Justia Civil Procedure Opinion Summaries

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law

Several individuals with developmental disabilities, along with Disability Rights New York (DRNY), an advocacy organization, alleged that New York State agencies responsible for services to people with developmental disabilities caused them to remain in restrictive institutional settings for extended periods, despite being eligible for community-based residential placements. The individual plaintiffs claimed they waited from nine months to six years for such placements, resulting in physical and psychological harm. DRNY, as the state’s designated Protection and Advocacy System, joined the suit, asserting authority to represent the interests of individuals with disabilities under federal law.The United States District Court for the Southern District of New York first addressed the defendants’ motion to dismiss DRNY’s claims for lack of standing, agreeing that DRNY had not suffered an injury in fact and rejecting its argument that federal statutes conferred “congressionally authorized representational standing.” The district court also dismissed the individual plaintiffs’ claims as moot, based on pre-motion letters from the defendants indicating that all individual plaintiffs had since been moved out of institutional facilities. Additionally, the court denied a motion by other individuals seeking to intervene as plaintiffs, finding the motion untimely.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal of DRNY’s claims, holding that DRNY lacked standing because it had not suffered a concrete injury and that Congress could not override Article III’s standing requirements by statute. The Second Circuit also affirmed the denial of the motion to intervene, finding no abuse of discretion in the district court’s timeliness determination. However, the Second Circuit vacated the dismissal of the individual plaintiffs’ claims as moot, holding that the district court erred by dismissing those claims based solely on pre-motion letters without full briefing or a hearing. The case was remanded for further proceedings on the individual plaintiffs’ claims. View "A.H. v. N.Y. State Dep't of Health" on Justia Law

A group of individuals in the custody of the Illinois Department of Corrections (IDOC) filed a lawsuit in 2007, alleging inadequate mental healthcare. The case developed into a class action, and in 2016, the parties reached a settlement agreement that required IDOC to meet specific mental-health treatment benchmarks. The agreement included a provision for $1.9 million in attorney’s fees to be paid to plaintiffs’ counsel if the court granted relief for violations of the agreement. In 2018, the district court found IDOC in breach and issued an injunction, triggering the fee provision. While the defendants appealed, the parties entered into further agreements, resulting in the $1.9 million being paid to plaintiffs’ counsel.The United States District Court for the Central District of Illinois later extended its enforcement jurisdiction over the settlement agreement, but after the expiration of that jurisdiction, the court returned the case to its active docket. The parties continued to litigate, with plaintiffs filing amended complaints and defendants moving to dismiss. More than a year after resuming active litigation, the district court raised concerns about its subject-matter jurisdiction, ultimately concluding that its jurisdiction over the underlying claims ended when its enforcement jurisdiction over the settlement agreement expired. The court dismissed all claims and denied the defendants’ motion to recover the $1.9 million in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that, under the parties’ agreements, the payment of $1.9 million in attorney’s fees to plaintiffs’ counsel was proper and did not need to be returned, even after the district court’s injunction was vacated. The court also vacated the district court’s dismissal of the underlying claims, remanding for the district court to determine whether the settlement agreement moots those claims. The Seventh Circuit affirmed the denial of the defendants’ motion to recover the attorney’s fees. View "Daniels v. Jones" on Justia Law

Three registered Texas voters alleged that three local officials—a justice of the peace, a sheriff, and a constable—conspired to punish them for political reasons. The plaintiffs were arrested after reporting for jury duty, accused of falsely claiming residency in Loving County. The officials argued they were enforcing voter-eligibility rules, while the plaintiffs claimed it was retaliation to silence dissent. The plaintiffs sued under § 1983, alleging constitutional violations.The United States District Court for the Western District of Texas granted judicial and quasi-judicial immunity to the officials for some claims but denied judicial immunity for actions related to the jury proceeding. The officials appealed the denial of judicial immunity, and the plaintiffs cross-appealed the grant of immunity on other claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that presiding over the jury proceeding was a judicial act protected by absolute judicial immunity. Consequently, the court reversed the district court's denial of judicial immunity for the jury proceeding. Regarding the plaintiffs' cross-appeal, the court found it lacked jurisdiction to review those claims at this interlocutory stage and dismissed the cross-appeal.The court's main holding was that the actions of the justice of the peace in presiding over the jury proceeding were judicial in nature and thus protected by absolute judicial immunity. The court reversed the district court's decision in part and dismissed the cross-appeal for lack of jurisdiction. View "Jones v. King" on Justia Law

Chosen Consulting, LLC, doing business as Chosen Healthcare, and other related entities (collectively "Chosen") filed a lawsuit against the Town Council of Highland, Indiana, the Highland Municipal Plan Commission, and the Town of Highland, Indiana (collectively "the Town"). Chosen alleged that the Town discriminated against patients with addiction-related ailments by refusing to provide a letter stating that Chosen’s proposed use of its property complies with local zoning requirements. Chosen claimed this discrimination violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, seeking compensatory, injunctive, and declaratory relief.The United States District Court for the Northern District of Indiana granted summary judgment to the Town. The district court held that Chosen's claim for injunctive relief under the ADA and the Rehabilitation Act was not ripe for adjudication because Chosen had not obtained a final decision from the local zoning authorities. The court indicated that Chosen needed to pursue its request for zoning approval through the Board of Zoning Appeals (BZA) and, if necessary, appeal any final decision entered by the BZA to the state courts before seeking an injunction in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit held that Chosen's claim for injunctive relief was not ripe because Chosen had not satisfied the finality requirement set forth in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City. The court emphasized that Chosen needed to follow the local zoning procedures, including applying for a use variance or seeking a declaratory judgment in state court, to obtain a final decision from the Town. Until Chosen completed these steps, the dispute was not ripe for federal court review. View "Chosen Consulting, LLC v Town Council of Highland" on Justia Law

John Baldwin sued Union Pacific Railroad Company under the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA), alleging he was unlawfully removed from his position following a fitness-for-duty evaluation. Baldwin, who had degenerative arthritis and underwent a double hip replacement, experienced a bursitis flare-up while working, leading to a fitness-for-duty evaluation. Despite being cleared by his orthopedic surgeon and a physical exam, Union Pacific's Chief Medical Officer imposed work restrictions based on Baldwin's exercise tolerance test results, which showed low aerobic capacity and mild hypertension. Baldwin was ultimately prevented from returning to his job.The United States District Court for the District of Nebraska denied both parties' summary judgment motions. Baldwin voluntarily dismissed his disparate impact and ADEA claims, proceeding to trial on the ADA claims for disparate treatment and failure to accommodate. The jury found that Union Pacific discriminated against Baldwin based on a perceived disability but concluded he posed a direct threat to himself. The district court entered judgment for Union Pacific and denied Baldwin’s motion for a new trial, which challenged the jury instructions.The United States Court of Appeals for the Eighth Circuit reviewed the case. Baldwin argued that the jury instructions misallocated the burden of proof and omitted essential elements of the direct threat defense. The court found that while the direct threat instruction was incomplete, it did not affect the trial's outcome. The business judgment instruction was deemed appropriate and did not mislead the jury. The court affirmed the district court's judgment, concluding that the instructions, taken as a whole, did not mislead the jury or affect Baldwin's substantial rights. View "Baldwin v. Union Pacific Railroad Co." on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

Donna Christensen, a twenty-year-old inmate at Vilas County Jail, died by suicide after twenty-five days in confinement. She had a history of substance abuse and mental illness and had previously reported suicidal thoughts and hallucinations. During her incarceration, she exhibited withdrawal symptoms and had an altercation with jail staff, leading to her placement on suicide watch. Despite her initial suicidal ideations, she was removed from suicide watch after a brief assessment by a social worker. She was later placed in solitary confinement, where she remained until her death.The Christensens, Donna's parents, sued Vilas County, the jail's medical service provider, and various employees, alleging that Donna's death resulted from inadequate medical treatment, excessive force, and due process violations. The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants, ruling against the Christensens. The court also denied the Christensens' requests to amend their complaint and extend deadlines for additional discovery.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Christensens failed to present sufficient evidence to establish that the defendants were deliberately indifferent to Donna's serious medical condition under the Eighth Amendment. The court found no genuine dispute of material fact regarding the defendants' conduct and concluded that no reasonable jury could find in favor of the Christensens. The court also upheld the district court's denial of the Christensens' motions for additional discovery and to amend their complaint, finding no abuse of discretion in the lower court's case management decisions. View "Christensen v Weiss" on Justia Law

Edward Snukis was stopped by Officers Matthew Taylor and Trevor Koontz after a report of an impaired man refusing to leave a parking lot. The encounter escalated when Snukis resisted commands and struck Officer Koontz. Officer Taylor tased Snukis twice, and both officers pinned him to the ground, with Taylor striking Snukis in the head six times. After securing Snukis in handcuffs, the officers noticed he had lost consciousness and provided emergency assistance, but Snukis died later that evening. Snukis’s children, as co-administrators of his estate, sued the officers and the City of Evansville under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendants. The estate appealed the decision, focusing on claims against the officers for excessive force, failure to intervene, and failure to render medical aid.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the officers' use of force was reasonable given Snukis’s resistance and the threat he posed. The court found that Officer Taylor’s use of the taser and subsequent strikes were justified due to Snukis’s active resistance. The court also determined that the officers provided prompt and appropriate medical care once Snukis lost consciousness. Consequently, the court affirmed the district court’s grant of summary judgment in favor of the officers. View "Snukis v. Taylor" on Justia Law

Davariol Marquavis Taylor, an incarcerated individual, sued several members of the correctional staff at Marquette Branch Prison under 42 U.S.C. § 1983, alleging constitutional violations. Taylor claimed that a nurse administered incorrect medication, resulting in another inmate's overdose and death. He also alleged that a doctor sexually assaulted him and punched him when he resisted. Taylor sought to proceed in forma pauperis, which allows a litigant to avoid paying filing fees upfront due to financial constraints.The United States District Court for the Western District of Michigan denied Taylor's motion to proceed in forma pauperis, citing the Prison Litigation Reform Act’s (PLRA) “three-strikes” rule, which prevents incarcerated individuals from proceeding in forma pauperis if they have had three or more prior cases dismissed as frivolous, malicious, or failing to state a claim. The district court identified four previous cases as strikes against Taylor and dismissed his suit when he did not pay the filing fee. Taylor appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Taylor had only two valid PLRA strikes, not three. The court determined that the district court's original order incorrectly counted two cases, Adler and Stump, as strikes. The court clarified that dismissals based on Eleventh Amendment immunity or improper filing under § 1983 do not count as strikes unless all claims in the complaint are dismissed for being frivolous, malicious, or failing to state a claim. Consequently, the Sixth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Taylor v. Stevens" on Justia Law