Justia Civil Rights Opinion Summaries

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

A group of student and parent organizations, along with individual students, brought suit against state and city officials responsible for New York City’s public education system. They alleged that admissions and screening policies, curriculum content, and a lack of teacher diversity in the city’s schools discriminated against Black and Latino students, resulting in segregation, unequal educational opportunities, and poor educational outcomes. The plaintiffs claimed these practices violated the New York State Constitution’s Education Article, the State Equal Protection Clause, and the New York State Human Rights Law, seeking declaratory and injunctive relief to eliminate admissions screens and address alleged discrimination.The Supreme Court, New York County, dismissed the complaint, finding the issues nonjusticiable as they involved educational policy decisions reserved for the legislature. The Appellate Division, First Department, modified that decision, holding that the claims were justiciable and that the complaint stated viable causes of action under the Education Article, the Equal Protection Clause, and, as to the City defendants, the Human Rights Law. The Appellate Division granted leave to appeal and certified the question of whether its order was properly made.The New York Court of Appeals reviewed the sufficiency of the complaint under the standard for motions to dismiss. The Court held that the plaintiffs failed to adequately plead a deprivation of a sound basic education, as their allegations of deficient resources and discriminatory policies were vague, conclusory, and did not demonstrate a district-wide failure or causation. The Court also found that the equal protection claim lacked sufficient allegations of intentional discrimination, and the Human Rights Law claim was not supported by specific facts. The Court of Appeals modified the Appellate Division’s order and dismissed the complaint, answering the certified question in the negative. View "IntegrateNYC, Inc. v State of New York" on Justia Law

A transgender woman sought to compete in the women’s division of powerlifting competitions organized by a national governing body. After registering and applying for a therapeutic use exemption to take a medication as part of her gender-affirming care, she was informed that the organization’s policy categorically barred transgender women from competing in the women’s division. The organization justified its policy by asserting that transgender women have an unfair competitive advantage due to “male physiology.” The woman’s competition card was revoked, and she was denied participation.The case was first heard in the Minnesota District Court, which granted partial summary judgment in favor of the plaintiff on her claims of sexual orientation discrimination in both public accommodations and business, as well as sex discrimination in business, under the Minnesota Human Rights Act (MHRA). The district court found the organization’s policy facially discriminatory and not justified by a legitimate business purpose. However, it denied summary judgment on the claim of sex discrimination in public accommodations, citing a statutory exemption for athletic events. The court also issued injunctive relief, ordering the organization to cease discriminatory practices and revise its policy.On appeal, the Minnesota Court of Appeals reversed the district court’s grant of partial summary judgment and injunctive relief, finding genuine issues of material fact regarding the organization’s motivation and the applicability of the legitimate business purpose defense.The Minnesota Supreme Court held that the organization’s policy was facially discriminatory and constituted direct evidence of discrimination based on sexual orientation under the MHRA. The court reinstated summary judgment for the plaintiff on the public accommodations claim, as no statutory defense was asserted. However, it found a genuine dispute of material fact regarding the legitimate business purpose defense for the business discrimination claim, affirming the appellate court’s reversal on that issue. The case was remanded for further proceedings. View "Cooper vs. USA Powerlifting" on Justia Law

A man experiencing a mental health crisis was fatally shot by police officers in his Newton, Massachusetts apartment building after a report of an attempted armed robbery at a nearby candy store. When officers arrived, the man, holding a kitchen knife, fled into his apartment building. Officers pursued him to the third floor, where he threatened self-harm and engaged in erratic behavior. Police attempted to negotiate with him for about twenty minutes, eventually convincing him to drop the knife and a fire extinguisher. As officers prepared to incapacitate him with a beanbag shotgun, the weapon malfunctioned. Some officers reported that the man then picked up the knife and moved toward them, prompting two officers to fire their sidearms, resulting in his death.The decedent’s parents, acting as representatives of his estate, filed suit in the United States District Court for the District of Massachusetts against the City of Newton and several police officers. They alleged excessive force under 42 U.S.C. § 1983, violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and various state law claims. The district court dismissed all claims, finding the officers were entitled to qualified immunity and that the plaintiffs had not sufficiently pleaded municipal liability or viable claims under the ADA or state law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The First Circuit affirmed the dismissal of all claims except the § 1983 excessive force claim against the officers related to the fatal shooting. The court held that, at the pleading stage, there were disputed material facts regarding whether the decedent was armed and posed an immediate threat when lethal force was used. The judgment was vacated as to this claim and remanded for further proceedings; all other dismissals were affirmed. View "Conlon v. Scaltreto" on Justia Law

A 69-year-old employee of the Cook County Sheriff’s Office, who previously had a long career with the Chicago Police Department, was terminated from his position as Assistant Chief of the Electronic Monitoring Unit. The termination followed an internal investigation into his work performance, which included allegations that he was absent from his post without authorization, failed to communicate with his team, and used work hours and resources for personal business. The investigation, initiated after a complaint by his supervisor, involved interviews with colleagues and a review of GPS and work records, ultimately concluding that he had neglected his duties on multiple occasions.After his termination, the employee filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against his supervisor in her individual capacity and the Sheriff in his official capacity, alleging age discrimination under the Fourteenth Amendment (via 42 U.S.C. § 1983), the Age Discrimination in Employment Act (ADEA), and the Illinois Human Rights Act (IHRA). He also brought an indemnification claim against Cook County. During discovery, he presented affidavits from other older officers alleging ageist comments and discriminatory treatment by the same supervisor. The district court granted summary judgment for all defendants, finding insufficient evidence of age-based disparate treatment or causation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, and that the evidence did not support a finding that any alleged discriminatory animus by the supervisor proximately caused the termination. The court also found that the internal investigation and the ultimate decisionmaker’s independent review provided legitimate, non-discriminatory reasons for the termination, precluding liability under the Fourteenth Amendment, ADEA, and IHRA. View "Gaines v Dart" on Justia Law

Isaac Contreras, a criminally committed patient at the Arizona State Hospital, was confined in an isolation cell for 665 days under the hospital’s “Administrative Separation” policy after a series of behavioral incidents. Emmanuel Walker, acting as Contreras’s guardian, filed suit in Arizona Superior Court against the State of Arizona and several officials, alleging that Contreras’s confinement violated his rights under both state and federal law. The complaint included two federal claims under 42 U.S.C. § 1983 and five state law claims, including one under Arizona Revised Statutes § 36-516, which protects the rights of seriously mentally ill persons.After the case was removed to the United States District Court for the District of Arizona based on federal question jurisdiction, the State moved for judgment on the pleadings on the § 36-516 claim. The district court granted the motion, dismissing that claim, and did not enter partial judgment under Rule 54(b). To expedite appellate review of this dismissal, the parties jointly stipulated to dismiss all remaining claims, both state and federal, with prejudice. The district court then dismissed the entire case, and Walker appealed the dismissal of the state law claim.While the appeal was pending, the Supreme Court decided Royal Canin U.S.A., Inc. v. Wullschleger, which held that if a plaintiff eliminates all federal claims after removal, the federal court loses jurisdiction and must remand the case to state court. The United States Court of Appeals for the Ninth Circuit held that a joint stipulation of dismissal functions the same as an amendment for jurisdictional purposes. The court concluded that the district court lost jurisdiction before entering final judgment and was required to remand the remaining state law claim to the Arizona Superior Court. The Ninth Circuit remanded the case to the district court with instructions to reopen and remand the state law claim. View "WALKER V. STATE OF ARIZONA" on Justia Law

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law

Several healthcare employees in Colorado, including those at the University of Colorado Hospital Authority and South Denver Cardiology Associates, were terminated after refusing to comply with their employers’ COVID-19 vaccination mandates. These mandates, implemented in 2021, required employees to either be vaccinated or obtain a medical or religious exemption. The plaintiffs declined vaccination and did not seek exemptions, resulting in their dismissal.Following their terminations, the plaintiffs filed separate lawsuits in the United States District Court for the District of Colorado, asserting nearly identical claims. They alleged violations of statutory, constitutional, and contractual rights, including claims under 42 U.S.C. § 1983, state-law breach of contract and tort claims, and an implied private right of action under the Food, Drug, and Cosmetic Act. The defendants moved to dismiss on grounds such as sovereign immunity, qualified immunity, and failure to state a claim. The district courts dismissed all claims, finding that the plaintiffs had not adequately pled any viable legal theory. The courts also denied the plaintiffs’ requests to amend their complaints after judgment was entered.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissals de novo. The court held that none of the statutes cited by the plaintiffs—including the Emergency Use Authorization statute, the PREP Act, and 10 U.S.C. § 980—unambiguously conferred individual rights enforceable under § 1983. The court also found that the constitutional claims, including those based on due process and equal protection, were not adequately pled and that the breach of contract claim was waived for lack of argument. The Tenth Circuit affirmed the district courts’ judgments, holding that the plaintiffs failed to state any claim upon which relief could be granted and that the lower courts did not abuse their discretion in denying leave to amend. View "Timken v. South Denver Cardiology Associates" on Justia Law

A former employee of an Oklahoma-based aviation training company alleged that his one-year employment contract was not renewed because he is a disabled veteran and because he complained to human resources about his supervisor’s disparaging comments regarding his disability. The employee, a Marine veteran with a high VA disability rating, worked as a Loadmaster Instructor in Kuwait. During his tenure, he disclosed his disability status for affirmative action purposes and later informed his supervisor and a co-worker when his rating increased. After this disclosure, his supervisor made inappropriate remarks about the disability system and the employee’s status, which led to a complaint and a subsequent reprimand of the supervisor. The employee’s FAA flight certificate expired shortly before his contract ended, and he received a negative performance appraisal from his immediate supervisor. The company’s higher management, who were responsible for contract renewal decisions, cited subpar job performance and the lapse of the flight certificate as reasons for not renewing the contract.The United States District Court for the Western District of Oklahoma granted summary judgment to the employer on all claims. The court found that the employee failed to present sufficient evidence that the stated reasons for non-renewal were pretextual under the Americans with Disabilities Act (ADA) or that the decision was motivated by discriminatory or retaliatory animus. The court also held that the Uniformed Services Employment and Reemployment Rights Act (USERRA) does not protect against discrimination based solely on disability status, but rather on military service itself.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The appellate court held that the employee did not create a triable issue of fact under the “cat’s paw” theory linking a supervisor’s alleged bias to the ultimate decisionmakers. The court also confirmed that USERRA does not extend to claims of discrimination based solely on disability status. View "Sellman v. Aviation Training Consulting" on Justia Law