Justia Civil Rights Opinion Summaries

The case revolves around an incident involving Michael Miller, a white Correctional Security Operations Supervisor at Chittenden Regional Correctional Facility (CRCF), and a black coworker. Miller asked the coworker if the food he was heating in the microwave was fried chicken, a comment the coworker perceived as racially discriminatory. Following an investigation, the State of Vermont terminated Miller's employment, citing violations of several personnel policies and work rules, including allegations of racial discrimination and harassment.The Vermont Labor Relations Board, however, reversed the State's decision. It found that while Miller's comments were inappropriate and unprofessional, they did not constitute racial discrimination or harassment as defined by the applicable personnel policies. The Board also found that the State failed to prove that Miller was untruthful during the investigation. Consequently, the Board reduced Miller's penalty to a twenty-day suspension.The State appealed the Board's decision to the Vermont Supreme Court, arguing that the Board misinterpreted the meaning of racial discrimination and harassment in the personnel policies. The Supreme Court affirmed the Board's decision, stating that the Board's interpretation of the policies was within its discretion and was supported by analogous definitions under Title VII of the Civil Rights Act of 1964. The Court also noted that the State could amend the language of the policies to more clearly define what constitutes racial discrimination or harassment. View "In re Grievance of Miller" on Justia Law

The case revolves around Christopher Smith, who was convicted of first-degree murder for the death of Nakisa Benson. Smith was initially deemed incompetent to stand trial but was later found competent. During the jury selection process, Smith's counsel exercised ten peremptory strikes on potential jurors, nine of whom were white. The State raised a reverse-Batson challenge, arguing that the strikes were racially motivated. The circuit judge conducted a Batson hearing and disallowed several of Smith's strikes, finding that the reasons provided were not race-neutral.Smith appealed his conviction to the Court of Appeals, arguing that the trial court erred by admitting certain autopsy photographs and by overruling five of his peremptory strikes. The Court of Appeals found no error and affirmed the conviction. Smith then filed a petition for writ of certiorari, contending that the Court of Appeals erred in its Batson analysis with respect to two jurors. He requested that the case be remanded for a proper Batson hearing.The Supreme Court of Mississippi reviewed the case and the Batson challenge. The Court gave great deference to the trial court's findings, stating that it would not overrule a trial court on a Batson ruling unless the record indicated that the ruling was clearly erroneous or against the overwhelming weight of the evidence. The Court found that Smith's counsel had shown a clear pattern of striking jurors because of their race, which was evident from his choice of words during the trial court’s Batson hearing. The Court affirmed the judgments of the Court of Appeals and of the Copiah County Circuit Court, denying Smith's request for a Batson hearing on the two jurors. View "Smith v. State" on Justia Law

Leroy Johnson, a supervisor at Westinghouse Air Brake Technologies Corporation (Wabtec), was terminated after failing to fully disclose his contact with a COVID-19 positive individual, violating the company's COVID-19 protocols and a Last Chance Agreement he had signed. Johnson, the only salaried black employee at the plant, sued Wabtec for wrongful termination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act of 1965, and the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment in favor of Wabtec.The district court's decision was based on the conclusion that Johnson had not established a prima facie case of discrimination. Johnson had argued that he was treated less favorably than similarly situated white employees, but the court found that the employees he cited were not similarly situated as they were not terminated for misconduct. The court also found that Johnson's failure to fully disclose his potential COVID-19 exposure constituted a safety concern and misconduct, which was grounds for termination under the Last Chance Agreement.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Johnson had not established a prima facie case of discrimination and that his termination was due to his misconduct, not his race or age. The court also noted that Johnson had waived his ADEA claim by failing to address its merits in his opening brief. View "Johnson v. Westinghouse Air Brake Technologies Corporation" on Justia Law

The case involves Billy Jo Faughn, who was convicted of wanton murder and operating a motor vehicle under the influence of methamphetamine, resulting in a fatal accident. Faughn had left a funeral and visited the home of a known methamphetamine dealer before the accident. An eyewitness saw Faughn driving erratically and at high speed before his vehicle left the road, traveled through a yard, and struck Sarah Barrow, who was tending to her flowers. Barrow died from her injuries. A blood test revealed methamphetamine in Faughn's system. Faughn was sentenced to life imprisonment.Faughn appealed his conviction, raising four claims of error. He argued that the trial court erred by allowing some of the Commonwealth’s witnesses to testify via Zoom, which he claimed violated his right to confront the witnesses. He also claimed prosecutorial misconduct, and argued that the court erred by admitting only a portion of a bodycam video. Lastly, he argued that the cumulative effect of these errors entitled him to a new trial.The Supreme Court of Kentucky affirmed the judgment of the Todd Circuit Court. The court found that while the trial court erred in allowing remote testimony, this error was harmless beyond a reasonable doubt given the overwhelming evidence against Faughn. The court also found no prosecutorial misconduct and ruled that the admission of the bodycam video was also harmless error. The court concluded that the cumulative effect of these errors did not render Faughn’s trial fundamentally unfair. View "Faughn v. Commonwealth" on Justia Law

The case involves two sets of plaintiffs, Douglas Bienvenu et al. and John Doe et al., who filed lawsuits against two defendants for alleged sexual abuse of minors. The plaintiffs argued that the revival provisions of Section 2 of 2021 La. Acts 322 and Section 2 of 2022 La. Acts 386, which were designed to revive previously prescribed claims related to sexual abuse of minors, were constitutional and should apply retroactively. The defendants, on the other hand, contended that the retroactive application of the amended statute would unconstitutionally deprive them of a vested property right to claim the accrued defense of liberative prescription.The case was initially heard in the 16th Judicial District Court, Parish of St. Martin. The district court ruled in favor of the plaintiffs, overruling the exception of prescription and finding that Act 322, as interpreted by Act 386, was constitutional and applied retroactively to revive all causes of action related to sexual abuse of a minor that previously prescribed under any Louisiana prescriptive period.The Supreme Court of Louisiana granted a rehearing to address the plaintiffs' contention that the original opinion erred in its due process analysis. The court vacated its original opinion and affirmed the district court's judgment. The court held that the legislature's intent to apply the amended provisions of La. R.S. 9:2800.9 retroactively by reviving previously prescribed claims was clearly and explicitly stated in Act 386. The court also held that when a party acquires the right to plead the defense of liberative prescription, that right becomes a vested property right protected by the constitution’s due process guarantees. However, the court found that the revival provision in Act 386 was rationally related to a legitimate government interest and therefore did not violate the due process clause. The case was remanded to the district court for further proceedings consistent with the Supreme Court's opinion. View "Bienvenu v. Defendant 1" on Justia Law

Survivors of the 1921 Tulsa Race Massacre and representatives of the estate of a deceased survivor filed a lawsuit against the City of Tulsa, the Tulsa Regional Chamber, the Board of County Commissioners for Tulsa County, the Sheriff of Tulsa County, and the Oklahoma Military Department. The plaintiffs alleged that the defendants' actions and omissions, beginning with the massacre and continuing to the present day, constituted a public nuisance. They also claimed that the defendants had unjustly enriched themselves by exploiting the massacre for their own economic and political gain.The District Court of Tulsa County dismissed the plaintiffs' claims. It found that the plaintiffs had failed to state a justiciable public nuisance claim and had not proposed a legally cognizable abatement remedy. The court also dismissed the unjust enrichment claim, citing a failure to correct a defective pleading.The plaintiffs appealed to the Supreme Court of the State of Oklahoma. They argued that the district court had erred in dismissing both their public nuisance and unjust enrichment claims. The Supreme Court retained the case for review.The Supreme Court affirmed the district court's decision. It held that the plaintiffs' grievances did not fall within the scope of Oklahoma's public nuisance statute. The court also found that the plaintiffs' allegations did not support a claim for unjust enrichment under the equitable doctrine. The court noted that the plaintiffs' grievances were legitimate but stated that the law did not permit the court to extend the scope of the public nuisance doctrine or the doctrine of unjust enrichment to provide the plaintiffs with the justice they sought. View "Randle v. City of Tulsa" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

The case revolves around a dispute between Sheena Hayes and Morgan Lawrence-Hayes, and Richard Penkoski. The dispute arose from Penkoski's social media posts, which the Hayes couple claimed were harassing and stalking. Penkoski, a public figure who identifies as a pastor, activist, and street preacher, posted content on Facebook criticizing the Hayes couple's church and their organization, Oklahomans for Equality. The Hayes couple, who are also public figures, claimed that they and their minor child were pictured in the posts, which they found offensive and threatening.The Hayes couple obtained a protective order against Penkoski from the District Court of Washington County. The court issued a permanent order of protection for five years, prohibiting Penkoski from posting any pictures, images, videos, or any likenesses of the Hayes couple or their minor child on any social media, making reference to them, or coming within 500 feet of them.Penkoski appealed the decision, arguing that his actions did not meet the requirements of stalking or harassment as defined by the Protection from Domestic Abuse Act, and that his posts were protected by his constitutional right to free speech.The Supreme Court of the State of Oklahoma reversed the lower court's decision. The court found that Penkoski's actions were not directed toward an individual person, but rather were public Facebook posts that named two organizations, not individuals. The court concluded that Penkoski did not direct his posts or comments toward the Hayes couple, and therefore, the district court abused its discretion in issuing the order of protection. The court vacated the order of protection. View "Hayes v. Penkoski" on Justia Law

The plaintiff, Gary Avant, was a truck driver for Muskogee County. County officials believed that Avant was complaining to other citizens about the county’s road plan and the assignment of a county worker. Avant was subsequently fired by the county commissioner. Avant sued the commissioner under 42 U.S.C. § 1983, claiming retaliation in violation of the First Amendment. However, during the litigation, Avant denied making the statements that led to his firing. The commissioner moved for summary judgment, arguing that the perceived speech hadn’t involved a matter of public concern. The district court denied this part of the motion, and the case was remanded for the district court to develop the record.After remand, the district court again denied summary judgment, leading the commissioner to appeal again. On appeal, the commissioner argued that Avant hadn’t pleaded a claim for perceived speech and that qualified immunity applies given the lack of precedent on how to assess a public concern for perceived speech.The United States Court of Appeals for the Tenth Circuit found that it lacked jurisdiction to consider the adequacy of the pleadings. However, it did have jurisdiction over the commissioner’s argument for reversal based on the absence of a clearly established violation. The court concluded that Avant had not shown that the perceived speech involved a clearly established public concern. Therefore, the commissioner was entitled to qualified immunity, and the court reversed the denial of qualified immunity and remanded the case for the district court to grant summary judgment to the commissioner in his personal capacity on the First Amendment claim for retaliation based on perceived speech. View "Avant v. Doke" on Justia Law

The case revolves around Angela Singleton, a former employee of the Maryland Technology Development Corporation (TEDCO), who filed a lawsuit against TEDCO alleging sex- and race-based discrimination and retaliation. TEDCO, an entity created by the State of Maryland to promote economic development, argued that it was an "arm of the State" and therefore immune under the Eleventh Amendment from suits brought in federal court. Singleton countered that TEDCO was essentially a series of social impact and venture funds overseen by the corporation and did not qualify as an arm of the State.The United States District Court for the District of Maryland dismissed Singleton's complaint, agreeing with TEDCO's argument that it was indeed an arm of the State and therefore entitled to Eleventh Amendment immunity. Singleton appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that although the State of Maryland was not legally obligated to pay TEDCO's debts, it was practically responsible for the entity's solvency. The court also noted that the State exercised significant control over TEDCO, that TEDCO's concerns were statewide, and that the State treated TEDCO substantially as an agency. Therefore, the court concluded that TEDCO was an arm of the State and protected from Singleton's suit by the Eleventh Amendment. View "Singleton v. Maryland Technology and Development Corporation" on Justia Law