Justia Civil Rights Opinion Summaries

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

The State of Nevada charged Matthew Desavio with a felony for making threats or conveying false information concerning an act of terrorism. Desavio was found incompetent to stand trial and was ordered to be transferred for competency restoration treatment. However, the State failed to transfer him, leading to a nearly 90-day delay. Desavio moved to dismiss the charge due to this delay, and the district court initially held the Nevada Division of Public and Behavioral Health in contempt and fined them, but eventually dismissed the criminal complaint without prejudice.The Eighth Judicial District Court in Clark County reviewed the case and dismissed the criminal complaint without prejudice due to the State's failure to transfer Desavio for competency restoration treatment. The State appealed, arguing that the district court lacked a legal basis to dismiss the case under the competency statutes and the recent decision in State v. Gonzalez. The district court found that the delay violated Desavio's due process rights, which constituted ongoing prejudice.The Supreme Court of Nevada reviewed the case and affirmed the district court's decision. The court held that the dismissal without prejudice was appropriate to remedy the ongoing prejudice to Desavio's due process rights. The court noted that the district court had tried lesser sanctions, such as holding the Division in contempt and imposing fines, but these measures proved ineffective. The Supreme Court concluded that the district court did not abuse its discretion in dismissing the charge without prejudice, as it was a necessary step to address the violation of Desavio's due process rights. View "State v. Desavio" on Justia Law

Ali Tuckett sought damages from the State of New York under Court of Claims Act § 8-b, claiming unjust conviction and imprisonment. Tuckett's 2011 conviction for sexually abusing his minor cousin, N.M., was vacated after N.M. recanted his testimony in 2013, admitting he had lied. Tuckett then filed a claim for damages, asserting his innocence and that he did not cause his conviction.The Court of Claims dismissed Tuckett's claim, concluding he did not prove his innocence by clear and convincing evidence. The court excluded polygraph evidence Tuckett wanted to present and found N.M.'s recantation not credible, relying on testimony from the original investigation and trial. The Appellate Division affirmed the dismissal, agreeing that any reliance on hearsay was harmless and that the court's findings were supported by the record. Two justices dissented, believing the court improperly relied on evidence outside the record and hearsay.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's decision. The court found that any potential hearsay error was harmless given the substantial non-hearsay evidence supporting the Court of Claims' decision. The court also determined that the findings of fact were supported by the record and that the Court of Claims did not improperly rely on evidence outside the record. Additionally, the court rejected Tuckett's argument that the Court of Claims applied an incorrect presumption regarding the reliability of recantation testimony, noting that the court provided specific reasons for finding N.M.'s recantation not credible.The Court of Appeals held that Tuckett failed to prove his innocence by clear and convincing evidence and affirmed the dismissal of his claim. View "Tuckett v State of New York" on Justia Law

Professor James Wetherbe, known for his anti-tenure views, claimed he faced retaliation from Lance Nail, the then-dean of the business school at Texas Tech University (TTU), for his public criticisms of tenure. Wetherbe alleged that Nail's retaliatory actions included removing him from teaching assignments, falsely accusing him of misconduct, and revoking his emeritus status, among other adverse actions. Wetherbe sued Nail under 42 U.S.C. §1983 for violating his First Amendment rights and sought injunctive and declaratory relief against the current dean, Margaret Williams.The United States District Court for the Northern District of Texas denied the defendants' second amended Rule 12(c) motion, holding that Wetherbe sufficiently alleged a constitutional violation and that Nail’s actions were objectively unreasonable in light of clearly established law. The defendants appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court concluded that the contours of First Amendment law regarding retaliation were not clearly established at the time the events occurred. Specifically, the court found that it was not clearly established that Wetherbe’s speech regarding tenure was on a matter of public concern. Consequently, the court reversed the district court’s order and rendered judgment in favor of the defendants, granting Nail qualified immunity from Wetherbe’s First Amendment retaliation claims. The court did not address Wetherbe’s claims for declaratory and injunctive relief against Williams, as the district court had not ruled on those claims. View "Wetherbe v. Texas Tech University" on Justia Law

Lawrence Davonn Foye was placed on court-supervised parole after being convicted of fleeing in a vehicle with reckless indifference. His parole conditions included not violating any laws, avoiding disreputable persons, and abstaining from drug use. In January 2023, his probation officer filed a petition to revoke his parole, alleging three violations: using marijuana, being charged with first-degree murder, and associating with a disreputable person. Following a hearing, the Circuit Court of Kanawha County revoked his parole and imposed the underlying sentence.The Circuit Court found that the State presented sufficient evidence to support the parole violations. Detective Adkins testified about the murder investigation, corroborating information from a cooperating witness with cell phone data and video footage. The court also noted that Foye did not contest the allegations of drug use and associating with a disreputable person. The court applied the "reasonable cause" standard from West Virginia Code § 62-12-10(a)(1) to revoke Foye's parole.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the Circuit Court's decision. The court clarified that the standard of proof for a final parole or probation revocation hearing under West Virginia Code § 62-12-10(a)(1) is proof by a preponderance of the evidence. The court found that the State met this standard by presenting sufficient evidence of all three parole violations. The court also addressed the procedural due process requirements, ensuring that Foye's rights were protected during the revocation process. View "State v. Foye" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

Petitioner Jayden Demarko McDaniel, a Black individual, was charged with multiple felonies, including attempted first-degree murder and gang-related offenses. McDaniel alleged that he was disparately charged with gang enhancements due to his race, in violation of the California Racial Justice Act of 2020 (RJA). He sought discovery of evidence from the prosecution to support his claim, arguing that statistical evidence indicated a racial disparity in the application of gang enhancements in San Mateo County.The San Mateo County Superior Court denied McDaniel's motion for discovery, concluding that he failed to demonstrate "good cause" as required by the RJA. The court found that McDaniel's statistical evidence lacked context and did not provide specific facts about his case or other similar cases involving non-Black defendants. McDaniel then filed a petition for writ of mandate with the Court of Appeal, which was initially denied without prejudice. He subsequently refiled his petition, which was again denied by the superior court.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that McDaniel had met the low threshold for demonstrating good cause for discovery under the RJA. The court held that McDaniel's county-specific statistical evidence, supported by an expert declaration, presented a plausible factual foundation for his claim of racial bias in charging decisions. The court emphasized that the RJA's discovery standard is intended to be broad and flexible, allowing for various types of evidence, including statistical data, to support a claim of racial disparity.The Court of Appeal vacated the trial court's order and remanded the case for a new hearing to reconsider McDaniel's discovery motion, directing the trial court to weigh the potential probative value of the requested information against the burdens of gathering it. View "McDaniel v. Superior Court" on Justia Law

Jason and Brandren Sims filed a lawsuit against the Dallas Independent School District (DISD) under 42 U.S.C. § 1983 after their mother, a special-education instructor, died following an assault by a student. They claimed that DISD was directly liable for her death due to an official policy or custom that led to a constitutional violation.The United States District Court for the Northern District of Texas dismissed the case for failure to state a claim. The plaintiffs appealed the decision, arguing that the district court erred in its dismissal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiffs failed to establish direct liability against DISD under § 1983. Specifically, the court noted that to prove such liability, plaintiffs must show an official policy or custom, knowledge of the policy by a policymaker, and a constitutional violation caused by that policy. The plaintiffs relied on the state-created danger theory of substantive due process to establish a constitutional violation. However, the Fifth Circuit reiterated that neither it nor the Supreme Court has ever adopted this theory. The court declined to recognize the state-created danger theory, citing the Supreme Court's caution against identifying unenumerated rights without a careful and deeply rooted historical basis. Consequently, the court affirmed the district court's dismissal of the case. View "Sims v. Dallas Independent School District" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

John Doe, a high school student with several psychological disabilities, repeated his freshman year at an out-of-state boarding school. Upon returning to Rhode Island, he sought a waiver from the Rhode Island Interscholastic League (the League) to extend his eligibility to play sports into his fifth year of high school, citing his disabilities as the reason for his request. The League denied the waiver, stating that his ineligibility was due to his voluntary decision to repeat the ninth grade, not his disabilities.Doe's parents appealed the League's decision to the Waiver Request Hearing Committee and the Principals' Committee, both of which upheld the denial. Subsequently, Doe filed a lawsuit in the District of Rhode Island, claiming that the League's refusal violated Titles II and III of the Americans with Disabilities Act (ADA). The district court granted a permanent injunction, allowing Doe to play sports in his fifth year, reasoning that the League's rule was not an essential aspect of its program and that Doe's disability was the but-for cause of his ineligibility.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's injunction. The appellate court concluded that Doe's disability was not the but-for cause of his ineligibility, as his decision to repeat the ninth grade was unrelated to his disability. Additionally, the court held that waiving the eight-semester rule would fundamentally alter the League's interscholastic athletics program, which aims to ensure competitive parity and maximize student participation. Thus, the requested accommodation was deemed unreasonable. View "Doe v. Rhode Island Interscholastic League" on Justia Law