Justia Civil Rights Opinion Summaries

Lakewood police agents followed Tien Dinh Pham after observing his vehicle leave a house in a high-crime area. They initiated a traffic stop for a lane change violation. Pham pulled into a parking lot, and the agents ordered him out of the vehicle. After a brief pat down, Pham was directed away from the car, leaving the door open. Agent Kyle Winters then deployed a drug-detection dog, which entered the vehicle and alerted to the presence of drugs. The agents searched the vehicle and found drugs, paraphernalia, and weapons. Pham was charged with multiple offenses, including possession with intent to distribute controlled substances and possession of a weapon by a previous offender.The Jefferson County District Court held a suppression hearing and ruled that the search was unconstitutional. The court found that the officers had no reason to remove Pham from his vehicle and acted improperly by leaving the door open, facilitating the dog's entry into the car. The court suppressed the evidence obtained from the search.The Supreme Court of Colorado reviewed the case. It concluded that the trial court erred in finding that removing Pham from his vehicle was improper, as officers may order a driver out of a vehicle during a lawful traffic stop for safety reasons. However, the court agreed that the dog's entry into the vehicle constituted a search under the Fourth Amendment. Since the search was conducted without probable cause, it was deemed unconstitutional. The Supreme Court of Colorado affirmed the trial court's suppression order and remanded the case for further proceedings. View "People v. Pham" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

The case involves a challenge to the constitutionality of 18 U.S.C. §§ 922(b)(1) and (c)(1), which prohibit Federal Firearms Licensees (FFLs) from selling handguns to individuals aged eighteen to twenty. The plaintiffs, including individuals in this age group and several nonprofit organizations, argue that these provisions infringe on their Second Amendment rights and deny them equal protection under the Fifth Amendment.The United States District Court for the Western District of Louisiana found that the plaintiffs had standing but dismissed the case under Rule 12(b)(6). The district court assumed that the Second Amendment's plain text covered the purchase of firearms by eighteen-to-twenty-year-olds but concluded that the prohibition was consistent with the nation's historical tradition of firearm regulation, relying on the framework established by the Supreme Court in New York Rifle & Pistol Ass’n, Inc. v. Bruen.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the Second Amendment does cover the right of eighteen-to-twenty-year-olds to purchase firearms. The court found that the historical evidence presented by the government, including 19th-century laws, was insufficient to establish a tradition of restricting firearm rights for this age group in a manner similar to the contemporary federal handgun purchase ban. The court emphasized that the Second Amendment's protections extend to all law-abiding, adult citizens, including those aged eighteen to twenty.The Fifth Circuit held that 18 U.S.C. §§ 922(b)(1) and (c)(1) and their attendant regulations are unconstitutional as they are inconsistent with the nation's historical tradition of firearm regulation. The court reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives" on Justia Law

The plaintiff, an adult in custody at an Oregon correctional institution, sued the Oregon Department of Corrections and others for breach of contract and civil rights violations. He sought economic damages based on lost future wages and employment opportunities, alleging that the department had breached an oral promise of nonretaliation by using negative video footage of him in training videos, which led to his loss of job assignments and income-generating opportunities. The plaintiff claimed $11,640 in economic damages due to this negative portrayal.The Marion County Circuit Court dismissed the plaintiff's complaint, agreeing with the department's argument that Article I, section 41(3) of the Oregon Constitution, which states that inmates have no legally enforceable right to a job or compensation for work performed while incarcerated, rendered the plaintiff unable to plead economic damages. The Court of Appeals affirmed the trial court's decision, reasoning that the constitution precluded the plaintiff from establishing economic damages in the form of lost income.The Supreme Court of the State of Oregon reviewed the case and held that the trial court erred in granting the department's motion to dismiss. The court concluded that the lack of a right to employment does not establish, as a matter of law, that the plaintiff cannot prove economic damages in the form of future lost wages. The court emphasized that challenges to the sufficiency of proof are properly suited to a motion for summary judgment or trial, not a motion to dismiss. The decision of the Court of Appeals was affirmed in part and reversed in part, and the judgment of the circuit court was also affirmed in part and reversed in part. The case was remanded to the circuit court for further proceedings. View "Huskey v. Dept. of Corrections" on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law

Lamont Heard, a Michigan prisoner, claimed that prison officials retaliated against him for his litigation activities by transferring him to a different housing unit. He sought to sue the officials under 42 U.S.C. § 1983 for allegedly violating his First Amendment rights. Heard was transferred on January 10, 2017, and filed a grievance the next day. After exhausting his administrative remedies, he filed a lawsuit on January 19, 2021, four years and nine days after the transfer.The United States District Court for the Eastern District of Michigan dismissed Heard's claim for failure to exhaust administrative remedies. Heard then exhausted his remedies and refiled his lawsuit. The district court dismissed the refiled claim as untimely, reasoning that Michigan's tolling provision, which pauses the statute of limitations while a claim is pending in court, conflicted with the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Michigan's tolling provision does not conflict with the PLRA's exhaustion requirement. The PLRA requires prisoners to exhaust administrative remedies before filing a federal lawsuit but does not address tolling. The court emphasized that federal courts have historically borrowed state statutes of limitations and tolling provisions for § 1983 suits. The court found that Michigan's tolling rule, which pauses the statute of limitations during a prior suit, is consistent with the PLRA and does not undermine its purposes. Consequently, the Sixth Circuit reversed the district court's judgment, allowing Heard's claim to proceed. View "Heard v. Strange" on Justia Law

In this case, the defendant was on trial for murder. During jury deliberations, an argument between two jurors led to allegations of racial bias. The judge conducted a limited inquiry into the matter but did not fully investigate the allegations. The defendant was convicted of murder in the second degree, unlawful possession of a firearm, and unlawful possession of a loaded firearm.The case was initially tried in the Superior Court Department, where the defendant was found guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the trial judge's limited inquiry into the allegations of racial bias was insufficient. The court held that the judge should have conducted a more thorough investigation to determine whether the alleged racial bias affected the jury's impartiality. The court emphasized the importance of ensuring a fair and impartial trial, free from racial bias.As a result, the Supreme Judicial Court vacated the defendant's convictions and remanded the case for a new trial. The court's main holding was that the trial judge's failure to adequately investigate the allegations of racial bias created a substantial risk of a miscarriage of justice, warranting a new trial. View "Commonwealth v. Vasquez" on Justia Law