Justia Civil Rights Opinion Summaries

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law

An educator employed by the New York City Department of Education (DOE) was appointed Executive Director of the “AP for All” program, where she supervised a diverse team and was credited with expanding access to Advanced Placement courses. Early in her tenure, she experienced racial tensions with subordinates, including accusations of “microaggressions” and being labeled as exhibiting “white fragility.” These tensions escalated after a new Chancellor implemented an “equity agenda” that included mandatory implicit bias trainings. The plaintiff, who is Caucasian, alleged that these trainings and subsequent workplace interactions fostered a racially hostile environment, with repeated negative generalizations about white employees and a lack of intervention by supervisors when she complained.The plaintiff initially filed suit in the Supreme Court of New York, later amending her complaint to assert claims under 42 U.S.C. § 1983 for race discrimination, hostile work environment, and constructive discharge. The case was removed to the United States District Court for the Southern District of New York, where the plaintiff voluntarily dismissed her state law claims. The district court granted summary judgment to the defendants, finding that the plaintiff failed to demonstrate a municipal policy or custom that caused her demotion, the alleged hostile work environment, or her constructive discharge.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision de novo. The Second Circuit affirmed the grant of summary judgment on the demotion and constructive discharge claims, holding that the plaintiff did not provide sufficient evidence that these actions were motivated by racial discrimination or that the employer intentionally created intolerable working conditions. However, the court vacated the summary judgment on the hostile work environment claim, finding that genuine disputes of material fact existed as to whether the DOE’s actions and inaction amounted to a municipal policy or custom that created a racially hostile environment. The case was remanded for further proceedings on that claim. View "Chislett v. New York City Department of Education" on Justia Law

In 1996, the defendant broke into a home, raped a woman at knifepoint, and carried a child at knifepoint while stealing a firearm and ammunition. He was charged with multiple offenses, including kidnapping to commit robbery and, later, a one-strike rape allegation. After a mistrial due to a deadlocked jury and the emergence of DNA evidence linking him to the crime, the defendant pled guilty in 1998 to several charges under a plea agreement. The plea resulted in the dismissal of the rape charge and the one-strike allegation, and the kidnapping charge was amended. He was sentenced to a determinate prison term, which was later reduced.In 2024, the defendant, who is ethnically Samoan, filed a motion in the Superior Court of Riverside County seeking discovery under the Racial Justice Act (RJA). He argued that the addition of the one-strike allegation before trial was racially motivated, citing a different case involving a white defendant who was not similarly charged. He requested records of comparable cases, including defendants’ races and charges. The People opposed, arguing that the plea negotiations were driven by DNA evidence, not the added charge, and that the comparison case was not analogous. The trial court granted the discovery motion but limited the scope of the records to be produced.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a petition for writ of mandate. The appellate court held that the defendant failed to establish good cause for discovery under the RJA because his factual scenario was not plausible in light of the record, the comparison case did not support an inference of racial disparity, and statewide incarceration statistics did not provide specific facts of misconduct in his case. The court granted the writ, directing the trial court to vacate its order granting discovery and to deny the motion. View "People v. Superior Ct. (Lalo)" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

A woman alleged that a sheriff’s deputy in Okanogan County, Washington, coerced her into sexual encounters over several years, exploiting her drug addiction and involvement in criminal activity. She claimed that the deputy’s misconduct began in 2014 and continued through 2021, with the deputy using his position to pressure her into unwanted sexual acts in exchange for not pursuing criminal charges against her. The woman also alleged that the sheriff’s office was aware of the deputy’s behavior but failed to take effective action, and that similar misconduct occurred with other deputies and vulnerable women.After the woman filed suit in the United States District Court for the Eastern District of Washington, the defendants moved to dismiss, arguing that her claims were barred by Washington’s three-year statute of limitations. The district court agreed, holding that her claims were untimely and that her allegations did not sufficiently support municipal liability under Monell v. New York City Department of Social Services. The court dismissed her claims with prejudice and denied her request to amend her complaint.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that each alleged act of sexual misconduct constituted a discrete, independently wrongful act for statute of limitations purposes, so claims based on acts within three years of the complaint were timely. For earlier acts, the court found that the plaintiff plausibly alleged a delayed accrual theory, given the power imbalance and her delayed realization of harm. The court also held that the district court abused its discretion by denying leave to amend the Monell claim, as the plaintiff alleged facts supporting a pattern of deliberate indifference. The Ninth Circuit reversed the dismissal of both federal and state law claims and remanded for further proceedings. View "ST. CLAIR V. COUNTY OF OKANOGAN" on Justia Law

A hospital employee in Oregon, who identified as a practicing Christian, requested a religious exemption from her employer’s COVID-19 vaccine mandate, citing her belief that her body is a temple of the Holy Spirit and that she must avoid substances that could harm her body. The employer granted her exemption from vaccination but required her to wear personal protective equipment and undergo weekly antigen testing using a nasal swab treated with ethylene oxide. The employee objected to the testing, claiming her research showed the swab was carcinogenic and that using it would violate her religious duty to protect her body. She requested alternative accommodations, such as saliva testing or full-time remote work, but the employer denied these requests and ultimately terminated her employment when she refused to comply.The United States District Court for the District of Oregon dismissed her complaint for failure to state a claim, finding that her objection to the testing was based on secular, medical concerns rather than a bona fide religious belief. The court concluded that while her general belief in protecting her body as a temple was religious, her specific objection to the nasal swab was rooted in her personal interpretation of medical research.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that to state a claim for religious discrimination under Title VII and Oregon law, a plaintiff must plausibly allege that the specific accommodation request is rooted in a bona fide religious belief, not merely a secular or personal preference. The court found that the employee’s complaint did not sufficiently connect her religious beliefs to her objection to antigen testing, as her concerns were based on her own medical judgment rather than religious doctrine. The court declined to adopt a more lenient pleading standard and affirmed the dismissal with prejudice. View "DETWILER V. MID-COLUMBIA MEDICAL CENTER" on Justia Law

A North Carolina police officer, Clarence Belton, was shot multiple times by fellow officer Heather Loveridge during the execution of a search warrant. The incident, which resulted in serious injuries to Belton and ended his law enforcement career, was captured on video and body camera footage. Belton sued Loveridge and the City of Charlotte, alleging excessive force and other claims. During the litigation, both parties moved to seal the video exhibits related to the shooting, and the district court granted these motions, placing the footage under seal.After the district court denied Loveridge’s motion for summary judgment, which was later vacated and remanded by the United States Court of Appeals for the Fourth Circuit, a local television station, WBTV, sought to intervene in the case to unseal the video footage. Belton supported WBTV’s motion, but Loveridge opposed it, arguing that unsealing would jeopardize her right to a fair trial. The United States District Court for the Western District of North Carolina denied WBTV’s motion to intervene, citing lack of jurisdiction due to the pending appeal, and also denied the motion to unseal, finding no right of access under the common law or the First Amendment and concluding that Loveridge’s fair trial rights outweighed any public interest.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of WBTV’s motion to intervene, agreeing that the district court lacked jurisdiction at that stage. However, the appellate court treated WBTV’s appeal regarding the sealing order as a petition for a writ of mandamus. The Fourth Circuit held that the district court’s order sealing the video exhibits violated the First Amendment right of access to judicial records. The court vacated the sealing order and remanded with instructions to unseal the video footage, finding that Loveridge had not met her burden to justify continued sealing. View "Gray Media Group, Inc. v. Loveridge" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law