Justia Civil Rights Opinion Summaries

Dawn Lui, a longtime employee of the United States Postal Service (USPS), alleged disparate treatment, a hostile work environment, and unlawful retaliation under Title VII of the Civil Rights Act. Lui, a woman of Chinese ethnicity, claimed she was targeted with false complaints and grievances by employees at the Shelton Post Office due to her race, sex, and national origin. She was demoted from her position as Postmaster in Shelton, Washington, to a lower-paying Postmaster position in Roy, Washington, and replaced by a white man. Lui filed an informal discrimination complaint through USPS’s Equal Employment Opportunity (EEO) System and later a formal EEO complaint.The United States District Court for the Western District of Washington granted summary judgment to USPS on all of Lui’s claims. The court found that Lui failed to establish a prima facie case of discrimination, did not exhaust her administrative remedies for her hostile work environment claim, and failed to establish a causal connection for her retaliation claim.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Lui’s disparate treatment claim, holding that Lui established a prima facie case of discrimination by showing she was replaced by a white man, which gave rise to an inference of discrimination. The court also found a genuine dispute of material fact about whether the decision to demote Lui was influenced by subordinate bias.The Ninth Circuit vacated the district court’s summary judgment on Lui’s hostile work environment claim, concluding that Lui exhausted her administrative remedies and remanded the case for the district court to address the merits of this claim. However, the court affirmed the district court’s grant of summary judgment on Lui’s retaliation claim, finding that Lui failed to establish a causal connection between her protected activity and the demotion. View "LUI V. DEJOY" on Justia Law

Dewey Austin Barnett, II, acting pro se, sued a Missouri county and a jail administrator, Brenda Short, alleging that they refused to allow him to have a Bible while he was in administrative segregation at the Jefferson County jail. Barnett claimed that the lack of a Bible caused him anxiety, stress, and depression, and led him to feel guilt and shame. He sought damages and injunctive relief. Barnett attached a grievance and a letter to his complaint, detailing his requests for a Bible and the jail's responses.The United States District Court for the Eastern District of Missouri dismissed Barnett's case. The court held that Barnett's RLUIPA claim could not succeed because RLUIPA does not permit plaintiffs to recover money damages, and his request for injunctive relief was moot due to his transfer to another facility. The court also dismissed Barnett's § 1983 claim, stating that he did not adequately plead Short's personal involvement in the decision to deprive him of his Bible and that the decision did not substantially burden his free exercise of religion. Additionally, the court dismissed the § 1983 claim against the county, explaining that Barnett failed to allege a policy of denying Bibles to inmates in administrative segregation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed in part and reversed in part. The court held that RLUIPA permits claims for damages against the county, as "appropriate relief" includes damages. However, the court concluded that RLUIPA does not allow claims for damages against individuals in their personal capacities. The court also found that Barnett sufficiently alleged Short's personal involvement and that the deprivation of a Bible for a month substantially burdened his religious exercise. The court remanded the case for further proceedings on the RLUIPA claim against the county and the § 1983 claim against Short. View "Barnett v. Short" on Justia Law

Joel Uviles sued the City of New York under 42 U.S.C. § 1983, claiming that the New York City Department of Corrections (DOC) unlawfully detained him based on a state parole warrant. Uviles, who was on state parole, was arrested on new charges and detained without receiving a preliminary hearing within the required fifteen days. After posting bail on the new charges, he was still detained for another seventeen days until the state board of parole lifted the warrant.The United States District Court for the Eastern District of New York granted summary judgment in favor of the City. The court found that the City lawfully detained Uviles because the parole warrant was properly delivered to the New York City Police Department and the criminal court, and the warrant information was transmitted to the DOC. The court also held that the parole warrant remained facially valid even after the fifteen-day hearing deadline expired.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court concluded that the City lawfully detained Uviles because the parole warrant was valid until it was lifted by the state board of parole or a court. The court held that the City had no discretion to release Uviles without such authorization, and therefore, his detention was lawful. The court also noted that the failure to provide a timely preliminary hearing did not render the warrant facially invalid under state law. View "Uviles v. City of New York" on Justia Law

In the early morning of October 23, 2013, Colleen Ritzer, a Danvers High School math teacher, was found dead in the woods outside the high school. She had been raped, strangled, and stabbed. The defendant, a fourteen-year-old student in her class, was convicted by a Superior Court jury of first-degree murder, aggravated rape, and armed robbery. The primary issue at trial was whether the defendant lacked criminal responsibility due to mental illness.The defendant appealed, arguing that the trial judge impeded his ability to present his defense. He raised several issues: the exclusion of expert testimony on brain scans, limitations on expert testimony regarding his statements, improper cross-examination of defense experts, forced disclosure of psychological test data, the use of suppressed statements by the Commonwealth's expert, the denial of a jury instruction on adolescent brain development, insufficient evidence for the aggravated rape and armed robbery convictions, the denial of a motion to suppress evidence, improper prosecutorial conduct in closing arguments, the denial of a change of venue due to pretrial publicity, and the proportionality of his sentence under the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the exclusion of the brain scan evidence was within the judge's discretion due to its limited probative value and potential for unfair prejudice. The limitations on expert testimony were also upheld, since the defendant was able to present sufficient evidence of his mental state. The court found no abuse of discretion in the cross-examination of defense experts or the disclosure of psychological test data. The use of the suppressed statements by the Commonwealth's expert did not warrant exclusion of the testimony. The court also found no error in the denial of the jury instruction on adolescent brain development, the sufficiency of the evidence for the aggravated rape and armed robbery convictions, the denial of the motion to suppress, or the prosecutor's closing arguments. The court concluded that the defendant was not entitled to a change of venue and that his sentence was not disproportionate under the Massachusetts Declaration of Rights. View "Commonwealth v. Chism" on Justia Law

The complainant, John Ward, filed a complaint with the Commission on Human Rights and Opportunities (CHRO) alleging that the City of Stamford discriminated against him based on his veteran status and disability. The CHRO found reasonable cause and certified the complaint to the Office of Public Hearings (OPH). During the public hearing, Ward moved to amend his complaint to include a claim for denial of reasonable accommodations. The human rights referee granted the motion over the city's objection.The city filed an interlocutory administrative appeal with the Superior Court, arguing that the CHRO lacked jurisdiction to hear the amended complaint without a reasonable cause finding. The CHRO and Ward moved to dismiss the appeal, contending that interlocutory rulings are not appealable under General Statutes § 46a-94a (a) and that the statutory requirements for an interlocutory appeal under § 4-183 (b) were not met. The trial court denied the motions to dismiss, finding that the referee's ruling was a final decision under § 4-183 (a).The Supreme Court of Connecticut reviewed the case and concluded that the referee's ruling was not a final decision under § 4-183 (a) because it did not terminate any aspect of the case or determine any rights or obligations. The court also determined that § 46a-94a (a) allows for interlocutory appeals under § 4-183 (b), but the city's appeal did not meet the criteria for such an appeal because postponement would not result in an inadequate remedy. The court reversed the trial court's decision and remanded with direction to grant the motions to dismiss the city's appeal. View "Stamford v. Commission on Human Rights& Opportunities" on Justia Law

A neighbor called the Fort Worth Police Department at 2:25 a.m. on October 12, 2019, to report that Atatiana Jefferson's front door was open, which was unusual. Officer Aaron Dean and another officer responded, arriving at 2:28 a.m. and 2:29 a.m., respectively. Following protocol, they parked out of view and did not use emergency lights or sirens. They conducted a perimeter sweep of the house, using flashlights to look for signs of a break-in. Jefferson, who was home with her nephew, noticed someone outside and approached the window. Dean, without announcing himself as an officer, commanded Jefferson to show her hands and then fired a shot, killing her.The United States District Court for the Northern District of Texas denied Dean's motion to dismiss based on qualified immunity and stayed discovery. Dean appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's judgment regarding the excessive force claim, holding that Dean's use of deadly force without warning was objectively unreasonable under clearly established law. However, the court reversed the district court's judgment on the unreasonable search claim, finding that Dean was performing a community caretaking function and that there was no clearly established law indicating his actions were unreasonable. The case was remanded for further proceedings consistent with the opinion. View "Bakutis v. Dean" on Justia Law

Michael Chapman, an Alabama inmate, sued prison officials and staff for deliberate indifference to his medical needs, violating the Eighth Amendment. Chapman alleged that an untreated ear infection led to severe injuries, including mastoiditis, a ruptured eardrum, and a brain abscess. He also claimed that the prison's refusal to perform cataract surgery on his right eye constituted deliberate indifference. The district court granted summary judgment for all defendants except the prison’s medical contractor, which had filed for bankruptcy.The United States District Court for the Middle District of Alabama found Chapman’s claim against nurse Charlie Waugh time-barred and ruled against Chapman on other claims, including his request for injunctive relief against Commissioner John Hamm, citing sovereign immunity. The court also concluded that Chapman’s claims against other defendants failed on the merits and dismissed his state-law claims without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court reversed the district court’s determination that Chapman’s claim against Waugh was time-barred, finding that Chapman’s cause of action accrued within the limitations period. The court vacated the district court’s judgment for Waugh and remanded for reconsideration in light of the recent en banc decision in Wade, which clarified the standard for deliberate indifference claims. The court also vacated the judgment for Hamm on Chapman’s cataract-related claim for injunctive relief, as sovereign immunity does not bar such claims. Additionally, the court vacated the summary judgment for all other defendants due to procedural errors, including inadequate notice and time for Chapman to respond, and remanded for further consideration. View "Chapman v. Dunn" on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law

Stanley Felton, also known as G’esa Kalafi, was incarcerated at the Wisconsin Secure Program Facility from 2007 to 2015. He filed a pro se complaint under 42 U.S.C. § 1983 against several prison employees, alleging Eighth and Fourteenth Amendment violations due to his prolonged solitary confinement and First Amendment violations for the confiscation of his outgoing mail. Felton claimed that Warden Tim Haines and his successor Gary Boughton were responsible for his continued solitary confinement, and that three other officials, Lebbeus Brown, Joseph Cichanowicz, and Daniel Winkleski, illegally confiscated his mail.The United States District Court for the Western District of Wisconsin dismissed Felton’s Eighth and Fourteenth Amendment claims after screening the complaint and denied his motion to file an amended complaint. After discovery, the court granted summary judgment against Felton on his First Amendment claims, concluding that the prison officials were entitled to qualified immunity and that the confiscation of Felton’s mail did not violate his First Amendment rights.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decisions, holding that Felton did not adequately allege a Fourteenth Amendment due process violation, as the delayed review of his administrative confinement did not constitute a constitutional violation. The court also found that Felton had waived his Eighth Amendment claim on appeal by not sufficiently developing the argument. Regarding the First Amendment claims, the court concluded that the confiscation of Felton’s letter containing threatening language was justified and that the defendants were entitled to qualified immunity for retaining the state court order that accompanied the letter. The court emphasized that the defendants’ actions did not violate clearly established law. View "Felton v Brown" on Justia Law