Justia Civil Procedure Opinion Summaries

The plaintiff, Joshua Young, an employee of the Colorado Department of Corrections, claimed that mandatory Equity, Diversity, and Inclusion (EDI) training he was subjected to created a hostile work environment. Young resigned from the Department and filed a lawsuit claiming violations of Title VII and the Equal Protection Clause. He alleged that the training program violated Title VII by creating a hostile work environment and violated the Equal Protection Clause by promoting race-based policies. The district court dismissed both claims without prejudice. Young appealed the decision.The United States Court of Appeals for the Tenth Circuit examined Young's allegations and affirmed the district court's dismissal of Young's claims. The court found that while Young had plausibly alleged he was subjected to unwelcome harassment, he failed to adequately allege that the harassment was so severe or pervasive that it altered the terms of his employment and created an abusive working environment.The court also affirmed the district court's dismissal of Young's equal protection claim, agreeing that Young lacked standing to pursue the claim since he was no longer employed by the Department of Corrections and had not asked for reinstatement as part of his equal protection claim.Finally, the court held that the district court did not abuse its discretion when it declined to grant Young leave to amend his complaint, noting that Young neither requested leave to amend in his briefing nor filed a separate motion to amend. View "Young v. Colorado Department of Corrections" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit ruled on an appeal brought by Randall Artis, a former city councilman for East Chicago, Indiana. Artis was previously convicted of misappropriating public money for personal political gain. After returning to public service as a junior clerk, he was fired by his boss, Adrian Santos. Artis alleged that Santos fired him in retaliation for exercising his First Amendment free speech rights. The case went to trial, and a jury found in favor of Santos.Artis appealed, arguing that the district court erred in admitting the testimony of an expert witness, in denying him an impartial jury, and in issuing inaccurate and confusing jury instructions and verdict forms. He also questioned the jury's verdict. The appeals court affirmed the district court's judgment, finding no error or reason for a new trial.The court held that the district court did not abuse its discretion in allowing the expert witness to testify, and it did not err in denying Artis's for-cause challenge to a prospective juror. Moreover, the court ruled that the district court did not abuse its discretion in its choice of jury instructions and verdict form. Finally, the court found no inconsistency in the jury's verdict. View "Artis v. Santos" on Justia Law

The case revolves around plaintiff Rynold Dwayne Jackson, who alleged malicious prosecution and unfair business practices after an altercation at a hotel lounge. Jackson was refused service on the basis of intoxication. Following a dispute, Jackson and the hotel's director of security, Mario Lara, had physical contact leading to Jackson's prosecution for battery. After being found not guilty, Jackson filed a civil complaint against Lara and DT Management, LLC, the company managing the hotel and lounge.Jackson alleged malicious prosecution against Lara, claiming the criminal prosecution was based on a false assault accusation. He also alleged DT Management violated the Unfair Competition Law by denying equal access, permitting discriminatory behavior by employees, and selectively deleting incident footage.The defendants filed a motion for summary judgment, which the lower court granted. The court considered Jackson's failure to appear at the motion hearing as a submission on the tentative ruling. Jackson appealed this judgment.The Court of Appeal, Fourth Appellate District Division One, State of California, affirmed the lower court's judgment. They cited the interim adverse judgment rule, which establishes that a trial court judgment in favor of the plaintiff or prosecutor, unless obtained fraudulently, forms probable cause to bring the underlying action. The court found this rule applicable as Jackson's motion for acquittal in his criminal trial was denied, thus establishing probable cause for Lara's accusation.As for the unfair business practices claim, Jackson failed to substantiate his allegations with legal authority or argument, resulting in the dismissal of his claim. Furthermore, a new theory he proposed on appeal was disregarded as it was raised for the first time and not considered in the trial court. View "Jackson v. Lara" on Justia Law

In the United States Court of Appeals for the Seventh Circuit, Parents Protecting Our Children, an association of parents, sought an injunction against the Eau Claire Area School District in Wisconsin to stop the enforcement of the District’s Administrative Guidance for Gender Identity Support. The parents argued that the policy violated the Due Process and Free Exercise Clauses of the U.S. Constitution by interfering with their right to make decisions on behalf of their children. The District Court dismissed the case due to lack of subject matter jurisdiction, stating that the parents failed to identify any instance where the policy was applied in a way that infringed on parental rights.The Court of Appeals affirmed the lower court's ruling. The court held that the parents' concerns about potential applications of the policy did not establish standing to sue unless the policy resulted in an injury or created an imminent risk of injury. The court stated that the parents had brought a pre-enforcement facial challenge against the policy without any evidence of the School District applying the policy in a manner detrimental to parental rights.The court also noted that the Administrative Guidance did not mandate exclusion of parents from discussions or decisions regarding a student’s gender expression at school. The court found that the alleged harm was dependent on a speculative "chain of possibilities," which was insufficient to establish Article III standing. Therefore, the court upheld the dismissal of the lawsuit for lack of subject matter jurisdiction. View "Parents Protecting Our Children, UA v. Eau Claire Area School District" on Justia Law

The United States Court of Appeals for the Second Circuit reviewed a decision made by the United States District Court for the Southern District of New York. The plaintiff, Do No Harm, a membership organization, filed a suit against Pfizer Inc., alleging that a Pfizer fellowship program unlawfully excluded white and Asian-American applicants on the basis of race. The plaintiff sought a preliminary injunction, which was denied by the district court. The district court dismissed the case without prejudice because Do No Harm lacked Article III standing. The court reasoned that the organization failed to identify by name a single injured member.The Court of Appeals affirmed the district court's decision. It upheld that to establish standing under Article III, an association relying on injuries to individual members must name at least one injured member. The court also held that if a plaintiff fails to establish standing in the context of a motion for a preliminary injunction, the district court must dismiss their claims without prejudice rather than allowing the case to proceed if the plaintiff alleged sufficient facts to establish standing under the less onerous standard applicable at the pleading stage. View "Do No Harm v. Pfizer Inc." on Justia Law

The United States Court of Appeals for the Seventh Circuit reviewed a case involving David A. Schlemm, an inmate who had filed a First Amendment retaliation claim against Brendan Pizzala, Jay Van Lanen, and Michael Donovan. Schlemm's claim was based on accusations made against him for theft of sage from the chapel of the Green Bay Correctional Institution, which led to a conduct report being issued against him. The report was later dismissed after another correctional officer testified that he had given the sage to Schlemm. Schlemm then filed complaints against the defendants through the Inmate Complaint Review System (ICRS), claiming retaliation.The lower court had dismissed Schlemm's case, ruling it was time-barred due to the six-year statute of limitations. The court noted that Schlemm's lawsuit, filed in 2019, was more than six years after the 2012 search of his cell. On appeal, the defendants conceded that Schlemm had properly exhausted his administrative remedies, but argued his action was time-barred due to the six-day gap between the accrual of his claim and the filing of his administrative complaints.The Appeals Court reviewed the district court's dismissal de novo and concluded that the defendants had waived their specific statute of limitations argument regarding the six-day gap. They had raised this argument for the first time on appeal, having previously argued that Schlemm had not properly exhausted his administrative remedies. The court reversed the dismissal and remanded for further proceedings, noting that it did not need to address the question of whether the gap between claim accrual and grievance filing is included in the tolling period due to the defendants' waiver of their argument. View "Schlemm v. Pizzala" on Justia Law

The plaintiff, Michael Bacote Jr., an inmate with a history of mental illness, filed a claim for injunctive and declaratory relief against the Federal Bureau of Prisons, seeking to improve the conditions of his confinement at a maximum-security facility. However, during litigation, the Bureau voluntarily transferred Bacote to a mental health ward in a different penitentiary. Bacote's appeal to the United States Court of Appeals, Tenth Circuit, raised three issues: whether a class action settlement had preempted his claims, whether the district court had erred in denying him leave to amend his complaint, and whether the district court had erred in entering judgment for the Bureau.The Tenth Circuit did not reach the merits of Bacote's arguments. Instead, it dismissed the appeal as prudentially moot. The court reasoned that the Bureau's transfer of Bacote had materially changed the conditions of his confinement, rendering his request for relief from his previous conditions moot. It noted that the court had no information about Bacote's current conditions of confinement, and thus could not evaluate whether those conditions violated his rights. The court also observed that Bacote had not alleged that the Bureau had transferred him to moot his lawsuit or that he faced a risk of being returned to his prior conditions. Finally, the court expressed reluctance to issue a judgment affecting prison officials outside its jurisdiction. The court did not decide whether Bacote's claims were constitutionally moot, as it found them prudentially moot. View "Bacote v. FBP" on Justia Law

In this case, James Scott filed a civil rights lawsuit against the City of Sherwood, Sherwood City Attorney Stephen Cobb, and Sherwood City Code Enforcement Officer Sheila Reynolds. Scott owned property in Sherwood, Arkansas, which he used for storage and a repair business. After Sherwood annexed his property, Scott faced numerous complaints, citations, and prosecutions over the use of his property.Scott filed a lawsuit in state court, which was dismissed on grounds of sovereign immunity. Later, he filed a nearly identical lawsuit in federal court. The defendants moved for dismissal, arguing that the doctrine of res judicata, which prevents issues that have been judicially decided from being re-litigated, applied to Scott's claims. The district court granted the motion, and Scott appealed.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that under Arkansas law, all the elements for claim preclusion, a type of res judicata, were satisfied. The court noted that Scott's lawsuit in state court was fully contested in good faith and resulted in a dismissal with prejudice, which constituted a final judgment. The state court had jurisdiction over the matter, and Scott's state and federal lawsuits involved the same civil rights claims and parties.Scott argued that the Arkansas court did not have jurisdiction and that it did not enter a valid final judgment. The appellate court rejected these arguments, explaining that under Arkansas law, sovereign immunity is treated like an affirmative defense, not a matter of subject-matter jurisdiction. The court also noted that the proper course of action for Scott to remedy an erroneous decision would be an appeal or a post-judgment motion, not another lawsuit. View "Scott v. City of Sherwood, Arkansas" on Justia Law

This case involves an appeal from plaintiffs Sara Halsey and Susan Kiralis-Vernon against Fedcap Rehabilitation Services, Inc. The plaintiffs were participants in a state program, Additional Support for People in Retraining and Employment - Temporary Assistance for Needy Families (ASPIRE-TANF), for which Fedcap was a contract agency. The plaintiffs allege that Fedcap failed to correctly administer the program and fulfill its obligations, including informing them of available services and support, processing their requests for benefits, and engaging in an interactive process to evaluate their requests for reasonable accommodations. Kiralis-Vernon also alleges that a Fedcap employee verbally assaulted her due, in part, to her race.The U.S. District Court for the District of Maine dismissed the case, reasoning that the plaintiffs were required to first pursue an administrative remedy before the Department of Health and Human Services as required by Maine law. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the claims related to Fedcap’s administration of the ASPIRE-TANF program, agreeing that under Maine law, the plaintiffs had to first seek administrative review before bringing these claims to court.However, the appellate court vacated the dismissal of Kiralis-Vernon's claim of racial discrimination, ruling that this claim did not fall within the same jurisdiction and expertise of the Department, and thus, was not subject to the same requirement for administrative review. The case was remanded for further proceedings on this claim. View "Halsey v. Fedcap Rehabilitation Services, Inc." on Justia Law