Justia Civil Rights Opinion Summaries

A transgender prisoner, Robert Bayse, who identifies as a woman named Robbin, is serving two concurrent life sentences in a Georgia prison. Bayse suffers from gender dysphoria and borderline personality disorder and receives hormone therapy and mental-health counseling. Previously, Bayse was allowed to follow female grooming and cosmetic standards at another prison. However, at the current prison, these accommodations were denied, leading Bayse to file a lawsuit against several prison officials, alleging that the denial violated the Eighth Amendment's prohibition against cruel and unusual punishment.The United States District Court for the Southern District of Georgia denied the officials' motion for summary judgment based on qualified immunity. The court found that there was a genuine dispute of material fact regarding whether the social transitioning accommodations were medically necessary and whether the officials acted with deliberate indifference. The court also concluded that the officials were not entitled to qualified immunity because it was clearly established that denying medically necessary treatment for gender dysphoria constituted deliberate indifference.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's decision. The appellate court held that the burden of proving medical necessity for the social transitioning accommodations was on Bayse, and Bayse failed to provide sufficient evidence to meet this burden. The court also determined that the district court erred in its analysis of clearly established law by relying on nonprecedential decisions. Consequently, the Eleventh Circuit instructed the district court to grant qualified immunity to the prison officials. View "Bayse v. Philbin" on Justia Law

During a protest in Seattle on June 7-8, 2020, Taylor Cheairs was filming the event when Officer Anderson of the Seattle Police Department (SPD) threw a blast ball grenade that exploded and struck Cheairs in the groin, causing serious injury. Cheairs sued the City of Seattle, the SPD, and unnamed officers under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment and retaliation in violation of the First Amendment.The United States District Court for the Western District of Washington granted summary judgment in favor of the defendants. The court concluded that there was no Fourth Amendment violation because Cheairs was not seized, and no First Amendment violation because there was no evidence of retaliation. The court also ruled that without a constitutional violation, there could be no municipal liability under Monell v. Department of Social Services.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The Ninth Circuit held that although a reasonable fact finder could conclude that Cheairs was seized when Officer Anderson struck him with the blast ball, the use of force was reasonable under the circumstances. The court noted that the protesters near Cheairs posed an immediate threat to the safety of officers, citizens, and property. The court also held that Cheairs failed to establish a viable First Amendment retaliation claim because he did not provide evidence that his filming was a substantial or motivating factor in the use of force against him. Consequently, without a viable constitutional claim, Cheairs could not establish a claim for municipal liability. View "CHEAIRS V. CITY OF SEATTLE" on Justia Law

Chosen Consulting, LLC, doing business as Chosen Healthcare, and other related entities (collectively "Chosen") filed a lawsuit against the Town Council of Highland, Indiana, the Highland Municipal Plan Commission, and the Town of Highland, Indiana (collectively "the Town"). Chosen alleged that the Town discriminated against patients with addiction-related ailments by refusing to provide a letter stating that Chosen’s proposed use of its property complies with local zoning requirements. Chosen claimed this discrimination violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, seeking compensatory, injunctive, and declaratory relief.The United States District Court for the Northern District of Indiana granted summary judgment to the Town. The district court held that Chosen's claim for injunctive relief under the ADA and the Rehabilitation Act was not ripe for adjudication because Chosen had not obtained a final decision from the local zoning authorities. The court indicated that Chosen needed to pursue its request for zoning approval through the Board of Zoning Appeals (BZA) and, if necessary, appeal any final decision entered by the BZA to the state courts before seeking an injunction in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit held that Chosen's claim for injunctive relief was not ripe because Chosen had not satisfied the finality requirement set forth in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City. The court emphasized that Chosen needed to follow the local zoning procedures, including applying for a use variance or seeking a declaratory judgment in state court, to obtain a final decision from the Town. Until Chosen completed these steps, the dispute was not ripe for federal court review. View "Chosen Consulting, LLC v Town Council of Highland" on Justia Law

John Baldwin sued Union Pacific Railroad Company under the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA), alleging he was unlawfully removed from his position following a fitness-for-duty evaluation. Baldwin, who had degenerative arthritis and underwent a double hip replacement, experienced a bursitis flare-up while working, leading to a fitness-for-duty evaluation. Despite being cleared by his orthopedic surgeon and a physical exam, Union Pacific's Chief Medical Officer imposed work restrictions based on Baldwin's exercise tolerance test results, which showed low aerobic capacity and mild hypertension. Baldwin was ultimately prevented from returning to his job.The United States District Court for the District of Nebraska denied both parties' summary judgment motions. Baldwin voluntarily dismissed his disparate impact and ADEA claims, proceeding to trial on the ADA claims for disparate treatment and failure to accommodate. The jury found that Union Pacific discriminated against Baldwin based on a perceived disability but concluded he posed a direct threat to himself. The district court entered judgment for Union Pacific and denied Baldwin’s motion for a new trial, which challenged the jury instructions.The United States Court of Appeals for the Eighth Circuit reviewed the case. Baldwin argued that the jury instructions misallocated the burden of proof and omitted essential elements of the direct threat defense. The court found that while the direct threat instruction was incomplete, it did not affect the trial's outcome. The business judgment instruction was deemed appropriate and did not mislead the jury. The court affirmed the district court's judgment, concluding that the instructions, taken as a whole, did not mislead the jury or affect Baldwin's substantial rights. View "Baldwin v. Union Pacific Railroad Co." on Justia Law

Patricia Conway, a registered nurse, was terminated from Mercy Hospital St. Louis for refusing to comply with the hospital's COVID-19 vaccination policy, which required all employees to be vaccinated unless they obtained an approved medical or religious exemption. Conway requested a religious exemption, which was denied. She was subsequently terminated and filed a lawsuit alleging religious discrimination under Title VII of the Civil Rights Act of 1964.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of Mercy Hospital, finding that as a religious organization, the hospital was exempt under 42 U.S.C. § 2000e-1(a). Conway appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Mercy Hospital qualifies as a "religious organization" under § 2000e-1(a) due to its structure, mission, and affiliation with the Roman Catholic Church. The court found that the hospital's religious identity and mission, supported by uncontroverted facts, met the criteria for the exemption.The court also rejected Conway's arguments that Mercy Hospital waived its exemption by complying with the CMS mandate and that it should be estopped from invoking the exemption due to its internal vaccine policy. The court concluded that compliance with federal regulations does not waive a statutory exemption and that the hospital's policy did not constitute a clear representation that would induce detrimental reliance.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Mercy Hospital, upholding the exemption for religious organizations under Title VII. View "Conway v. Mercy Hospital St. Louis" on Justia Law

Kenin Edwards was sentenced to 21 months’ imprisonment for tax fraud after a series of procedural complications. Edwards, who was represented by four different attorneys throughout the process, delayed his trial multiple times before pleading guilty. After his guilty plea, he fired his final attorney, decided to represent himself, recanted his admission of guilt, sought to vacate his plea, and filed numerous frivolous motions. The government, which had initially agreed to recommend a five-month split sentence, sought a 21-month sentence due to Edwards's conduct.The United States District Court for the Central District of Illinois handled the case. Edwards's initial attorneys withdrew due to a breakdown in strategy, and his subsequent attorney was disqualified due to a conflict of interest. Edwards then retained a fourth attorney, with whom he eventually reached a plea agreement. However, Edwards later discharged this attorney as well and chose to represent himself. The district court conducted a Faretta hearing to ensure Edwards's waiver of counsel was knowing and intelligent. Despite Edwards's numerous pro se filings and attempts to withdraw his guilty plea, the district court denied his motions and sentenced him to 21 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. Edwards argued that his Sixth Amendment rights were violated when the district court disqualified his attorney and allegedly forced him to proceed pro se at sentencing. He also claimed the government breached the plea agreement by recommending a higher sentence. The Seventh Circuit dismissed Edwards's appeal, finding that he had waived his right to appeal in his plea agreement. The court held that Edwards's claims did not fall within the exceptions to the appeal waiver and that the government did not breach the plea agreement. View "United States v. Edwards" on Justia Law

The case involves Jane Roe, a student at Marshall University, who was sexually assaulted by her ex-boyfriend, John Doe, at an off-campus party following a football game in September 2022. Roe reported the incident to the police, who then informed the university. The university's Title IX office reviewed the case but determined it fell outside their jurisdiction as the incident occurred off-campus and was not part of a university-sponsored event. The matter was referred to the Office of Student Conduct, which investigated and disciplined both Doe and Roe for their respective violations of the Student Code.In the United States District Court for the Southern District of West Virginia, Roe filed a lawsuit against the Marshall University Board of Governors, alleging deliberate indifference and retaliation under Title IX. The district court granted summary judgment in favor of the university, finding that the university's response did not amount to deliberate indifference and that the university did not retaliate against Roe for reporting the assault.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the university did not have substantial control over the context of the harassment, as the incident occurred at a private off-campus residence. Additionally, the court found that Roe failed to provide sufficient evidence to show that the university's reasons for disciplining her were pretextual. The court concluded that the university's actions were not retaliatory and upheld the summary judgment in favor of the university. View "Roe v. Marshall University Board of Governors" on Justia Law

Officer Mason Roth shot and killed Bobby Jo Klum, who was walking through a residential neighborhood with a gun to his head, evading arrest, and ignoring officer commands to drop the weapon. Klum’s spouse and mother sued Officer Roth and the City of Davenport under 42 U.S.C. § 1983, alleging a violation of Klum’s Fourth Amendment right against unreasonable seizure. The district court granted qualified immunity to Officer Roth and concluded the City of Davenport was not liable under Monell v. Department of Social Services.The United States District Court for the Southern District of Iowa granted summary judgment to Officer Roth and the City of Davenport on all claims. The court concluded that Klum’s Fourth Amendment right against unreasonable seizure was not violated and that Klum did not possess a clearly established right against seizure by deadly force under the circumstances. Plaintiffs appealed the district court’s grant of summary judgment based on qualified immunity as to their excessive force claim against Officer Roth and the City of Davenport.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that any right was not clearly established at the time, and therefore, Officer Roth was entitled to qualified immunity. The court found that the totality of the circumstances, including Klum’s non-compliance, evasion, and proximity to bystanders, justified the use of deadly force. The court also upheld the district court’s grant of summary judgment on the Monell claim, concluding that Plaintiffs failed to raise a genuine issue as to whether the City of Davenport had a policy that directly caused the use of deadly force. View "Klum v. City of Davenport" on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law

Justin J. (Father) appealed a jurisdiction finding and disposition order declaring his children, Hunter V. and B.V., dependents of the juvenile court. The court sustained a petition under Welfare and Institutions Code section 300, subdivisions (b)(1) and (j), alleging the children's mother had a history of substance abuse and left the children without proper care. The petition also alleged Father had an extensive criminal history and was incarcerated, which placed the children at risk.The Los Angeles County Superior Court held a detention hearing where neither parent was present. The court detained the children and ordered monitored visitation for both parents. At the jurisdiction hearing, the court amended the petition to allege Father was unable to parent due to his incarceration and inability to make an appropriate plan for the children. The court sustained the amended allegations and proceeded with the disposition hearing, declaring the children dependents of the court and ordering reunification services for both parents.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court found that the juvenile court violated Father's due process rights by failing to provide notice of the amended allegations, which were based on a different set of facts and legal theory from the initial petition. The court also violated Father's statutory right to be present at the jurisdiction hearing, as required by Penal Code section 2625, subdivision (d). The appellate court applied the Chapman standard for federal constitutional error and concluded the error was not harmless beyond a reasonable doubt. Consequently, the court reversed the jurisdiction finding and disposition order as to Father and remanded the case for further proceedings with Father present unless he waives his right to be present. View "In re Hunter V." on Justia Law