Justia Civil Rights Opinion Summaries

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

Jonathan and Melissa Brizendine applied to become foster parents in January 2022. After completing their application, a DHS employee conducted a home visit and asked various questions, including about their religious affiliation. The Brizendines, who are non-religious, were also asked to provide additional information on Melissa’s PTSD and medical-marijuana use. On May 19, 2022, DHS denied their foster-parent application. The Brizendines filed a complaint on June 8, 2023, alleging that their application was denied due to their atheism and medical-marijuana use, claiming violations of the Arkansas Constitution, the Religious Freedom Restoration Act, and the Arkansas Medical Marijuana Amendment.The Pulaski County Circuit Court granted the State appellees' motion to dismiss, concluding that the Brizendines' complaint failed to state a claim under Arkansas Rule of Civil Procedure 12(b)(6) and that the State appellees were entitled to sovereign immunity. The court found that the Brizendines did not plead sufficient facts to show that the State’s actions were illegal or unconstitutional.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court's decision. The court held that the Brizendines' complaint was speculative and did not meet the fact-pleading requirements necessary to overcome sovereign immunity. The court noted that the complaint lacked specific facts to support the claim that DHS denied the application based on religious preferences and medical-marijuana use. Additionally, the complaint did not establish any involvement of Governor Sanders or the Child Welfare Agency Review Board in the application process. Therefore, the State appellees were entitled to sovereign immunity, and the dismissal was affirmed. View "Brizendine v. Department of Human Services" on Justia Law

Three organizations, Inclusive Louisiana, Mount Triumph Baptist Church, and RISE St. James, sued St. James Parish, the Parish Council, and the Parish Planning Commission, alleging violations of their constitutional and statutory civil rights. They claimed that the Parish discriminated against them by directing hazardous industrial development towards majority-Black districts and Black churches, where their members and congregants live. They also argued that the Parish's actions desecrated and restricted access to cemeteries of their enslaved ancestors.The United States District Court for the Eastern District of Louisiana dismissed all claims. It held that the plaintiffs lacked standing for some claims and that other claims were time-barred, as they were based on the Parish's 2014 Land Use Plan. The court also dismissed claims related to religious injuries, stating that the injuries were not traceable to the Parish's actions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in dismissing the claims as time-barred, noting that the plaintiffs alleged ongoing discriminatory practices, not just a single incident. The court also found that the plaintiffs had standing to sue for property injuries and health-related injuries. Additionally, the court held that the plaintiffs had standing to pursue claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Louisiana Constitution, as their alleged injuries were traceable to the Parish's conduct.The Fifth Circuit reversed the district court's dismissal of the claims and remanded the case for further proceedings. The court emphasized that the plaintiffs had sufficiently alleged ongoing discriminatory practices and injuries that were fairly traceable to the Parish's actions. View "Inclusive Louisiana v. St. James Parish" on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

The case involves Pueo Kai McGuire, who filed a 42 U.S.C. § 1983 action against the County of Hawai'i, the county prosecutor, and three deputy prosecutors, alleging violations of his constitutional rights, including malicious prosecution. The United States District Court for the District of Hawai'i certified a question to the Supreme Court of the State of Hawai'i to determine whether, under Hawai'i law, a county Prosecuting Attorney and/or Deputy Prosecuting Attorney acts on behalf of the county or the state when preparing to prosecute and/or prosecuting criminal violations of state law.The United States District Court for the District of Hawai'i reviewed the case and found the matter of whether county prosecutors act on behalf of the county or the state to be unsettled under Hawai'i law. Consequently, the court certified this question to the Supreme Court of the State of Hawai'i for clarification.The Supreme Court of the State of Hawai'i held that, under Hawai'i law, county prosecuting attorneys and their deputies act on behalf of the county when preparing to prosecute or prosecuting state law offenses. The court's decision was based on an analysis of the historical and current legal framework governing prosecutorial authority in Hawai'i, including the Hawai'i Constitution, state statutes, and county charters. The court emphasized that county prosecutors are primarily responsible for initiating and conducting criminal prosecutions within their county jurisdictions, with the state attorney general retaining only residual authority to intervene in compelling circumstances. The court declined to extend state sovereign immunity to county prosecutors, affirming that they are suable persons under 42 U.S.C. § 1983. View "McGuire v. County of Hawai'i" on Justia Law

In September 2020, inmate Garfield Holley, proceeding pro se, sued several officers at Wallens Ridge State Prison under Section 1983. Holley alleged that the officers transported him to a dental appointment in a dog cage and subjected him to subsequent mistreatment. He claimed that this treatment was in retaliation for filing a grievance about a delayed medical procedure. Holley, who has asthma, described being chained in a padlocked dog cage in near-freezing temperatures for over six hours, leading to pneumonia and delayed medical care. He also alleged a pattern of retaliatory treatment against prisoners who complained about their conditions.The United States District Court for the Western District of Virginia dismissed Holley's complaint without prejudice for failing to pay the filing fee, citing the three-strikes rule under the Prison Litigation Reform Act. The court found that Holley had not adequately alleged imminent danger of serious physical injury, as the incidents described occurred approximately two years before the complaint was filed. Holley's motion for reconsideration was denied, and he timely appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Holley had adequately pleaded imminent danger of serious physical injury, noting the specificity of his allegations and the ongoing pattern of retaliatory treatment against prisoners at Wallens Ridge State Prison. The court found that Holley's allegations were sufficient to meet the imminent-danger exception to the three-strikes rule. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Holley v. Combs" on Justia Law

Inmate Travis Dantzler filed a lawsuit under 42 U.S.C. § 1983, claiming that Dr. Tonia Baldwin, a physician at the Clarinda Correctional Facility (CCF), was deliberately indifferent to his knee pain by delaying an MRI and orthopedic referral for nonmedical reasons, specifically his parole eligibility. Dr. Baldwin sought summary judgment based on qualified immunity, arguing she was not deliberately indifferent and that the law was not clearly established. The district court denied her motion, finding a genuine issue of material fact regarding her deliberate indifference.The United States District Court for the Southern District of Iowa reviewed the case and concluded that Dantzler had created a material fact issue as to whether Dr. Baldwin was deliberately indifferent by delaying the MRI and orthopedic referral based on his parole eligibility. The court also determined that Dr. Baldwin was not entitled to qualified immunity, as it was clearly established that delaying medical care for nonmedical reasons could violate the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Dantzler had shown an objectively serious medical need and produced verifying medical evidence that the delay in treatment adversely affected his condition. The court also found that Dr. Baldwin's delay in scheduling the MRI for a nonmedical reason (parole eligibility) could support a finding of deliberate indifference. The court concluded that the law was clearly established, and Dr. Baldwin was on notice that delaying medical treatment for nonmedical reasons could constitute deliberate indifference. View "Dantzler v. Baldwin" on Justia Law

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law