Justia Civil Rights Opinion Summaries

The case involves three plaintiffs, Xingjian Sun, Xing Zhao, and Ao Wang, who sued their professor, Gary Gang Xu, for various allegations. Sun and Zhao, former students at the University of Illinois at Urbana-Champaign, accused Xu of sexual and emotional abuse. Wang, a professor at Wesleyan University, posted online that Xu had a history of sexually assaulting students. In response, Xu allegedly posted negative comments about Wang and sent a letter to his employer. Xu counterclaimed, asserting a defamation claim against Sun and claims for intentional infliction of emotional distress against all three plaintiffs.The case was tried in the United States District Court for the Central District of Illinois, where a jury found in favor of Xu on all issues and awarded him damages against Sun and Wang. The plaintiffs appealed, arguing that the district court erred in denying their motion for judgment as a matter of law regarding Xu’s intentional infliction of emotional distress counterclaims. They also contended that the district court erred in denying their motion for a new trial, based on the court’s decision to admit evidence that Sun had a relationship with another professor.The United States Court of Appeals for the Seventh Circuit reversed the judgment in favor of Xu on his counterclaim against Wang, finding that no reasonable jury could find Wang's conduct extreme and outrageous under Illinois law. However, the court affirmed the judgment in favor of Xu on his counterclaim against Sun, concluding that a reasonable jury could find that Sun's conduct met the requirements for intentional infliction of emotional distress. The court also affirmed the district court's denial of the plaintiffs' motion for a new trial. View "Sun v. Xu" on Justia Law

The case involves a group of convicted sex offenders who were confined in the Fishkill Residential Treatment Facility (RTF) while on post-release supervision (PRS). The Department of Corrections and Community Supervision (DOCCS) used the Fishkill RTF to confine these offenders past their maximum sentence expiration dates because they were unable to find housing that complied with the Sexual Assault Reform Act (SARA). The plaintiffs initiated a proceeding in 2016, seeking injunctions, declaratory relief, and class certification, arguing that DOCCS's operation of the Fishkill RTF failed to comply with the statutes governing RTFs because it did not offer adequate programming or employment opportunities.The Supreme Court dismissed part of the proceeding and converted the remaining into an action seeking a declaration that DOCCS's operation of the Fishkill RTF was non-compliant with the statutes governing RTFs. The court denied class certification, reasoning that the converted declaratory judgment action would adequately protect the interests of similarly situated offenders. After discovery, the defendants moved for summary judgment and a declaration in their favor. The Supreme Court granted defendants' motion in part, concluding that the internal programming was minimally adequate to satisfy DOCCS's statutory obligations. However, the court agreed with plaintiffs that DOCCS failed to provide adequate community-based opportunities.The Appellate Division modified the judgment by reversing the part that granted partial summary judgment to plaintiffs and granted defendants' motion in its entirety. The Court concluded that while the statute requires DOCCS to locate RTFs near a community with employment, training, and educational opportunities, there was no mandate that DOCCS offer such opportunities outside the facility.The Court of Appeals held that DOCCS's wholesale refusal to secure community-based opportunities for Fishkill RTF residents constitutes a violation of the statute. The Court concluded that DOCCS, at a minimum, must undertake reasonable efforts to secure community-based opportunities for those persons subject to its RTF programming. However, the Court agreed with the Appellate Division that the internal programming at the Fishkill RTF was at least minimally adequate. View "Alcantara v Annucci" on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law

Nicholas Queen, a former federal prisoner, filed a lawsuit against the United States under the Federal Tort Claims Act (FTCA), alleging that prison officials physically assaulted him in January 2019. The incident occurred when four correctional officers woke Queen up in his cell due to a supposed medical emergency. The parties dispute the events that followed, with the government claiming that Queen assaulted the officers, while Queen alleges that the officers physically attacked him without provocation. Following the incident, Queen complained of various physical pains, which he associated with the assault. However, prison medical officials dismissed his complaints, suggesting over-the-counter pain medication would suffice. After his release from prison, Queen was diagnosed with chronic back and right hip pain, which a medical doctor confirmed was severe enough to prevent him from working.The case was initially heard in the United States District Court for the Western District of Louisiana. The United States moved for the case to be dismissed at the summary judgment stage, arguing that Queen's injuries were de minimis and therefore insufficient to support an FTCA assault claim against a prison officer. The magistrate judge agreed with this argument and recommended dismissal. The district judge adopted this recommendation and dismissed Queen's case.Upon appeal to the United States Court of Appeals for the Fifth Circuit, the court found that the district court had erred in its decision. The appellate court noted that the de minimis injury test applied to constitutional claims does not apply to an injury alleged under Louisiana tort law, which does not impose a de minimis injury bar to tort claims. Therefore, the court reversed the district court's judgment and remanded the case for further proceedings. View "Queen v. United States" on Justia Law

Rick Milteer, a disabled veteran and an observant African American Messianic Jewish believer, was employed by Navarro County, Texas, in its Texoma High Intensity Drug Trafficking Area (HIDTA) division as an Information Technology (IT) manager. Milteer alleged that he faced discrimination, retaliation, and failure to accommodate in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990, and the Texas Commission on Human Rights Act. His claims were based on his supervisor's refusal to allow him to work remotely while recovering from surgery and during the Covid-19 pandemic, and his subsequent suspension and termination after he discovered a data breach and reported it.The district court granted summary judgment in favor of Navarro County, dismissing all of Milteer's claims. The court found that Navarro County was Milteer's employer and that the County had provided a legitimate, non-discriminatory reason for terminating Milteer's employment. The court also found that Milteer had failed to produce any evidence that he had informed the County of his disabilities or requested an accommodation from the County.The United States Court of Appeals for the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings. The appellate court found that the district court erred in treating Navarro County and the Texoma HIDTA as separate entities and in failing to impute the actions of Milteer's supervisor to the County. The court held that the Texoma HIDTA was not a legal entity capable of employing individuals, and that the actions and inactions of Milteer's supervisor could be imputed to the County. The court concluded that this error impacted the district court's analysis of Milteer's claims, necessitating a remand for further proceedings. View "Milteer v. Navarro County" on Justia Law

In the summer of 2020, amid pandemic mask mandates and nationwide racial justice protests, Whole Foods Market, Inc. began disciplining employees who wore facemasks to work supporting the Black Lives Matter movement, citing its dress code. The three plaintiff-appellants, Savannah Kinzer, Haley Evans, and Christopher Michno, persisted in wearing these masks, among taking other actions, until the company terminated them, ostensibly for repeated violations of the dress code or attendance policy. The Employees sued under Title VII, alleging retaliation. The district court granted Whole Foods' motion for summary judgment against all three.The United States Court of Appeals for the First Circuit held that summary judgment was improper against one of the Employees, Savannah Kinzer, an outspoken critic of Whole Foods whose termination arguably deviated from the company's disciplinary process, but affirmed the court's holding as to both Haley Evans and Christopher Michno. The Employees also asked the court to review a discovery order compelling the production of communications whose confidentiality they argue is protected by the National Labor Relations Act. The court declined to reach the merits of that issue. View "Kinzer v. Whole Foods Market, Inc." on Justia Law

The case revolves around the petitioner, Tom Nichols, also known as Nikki, who is currently serving a prison sentence for sex crimes against children. Nikki, a transgender woman in the process of transitioning, filed a petition for a sealed-record name change, arguing that an open-record proceeding could jeopardize her safety due to her gender identity.The District Court of the Third Judicial District initially denied Nikki's petition. The court's decision was based on the fact that Nikki failed to demonstrate probable cause that her safety was at risk, a requirement under Section 27-31-201, MCA, for a petition to proceed on a sealed-record basis. The court also had to be satisfied that the petitioner was not attempting to avoid debt or hide a criminal record.Upon appeal, the Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court noted that district courts have broad discretion to grant or deny a petition for a sealed-record name change. The Supreme Court would only reverse a district court decision if it was arbitrary or exceeded the bounds of reason, resulting in substantial injustice. In this case, the Supreme Court found that Nikki failed to provide specific instances of abuse or explain why an open-record proceeding would change her circumstances at the Montana State Prison. Furthermore, Nikki did not provide any support for the alleged risk of harm from members of the public. Therefore, the Supreme Court concluded that the District Court did not abuse its discretion when it determined the evidence was insufficient to support Nikki’s petition. View "In re Name Change of Nichols" on Justia Law

The case revolves around June LaMarr, an employee at the University of California Davis Medical Center, who was transferred to a different department following performance issues and conflicts with her supervisor. The transfer was initially temporary, but later became permanent, resulting in a decrease in LaMarr's pay. LaMarr sued the Regents of the University of California, alleging that her due process rights were violated as she was not provided a hearing under Skelly v. State Personnel Bd. before her demotion.The trial court found in favor of the Regents. It concluded that LaMarr was not deprived of due process when she was offered the option to either transfer to a non-supervisory position with reduced pay or return to her higher paying supervisory position and face possible termination proceedings. The court reasoned that the Regents never issued a notice of intent to dismiss and that LaMarr's feeling of duress did not trigger due process protections.In the Court of Appeal of the State of California Third Appellate District, LaMarr appealed the trial court's decision, arguing that the finding lacked substantial evidence. She contended that she was not informed of the adverse consequences of accepting a transfer and that her acceptance of the transfer was not voluntary.The appellate court affirmed the trial court's decision. It found substantial evidence that the Regents did not violate LaMarr's due process rights because she was never notified of an intent to terminate and any demotion was voluntary. The court also noted that a difficult choice is not the same as an involuntary choice. It concluded that there was substantial evidence supporting the trial court's finding that the Regents did not deprive LaMarr of due process. View "LaMarr v. The Regents of the University of California" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law