Justia Civil Rights Opinion Summaries

Former employees of Shriners Hospitals for Children were terminated for refusing to get a COVID-19 vaccination. They sued their employer, its agents, and the Executive Commissioner of Texas Health and Human Services, alleging violations of their right to refuse the vaccine under 42 U.S.C. § 1983, the Emergency Use Authorization (EUA) Statute, and various Texas state laws.The United States District Court for the Southern District of Texas dismissed all claims. It found no personal jurisdiction over the agents due to the fiduciary shield doctrine, determined that Shriners was not a state actor when it implemented the vaccination policy, and ruled that the EUA Statute did not apply. The court also dismissed the claims against the Commissioner, concluding she was not liable for failing to stop Shriners from enforcing the policy. The state-law claims were dismissed for lack of supplemental jurisdiction.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It agreed that there was no personal jurisdiction over the agents and that Shriners was not a state actor when it adopted the vaccination policy. The court also held that the EUA Statute did not apply to Shriners in its capacity as an employer and that the Commissioner was entitled to qualified immunity because the plaintiffs did not demonstrate a clearly established right requiring her intervention. The appellate court modified the dismissal of the state-law claims to be without prejudice and affirmed the judgment as modified. View "Pearson v. Shriners Hospitals" on Justia Law

Jacques Rivera, after being released from over 20 years in prison for a wrongful murder conviction, sued the City of Chicago and several police officers under 42 U.S.C. §1983 for civil rights violations. A jury awarded him over $17 million, and his attorneys sought more than $6 million in fees and costs. The case was settled for $18.75 million, including at least $3.75 million for attorneys' fees and costs. Chicago, which had an insurance policy with Starstone Insurance SE covering liabilities between $15 and $20 million, sought indemnity for the $3.75 million. Starstone refused, claiming their policy only covered damages, not attorneys' fees and costs, and filed for a declaratory judgment.The United States District Court for the Northern District of Illinois ruled in favor of Chicago, determining that the insurance policy covered the entire $18.75 million settlement as an "ultimate net loss" that Chicago was legally obligated to pay. Starstone appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court first addressed whether Starstone, a Societas Europaea (SE) based in Liechtenstein, qualified as a "corporation" under 28 U.S.C. §1332 for diversity jurisdiction purposes and concluded that it did. On the merits, the court found that the insurance policy's language covered the entire settlement amount, including attorneys' fees and costs, as part of the "ultimate net loss" Chicago was legally obligated to pay. The court affirmed the district court's decision, holding that the policy's terms included indemnity for attorneys' fees and costs awarded under statutory provisions. View "Starstone Insurance SE v City of Chicago" on Justia Law

Marina Debity brought claims against the Monroe County Board of Education for sex discrimination and retaliation under the Equal Pay Act (EPA), Title VII of the Civil Rights Act of 1964, and the Tennessee Human Rights Act (THRA). Debity alleged that the Board offered her a lower salary than it had paid a male predecessor, Matthew Ancel, for the same job and retaliated by withdrawing her job offer when she requested equal pay.A jury found that the Board offered Debity less money for legitimate reasons unrelated to her sex and did not retaliate against her. Despite these findings, the jury awarded Debity over $195,000 in damages, likely due to poor instructions on the verdict form. The magistrate judge noticed the inconsistency but dismissed the jury without allowing objections. The magistrate judge later denied Debity's motions for judgment as a matter of law and for a new trial, classifying the verdicts as special verdicts and reconciling the inconsistency by entering judgment based on the jury's answers to the interrogatories.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court concluded that the magistrate judge presented the jury with a general verdict on the retaliation claims and a general verdict with interrogatories on the discrimination claims. The jury's answers to the interrogatories on the discrimination claims were consistent with each other but inconsistent with the general verdict. The court affirmed the magistrate judge's decision to enter judgment based on the interrogatories.Regarding the Board's affirmative defense to the discrimination claims, the court held that budget constraints and market forces of supply and demand each provided an independent basis to uphold the jury's verdict. Both reasons were legitimate business explanations for offering Debity a lower salary than Ancel. Consequently, the court affirmed the judgment in favor of the Board on all claims. View "Debity v. Monroe Cnty. Bd. of Educ." on Justia Law

John A. Poole was convicted in 2002 of first-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. He was 18 years old at the time of the crime and was sentenced to life imprisonment without the possibility of parole. The Michigan Court of Appeals affirmed his convictions, and the Michigan Supreme Court denied his application for leave to appeal. Poole filed multiple motions for relief from judgment, which were denied.Following the U.S. Supreme Court's decisions in Miller v. Alabama and Montgomery v. Louisiana, which addressed mandatory life sentences for juveniles, Poole sought relief again. The Michigan Supreme Court remanded the case to the Court of Appeals to determine if Poole was entitled to relief under the state constitution's prohibition on cruel or unusual punishment, as extended to 18-year-olds in People v. Parks. The Court of Appeals held that Parks applied retroactively and vacated Poole's sentence, remanding for resentencing.The Michigan Supreme Court reviewed whether Parks should apply retroactively to cases where the period for direct review had expired. The court held that Parks, which extended Miller's protections to 18-year-olds under the Michigan Constitution, announced a substantive rule and should be applied retroactively. The court overruled the state retroactivity analysis in People v. Carp to the extent it survived Montgomery. The court affirmed the Court of Appeals' decision to vacate Poole's sentence and remanded the case for resentencing under MCL 769.25a. View "People Of Michigan v. Poole" on Justia Law

The plaintiff sought damages from the Department of Children and Families (DCF), alleging religious discrimination during child protection proceedings that led to the termination of his parental rights. The trial court dismissed most of the plaintiff’s claims as time-barred but allowed some timely allegations related to the termination trial to proceed. DCF’s motion to reargue, asserting that the litigation privilege barred the remaining claims, was denied by the trial court.DCF appealed to the Appellate Court, which concluded that the litigation privilege did indeed bar the plaintiff’s remaining timely allegations and directed the trial court to dismiss the complaint in its entirety. The trial court complied, dismissing the entire complaint before the plaintiff could seek further appellate review.The plaintiff and the Commission on Human Rights and Opportunities argued that the Appellate Court erred in applying the litigation privilege to bar the discrimination claims. They contended that the privilege should not apply to DCF, a governmental entity, and that the legislature intended to abrogate the privilege in discrimination cases.The Connecticut Supreme Court held that the litigation privilege barred the plaintiff’s timely allegations related to DCF’s conduct during the termination trial. The court reasoned that the plaintiff’s claims were akin to defamation, to which the privilege applies, and not to vexatious litigation, which challenges the purpose of the underlying action. The court also found that other remedies were available to address DCF’s conduct and declined to adopt a rule precluding nonpersons from invoking the privilege.However, the Supreme Court reversed the Appellate Court’s judgment to the extent that it directed the trial court to dismiss the entire complaint, as this hindered the plaintiff’s ability to appeal the dismissal of his untimely claims. The case was remanded to the Appellate Court to vacate the trial court’s judgment and to remand the case for a new judgment of dismissal, allowing the plaintiff to appeal the timeliness ruling. View "Ammar I. v. Dept. of Children & Families" on Justia Law

Kalel Martínez-Bristol was indicted on June 24, 2021, for being a felon in possession of a firearm and ammunition, and for possession of a machinegun. At the time, he was on federal supervised release for a 2011 drug conspiracy conviction. He pled guilty to the felon-in-possession charge on September 9, 2022. The presentence report identified the firearm as a pistol with a machinegun conversion device. Martínez did not object to the report. On February 6, 2023, he was sentenced to 46 months' imprisonment for the felon-in-possession conviction.The District Court for the District of Puerto Rico also addressed the supervised release violation. The government argued it was a Grade A violation due to the machinegun, while Martínez argued for a Grade B violation. The court initially granted a continuance for further evidence. At the continued hearing, the government presented evidence that the firearm was a machinegun, which Martínez did not cross-examine. The court determined it was a Grade A violation and sentenced Martínez to 15 months' imprisonment, consecutive to his other sentence.The United States Court of Appeals for the First Circuit reviewed the case. Martínez waived any appeal regarding his felon-in-possession conviction and sentence by not briefing those issues. He argued that his due process and confrontation rights were violated in the revocation hearing, but the court found no error. The court noted that Martínez had the evidence months before the hearing and did not object. The court affirmed the judgments, finding the government's evidence sufficient to establish the firearm as a machinegun. View "United States v. Martinez-Bristol" on Justia Law

Raymond Tackett, an inmate with the Indiana Department of Corrections (IDOC), suffered from Hepatitis C (HCV) and did not receive direct-acting antivirals (DAAs), a treatment that cures HCV. He died on November 29, 2019, from complications related to HCV. His daughter, Skyler Tackett, as the personal representative of his estate, filed an Eighth Amendment deliberate indifference claim and a state law medical malpractice claim against the medical professionals who treated him, Wexford Health Services, and Dr. Kristen Dauss, the Chief Medical Officer of the IDOC. She later dismissed all claims except the deliberate indifference claim against Dr. Dauss.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Dr. Dauss, finding that she took reasonable steps to expand access to DAAs and was not responsible for the treatment decisions that led to Mr. Tackett’s death. Ms. Tackett appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court found that Ms. Tackett presented insufficient evidence for a reasonable jury to find Dr. Dauss liable in her individual capacity. The court noted that Mr. Tackett was in a treatment priority group and that Nurse Myers had requested DAAs for him, but there was no evidence that Dr. Dauss’s actions or the IDOC policy prevented him from receiving the treatment. The court concluded that while Mr. Tackett’s death was tragic, there was no evidence that Dr. Dauss’s actions amounted to deliberate indifference under the Eighth Amendment. View "Tackett v Dauss" on Justia Law

Stacie Culp and Stephanie Peters, both servers at Remington of Montrose Golf Club, LLC, alleged they were sexually harassed by bartender Jason DeSalvo. They filed claims under Title VII of the Civil Rights Act of 1964 and the Colorado Anti-Discrimination Act (CADA) for sexual harassment and retaliation. Remington's management conducted a limited investigation, resulting in DeSalvo's suspension and demotion. Culp claimed her hours were reduced in retaliation, leading to her resignation. Peters alleged inadequate investigation and retaliation, including being scheduled to work with DeSalvo post-suspension, leading to her departure.The United States District Court for the District of Colorado granted summary judgment for Remington on Peters's retaliation claim but allowed other claims to proceed to trial. The jury found against Peters on her remaining claims and returned inconsistent special verdicts on Culp's claims, awarding her punitive damages under Title VII despite finding no violation of her rights.The United States Court of Appeals for the Tenth Circuit affirmed the district court's summary judgment on Peters's retaliation claim, holding that neither the inadequate investigation nor the scheduling with DeSalvo constituted materially adverse actions. However, the court found the jury's verdict on Culp's claims irreconcilably inconsistent and vacated the verdict, remanding for a new trial on her harassment and retaliation claims. The court upheld the district court's evidentiary rulings, noting that objections to the admission of certain evidence were not properly preserved for appeal. View "Culp v. Remington of Montrose Golf Club" on Justia Law

The case involves BAK Realty, LLC, and Crossing Over, Inc., which operate a sober house in a three-family dwelling in Fitchburg, Massachusetts. The sober house, located in a residential B (RB) district, houses thirteen unrelated individuals recovering from addiction. The City of Fitchburg's zoning ordinances classify the sober house as a boarding house, a use not permitted in the RB district. The plaintiffs argue that the city's zoning ordinances violate the anti-disability discrimination provision of the Zoning Act, G. L. c. 40A, § 3, fourth par., which they interpret as requiring the city to treat the sober house residents as a "family" under local zoning laws.The Superior Court judge granted partial summary judgment in favor of the plaintiffs, annulling the decision of the Fitchburg Zoning Board of Appeals (board). The judge concluded that G. L. c. 40A, § 3, required the city to treat the sober house residents the same as a family or any similar-sized group of unrelated persons, whichever is more favorable. The judge ruled that the city's zoning ordinances could not be enforced against the sober house residents.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Superior Court's interpretation. The court held that G. L. c. 40A, § 3, fourth par., does not preempt municipalities from defining "family" for zoning purposes. The statute requires that disabled persons in congregate living arrangements be treated the same as either families or similar-sized groups of unrelated persons, but not necessarily both. The court found that the residents of the sober house did not meet the local definition of "family" and were treated the same as any similar group of thirteen unrelated people living together. Therefore, the court reversed the judgment of the Superior Court, upholding the board's decision that the sober house was operating as a boarding house, a use not permitted in the RB district. View "BAK Realty, LLC v. City of Fitchburg" on Justia Law

Plaintiff Samantha Pike, a licensed alcohol and drug treatment counselor employed by Wellspring, Inc., worked at Maine's Adult Treatment and Recovery Court (TRC) in Penobscot County. Charles Budd, Jr., the presiding judge overseeing TRC, made unwelcome sexual advances towards Pike during an out-of-state conference and continued this behavior upon returning to Maine. Pike filed a § 1983 action against Budd, alleging a violation of the Equal Protection Clause due to a hostile work environment.The United States District Court for the District of Maine dismissed Pike's claim, granting Budd qualified immunity. The court reasoned that case law did not clearly establish that Budd's conduct would violate the Equal Protection Clause in this context, particularly given Pike's status as a private employee rather than a state employee. The district court also noted that Budd likely was not acting under color of state law during the conference.The United States Court of Appeals for the First Circuit reviewed the case and concluded that Pike plausibly alleged a violation of her equal protection right to be free from a hostile work environment. The court determined that Budd's conduct, both at the conference and in his chambers, was sufficiently severe and pervasive to alter the conditions of Pike's employment. The court also found that it was clearly established that a state actor creating a hostile work environment violates the Equal Protection Clause, regardless of the plaintiff's employment status. Consequently, the First Circuit vacated the district court's dismissal and remanded the case for further proceedings. View "Pike v. Budd" on Justia Law