Justia Civil Rights Opinion Summaries

The case involves the city of Grants Pass, Oregon, and its laws restricting public camping. The city's laws prohibit activities such as camping on public property or parking overnight in the city’s parks. Violations can result in fines and, in the case of multiple violations, imprisonment. A group of homeless individuals filed a class action lawsuit against the city, arguing that these ordinances violated the Eighth Amendment's prohibition against cruel and unusual punishment. The district court agreed with the plaintiffs, citing a previous Ninth Circuit decision, Martin v. Boise, which held that cities cannot enforce public camping ordinances against homeless individuals when the number of homeless individuals exceeds the number of available shelter beds.The Ninth Circuit affirmed the district court's decision, leading to the city's appeal to the Supreme Court. The Supreme Court reversed the Ninth Circuit's decision, holding that the enforcement of laws regulating camping on public property does not constitute "cruel and unusual punishment" prohibited by the Eighth Amendment. The Court reasoned that the Eighth Amendment focuses on the punishment a government may impose after a criminal conviction, not on whether a government may criminalize particular behavior in the first place. The Court also noted that the punishments imposed by the city of Grants Pass, such as fines and temporary bans from public parks, did not qualify as cruel and unusual under the Eighth Amendment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "City of Grants Pass v. Johnson" on Justia Law

The case involves two states and five individual social media users who sued several federal officials and agencies, alleging that the government pressured social media platforms to censor their speech in violation of the First Amendment. The plaintiffs' speech was related to COVID-19 and the 2020 election. The District Court issued a preliminary injunction, which was affirmed in part and reversed in part by the Fifth Circuit. The Fifth Circuit held that both the state and individual plaintiffs had standing to seek injunctive relief and that the government entities and officials, by coercing or significantly encouraging the platforms’ moderation decisions, transformed those decisions into state action.The Supreme Court of the United States reversed the Fifth Circuit's decision, holding that neither the individual nor the state plaintiffs have established Article III standing to seek an injunction against any defendant. The Court found that the plaintiffs' theories of standing depended on the platforms’ actions, yet the plaintiffs did not seek to enjoin the platforms from restricting any posts or accounts. Instead, they sought to enjoin the Government agencies and officials from pressuring or encouraging the platforms to suppress protected speech in the future. The Court concluded that the plaintiffs must show a substantial risk that, in the near future, at least one platform will restrict the speech of at least one plaintiff in response to the actions of at least one Government defendant. The Court found that the plaintiffs failed to meet this burden. View "Murthy v. Missouri" on Justia Law

This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Chiaverini v. City of Napoleon" on Justia Law

Sylvia Gonzalez, a city council member in Castle Hills, Texas, was involved in a campaign to remove the city manager, Ryan Rapelye. She gathered signatures for a petition, which was introduced at a city council meeting. After the meeting, the mayor, Edward Trevino, II, asked Gonzalez for the petition. Gonzalez found the petition in her binder, which she claimed was unintentional. Trevino reported this to the city police, leading to an investigation. A private attorney concluded that Gonzalez likely violated a Texas anti-tampering statute, leading to her arrest. The charges were later dismissed, but Gonzalez claimed this incident led her to step away from politics.Gonzalez filed a lawsuit under 42 U.S.C. §1983 in Federal District Court against Trevino, the police chief, and the private attorney, alleging that her arrest was in retaliation for her role in the petition and violated her First Amendment rights. The District Court denied the defendants' motion to dismiss the complaint, finding that it fell within an exception to the no-probable-cause rule recognized in Nieves. However, the Fifth Circuit reversed this decision, stating that Gonzalez's claim could only fall within the Nieves exception if she provided "comparative evidence" of similarly situated individuals who engaged in the same criminal conduct but were not arrested.The Supreme Court of the United States disagreed with the Fifth Circuit's interpretation of the Nieves exception. The Court found that the Fifth Circuit's requirement for specific comparator evidence was overly restrictive. The Court clarified that to fall within the Nieves exception, a plaintiff must produce objective evidence to prove that his arrest occurred in circumstances where officers typically exercise their discretion not to make arrests. The Court held that Gonzalez's evidence, showing that no one had ever been arrested for similar conduct, was a permissible type of evidence. The Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings. View "Gonzalez v. Trevino" on Justia Law

The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law

The Supreme Court of the United States reviewed a case involving the redrawing of congressional districts in South Carolina following the 2020 Census. The National Association for the Advancement of Colored People and a voter from District 1 challenged the new map, alleging that it resulted in racial gerrymanders in certain districts and diluted the electoral power of the state's black voters. The District Court held that the state drew District 1 with a 17% black voting-age population target in mind, violating the Equal Protection Clause and unlawfully diluting the black vote.The Supreme Court disagreed with the District Court's findings. The Court found that the District Court erred in its conclusion that race predominated in the design of District 1. The Court noted that the challengers did not provide sufficient evidence to show that the legislature subordinated traditional race-neutral districting principles to racial considerations. The Court also criticized the District Court for not drawing an adverse inference from the challengers' failure to submit an alternative map that would have allowed the state to achieve its districting goals while maintaining a higher black voting-age population in District 1.The Supreme Court reversed the District Court's decision in part and remanded the case for further proceedings. The Court concluded that the same findings of fact and reasoning that guided the court's racial-gerrymandering analysis also guided the analysis of the challengers' independent vote-dilution claim, and that conclusion also could not stand. The Court found that the District Court erred in conflating the two claims. View "Alexander v. South Carolina State Conference of the NAACP" on Justia Law

The case involves two petitioners, Halima Culley and Lena Sutton, who loaned their cars to others who were subsequently arrested for drug-related offenses. The cars were seized under Alabama's civil forfeiture law, which allowed for the seizure of a car "incident to an arrest" as long as the state promptly initiated a forfeiture case. The State of Alabama filed forfeiture complaints against the cars 10 and 13 days after their seizure, respectively. While the forfeiture proceedings were pending, Culley and Sutton each filed purported class-action complaints in federal court, claiming that state officials violated their due process rights by retaining their cars during the forfeiture process without holding preliminary hearings.The Eleventh Circuit affirmed the dismissal of the petitioners' claims, holding that a timely forfeiture hearing affords claimants due process and that no separate preliminary hearing is constitutionally required. The petitioners argued that the Due Process Clause requires a separate preliminary hearing before the forfeiture hearing.The Supreme Court of the United States affirmed the Eleventh Circuit's decision. The Court held that in civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing. The Court's decision was based on its precedents, which established that a timely forfeiture hearing satisfies due process in civil forfeiture cases. The Court also noted that historical practice reinforces its conclusion that due process does not require preliminary hearings in civil forfeiture cases. View "Culley v. Marshall" on Justia Law

Sergeant Jatonya Clayborn Muldrow, a police officer in the St. Louis Police Department, alleged that she was transferred from her position in the Intelligence Division to a uniformed job in another department because of her gender. Despite maintaining her rank and pay, Muldrow's responsibilities, perks, and schedule were significantly altered. She filed a Title VII suit against the City of St. Louis, claiming that the transfer constituted sex discrimination with respect to her employment terms and conditions.The District Court granted the City summary judgment, and the Eighth Circuit affirmed, holding that Muldrow had to show that the transfer caused her a "materially significant disadvantage." The courts ruled that since the transfer did not result in a reduction to her title, salary, or benefits and only caused minor changes in working conditions, Muldrow's lawsuit could not proceed.The Supreme Court of the United States disagreed with the lower courts' interpretation of Title VII. The Court held that an employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. The Court rejected the City's arguments based on statutory text, precedent, and policy, and vacated the judgment of the Eighth Circuit, remanding the case for further proceedings under the correct Title VII standard. The Court clarified that Muldrow only needed to show some injury respecting her employment terms or conditions, not that the harm was significant. View "Muldrow v. City of St. Louis" on Justia Law

The case involves Yonas Fikre, a U.S. citizen and Sudanese emigree, who brought a lawsuit alleging that the government unlawfully placed him on the No Fly List. Fikre claimed that the government violated his rights to procedural due process and placed him on the list for constitutionally impermissible reasons related to his race, national origin, and religious beliefs. In 2016, the government removed Fikre from the No Fly List, and argued in court that this action rendered Fikre's lawsuit moot. The district court agreed with the government's assessment, but the Ninth Circuit reversed, stating that a party seeking to moot a case based on its own voluntary cessation of challenged conduct must show that the conduct cannot “reasonably be expected to recur.”The Supreme Court of the United States affirmed the Ninth Circuit's decision. It held that the government failed to demonstrate that the case was moot. The Court stated that a defendant's "voluntary cessation of a challenged practice" will moot a case only if the defendant can prove that the practice cannot "reasonably be expected to recur." The Court found that the government's declaration that it will not relist Fikre based on "currently available information" did not suffice to demonstrate that Fikre will not be placed on the No Fly List in the future if he engages in the same or similar conduct. Therefore, the government has not borne its burden of proving that the dispute is moot. View "FBI v. Fikre" on Justia Law

In a case involving a city manager's personal social media account, a citizen sued the city manager under 42 U.S.C. §1983, alleging that his First Amendment rights were violated when the manager deleted his comments and blocked him from commenting further. The city manager argued that he operated his social media account in his private capacity, thus not constituting state action required for §1983 liability. The District Court and the Sixth Circuit affirmed this view, determining that the city manager's social media conduct did not constitute state action.The Supreme Court of the United States vacated the Sixth Circuit's decision, remanding the case for further proceedings. The court held that a public official's social media activity constitutes state action under §1983 only if the official both (1) possessed actual authority to speak on the State's behalf on a particular matter, and (2) purported to exercise that authority when speaking in the relevant social-media posts. The court emphasized that the first prong is grounded in the requirement that the conduct causing the deprivation of a federal right be fairly attributable to the State. The second prong requires that the official must purport to use that authority. The court noted that the nature of the technology matters to the state-action analysis and that the state-action doctrine requires a fact-intensive inquiry. View "Lindke v. Freed" on Justia Law