Justia Civil Rights Opinion Summaries

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

The case involves Alonzo Cortez Johnson, a state prisoner who petitioned for federal habeas relief under 28 U.S.C. § 2254. Johnson, a Black man, claimed that his constitutional rights were violated because the state court failed to follow the appropriate procedural steps under Batson v. Kentucky, which prohibits racial discrimination in jury selection. Johnson alleged that the prosecutor had exercised peremptory strikes based on race. The Tenth Circuit Court of Appeals agreed that the state court had mishandled the Batson procedural framework and remanded the case to the district court to hold a Batson reconstruction hearing, unless doing so would be impossible or unsatisfactory.On remand, the district court granted Johnson conditional habeas relief, deciding that holding a Batson reconstruction hearing would be “both impossible and unsatisfactory.” The court reasoned that it could not sufficiently reconstruct all relevant circumstances to meaningfully apply Batson’s third step, which involves determining whether the prosecutor’s stated reasons for the strikes were actually a pretext for discrimination.The Tenth Circuit Court of Appeals disagreed with the district court's decision. The court found that the district court had enough evidence to hold a Batson reconstruction hearing at step two, which involves the prosecution providing a race-neutral reason for the objected-to strike(s). The court concluded that the district court had applied the “impossible or unsatisfactory” standard too harshly and remanded the case back to the district court to hold a Batson reconstruction hearing. View "Johnson v. Rankins" on Justia Law

The case involves Travis Woods, a wheelchair user, who sued the Central New York Regional Transportation Authority and its subsidiary Centro of Oneida, Inc. (collectively, "Centro"), which operate the public bus service in Oneida County. Woods claimed that Centro violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by failing to provide wheelchair-accessible bus stops. He argued that the district court erred in granting summary judgment to Centro on his claims.The United States District Court for the Northern District of New York granted summary judgment to Centro, dismissing Woods's complaint. The court found that Centro's paratransit service and its flexible pick-up and drop-off policy were reasonable accommodations providing meaningful access to Centro’s bus service.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court found that Woods's claims under sections 12147 and 12148 of the ADA failed as a matter of law. The court concluded that Woods had not shown that the altered portions of Centro’s bus stops were inaccessible or that Centro’s bus service was not readily accessible to individuals with disabilities. The court also found that Woods had not established that any modifications to Centro’s policies, practices, or procedures were necessary to avoid discrimination or to provide program access. Therefore, the court affirmed the judgment of the district court. View "Woods v. Centro of Oneida, Inc." on Justia Law

In March 2020, Idaho enacted the Fairness in Women’s Sports Act, a law that categorically bans transgender women and girls from participating in women's student athletics. The Act also provides a sex dispute verification process, which allows any individual to dispute the sex of any student athlete participating in female athletics in the State of Idaho and require her to undergo intrusive medical procedures to verify her sex. Lindsay Hecox, a transgender woman who wished to try out for the Boise State University women’s track and cross-country teams, and Jane Doe, a cisgender woman who played on high school varsity teams and feared that her sex would be disputed under the Act due to her masculine presentation, filed a lawsuit against the Act.The United States District Court for the District of Idaho granted a preliminary injunction against the Act, holding that it likely violated the Equal Protection Clause of the Fourteenth Amendment. The court found that the Act subjects only students who wish to participate in female athletic competitions to an intrusive sex verification process and categorically bans transgender girls and women at all levels from competing on female teams. The court also found that the State of Idaho failed to provide any evidence demonstrating that the Act is substantially related to its asserted interests in sex equality and opportunity for women athletes.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision, holding that the Act likely violates the Equal Protection Clause. The court found that the Act discriminates on the basis of transgender status and sex, and that it is not substantially related to its stated goals of equal participation and opportunities for women athletes. The court remanded the case to the district court to reconsider the appropriate scope of injunctive relief. View "Hecox v. Little" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves Rosalina Calonge, who sued Officer Edward Carboni and the City of San Jose under 42 U.S.C. § 1983, alleging that Officer Carboni used excessive deadly force when he shot and killed her son, Francis Calonge. The incident occurred when police officers responded to 911 calls reporting a man with a gun. They located Francis Calonge, who had what appeared to be a gun in his waistband. Officer Carboni shot and killed Calonge after following him for about a minute as he walked down a street.The United States District Court for the Northern District of California granted summary judgment in favor of Officer Carboni, ruling that he was entitled to qualified immunity because the plaintiff had failed to identify specific caselaw clearly establishing that Officer Carboni’s conduct violated the Fourth Amendment.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court found that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could decide that Officer Carboni violated Calonge’s Fourth Amendment right to be free from excessive force. The court also concluded that the relevant law was clearly established at the time, so Officer Carboni was not entitled to qualified immunity. The court resolved three disputed facts in the plaintiff’s favor for purposes of the appeal: Calonge was not drawing his gun or making a threatening gesture when Officer Carboni shot him; there were no bystanders in Calonge’s vicinity when he was shot; and officers did not instruct Calonge to get on the ground or otherwise stop. The court held that the totality of the circumstances did not justify deadly force. View "CALONGE V. CITY OF SAN JOSE" on Justia Law

Seattle Pacific University (SPU), a religious institution, filed a lawsuit against the Washington Attorney General, alleging First Amendment violations arising from the Attorney General's investigation into the university's employment policies and history under the Washington Law Against Discrimination (WLAD). SPU prohibits employees from engaging in same-sex intercourse and marriage. After receiving complaints, the Attorney General requested documents related to SPU's employment policies, employee complaints, and job descriptions. SPU sought to enjoin the investigation and any future enforcement of WLAD.The district court dismissed the suit, citing lack of redressability and Younger abstention. The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that SPU failed to allege a cognizable injury for its retrospective claims, as the Attorney General's request for documents carried no penalties for non-compliance. However, the court found that SPU had standing for its prospective pre-enforcement injury claims, as SPU intended to continue employment practices arguably proscribed by WLAD, the Attorney General had not disavowed its intent to investigate and enforce WLAD against SPU, and SPU's injury was redressable. The court also held that Younger abstention was not warranted as there were no ongoing enforcement actions or any court judgment. The case was remanded to the district court to consider prudential ripeness. View "SEATTLE PACIFIC UNIVERSITY V. FERGUSON" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law