Justia Civil Rights Opinion Summaries

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

James Conn murdered Savannah Puckett, and his parents, Mollie and Michael Slaybaugh, suffered property damage when police arrested Conn at their home. The Slaybaughs filed a lawsuit under 42 U.S.C. § 1983, seeking compensation for the damage under the Takings Clause of the Fifth Amendment and its Tennessee Constitution counterpart.The United States District Court for the Middle District of Tennessee dismissed the Slaybaughs' claims. The court ruled that the police actions did not constitute a taking for public use under the Fifth Amendment because the damage occurred while enforcing criminal laws. The court also dismissed the state-law claim, stating that the Tennessee Constitution offers protections co-extensive with the Fifth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the Slaybaughs did not state a valid takings claim because the police actions were privileged under the search-and-arrest privilege. This privilege allows law enforcement to use reasonable force to enter property and make an arrest without being liable for resulting property damage, provided the actions are lawful and reasonable. The court found no evidence suggesting the police acted unlawfully or unreasonably. Consequently, the court affirmed the district court's dismissal of both the federal and state constitutional claims. View "Slaybaugh v. Rutherford County" on Justia Law

Michael Harvel, a county official, was convicted by a jury for sexually assaulting seven women he supervised, violating their constitutional rights under 18 U.S.C. § 242. Harvel appealed, raising issues about the timeliness of the charges, the indictment's sufficiency, and the admission of certain evidence.The United States District Court for the Middle District of Tennessee initially handled the case. Harvel argued that the most serious charges were not brought within the five-year statute of limitations under 18 U.S.C. § 3282(a). However, the court found that these charges were "punishable by death" under 18 U.S.C. § 3281, thus not subject to the five-year limit. Harvel also claimed that the introduction of "other crimes" evidence violated the Due Process Clause and Federal Rule of Evidence 403. The district court allowed this evidence, finding it relevant and not overly prejudicial.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's rulings, holding that the charges were timely under § 3281 because the crimes included kidnapping and aggravated sexual abuse, which are punishable by death under § 242. The court also rejected Harvel's due process challenge to Rule 413, which allows the admission of other sexual assaults to show propensity, and found no abuse of discretion in the district court's Rule 403 balancing. Additionally, the court upheld the denial of Harvel's motion for a mistrial, concluding that the district court's limiting instructions were sufficient to mitigate any potential prejudice from the inadmissible testimony.In conclusion, the Sixth Circuit affirmed Harvel's convictions and the 204-month sentence, finding no merit in his arguments regarding the statute of limitations, the indictment's sufficiency, or the evidentiary rulings. View "United States v. Harvel" on Justia Law

Meng Huang, a former Ph.D. student at The Ohio State University (OSU), alleged that her advisor, Professor Giorgio Rizzoni, sexually harassed and assaulted her during her studies. Huang filed a lawsuit against OSU and Rizzoni, claiming Title VII quid pro quo sexual harassment and retaliation against OSU, and a due process violation against Rizzoni under 42 U.S.C. § 1983.The United States District Court for the Southern District of Ohio granted summary judgment to OSU on Huang’s Title VII claims, concluding she was not an "employee" under Title VII until August 2017. The court also ruled that Huang’s retaliation claim failed because her first protected activity occurred after the alleged adverse actions. Huang’s § 1983 claim against Rizzoni proceeded to trial, where the court trifurcated the trial and excluded evidence of Rizzoni’s alleged manipulation and coercion. The jury found in favor of Rizzoni.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in determining Huang was not an employee under Title VII before August 2017, as her research work and the control Rizzoni exerted over her indicated an employment relationship. The court also held that Huang’s resistance to Rizzoni’s advances constituted protected activity under Title VII, and she presented sufficient evidence of adverse employment actions linked to her resistance.The Sixth Circuit reversed the district court’s summary judgment on Huang’s Title VII claims, vacated the trial verdict in favor of Rizzoni on the § 1983 claim, and remanded for a new trial. The court emphasized that the district court’s exclusion of relevant evidence regarding Rizzoni’s power and manipulation was an abuse of discretion, which prejudiced Huang’s ability to present her case. View "Huang v. Ohio State University" on Justia Law

Victor S. Couzens, the senior pastor of Inspirational Bible Church (IBC), faced a significant decline in church membership and financial troubles following public accusations of an adulterous relationship. In response, church leaders organized a vote to remove him from his position. To enforce this decision, they hired off-duty police officers for the next Sunday service. When Couzens attempted to address the congregation, the officers threatened him with arrest, leading him to leave the church. Couzens subsequently sued the officers, their police chief, and the City of Forest Park, alleging a conspiracy to deny him his constitutional rights.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants. The court found that while the officers' actions could be seen as a seizure under the Fourth Amendment, their actions were not unreasonable. The court also determined that the free exercise claim failed because the police department's policy did not target religious conduct. Without constitutional violations from individual defendants, the court found no merit in the municipal liability and civil conspiracy claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable given the circumstances and the evidence they had, including a letter indicating Couzens' removal as pastor. The court also found that Couzens failed to establish a violation of his First Amendment rights, as the officers' actions did not reflect state interference in church governance. Consequently, the court upheld the summary judgment on the constitutional, civil conspiracy, and municipal liability claims. View "Couzens v. City of Forest Park, Ohio" on Justia Law

Two young African American boys died in a house fire after two City of Flint firefighters failed to properly search the home. The then-City Fire Chief, Raymond Barton, attempted to discharge the firefighters for gross misconduct. However, Flint’s Mayor, Sheldon Neeley, allegedly intervened to cover up the firefighters' actions to gain support from the firefighters’ union for his re-election. When Barton refused to comply with Neeley’s directives to alter official reports and make false public statements, Neeley fired him.In the United States District Court for the Eastern District of Michigan, Barton filed a lawsuit claiming that his termination was retaliation in violation of his First Amendment rights. The district court denied Neeley’s motion to dismiss based on qualified immunity, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Barton plausibly alleged a violation of his First Amendment rights, as public employees cannot be compelled to make false, politically motivated statements on matters of public concern in response to threats of retaliation. The court affirmed the district court’s denial of qualified immunity to Neeley, concluding that Barton’s refusal to alter reports and make false statements was protected speech, and that it was clearly established that such compelled speech and retaliation violated the First Amendment. View "Barton v. Neeley" on Justia Law

Alvin Moore, a Black man, worked at Coca-Cola Bottling Company (CCBC) from 2015 to 2018. In March 2017, after a workplace accident, Moore tested positive for marijuana at a level below the company's threshold. Despite this, he signed a Second Chance Agreement (SCA) requiring random drug testing for 24 months. In June 2017, Moore was fired for insubordination but was reinstated under a Last Chance Agreement (LCA), which he signed under pressure. In 2018, Moore tested positive for marijuana again and was terminated. He sued CCBC for racial discrimination and retaliation under Title VII and Ohio law.The United States District Court for the Southern District of Ohio granted summary judgment in favor of CCBC, finding that Moore had waived his pre-LCA claims by signing the LCA and failed to establish that CCBC's reasons for his termination were pretextual. The court presumed Moore had made a prima facie case for racial discrimination and retaliation but concluded that Moore did not show that CCBC's reasons for his termination were a pretext for discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding whether Moore voluntarily waived his pre-LCA claims by signing the LCA. The court noted that Moore's union representative had advised him to sign the LCA, suggesting he could still pursue his claims. The court also found that Moore had shown enough evidence to suggest that CCBC's reasons for his termination could be pretextual, particularly in light of the different treatment of similarly situated white employees.The Sixth Circuit reversed the district court's summary judgment and remanded the case for further proceedings, allowing Moore to pursue his claims of racial discrimination and retaliation. View "Moore v. Coca-Cola Consolidated, Inc." on Justia Law

Wade Jones was incarcerated at the Kent County Correctional Facility for five days in April 2018. During his incarceration, he experienced severe alcohol withdrawal symptoms. Despite being placed on an alcohol-withdrawal protocol, Jones did not receive timely or adequate medical care. On April 27, 2018, Jones went into cardiac arrest and was later transferred to a hospital, where he died a week later. His estate sued Kent County and several nurses, alleging deliberate indifference to his medical needs.The United States District Court for the Western District of Michigan held a trial where a jury found that nurses Melissa Furnace, Chad Goetterman, and James Mollo were deliberately indifferent to Jones’s medical condition, which was a proximate cause of his death. The jury awarded Jones’s estate $6.4 million in compensatory damages. The defendants moved for judgment as a matter of law or a new trial, arguing that the jury’s verdict was inconsistent, that no reasonable jury could find proximate cause, that the estate’s counsel engaged in misconduct, and that a juror’s failure to disclose his criminal history warranted a new trial. The district court denied these motions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the defendants had forfeited their inconsistent-verdict argument by not objecting before the jury was discharged. It also found sufficient evidence to support the jury’s finding of proximate cause, noting that the jury could reasonably conclude that the nurses’ failure to provide timely medical care significantly decreased Jones’s likelihood of survival. The court further held that the estate’s counsel’s emotional display during trial did not constitute contumacious conduct warranting a new trial. Lastly, the court found no basis for a new trial due to juror misconduct, as the juror was never directly asked about his own criminal history during voir dire. View "Jones v. Kent County" on Justia Law

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law