherance of a drug-trafficking crime. The Sixth Circuit reversed. The affidavit in support of the DVR warrant lacked reliable evidence to establish probable cause to believe that the shed fire was due to arson or any other criminal activity. The incriminating evidence should be suppressed because it stemmed from the exploitation of the unlawful DVR warrant. View "United States v. Waide" on Justia Law

In 1985, two people were shot to death in rural Garrard County. Haight, who had escaped from jail days earlier, was captured in a nearby cornfield. During a chase, police discovered the victims’ possessions and both handguns used to commit the murders in a stolen truck abandoned by Haight. Haight pled guilty in exchange for the prosecutor’s recommendation of a life sentence without parole for 25 years. The court accepted Haight’s plea but sentenced him to death. The Kentucky Supreme Court vacated. Haight unsuccessfully sought specific enforcement of the plea agreement, was allowed to withdraw his plea, and went to trial. Haight admitted to the murders from the witness stand, claiming that he was suffering from “extreme emotional disturbance” and intoxication. The jury found him guilty of two counts each of intentional murder and first-degree robbery, and possession of a firearm by a convicted felon. Haight’s convictions and death sentence were affirmed. Haight was denied postconviction relief without discovery or an evidentiary hearing.In 2002, Haight sought habeas relief. The district court stayed the federal action. The Kentucky Court of Appeals and Kentucky Supreme Court refused to consider his unexhausted issues. Haight successfully moved to have the now-exhausted issues included in his amended 28 U.S.C. 2254 petition, which raised 45 grounds. Haight’s motion and application for the appointment of experts and his motion for discovery and an evidentiary hearing were denied.The Sixth Circuit affirmed the denial of relief, rejecting claims of ineffective assistance; upholding the refusals to permit the defense to have Haight examined by a neuropsychologist before sentencing and to appoint medical experts; rejecting challenges to jury instructions and to the exclusion of certain potential jurors; and rejecting arguments concerning the refusal to enforce the plea agreement. Kentucky’s death penalty statute is not facially unconstitutional. View "Haight v. Jordan" on Justia Law

Helphenstine was arrested for drug offenses on April 14 and taken to jail. Around 8:30 p.m. on Sunday, April 16, Helphenstine vomited and was moved to a “detox” cell. A local doctor was contractually obligated to visit the jail once a week. He came on Tuesday nights. Helphenstine’s condition deteriorated. Knowing that the office was closed, deputies faxed the doctor a non-emergency medical request, stating Helphenstine was vomiting and soiling himself, refusing to eat or drink, and had not gotten out of bed for 24 hours. The doctor testified he called the jail and directed that Helphenstine be taken to a hospital but was told that Helphenstine refused. There is no record of these calls. The doctor faxed prescriptions for antiemetics; although it was a Tuesday and although he knew of Helphenstine’s condition, he did not visit the jail. Around midnight, Helphenstine laid on his mat, where he remained. Around 3:30 a.m., Helphenstine was unresponsive; jailers began CPR and called 911. Helphenstine was pronounced dead en route to the hospital.Plaintiff’s experts testified that Helphenstine died either from withdrawal or from severe dehydration caused by withdrawal. Helphenstine’s death certificate lists his cause of death as “acute (fentanyl) and chronic drug abuse,” with the interval between onset and death listed as 6 minutes; fentanyl was present in Helphenstine’s blood. The district court rejected a deliberate indifference claim under 42 U.S.C. 1983. The Sixth Circuit reversed in part. A jury could conclude that Helphenstine’s death was the result of deliberate indifference by the county and the doctor; the individual defendants are not entitled to qualified immunity. View "Helphenstine v. Lewis County" on Justia Law