Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Third Circuit
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The case revolves around a local ordinance in the Borough of Camp Hill that regulates the display of signs on private property. The ordinance categorizes signs into about twenty different types, each with its own set of restrictions. Two residents, Katherine Pearson and Caroline Machiraju, displayed political signs on their lawns in the lead-up to the 2022 midterm elections. However, they were told to remove their signs as they violated the local sign ordinance. The ordinance categorized their signs as "Temporary Signs" and further classified them as "Personal Expression Signs," which express a non-commercial message. The ordinance limited the number of such signs a resident could display and the time frame within which they could be displayed.The residents complied with the directive but subsequently sued Camp Hill, challenging the provisions of the ordinance under the First Amendment. The United States District Court for the Middle District of Pennsylvania granted them summary judgment on their facial challenge, ruling that the provisions were content-based and failed strict scrutiny.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the ordinance was content-based as it classified signs based on their content, favoring commercial expression over noncommercial and holiday messages over non-holiday messages. The court held that such content-based restrictions could only stand if they furthered a compelling government interest and were narrowly tailored to achieve that interest. The court found that Camp Hill's interests in traffic safety and aesthetics, while legitimate, were not compelling and that the ordinance was not narrowly tailored to serve those interests. The court concluded that the ordinance was unconstitutional on its face. View "Camp Hill Borough Republican Association v. Borough of Camp HIll" on Justia Law

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Paul Montemuro was elected as the President of the Jim Thorpe Area School Board. However, a week later, the Board elected someone else without giving Montemuro any prior notice. Montemuro sued the Board members who voted against him and the Jim Thorpe Area School District, alleging that they had deprived him of his property without due process, in violation of 42 U.S.C. § 1983 and the Fourteenth Amendment. The defendants claimed qualified immunity.The District Court held that Montemuro had a clearly established property right in his employment and had been deprived of that right without due process. The defendants appealed this decision, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court found that Pennsylvania law clearly established that Montemuro had a property interest in his job as the Board President. The Court also accepted Montemuro's allegation that he was removed from office without notice. Therefore, the Court concluded that the defendants were not entitled to qualified immunity because they had violated Montemuro's clearly established right to due process. View "Montemuro v. Jim Thorpe Area School District" on Justia Law

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Michael Rivera, a Pennsylvania state prisoner, was in an open-air telephone cage when he overheard prison officials preparing to forcibly extract another inmate, Ryan Miller, from a nearby cell. Anticipating the use of pepper spray, Rivera informed the officials that exposure to the spray would trigger his asthma. Despite his pleas to be moved back to his cell, the officials refused, citing the lack of available personnel due to the ongoing preparations for Miller's extraction. After the pepper spray was deployed, Rivera suffered an asthma attack. He sued the prison officials for damages, alleging they had acted with deliberate indifference to the substantial risk of serious harm to him, in violation of the Eighth Amendment.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the prison officials. The court concluded that the law was not clearly established to the extent that the officials would have known that their actions violated the Eighth Amendment.On appeal, the United States Court of Appeals for the Third Circuit affirmed the lower court's decision. The appellate court found that the prison officials were entitled to qualified immunity because their actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. The court noted that the officials were confronted with competing institutional concerns and that the cited case law did not clearly establish that the officials' decision to prioritize one prisoner's health and safety over another's violated the Eighth Amendment. View "Rivera v. Redfern" on Justia Law

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A dispute arose over Pennsylvania's rule requiring mail-in and absentee voters to date the return envelope carrying their ballot. The Supreme Court of Pennsylvania had ruled this requirement mandatory and declared that undated or incorrectly dated ballots were invalid under state law. The case centered on whether federal law, specifically Section 10101(a)(2)(B) of the Civil Rights Act of 1964, mandated that these non-compliant ballots be counted. This provision prohibits the denial of the right to vote due to an immaterial error or omission on paperwork related to voting.The District Court granted summary judgment for the plaintiffs, declaring that rejecting timely received mail ballots due to missing or incorrect dates violated the federal provision. They reasoned that the date requirement was immaterial, as it played no role in determining a vote's timeliness.However, the appellate court reversed this decision. The court held that the federal provision only applies when the state is determining who may vote, not how a qualified voter must cast their ballot. They found that the provision does not apply to rules, like the date requirement, that govern how a qualified voter must cast their ballot for it to be counted. The court concluded that a contrary approach could not be reconciled with the text and historic backdrop of the statute. Therefore, the court ruled that the federal provision does not override Pennsylvania's date requirement for casting a mail-in ballot. The case was remanded for further consideration of the plaintiffs' pending equal protection claim. View "Pennsylvania State Conference of NAACP Branches v. Northampton County Board of Elections" on Justia Law

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In a case before the United States Court of Appeals for the Third Circuit, the plaintiff, Troy Moore, Sr., a prisoner, sued Correctional Officer Saajida Walton under 42 U.S.C. § 1983, alleging that she violated his Eighth Amendment rights. The claim was based on an incident where a toilet in Moore’s prison cell exploded and Walton refused to let him out of his cell to clean up for over eight hours. Moore originally filed the complaint under a misspelled version of Walton’s name. The correct spelling was not provided until after the statute of limitations for his claim had expired. The District Court granted summary judgment to Walton based on the statute of limitations.The Circuit Court held that the District Court misapplied the relation back analysis under Federal Rule of Civil Procedure 15(c)(1)(C) by failing to consider the period for service provided by Federal Rule of Civil Procedure 4(m). It held that Rule 15(c)(1)(C)’s reference to “the period provided by Rule 4(m)” includes any extensions for service granted under Rule 4(m) for good cause. The case was remanded to the District Court to determine whether Walton received notice of the action by a certain date and, if so, whether Moore could demonstrate the absence of prejudice—the final element necessary to satisfy the relation back inquiry. If all these conditions were met, the District Court would then need to consider the merits of Moore’s Eighth Amendment claim. View "Moore v. Walton" on Justia Law

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In this case, Kobe Pinkney sued Officer Jared Frum and others for false arrest and malicious prosecution. Officer Frum, in an investigation into an assault, had obtained an arrest warrant for Pinkney based on a witness statement. However, the court found that Officer Frum had misrepresented information in the warrant application, overstating the certainty of the witness, ignoring inconsistencies, and omitting key facts. The court found that Officer Frum had recklessly disregarded the truth, and the misrepresentations and omissions were deemed material to the finding of probable cause.The court concluded that the single witness identification, without more, must have at least basic signs of reliability to amount to probable cause. The court noted that this bar is not high; either corroboration or an appropriate witness interview may suffice. But based on the facts alleged, neither happened in Pinkney's case. Thus, Officer Frum was found to have violated Pinkney’s Fourth Amendment rights by arresting him without probable cause.Further, the court ruled that Pinkney’s right not to be arrested without probable cause was clearly established, as was his right not to be prosecuted without probable cause. Hence, a reasonable officer would have known that Officer Frum’s alleged conduct was unlawful. Therefore, the court affirmed the lower court's decision and allowed the case to proceed. View "Pinkney v. Meadville Pennsylvania" on Justia Law

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The US Court of Appeals for the Third Circuit dealt with two consolidated cases involving two New Jersey parents, who claimed they were retaliated against for protesting school policies related to mandatory masking during the COVID-19 pandemic. One parent, George Falcone, was issued a summons for defiant trespass after refusing to wear a mask at a school board meeting, while another parent, Gwyneth Murray-Nolan, was arrested under similar circumstances. Falcone claimed retaliation for exercising his First Amendment rights, while Murray-Nolan argued the same and also claimed she was deprived of substantive due process. The district court dismissed both cases. On appeal, the court found that Falcone had standing to sue, reversing and remanding the lower court's decision. However, the court affirmed the dismissal of Murray-Nolan's case, concluding that refusing to wear a mask during a pandemic was not protected conduct under the First Amendment. View "Murray-Nolan v. Rubin" on Justia Law

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In the case at hand, the United States Court of Appeals for the Third Circuit affirmed the dismissal of claims brought by a group of students and Children’s Health Defense, Inc. against Rutgers University. The plaintiffs challenged the university's COVID-19 vaccination policy, which required in-person students to be vaccinated or else enroll in online programs or seek exemptions for medical or religious reasons. The court found that the university's policy did not violate the plaintiffs' constitutional or statutory rights.The court held that there is no fundamental right to refuse vaccination. It applied the rational basis review and concluded that Rutgers University had a rational basis for its policy given the challenges posed by the COVID-19 pandemic. The court also rejected the plaintiffs' claim that the policy was ultra vires under New Jersey law, determining that Rutgers was authorized to require COVID-19 vaccinations under state law. Furthermore, the court dismissed the plaintiffs' equal protection claim, concluding that Rutgers had a rational basis for its differential treatment of students and staff, as well as vaccinated and unvaccinated students. View "Children's Health Defense Inc. v. Rutgers, the State University of New Jersey" on Justia Law

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This case involved a dispute over the rights of retired law enforcement officers to carry concealed firearms in New Jersey. The plaintiffs, three retired officers and two organizations, sued New Jersey officials, arguing that a federal statute, the Law Enforcement Officers Safety Act (LEOSA), gives them a federal right to carry a concealed firearm anywhere in the United States, including within New Jersey, and that LEOSA preempts any more burdensome state requirements. The state countered that the federal statute does not provide such an enforceable right, and even if it did, it would only apply to officers who retired from federal or out-of-state law enforcement agencies. The United States Court of Appeals for the Third Circuit held that LEOSA does provide certain retired officers with an enforceable right to carry concealed firearms, and that this right extends equally to officers who retired from New Jersey agencies and those who retired from federal or out-of-state agencies. The court concluded that LEOSA also preempts contrary aspects of New Jersey law. Therefore, the court affirmed the District Court’s order granting declaratory and injunctive relief to the retired officers. View "Federal Law Enforcement Officers Association v. Attorney General New Jersey" on Justia Law

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This case involves a dispute over the interpretation of the federal Law Enforcement Officers Safety Act of 2004 (LEOSA), which allows certain qualified retired law enforcement officers to carry concealed firearms, and its relation to New Jersey’s more restrictive retired police officer permitting law. The retired law enforcement officers from various agencies claimed that LEOSA provided them with a federal right to carry concealed firearms in New Jersey, superseding the state law. The State of New Jersey argued that LEOSA did not provide an enforceable right and, if it did, it would only apply to officers who retired from federal or out-of-state law enforcement agencies—not to officers who retired from New Jersey law enforcement agencies.The United States Court of Appeals for the Third Circuit held that LEOSA does provide certain retired officers who meet all the statutory requirements with an enforceable right, and that right extends equally to officers who retired from New Jersey agencies and those who retired from federal or out-of-state agencies. The court held that the federal statute also preempts contrary aspects of New Jersey law. Therefore, the court affirmed the District Court’s order granting declaratory and injunctive relief to the retired officers, allowing them to carry concealed firearms. View "Federal Law Enforcement Officers Association v. Attorney General New Jersey" on Justia Law