Justia Civil Rights Opinion Summaries

Plaintiffs David Moore and David Ermold sued Kim Davis, the clerk of Rowan County, Kentucky, under 42 U.S.C. § 1983 for refusing to issue them a marriage license, claiming it violated their constitutional right to marry. This refusal occurred after the Supreme Court's decision in Obergefell v. Hodges, which legalized same-sex marriage nationwide. Davis, citing her religious beliefs, stopped issuing all marriage licenses until the state provided her with an accommodation. Plaintiffs sought damages for the emotional distress caused by Davis's actions.The United States District Court for the Eastern District of Kentucky ruled in favor of the plaintiffs on liability, and a jury awarded them compensatory damages. Davis appealed, arguing she was entitled to qualified immunity, had defenses under the Free Exercise Clause and the Kentucky Religious Freedom Restoration Act (RFRA), and that the evidence of emotional distress was insufficient to support the jury's award.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Davis was not entitled to qualified immunity because Obergefell clearly established the right to same-sex marriage, and Davis's actions violated that right. The court also rejected Davis's Free Exercise Clause defense, stating that the First Amendment does not protect state actions that violate constitutional rights. Additionally, the court found that Kentucky's RFRA did not apply in this case because the state was not a party to the lawsuit.The court further upheld the jury's award of damages, finding that the plaintiffs provided sufficient evidence of emotional distress. The court noted that the plaintiffs' detailed testimony about their emotional harm was corroborated and not merely conclusory. Davis's request for remittitur was not considered because it was raised for the first time in her reply brief. The Sixth Circuit thus affirmed the district court's judgment in favor of the plaintiffs. View "Ermold v. Davis" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

Triston Harris Steinman was stopped by Nevada State Trooper William Boyer for speeding. During the stop, Boyer observed an ammunition box in Steinman's car and learned that Steinman had a felony conviction. Boyer asked Steinman to exit the vehicle and sit in the patrol car while he ran a criminal history check. Steinman admitted to having ammunition but denied having firearms. Boyer eventually seized the car and obtained a search warrant, leading to the discovery of firearms, ammunition, and other contraband.The District Court for the District of Nevada suppressed the evidence, ruling that Boyer unlawfully prolonged the traffic stop without reasonable suspicion and lacked probable cause to seize the vehicle. The court also found the search warrant overbroad and invalid.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Boyer did not unlawfully prolong the stop, as his actions were within the scope of the traffic stop's mission and did not measurably extend its duration. The court also found that Boyer had reasonable suspicion of an independent offense after learning of Steinman's felony conviction. Additionally, the court ruled that Boyer had probable cause to seize the vehicle based on evidence of federal and state law violations. The court concluded that the search of the vehicle was permissible under the automobile exception to the Fourth Amendment's warrant requirement, despite the overbroad warrant. Thus, the suppression of the evidence was reversed. View "USA V. STEINMAN" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

Several property management companies advertised their apartment buildings on Facebook, targeting users who are 50 years old or younger. Neuhtah Opiotennione, who is older than 50, did not see these advertisements and claimed that the companies discriminated against her based on her age. She filed a lawsuit seeking a declaratory judgment, a permanent injunction, and damages.The United States District Court for the District of Maryland dismissed Opiotennione’s complaint, ruling that she lacked standing to sue because she had not suffered a concrete and particularized injury in fact. The court found that Opiotennione had not demonstrated how the alleged discrimination personally affected her.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s decision. The Fourth Circuit held that Opiotennione failed to allege a concrete and particularized injury in fact. The court noted that merely being a member of the disfavored age group did not constitute a particularized injury. Additionally, the court found that Opiotennione did not allege that she was personally denied information or housing opportunities by the defendants, as she had not actively sought information from them. The court also rejected her claims of informational and stigmatic injuries, concluding that she had not demonstrated a personal denial of information or a concrete stigmatic injury. Thus, the Fourth Circuit affirmed the district court’s dismissal of the case for lack of standing. View "Opiotennione v. Bozzuto Management Co." on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

Reed Day and Albert Jacobs, Arizona residents, wanted to ship wine directly from out-of-state retailers who do not have in-state premises in Arizona. Arizona law, however, requires retailers to have a physical presence in the state to ship wine directly to consumers. Plaintiffs filed a civil rights action under 42 U.S.C. § 1983 against Arizona state officials, claiming that this statutory scheme violates the Commerce Clause.The United States District Court for the District of Arizona granted summary judgment in favor of the state officials and the intervenor-defendant, the Wine and Spirits Wholesalers Association of Arizona. The district court found that the plaintiffs likely lacked standing and that, even if they did, the Arizona laws were not discriminatory. The court reasoned that the physical presence requirement applied equally to in-state and out-of-state retailers and was essential to Arizona’s three-tier system for alcohol distribution.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the plaintiffs had standing because the district court could grant some form of relief. However, the court found that the plaintiffs failed to show that Arizona’s physical presence requirement was discriminatory. The requirement applied even-handedly to all retailers, regardless of their state of origin, and was not so onerous as to be discriminatory. The court noted that out-of-state businesses could and did obtain retail licenses in Arizona, indicating that the laws did not have a discriminatory effect in practice. The court concluded that Arizona’s laws did not violate the dormant Commerce Clause. View "Day v. Henry" on Justia Law

Yathomas Riley was convicted of malice murder and other crimes related to the shooting death of his wife, Dr. Lisa Marie Riley, in the presence of their infant son. The crimes occurred on June 14 and July 9, 2015. Riley was indicted on multiple counts, including malice murder, felony murder, and aggravated assault. After a jury trial, Riley was found guilty on all counts and sentenced to life in prison without parole, along with additional consecutive and concurrent prison terms for other charges.Riley filed a motion for a new trial, which was denied by the trial court. He then appealed to the Court of Appeals, which transferred the case to the Supreme Court of Georgia. The Supreme Court remanded the case to the trial court to determine if Riley knowingly and voluntarily chose to represent himself on appeal. The trial court confirmed this, and the case was resubmitted to the Supreme Court.The Supreme Court of Georgia reviewed Riley's claims, including the trial court's decision to allow the lead investigator to remain in the courtroom, the presentation of allegedly false evidence, and claims of ineffective assistance of counsel. The court found no abuse of discretion in allowing the investigator to stay, as he was the State's chief investigative agent. Riley's claims about false evidence and perjured testimony were either not preserved for appeal or lacked supporting evidence. The court also found that Riley failed to demonstrate that his trial counsel's performance was deficient or that any alleged deficiencies prejudiced his defense.Riley's claim that his trial counsel conceded guilt in violation of McCoy v. Louisiana was also rejected. The court concluded that counsel did not concede guilt but rather argued alternative theories to support acquittal, which did not violate Riley's Sixth Amendment rights. The Supreme Court of Georgia affirmed Riley's convictions and sentences. View "RILEY v. THE STATE" on Justia Law

In February 2020, Nicolas Robertson was shot and killed in Jackson, Mississippi. Two months later, Samuel Jennings, who was arrested for burglary and grand larceny, provided a statement to Detective Jacquelyn Thomas implicating Desmond Green in the murder. Green was subsequently indicted by a grand jury and detained for nearly two years. In March 2022, Jennings recanted his statement, admitting he was under the influence of drugs when he implicated Green and had no actual knowledge of the murder. Green was released from jail after the charges were dismissed.Green sued Detective Thomas under 42 U.S.C. § 1983, alleging violations of his Fourth and Fourteenth Amendment rights, including malicious prosecution and false arrest without probable cause. The United States District Court for the Southern District of Mississippi denied Detective Thomas qualified immunity at the motion-to-dismiss stage, allowing Green's claims to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Green sufficiently alleged violations of his clearly established Fourth Amendment right against false arrest and his Fourteenth Amendment due process rights. The court found that Detective Thomas allegedly manipulated a photo lineup and withheld exculpatory evidence from the grand jury, which could have influenced the grand jury's decision to indict Green. However, the court granted Detective Thomas qualified immunity on Green's malicious prosecution claim, as the constitutional tort of malicious prosecution was not clearly established in the Fifth Circuit at the time of Green's arrest.The Fifth Circuit affirmed the district court's denial of qualified immunity for Green's false arrest and due process claims but reversed the denial of qualified immunity for the malicious prosecution claim. View "Green v. Thomas" on Justia Law