Justia Civil Rights Opinion Summaries

DC Operating, a strip club in El Paso, Texas, and two of its employees, Nuvia Medina and Michelle Corral, challenged the constitutionality of S.B. 315, a Texas law that raised the minimum age of employment at sexually-oriented businesses from 18 to 21. The law was enacted to curb human trafficking. The plaintiffs argued that the law infringed on the employees' constitutional rights to expressive interest in nude dancing and occupational freedom. They also raised a claim of sex discrimination under the Equal Protection Clause for the first time on appeal.The United States District Court for the Western District of Texas upheld the constitutionality of S.B. 315, following similar rulings in other cases. The plaintiffs then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit dismissed the appeal for lack of jurisdiction. The court found that DC Operating lacked standing to bring the appeal because it did not assert any legal interests of its own, only those of its employees. The court noted that a plaintiff must assert its own legal rights and interests and cannot rest its claim to relief on the legal rights or interests of third parties. The court also found that the overbreadth claim brought by DC Operating did not alter the standing analysis because the plaintiff still needed to satisfy Article III requirements.Furthermore, the court found that the appeal was moot as to the two employees, Medina and Corral, because they had turned 21 and were no longer subject to the law they were challenging. The plaintiffs did not argue that the employees' claims remained justiciable or that an exception to mootness applied. Therefore, the court dismissed the appeal for lack of jurisdiction. View "DC Operating v. Paxton" on Justia Law

The case involves Dr. Adam Lowther and his wife, Jessica Lowther, who sued various state officials on behalf of themselves and their children, alleging constitutional claims under 42 U.S.C. § 1983 and state law claims under the New Mexico Tort Claims Act. The claims arose from the warrantless entry into their home, the arrest of Dr. Lowther, and the removal of their children by officials from New Mexico’s Children, Youth, and Family Department (CYFD) and the Bernalillo County Sheriff’s Department (BCSD). The actions of the officials were based on an anonymous report alleging that Dr. Lowther was sexually abusing his four-year-old daughter.The United States District Court for the District of New Mexico granted summary judgment in favor of the defendants, concluding that they were entitled to qualified immunity on the § 1983 claims and that the state law claims failed for similar reasons. The Lowthers appealed the decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the officials had reasonable suspicion that the children had been abused and were in imminent danger, which justified the warrantless entry into the Lowthers' home and the removal of the children. The court also held that the officials had probable cause to arrest Dr. Lowther. Therefore, the officials were entitled to qualified immunity, and the Lowthers' claims were dismissed. View "Lowther v. Children Youth and Family Department" on Justia Law

A prisoner, Khalfan Khamis Mohamed, alleged that officials from the Federal Bureau of Prisons (BOP) beat him while others watched. He brought claims under the Eighth Amendment for excessive force and failure to intervene, arguing that the BOP officials' actions gave him a cause of action under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The BOP officials moved to dismiss the claims, arguing that Bivens did not extend to Mohamed's claims. The district court denied their motion.The BOP officials appealed the district court's decision, seeking interlocutory review. However, the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction. The court found that the BOP officials had not shown that the district court's order extending Bivens to Mohamed's Eighth Amendment excessive force and failure to intervene claims qualified for interlocutory review under the collateral order doctrine. The court noted that the BOP officials bore the burden of establishing the court's appellate jurisdiction and had failed to convince the court to create an exception to the final judgment rule for all district court orders extending a Bivens remedy. The court also noted that the BOP officials had not shown that Bivens extension orders were effectively unreviewable after final judgment and therefore had not satisfied the third Cohen factor. View "Mohamed v. Jones" on Justia Law

Dr. Jennifer Seed, a former employee of the Environmental Protection Agency (EPA), filed a lawsuit against the EPA and the United States, alleging age discrimination. Seed claimed that she was involuntarily demoted to a junior position as older managers were replaced with younger employees. The district court granted summary judgment in favor of the EPA, concluding that Seed had not provided sufficient evidence to support her claim of age discrimination.The district court's decision was based on its finding that Seed had not provided direct evidence of discriminatory intent that would entitle her to a trial, nor had she provided indirect evidence that would give rise to an inference of discrimination. The court also found that Seed had not shown that she was treated less favorably than younger employees after her reassignment or that her treatment was based on her age.On appeal, the United States Court of Appeals for the District of Columbia Circuit dismissed Seed's appeal, ruling that the court lacked jurisdiction to address the merits of her reassignment claims because she lacked standing under Article III of the United States Constitution. The court found that Seed had not demonstrated that a favorable court decision would likely redress her claimed injuries. The court therefore remanded the case to the district court with instructions to vacate the grant of summary judgment and to dismiss the reassignment claim for lack of standing. View "Seed v. EPA" on Justia Law

The case involves Christine Savage, a police officer who filed a lawsuit against the Neptune Township Police Department and others for sexual harassment, sex discrimination, and retaliation. The parties entered into a settlement agreement in 2014, which included a non-disparagement clause. Savage filed a second lawsuit in 2016, alleging continued and intensified discrimination, harassment, and retaliation. The parties entered into another settlement agreement in 2020, which also included a non-disparagement clause. After a television interview with Savage aired in 2020, the defendants claimed that Savage violated the non-disparagement provision of the settlement agreement.The trial court granted the defendants' motion to enforce the second settlement agreement, finding that the Law Against Discrimination (LAD) barred only non-disclosure and confidentiality agreements, and that Savage violated a non-disparagement clause. The Appellate Division affirmed in part and reversed in part, finding the non-disparagement clause enforceable but holding that Savage had not violated it.The Supreme Court of New Jersey held that the non-disparagement clause in the settlement agreement is against public policy and cannot be enforced. The court found that the LAD protects Savage’s statements. The court concluded that the non-disparagement clause in the agreement directly conflicts with the LAD as it encompasses and would bar speech the statute protects. The court reversed in part, affirmed in part, and remanded the case. View "Christine Savage v. Township of Neptune" on Justia Law

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

The case revolves around an incident involving Corey Fisherman, an inmate at Minnesota’s maximum-security prison, and David Launderville, a prison guard. Fisherman was being transferred to a more restrictive area after a shank was found in his cell. During the transfer process, Fisherman initially refused to undergo a strip search, leading to the intervention of the A-Team, a group of guards trained to handle noncompliant inmates, which included Launderville. After the search, Fisherman objected to kneeling and placing his hands through a small opening in his cell door. Once he complied, he was handcuffed. Fisherman alleges that Launderville kneed him six times, three times each in the face and body, while another guard kneeled on his legs. Launderville, however, claims he struck Fisherman twice in the leg because he was resisting.The case was initially heard in the United States District Court for the District of Minnesota. The magistrate judge identified a potential jury issue: whether Launderville struck a restrained inmate six times in the face and body or a partially unrestrained one just twice in the leg. The district court adopted the report and recommendation, leading to an appeal to the United States Court of Appeals for the Eighth Circuit.The Court of Appeals affirmed the district court's decision, denying Launderville's claim of qualified immunity. The court found that a reasonable jury could conclude that the repeated blows to Fisherman's head and body were "malicious and sadistic." The court also determined that the law was clearly established that repeatedly striking a fully restrained inmate violates the Eighth Amendment. Therefore, the court concluded that every reasonable official in Launderville's position would have understood that kneeing a restrained inmate several times in the face and body violated that right. View "Fisherman v. Launderville" on Justia Law

In this case, Austin Thompson Hughes, a former police officer and Uber driver, reported a drunk driver swerving across a highway in Houston. After the drunk driver crashed, Hughes, still on the phone with 911, performed a citizen's arrest in accordance with Texas law. However, when police officers arrived at the scene, they released the drunk driver and arrested Hughes, charging him with a felony for impersonating a peace officer. Hughes spent thousands of dollars defending against these charges before they were dropped by the City of Houston. Hughes then filed a § 1983 suit against the two officers who arrested him.The case was initially heard in the United States District Court for the Southern District of Texas, where the officers moved to dismiss Hughes's complaint, asserting qualified immunity. The district court denied the officers' motions, leading to an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision, denying the officers' qualified immunity. The court found that Hughes had sufficiently pleaded that the officers violated his Fourth Amendment rights by arresting and prosecuting him without probable cause because they included material misstatements and omissions in their warrant affidavit and materials. The court also found that a corrected warrant affidavit could not have established probable cause to arrest and prosecute Hughes. The court concluded that no reasonable officer could have suspected Hughes committed a felony, given the inconsistencies in the drunk driver's statement, the driver's obvious intoxication, and the evidence supporting Hughes's account. View "Hughes v. Garcia" on Justia Law

The plaintiff, John Deaton, was arrested and charged with assault, battery, and disorderly conduct following an altercation at a youth football game. Although the charges were later dismissed, Deaton filed state and federal claims against the Town of Barrington and several individuals, including police officers and the town manager. The case was removed from state court to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of the defendants on most counts and remanded three counts to the state court for resolution. Deaton appealed, arguing that the district court improperly found that probable cause to arrest him existed, improperly denied his post-judgment motion, and should have abstained and remanded to state court to allow the state claims to be resolved.The district court had granted summary judgment in favor of the defendants, finding that there was probable cause for Deaton's arrest. The court also denied Deaton's post-judgment motion for relief. Deaton appealed these decisions, arguing that the district court had improperly found probable cause for his arrest, improperly denied his post-judgment motion, and should have abstained from hearing the case and remanded it to state court.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that the district court had correctly determined that there was probable cause for Deaton's arrest. The court also found that the district court had not erred in denying Deaton's post-judgment motion for relief. Finally, the court determined that abstention was not appropriate in this case, as resolution of the state law question would not avoid the need to resolve a significant federal constitutional question. View "Deaton v. Town of Barrington" on Justia Law

The case involves a group of petitioners who challenged a trial court's decision to establish a 200-foot buffer zone around the Norfolk County Superior Court House during the trial of a high-profile murder case. The buffer zone was created in response to protests and demonstrations near the courthouse, which the Commonwealth argued could jeopardize a fair trial. The petitioners, who sought to intervene in the trial court proceedings to oppose the buffer zone, argued that it infringed on their First Amendment rights.The trial judge allowed the Commonwealth's motion for a buffer zone, albeit reducing it from the requested 500 feet to 200 feet. The judge denied the petitioners' motion to intervene, arguing that the buffer zone was necessary to ensure a fair trial and to protect jurors and witnesses from potential intimidation or harassment. The petitioners subsequently filed petitions for relief from both the buffer zone order and the denial of their motion to intervene.The single justice of the Supreme Judicial Court denied the petitions, concluding that the trial judge's decision was an ordinary procedural ruling and did not warrant the court's extraordinary power of general superintendence. The single justice also found that the buffer zone met the "reasonable restriction" requirements, being content-neutral, narrowly tailored to serve a significant governmental interest, and leaving open ample alternative channels for communication.The Supreme Judicial Court affirmed the single justice's decision, rejecting the petitioners' argument that the buffer zone order should be analyzed under strict scrutiny as a prior restraint on speech. The court found that the buffer zone did not forbid protestors from expressing their message, but merely restricted where they could do so. The court also noted that the petitioners failed to provide sufficient evidence to establish that the buffer zone extended onto public sidewalks or other areas constituting a public forum. View "Spicuzza v. Commonwealth" on Justia Law