Justia Civil Rights Opinion Summaries

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In this lawsuit, Keith Sylvester alleged that Detective James Barnett violated his Fourth Amendment rights by causing his arrest and detention without probable cause. Sylvester's parents were murdered and their house set on fire. Detective Barnett led the investigation and suspected Sylvester was the culprit, ultimately obtaining an arrest warrant for him. Sylvester spent over a year in jail until the charges were dropped. Sylvester claimed that Barnett lacked probable cause when he applied for the arrest warrant, arguing that key exonerating evidence was omitted from the affidavit.The district court granted Detective Barnett summary judgment, stating that the record did not establish that Barnett knew about the exonerating information when he wrote the warrant affidavit. The court concluded that, based on the totality of circumstances known to Barnett at the time of the arrest, his suspicion of Sylvester was reasonable.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision. The appellate court found that there were material facts omitted from the warrant affidavit. When those omissions were corrected, the affidavit failed to establish even arguable probable cause for Sylvester's arrest. The court further held that a reasonable jury could find that Barnett intentionally or recklessly left out information that exonerated Sylvester. If a jury finds such misconduct, qualified immunity would not shield Barnett from liability. Therefore, the case was remanded for further proceedings. View "Sylvester v. Barnett" on Justia Law

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The plaintiff, Joshua Young, an employee of the Colorado Department of Corrections, claimed that mandatory Equity, Diversity, and Inclusion (EDI) training he was subjected to created a hostile work environment. Young resigned from the Department and filed a lawsuit claiming violations of Title VII and the Equal Protection Clause. He alleged that the training program violated Title VII by creating a hostile work environment and violated the Equal Protection Clause by promoting race-based policies. The district court dismissed both claims without prejudice. Young appealed the decision.The United States Court of Appeals for the Tenth Circuit examined Young's allegations and affirmed the district court's dismissal of Young's claims. The court found that while Young had plausibly alleged he was subjected to unwelcome harassment, he failed to adequately allege that the harassment was so severe or pervasive that it altered the terms of his employment and created an abusive working environment.The court also affirmed the district court's dismissal of Young's equal protection claim, agreeing that Young lacked standing to pursue the claim since he was no longer employed by the Department of Corrections and had not asked for reinstatement as part of his equal protection claim.Finally, the court held that the district court did not abuse its discretion when it declined to grant Young leave to amend his complaint, noting that Young neither requested leave to amend in his briefing nor filed a separate motion to amend. View "Young v. Colorado Department of Corrections" on Justia Law

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The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit reviewed an appeal by Dr. LeThenia Joy Baker against her former employer, Upson Regional Medical Center. Dr. Baker alleged that Upson violated the Equal Pay Act (“EPA”) and Title VII of the Civil Rights Act of 1964 by providing her a less favorable bonus compensation structure than that of her male colleague. Though Upson admitted that Dr. Baker was paid less than her male colleague, they argued that the pay disparity was due to the male doctor's greater experience, not his gender. The district court ruled in favor of Upson, stating that the EPA claim failed as Upson established a defense that the bonus structure, which paid Dr. Baker less than her comparator, was based on factors other than sex.The Eleventh Circuit upheld the district court's decision, stating that Upson had met its burden of proving that the difference in bonus compensation was based on factors other than sex. The court clarified that under the EPA, it only consists of a two-step analysis. First, the plaintiff must establish a prima facie case showing that she performed substantially similar work for less pay. Second, if the plaintiff establishes a prima facie case, the burden shifts to the employer to prove that the pay differential was justified under one of the Equal Pay Act’s statutory exceptions. If the employer fails, the plaintiff wins. The plaintiff is not required to prove discriminatory intent on the part of the defendant. The court concluded that no reasonable jury could find in favor of Dr. Baker on the question of whether her sex was considered in the different bonus structure she agreed to. View "Baker v. Upson Regional Medical Center" on Justia Law

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This case was brought before the United States Court of Appeals For the Seventh Circuit by plaintiffs John Brooks and Gregory Simmons against the City of Pekin and four of its employees. Brooks, a former police lieutenant who developed sleep apnea, claimed that the City violated the Americans with Disabilities Act by failing to reasonably accommodate his condition, discriminating against him, and retaliating against him for raising complaints. Simmons, a former police officer, alleged retaliation under Title VII of the Civil Rights Act of 1964 for reporting sexually harassing comments made by his former boss. The district court had granted summary judgment in favor of the defendants.The Court of Appeals affirmed the lower court's decision. The Court found that Brooks failed to show that the City had not offered him reasonable accommodations for his sleep apnea. The Court also ruled that Brooks could not establish disparate treatment because he failed to identify similarly situated employees who received more favorable treatment. Furthermore, Brooks was unable to prove retaliation because he lacked evidence that the City's reason for disciplining him was pretextual.Regarding Simmons, the Court found that he could not establish a claim for retaliation under Title VII because the inappropriate comments made about him were not because of his sex and were not severe or pervasive enough to create an abusive working environment. Moreover, Simmons could not show that his termination was due to his complaints against his former boss. The Court also noted that the district court did not err in denying the plaintiffs' request to amend their summary judgment response. The Court declined the City's request to impose sanctions on Brooks and Simmons, reasoning that their appeal was not frivolous. View "Brooks v. City of Pekin" on Justia Law

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In this case, a minor identified as M.U., through her parents, filed a complaint against Team Illinois Hockey Club, Inc. and the Amateur Hockey Association of Illinois, Inc., alleging that they violated Section 5-102(A) of the Illinois Human Rights Act by discriminating against her due to her disability. M.U. claimed that Team Illinois excluded her from participating in its activities at Seven Bridges Ice Arena, a public accommodation, due to her mental health conditions, thereby denying her full and equal enjoyment of the facilities and services.The defendants filed a motion to dismiss the complaint, arguing that M.U.'s allegations pertained to her exclusion from the team and its activities, not a place of public accommodation. The circuit court agreed and dismissed the complaint. The appellate court, however, reversed this decision, stating that Team Illinois, by its lease and operation of Seven Bridges, could not deny M.U., based on her disability, the privilege of participation in athletic events held at places of public accommodation.The Supreme Court of the State of Illinois affirmed the appellate court's judgment. It held that the Act did not delineate between “portions” of a place of public accommodation subject to its provisions. The court noted that, while Team Illinois itself might not be a place of public accommodation, it operated within one and was thus subject to the Act. The court concluded that M.U.'s allegations were sufficient to state a cause of action under Section 5-102(A) of the Act. The case was remanded to the circuit court for further proceedings. View "M.U. v. Team Illinois Hockey Club, Inc." on Justia Law

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In this case, the United States Court of Appeals for the Seventh Circuit ruled on an appeal brought by Randall Artis, a former city councilman for East Chicago, Indiana. Artis was previously convicted of misappropriating public money for personal political gain. After returning to public service as a junior clerk, he was fired by his boss, Adrian Santos. Artis alleged that Santos fired him in retaliation for exercising his First Amendment free speech rights. The case went to trial, and a jury found in favor of Santos.Artis appealed, arguing that the district court erred in admitting the testimony of an expert witness, in denying him an impartial jury, and in issuing inaccurate and confusing jury instructions and verdict forms. He also questioned the jury's verdict. The appeals court affirmed the district court's judgment, finding no error or reason for a new trial.The court held that the district court did not abuse its discretion in allowing the expert witness to testify, and it did not err in denying Artis's for-cause challenge to a prospective juror. Moreover, the court ruled that the district court did not abuse its discretion in its choice of jury instructions and verdict form. Finally, the court found no inconsistency in the jury's verdict. View "Artis v. Santos" on Justia Law

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The Supreme Court of Alabama has reversed a lower court's decision in a case involving claims of defamation, invasion of privacy, and violation of the Alabama Right of Publicity Act. The lawsuit was filed by Jennifer South, individually and as administratrix of the estate of her deceased husband, Jules Pierre Gillette, against Regional Prime Television and Tommy Dwayne Hubbard. The case arose from an episode of a show titled 'Ghostly Encounters' that was filmed in a former school building where South and Gillette had lived. The episode included allegations that Gillette had a drinking problem, was paranoid, abused little boys, physically abused South, and locked her in a closet in their home. The Supreme Court found that South did not present substantial evidence to support her defamation claim and that the estate failed to prove that the use of Gillette's indicia of identity in the episode was "for the purposes of trade". The court rendered a judgment in favor of Hubbard and Regional Prime on the estate's right-of-publicity claim and South's defamation claim, and remanded the case for a new trial as to South's invasion-of-privacy and tort-of-outrage claims. View "Regional Prime Television v. South" on Justia Law

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Maximo Espinal, a security guard, was arrested by Houston police officers for aggravated assault. Although a grand jury initially indicted Espinal, the charges were subsequently dropped. Espinal then sued the officers involved and the City of Houston, claiming he had been subjected to false arrest, malicious prosecution, and assault. The district court dismissed all of Espinal's claims based on the officers' qualified immunity and immunity under Texas law.Espinal's arrest occurred after he had a heated interaction with a plainclothes police officer, M.T. Long, who was trespassing on the property Espinal was guarding. After Espinal instructed Officer Long to leave, the officer returned with multiple police vehicles and arrested Espinal. Espinal alleged that the officers made no effort to view or collect video surveillance evidence that he said would prove his innocence.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court ruled that the officers had probable cause for Espinal's arrest. Furthermore, the court found that even if the officers had lacked probable cause, the grand jury's subsequent indictment of Espinal shielded them from liability under the independent intermediary doctrine. The court also rejected Espinal's claim that he had been maliciously prosecuted, finding that Espinal failed to allege that the officers had misled the grand jury. Finally, the court ruled that Espinal's assault claim was barred by the Texas Tort Claims Act. View "Espinal v. City of Houston" on Justia Law

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The case revolves around plaintiff Rynold Dwayne Jackson, who alleged malicious prosecution and unfair business practices after an altercation at a hotel lounge. Jackson was refused service on the basis of intoxication. Following a dispute, Jackson and the hotel's director of security, Mario Lara, had physical contact leading to Jackson's prosecution for battery. After being found not guilty, Jackson filed a civil complaint against Lara and DT Management, LLC, the company managing the hotel and lounge.Jackson alleged malicious prosecution against Lara, claiming the criminal prosecution was based on a false assault accusation. He also alleged DT Management violated the Unfair Competition Law by denying equal access, permitting discriminatory behavior by employees, and selectively deleting incident footage.The defendants filed a motion for summary judgment, which the lower court granted. The court considered Jackson's failure to appear at the motion hearing as a submission on the tentative ruling. Jackson appealed this judgment.The Court of Appeal, Fourth Appellate District Division One, State of California, affirmed the lower court's judgment. They cited the interim adverse judgment rule, which establishes that a trial court judgment in favor of the plaintiff or prosecutor, unless obtained fraudulently, forms probable cause to bring the underlying action. The court found this rule applicable as Jackson's motion for acquittal in his criminal trial was denied, thus establishing probable cause for Lara's accusation.As for the unfair business practices claim, Jackson failed to substantiate his allegations with legal authority or argument, resulting in the dismissal of his claim. Furthermore, a new theory he proposed on appeal was disregarded as it was raised for the first time and not considered in the trial court. View "Jackson v. Lara" on Justia Law