Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against defendants after her son died of complications from heatstroke while he was incarcerated. On interlocutory appeal, defendants challenged the district court's order deferring ruling on their motion to dismiss on the basis of qualified immunity and ordered limited discovery. The court concluded that it lacked jurisdiction over the appeal and dismissed because the district court correctly concluded that the complaint was sufficient and that further factual development was needed to rule on defendants’ qualified immunity defense, and because the discovery that the district court ordered was narrowly tailored to the facts needed to rule on the defense View "Hinojosa v. Livingston" on Justia Law

In a first appeal, the court reversed summary judgment in favor of the Board, holding that material fact issues surrounded the discriminatory purpose and effect of the Board’s adoption of a redistricting plan that concentrated economically disadvantaged students in a majority-nonwhite school district. On remand, the district court entered judgment for the Board. The court affirmed the judgment, concluding that the district court did not err in concluding that Option 2f does not make express racial classifications and so is not subject to strict scrutiny on that basis. Option 2f employed several means to shift the student population among the east bank schools. The court rejected plaintiff's alternative theory that, despite Option 2f’s facial neutrality, the redistricting plan’s funneling feature is nevertheless subject to strict scrutiny because it had both a discriminatory purpose and a discriminatory effect. The court agreed with the district court's conclusion that rational basis review is satisfied as to the equal protection claim and the court rejected plaintiff's remaining claims. Accordingly, the court affirmed the district court's grant of summary judgment for the Board. View "Lewis, Sr. v. Ascension Parish Sch. Bd." on Justia Law

Plaintiff filed suit against her former employer, alleging claims of retaliation after her attempt to rescind her resignation was denied. Plaintiff offered her resignation, but before she finished her employment, she testified against the Executive Director, claiming sexual harassment. Then plaintiff attempted to rescind the resignation but the Executive Director rejected her rescission. The court reversed the district court's grant of summary judgment because rejecting an employee’s rescission of resignation can sometimes constitute an adverse employment action and because plaintiff has demonstrated a substantial conflict of evidence on the question of whether her employer would have taken the action ‘but for’ her testimony. View "Porter v. Houma Terrebonne Hous. Auth." on Justia Law

Plaintiff filed suit against the company managing the prison he was incarcerated in, and others, for multiple violations of his constitutional rights. On appeal, plaintiff challenged the district court’s denial of his motion for appointment of counsel to help litigate his civil rights claims against defendants. The district court denied the motion because it had no funding with which to compensate an appointed attorney, and it could find “no attorneys in the area willing or able to take the case pro bono.” Then the district court entered summary judgment against plaintiff. The court vacated and demanded, concluding that federal courts have inherent power to order counsel to accept an uncompensated appointment under the limited factual circumstances here. On remand, the district court must consider whether a compulsory appointment is warranted. View "Naranjo v. Thompson" on Justia Law

Plaintiffs filed suit against defendants after their son, Quamaine Mason, was fatally shot while Officer Martin Faul was responding to a reported armed robbery. The complaint alleged Monell claims against Faul's employer, Lafayette, and Lafayette's Chief of Police, as well as claims against all three defendants under Louisiana law. The court reversed the district court's grant of summary judgment to Faul on plaintiff's Fourth Amendment and state law claims because there are material fact issues that preclude summary judgment in favor of Faul on the basis of qualified immunity. In this case, a reasonable jury could conclude that when Faul fired the final two shots, Mr. Mason would have appeared incapacitated to an objectively reasonable officer. The court otherwise affirmed the judgment. View "Mason v. City of Lafayette" on Justia Law

Three movants appealed the denial of their motion to intervene in State of Texas v. United States, where 26 states seek injunctive relief against the United States and several officials of DHS to prevent them from implementing a program entitled “Deferred Action for Parents of Americans and Lawful Permanent Residents” (DAPA). Movants are aliens who have lived in the United States for more than ten years, currently live in the Rio Grande Valley, and have minor children who are United States citizens. Movants believe that they are likely to receive grants of deferred action if DAPA goes into effect. The court reversed the district court's order denying intervention because movants satisfy the requirements for intervention by right under Federal Rule of Civil Procedure 24(a)(2). The court remanded to the district court. View "State of Texas v. United States" on Justia Law

This case stemmed from desegregation litigation between the United States, the District, and Intervenors, a class representing current and future students attending the District's schools. The district court moved for unitary status in 2013 in the only area of its school system remaining under federal supervision: faculty and staff assignments. The United States and the Intervenors objected. The district court denied unitary status based on the District’s noncompliance with the court’s desegregation order. Both the District and the Intervenors moved for reconsideration, and the district court denied both motions. The Intervenors appealed the district court’s order denying unitary status and order denying reconsideration. The court concluded that the Intervenors are not sufficiently aggrieved and therefore lack standing to appeal the district court’s orders. Accordingly, the court dismissed the appeal on the merits. View "United States v. Mississippi" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging civil rights violations because the police issued an “Official Notification of Trespass Warning” prohibiting her from entering city-owned property, which was later lifted. The district court concluded that the officers were entitled to qualified immunity as to the majority of plaintiff's claims, but denied qualified immunity on the procedural due process and direct municipal liability claims. Defendants appealed the denial of qualified immunity.The court reversed and remanded, concluding that the alleged constitutional right was not clearly established at the time of the incident, so the officers are entitled to qualified immunity. View "Vincent v. City of Sulphur" on Justia Law

Plaintiffs filed suit against the school district and its employees, alleging claims related to the sexual molestation of A.W. by her teacher. The district court dismissed the claims under Rule 12(b)(6) as time-barred. At issue is the Texas statute of limitations that applies to Title IX of the Education Act of 1972, 20 U.S.C. 1681 et seq., and 42 U.S.C. 1983 claims involving sexual abuse. The court concluded that the district court did not err in finding that plaintiffs’ Title IX and section 1983 claims are time-barred because plaintiffs' claims accrued more than two years prior to their filing suit and the equitable tolling principles they have identified do not apply. Accordingly, the court affirmed the judgment and did not reach the remaining issues raised on appeal. View "King-White v. Humble Indep. Sch. Dist." on Justia Law

Plaintiffs filed suit under Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, and 42 U.S.C. 1983 against the district and two district employee, alleging discrimination based on race and a hostile educational work environment. The court applied the deliberate indifference standard for a Title VI student-on-student harassment claim and concluded that plaintiffs have raised a genuine dispute that a racially hostile environment existed. However, the court concluded that the district court did not err in granting summary judgment on the Title VI claim where plaintiffs have failed to raise a genuine dispute over whether the school district was deliberately indifferent to the harassment. Further, the court concluded that the district court did not err in granting summary judgment as to the claim against the school district and the employees under section 1983. Accordingly, the court affirmed the judgment. View "Fennell v. Marion I.S.D." on Justia Law