Justia Civil Rights Opinion Summaries

Wayne Bowker died at the Carter County Jail on June 30, 2016, while awaiting trial for a drug possession charge. In the days and weeks preceding his death, Bowker did not receive several of his prescribed medications, experienced incontinence and catatonia, and was able to communicate with jail staff only by using strange repetitive phrases. Despite Bowker’s condition, jail officials failed to provide any medical attention in the nineteen days leading up to his death. His mother, Judy Prince, as the administrator of his estate, filed suit under 42 U.S.C. 1983 alleging violations of the Eighth and Fourteenth Amendments to the United States Constitution, and other claims. The issue this case presented for the Tenth Circuit's review centered on whether the district court properly granted summary judgment on qualified immunity grounds to jail nurse Kimberlee Miller in her individual capacity, and whether it properly granted summary judgment to the Sheriff of Carter County in his official capacity. The Court concluded a reasonable jury could determine Miller violated Bowker’s constitutional right by acting with deliberate indifference toward his psychosis, incontinence, and catatonia. In addition, a reasonable jury could have concluded that Carter County’s failure to medically train jail employees, adequately staff the jail, and provide timely medical attention caused Bowker’s death. The Court reversed district court’s grants of summary judgment. View "Prince v. Sheriff of Carter County, et al." on Justia Law

Defendant-Appellant United Airlines (“United”) appealed a district court’s denial of its motion for judgment as a matter of law (“JMOL”), and its motion for new trial. A jury found that United discriminated against two flight attendants, Plaintiffs-Appellees Jeanne Stroup and Ruben Lee by terminating them because of their ages in willful violation of the Age Discrimination in Employment Act (“ADEA”). United filed its motions with the district court, contending, among other things, that the jury’s verdict was based on legally insufficient evidence and the court erred in admitting Plaintiffs’ testimony about their emotional distress. The district court denied the motions. United contended: (1) the district court erred in denying its JMOL motion because (a) there was insufficient evidence to support the jury’s finding that United discriminated against Plaintiffs because of their ages in violation of the ADEA, and (b) similarly, there was insufficient evidence to support the jury’s finding that United acted willfully in committing any ADEA violation; and (2) the court abused its discretion and committed reversible error when it admitted Plaintiffs’ allegedly irrelevant and highly prejudicial emotional distress testimony. After review, the Tenth Circuit concluded there was sufficient evidence for the jury to reasonably find that, not only did United violate the ADEA by discriminating against Plaintiffs, but it did so willfully. Furthermore, the Court determined the district court did not err by admitting the challenged emotional distress testimony. View "Stroup, et al. v. United Airlines" on Justia Law

Plaintiff-appellant Tiffany Litzsinger worked for the Adams County Coroner’s Office from 2013 until she was terminated in 2018. During her time there, Litzsinger suffered from anxiety and depression, both of which worsened in the months leading up to her termination. After an anxiety episode, Adams County granted Litzsinger temporary leave under the Family and Medical Leave Act (FMLA). When Litzsinger returned from her FMLA leave, the Coroner placed Litzsinger on probation for myriad violations of workplace policies. Shortly after Litzsinger’s probation began, the Coroner terminated Litzsinger for violating the terms of her probation. Litzsinger sued the Coroner’s Office under the FMLA and Americans with Disabilities Act (ADA), claiming the Coroner terminated her in retaliation for exercising her rights under both statutes. The district court granted summary judgment for the Coroner’s Office because Litzsinger failed to demonstrate that the Coroner’s reason for terminating her was pretextual. The Tenth Circuit affirmed, finding a rational jury could not find that the Coroner’s proffered reason for firing Litzsinger was pretextual. View "Litzsinger v. Adams County Coroner's Office" on Justia Law

Plaintiff-appellant Ahmad Ajaj, a practicing Muslim, was a Bureau of Prisons (BOP) inmate serving a 114-year sentence for terrorist acts connected with the 1993 World Trade Center bombing. Ajaj sued to obtain injunctive relief against BOP and damages from BOP officials on several grounds, including violations of his rights to free exercise of religion under the Religious Freedom Restoration Act (RFRA). The United States District Court for the District of Colorado dismissed his claims, and Ajaj appealed, contending the district court erred by holding: (1) his claim against the BOP for denial of his right to group prayer was moot; and (2) that RFRA did not provide a claim for damages against government officials in their individual capacities. After review, the Tenth Circuit Court of Appeals agreed with Ajaj and reversed the challenged rulings. The Court found the mootness ruling was based on a misconception of the evidence of Ajaj’s prison conditions. And the Supreme Court ruled in Tanzin v. Tanvir, 141 S. Ct. 486 (2020), that damages claims were permissible under RFRA. The Court rejected Ajaj’s contention that the doctrine of qualified immunity was inapplicable to RFRA claims, but declined to resolve whether the individual defendants in this case showed entitlement to qualified immunity, leaving that matter to the district court in the first instance. View "Ajaj v. Federal Bureau of Prisons, et al." on Justia Law

Metropolitan State University of Denver (MSU) student Rowan Thompson had a classroom dispute with her chemistry professor that ultimately prompted Thompson to drop the professor’s class. But when Thompson emailed her former classmates to express her displeasure with the professor and to suggest that her classmates leave “honest” end-of-term evaluations. Thomas Ragland, MSU’s Associate Director for Student Conduct, allegedly prohibited Thompson from further contacting the professor or even discussing the professor with any students taking any of the professor’s classes. Thompson sued Ragland under 42 U.S.C. 1983, arguing that he violated her First Amendment right to freedom of speech. The district court dismissed the complaint for failure to state a claim, holding that Ragland had not violated clearly established law and therefore was entitled to qualified immunity. The Tenth Circuit disagreed and reversed. "Because one can infer from the allegations in the complaint that there was no proper justification for Ragland’s actions, the complaint states a violation of clearly established law governing the regulation of student speech." View "Thompson v. Ragland" on Justia Law

Plaintiff-appellee Camille Sturdivant sued her former coach on a high school dance team, Carley Fine, invoking 42 U.S.C. 1983, and alleging race discrimination in violation of the Fourteenth Amendment’s Equal Protection Clause. Fine moved for summary judgment, urging qualified immunity based on the absence of: (1) an act under color of state law; and (2) a denial of equal protection. The district court denied the motion, concluding that a reasonable factfinder could infer that Fine had acted as head coach and “intentionally deprived [Camille] of educational benefits based on [her] race.” Fine appealed, presenting two alternative arguments for qualified immunity: (1) She did not act under color of state law because she was no longer employed as the head coach when she allegedly violated Camille’s rights; and (2) She did not violate a clearly established constitutional right. The Tenth Circuit determined it lacked jurisdiction to consider Fines first argument; the Court's jurisdiction in an interlocutory appeal did not extend to the applicability of section 1983. Thus, this portion of the appeal was dismissed. The Court did have jurisdiction on Fine's section argument, and found that a reasonable factfinder could find the violation of a clearly established right to equal protection. So the Court affirmed the district court’s denial of summary judgment based on qualified immunity. View "Sturdivant v. Fine, et al." on Justia Law

Deborah Laufer was qualified as disabled under the Americans with Disabilities Act (“ADA”) and was a self-described ADA “tester.” In that capacity, she visited the Elk Run Inn’s online reservation system (“ORS”) to determine whether it complied with the ADA, though she had no intention to stay there. Laufer sued Randall and Cynthia Looper, the owners of the Elk Run Inn, alleging that the ORS lacked information about accessibility in violation of an ADA regulation. The district court dismissed Laufer’s complaint without prejudice for lack of Article III standing because she failed to allege that she suffered a concrete and particularized injury. Finding no reversible error in the district court's judgment, the Tenth Circuit affirmed dismissal. View "Laufer v. Looper, et al." on Justia Law

Plaintiff Jamie Herrmann appeals the district court’s grant of summary judgment to Defendant Salt Lake City Corporation (“the City”) on her claims for failure to accommodate her disability, disability discrimination, and retaliation under the Americans with Disabilities Act (“ADA”). Herrmann began working for the City in 2002 and successfully held different positions in the Salt Lake City Justice courts for nine years. Starting in 2011, Herrmann began working as an in-court clerk, which required her to spend more time in court than her previous positions. Herrmann was diagnosed with PTSD, stemming from a nearly decade-long abusive marriage. Her presence in the courtroom during domestic violence cases frequently triggered her anxiety, causing severe migraines that could last for several days at a time and resulting in a significant downturn in her productivity. Herrmann raised three claims under the ADA: (1) failure to provide reasonable accommodations, (2) disability discrimination, and (3) retaliation. The Tenth Circuit found Herrmann presented some evidence supporting a conclusion that she could not be accommodated within her existing position. Therefore, the district court erred in holding that Herrmann did not meet her prima facie case. As the district court did not address the other elements of Herrmann’s prima facie case the City challenged, judgment was reversed and the case remanded to provide the district court with that opportunity. View "Herrmann v. Salt Lake City Corporation" on Justia Law

Plaintiff-Appellant Viktorya Reznik appealed the district court’s dismissal of her Title VII retaliation action against her former employer, Defendant-Appellee inContact, Inc. (inContact). From January 2018 to May 2019, Reznik worked as a Director of Project Management for inContact, a Utah-based corporation offering cloud-based services to companies using call centers. In April 2019, Reznik received internal complaints about racial slurs in the workplace from two native Filipino employees who worked in the company’s Manila, Philippines office. They claimed that an inContact manager, Scott Mendenhall, had repeatedly subjected them and other native Filipino employees to racial slurs, calling them “monkeys” and “not human.” Mendenhall worked in the same Salt Lake County facility as Reznik. Weeks after Reznik reported the harassment to company management, she was terminated as "not a good culture fit" and "not a good fit." Following Reznik’s termination and administrative exhaustion, she filed her Title VII complaint in federal district court. inContact moved to dismiss and the district court granted the motion. According to the district court, Reznik failed to state a claim because she did not show an objectively reasonable belief that she opposed conduct unlawful under Title VII. Finding Reznik's belief she was opposing conduct unlawful under Title VII was objectively reasonable, the Tenth Circuit reversed the district court's dismissal. View "Reznik v. inContact" on Justia Law

The City of Albuquerque, New Mexico (“Albuquerque” or “the City”) enacted a city-wide ordinance that, in pertinent part, prohibited pedestrians from: (1) congregating within six feet of a highway entrance or exit ramp; (2) occupying any median deemed unsuitable for pedestrian use; and (3) engaging in any kind of exchange with occupants of a vehicle in a travel lane. Plaintiffs-Appellees, residents of Albuquerque who engaged in a variety of expressive activities (like panhandling, protesting, or passing out items to the needy), sued the City in federal court, alleging that the Ordinance impermissibly burdened the exercise of their First Amendment rights. The City argued the Ordinance was necessary to address persistent and troubling pedestrian safety concerns stemming from high rates of vehicular accidents throughout Albuquerque, and, in relation to this pressing interest, the Ordinance was narrowly tailored and did not burden substantially more speech than necessary. The district court disagreed, finding that those provisions of the Ordinance violated Plaintiffs’ First Amendment rights because they were not narrowly tailored to the City’s interest in increasing pedestrian safety and, more specifically, reducing pedestrian-vehicle collisions. On appeal, the City argued the district court erred in concluding the Ordinance did not pass First Amendment muster, and it specifically focused on the question of narrow tailoring, arguing that the City did, indeed, appropriately tailor the Ordinance. After review, the Tenth Circuit rejected the City’s position, holding that the Ordinance was not narrowly tailored and, therefore, violated the First Amendment. View "Martin, et al. v. City of Albuquerque" on Justia Law