Justia Civil Rights Opinion Summaries

Junius Joyner, III, an African-American male, was hired by a legal staffing agency, Mestel & Company (Hire Counsel), and assigned to work at Morrison & Foerster LLP in Washington, D.C. He worked on the merger of Sprint Corporation with T-Mobile U.S., Inc. from July to December 2019. Joyner alleged several incidents of racial discrimination and a hostile work environment, including delayed work assignments, derogatory comments, and harassment by coworkers. He also claimed wrongful discharge under D.C. law, asserting he was terminated after reporting potential antitrust violations.The United States District Court for the District of Columbia dismissed Joyner’s complaint for failure to state a claim. The court found that Joyner did not provide sufficient facts to support his claims of racial discrimination and a hostile work environment under 42 U.S.C. § 1981 and Title VII. The court also dismissed his wrongful discharge claim under D.C. law, concluding that it lacked supplemental jurisdiction over this state law claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of Joyner’s federal claims, agreeing that Joyner failed to plausibly allege that his treatment was racially motivated or that the work environment was sufficiently hostile. The court found that Joyner’s allegations did not meet the necessary standard to infer racial discrimination or a hostile work environment. However, the appellate court vacated the district court’s judgment on the wrongful discharge claim, holding that the district court lacked jurisdiction over this claim and remanded it with instructions to dismiss for lack of jurisdiction. View "Joyner v. Morrison and Foerster LLP" on Justia Law

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law

In this case, Olivia Boone, on behalf of her autistic son K.A., challenged the Rankin County Public School District's decision to move K.A. to a new program at a different school without her consent. Boone filed a complaint with the Mississippi Department of Education, alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by unilaterally making the placement decision. A hearing officer found that the school district violated the IDEA and ordered relief but denied Boone's request for compensatory educational services. Boone then filed a suit seeking compensatory educational services and attorneys' fees.The United States District Court for the Southern District of Mississippi affirmed the hearing officer's decision, holding that Boone was entitled to attorneys' fees but not compensatory educational services. Boone appealed the denial of compensatory educational services, and the school district cross-appealed the finding that it violated the IDEA and the award of attorneys' fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The court held that the school district denied K.A. a free appropriate public education by failing to individualize his education plan to address his elopement tendencies and by predetermining his placement without Boone's input. However, the court found that Boone did not prove that Brandon Middle School was not K.A.'s least restrictive environment. The court also held that Boone was not entitled to compensatory educational services, as the district court did not abuse its discretion in limiting relief to address Boone's primary concerns. Finally, the court affirmed that Boone was a prevailing party entitled to attorneys' fees, as the relief awarded altered the legal relationship between K.A. and the school district and fostered the purposes of the IDEA. View "Boone v. Rankin County" on Justia Law

A group of current and former pretrial detainees filed a putative class action against Prince George’s County, Maryland, and 11 state court judges, alleging that their detentions and the policies leading to them were unconstitutional. The plaintiffs sought a declaratory judgment, injunctive relief, and compensatory damages, claiming violations of the Due Process Clause and the Maryland Constitution.The United States District Court for the District of Maryland granted judgment on the pleadings, concluding that the judges and the county had absolute immunity from the plaintiffs’ claims for damages and an injunction, and that a declaratory judgment could not provide meaningful relief. The district court dismissed the judicial defendants based on absolute judicial immunity and dismissed the claims against the county based on quasi-judicial immunity. Additionally, the district court dismissed seven plaintiffs who had been released from pretrial detention, reasoning that they would not benefit from any available remedy.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal of the judicial defendants but concluded that the dismissal should have been for lack of subject matter jurisdiction due to the absence of an Article III case or controversy. The court held that the judicial defendants were acting in an adjudicative capacity, not as adversaries, and thus there was no justiciable controversy. The court also reversed the district court’s dismissal of the claims against the county, holding that municipalities do not enjoy immunity from suit under 42 U.S.C. § 1983. The court remanded the case for further proceedings consistent with its opinion, including the reinstatement of the claims of the seven plaintiffs who had been released from pretrial detention. View "Frazier v. Prince Georges County" on Justia Law

In the spring of 2020, a woman with a history of severe mental illness was detained at the Bucks County Correctional Facility after an altercation with a neighbor. While in custody, she was allegedly subjected to repeated uses of force by corrections officers, including being pepper sprayed, handcuffed, and placed in a restraint chair on multiple occasions. The complaint asserts that these actions were taken as punishment for her inability to comply with directives due to her mental illness, and that she did not pose a threat to staff or other inmates. Her condition deteriorated significantly during her detention, leading to her eventual transfer to a mental hospital, by which time she was reportedly catatonic and unresponsive.Her parents, acting on her behalf, filed suit in the United States District Court for the Eastern District of Pennsylvania against Bucks County and various corrections officers, alleging violations of her constitutional rights under 42 U.S.C. § 1983. The District Court found that the complaint sufficiently alleged a violation of her Fourteenth Amendment right to be free from excessive force and denied the defendants’ motion to dismiss on qualified immunity grounds. The court reasoned that the complaint was not detailed enough to determine whether the right at issue was clearly established at the time of the alleged conduct, and that further factual development was necessary.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that when a complaint plausibly alleges a constitutional violation but lacks sufficient detail to assess whether the right was clearly established, qualified immunity cannot be granted at the motion-to-dismiss stage. The court concluded that the defendants’ entitlement to qualified immunity was not apparent from the face of the complaint and remanded the case for limited discovery to develop the facts necessary for a proper qualified immunity analysis. View "Stringer v. County of Bucks" on Justia Law

In this case, inmate Kyle Richards alleged that Thomas Perttu, a prison employee, sexually harassed him and other inmates. Richards also claimed that Perttu destroyed his grievance documents and retaliated against him for attempting to file them. Richards sued Perttu under 42 U.S.C. §1983 for violating his constitutional rights, including his First Amendment right to file grievances. Perttu moved for summary judgment, arguing that Richards had failed to exhaust available grievance procedures as required by the Prison Litigation Reform Act (PLRA).The Magistrate Judge found a genuine issue of fact regarding whether Richards was excused from exhausting his claims due to Perttu's interference and held an evidentiary hearing. The Magistrate Judge concluded that Richards's witnesses lacked credibility and recommended dismissal without prejudice for failure to exhaust. The District Court adopted this recommendation. The Sixth Circuit reversed, holding that the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case.The Supreme Court of the United States held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The Court reasoned that the usual practice under the Federal Rules of Civil Procedure is that factual disputes regarding legal claims go to the jury. The PLRA is silent on whether judges or juries should resolve exhaustion disputes, and this silence indicates that the usual practice should be followed. The Court affirmed the judgment of the Sixth Circuit. View "Perttu v. Richards" on Justia Law

Plaintiff SeanPaul Reyes, who frequently posts videos of his interactions with police on YouTube, challenged a New York City Police Department (NYPD) policy that prohibits video recording inside police facilities. Reyes, who had been arrested twice for recording inside police stationhouses, argued that the policy violated his rights under the First Amendment and the New York State and New York City Right to Record Acts (RTRAs). He sought a preliminary injunction to prevent the City from enforcing the policy and to remove signs stating the policy.The United States District Court for the Southern District of New York granted Reyes a preliminary injunction based on his state and local law claims, despite finding that he was unlikely to succeed on his First Amendment claim. The court concluded that Reyes demonstrated a likelihood of success on the merits of his RTRAs claims, irreparable harm, and that the public interest favored an injunction.The City of New York appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court erred in exercising supplemental jurisdiction over the state and local claims and in finding that Reyes met the requirements for a preliminary injunction. The Second Circuit found no abuse of discretion in the district court's exercise of supplemental jurisdiction or its determination of irreparable harm. However, the court noted that the resolution of whether Reyes is likely to succeed on the merits and whether the public interest favors an injunction depends on the interpretation of the RTRAs.Given the lack of clear guidance from New York courts on whether the RTRAs afford a right to record inside police stationhouses, the Second Circuit certified the following question to the New York Court of Appeals: Does either N.Y. Civ. Rights Law § 79-p or N.Y.C. Admin. Code § 14-189 afford individuals the right to video record law enforcement activities inside public facilities, specifically inside the publicly accessible lobbies of police stationhouses, notwithstanding the NYPD policy forbidding such recording? The decision on the appeal is reserved pending the response from the New York Court of Appeals. View "Reyes v. City of New York" on Justia Law

Dr. Sari Edelman, a female rheumatologist, was employed by the New York University (NYU) hospital system. After nearly five years of employment without disciplinary issues, she had disputes with Joseph Antonik and David Kaplan regarding her office space. Edelman claimed that Antonik used a gender-based slur and behaved aggressively, and that Kaplan's subsequent handling of the issue was discriminatory. She lodged complaints with NYU human resources, alleging gender discrimination and hostile behavior. Her employment contract was not renewed the following year, leading to her termination.Edelman sued various NYU entities and individual employees, asserting claims under the federal and New York Equal Pay Acts, Title VII, the New York State Human Rights Law, and the New York City Human Rights Law. The United States District Court for the Southern District of New York granted partial judgment as a matter of law (JMOL) in favor of some defendants and dismissed certain claims. The jury found in favor of Edelman on her retaliation claims against NYU and Antonik, awarding her $700,000 in damages, but found for the defendants on all other claims. The District Court later granted judgment notwithstanding the verdict (JNOV) for the defendants, vacating the jury's verdict in favor of Edelman.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that there was sufficient evidence to support the jury's verdicts in Edelman's favor on her retaliation claims against NYU and Antonik. The court vacated the District Court's grant of JNOV for these claims and remanded with instructions to reinstate the jury's verdict. The court also vacated the District Court's decision granting JMOL in favor of Kaplan on the retaliation claim and remanded for a new trial on that claim. The judgment on the remaining claims was affirmed. View "Edelman v. NYU Langone Health System" on Justia Law

The case involves a challenge to the ward map adopted by the Jersey City Ward Commission following the 2020 federal census. The Commission found a 59% population deviation between the most and least populous wards, which exceeded the maximum allowed by the Municipal Ward Law (MWL). The Commission created a new map with a 1.8% deviation and revised the boundaries of all six wards. Plaintiffs, including individuals and community organizations, argued that the new map failed to meet the MWL’s compactness requirement and violated equal protection principles under the New Jersey Constitution. They also claimed a violation of the New Jersey Civil Rights Act (NJCRA).The trial court concluded that the Commission’s map created sufficiently compact wards under the MWL and dismissed the plaintiffs’ statutory and constitutional claims. The Appellate Division reversed the dismissal of the MWL claims, remanding for factfinding on whether the Commission’s determination of compactness had a rational basis. It affirmed the dismissal of the equal protection and NJCRA claims.The New Jersey Supreme Court reviewed the case, focusing on the MWL, equal protection, and NJCRA claims. The Court held that the Commission’s map was a proper exercise of its discretion under the MWL. It found that the Commission was not required to use mathematical measures of compactness or consider communities of interest in its determination. The Court reversed the Appellate Division’s remand for additional factfinding, reinstating the trial court’s judgment on the MWL claim. The Court also affirmed the dismissal of the equal protection and NJCRA claims, concluding that the Commission’s compliance with the MWL negated the equal protection claim and that no statutory or constitutional violation occurred to support the NJCRA claim. View "Jersey City United Against the New Ward Map v. Jersey City Ward Commission" on Justia Law

Two plaintiffs, a middle school teacher and an assistant principal, were employed by a school district in Oregon. They created the "I Resolve" campaign, which included a website and a video uploaded to YouTube, advocating for policies on gender identity, parental rights, and education. They used their own devices and time but also sent emails from their school accounts to district employees with links to the campaign. Following complaints from employees, students, and concerned citizens, and an independent investigator's determination that they violated district policies, the district terminated them but later reinstated them and transferred them to other positions.The United States District Court for the District of Oregon granted summary judgment in favor of the school district and individual defendants on all claims. The plaintiffs alleged that their termination was in retaliation for their protected speech and that they were discriminated against based on their religion and viewpoint. The district court concluded that the defendants' interests in avoiding disruption outweighed the plaintiffs' First Amendment rights and that the individual defendants were entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed in part and vacated in part the district court's summary judgment. It held that there were genuine disputes regarding the circumstances of the plaintiffs' expressive conduct and the extent of the resulting disruption. The court affirmed the summary judgment for the individual defendants on the First Amendment claim for damages due to qualified immunity but vacated the summary judgment for the district on the First Amendment claim for damages and the related claims for declaratory and injunctive relief. The court also vacated the summary judgment on the plaintiffs' Fourteenth Amendment Equal Protection claim and the Title VII claim, finding genuine issues of material fact regarding the credibility of the district's proffered reasons for the terminations. View "DAMIANO V. GRANTS PASS SCHOOL DISTRICT NO. 7" on Justia Law