Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries
Articles Posted in Civil Rights
Mayorga v. Merdon
Plaintiff filed suit against the the Acting Architect of the Capitol (AOC), in her official capacity, alleging that the selecting officials at the AOC denied him a promotion on the basis of his race and national origin in violation of Title VII of the Civil Rights Act of 1964.The DC Circuit vacated the district court's grant of summary judgment to the AOC, holding that a jury reasonably could find the panelists did not select plaintiff for promotion because of his race or national origin. Because plaintiff argued his case as a single-motive claim and at oral argument forfeited any potential mixed-motive claim he could have made, he bears the burden of showing the alleged animus was a but-for cause of the decision not to promote him. Therefore, the court remanded for trial where plaintiff will bear the typical burden in this single-motive case to establish that he would have been selected for the promotion but for the alleged improper motive. View "Mayorga v. Merdon" on Justia Law
Qassim v. Trump
Petitioner challenged the district court's denial of his petition for writ of habeas corpus, raising a due process challenge to the government's use of undisclosed classified information as a basis for his detention.The DC Circuit held that the district court's ruling that binding circuit precedent denied petitioner all rights to due process was in error. The court explained that Kiyemba v. Obama ruled only that the Due Process Clause does not invest detainees who have already been granted habeas corpus with a substantive due process right to be released into the United States. However, Kiyemba did not decide, or have any occasion to address, what constitutional procedural protections apply to the litigation of a detainee's habeas corpus petition in the first instance. Furthermore, no other decision of this circuit has adopted a categorical prohibition on affording detainees seeking habeas relief any constitutional procedural protections. The court held that the governing law is that petitioner and other alien detainees must be afforded a habeas process that ensures "meaningful review" of their detention pursuant to Boumediene v. Bush. Therefore, the court remanded the case for further proceedings to be conducted within the correct legal framework and to develop the needed factual record. View "Qassim v. Trump" on Justia Law
Mawakana v. Board of Trustees of the University of the District of Columbia
After plaintiff was denied tenure and terminated by the University, he filed suit against the Board of Trustees, claiming that the University discriminated against him based on race and violated both the terms and spirit of its contract with him.The DC Circuit reversed the district court's grant of summary judgment to the University on the Title VII, D.C. Human Rights Act (DCHRA), and contract claims. As to the statutory claims under Title VII and the DCHRA, the court held that plaintiff raised a plausible inference that race was a motivating factor in the University's decision to deny him tenure. As to the contract claims, the court held that the claims were not time-barred. On the merits, the court held that there was an unresolved factual dispute regarding whether an implied-in-fact contract between plaintiff and the University existed and, if it did, what the terms and intent of that contract were. Accordingly, the court remanded for further proceedings. View "Mawakana v. Board of Trustees of the University of the District of Columbia" on Justia Law
J.D. v. Azar
Plaintiffs have shown a likelihood of success in connection with their claim that ORR's restriction on abortion access infringes their protected right to choose to terminate their pregnancies. In 2017, the government instituted a policy effectively barring any unaccompanied alien child in the custody of the Office of Refugee Resettlement (ORR) from obtaining a pre-viability abortion. The district court granted a preliminary injunction and the government appealed.Agreeing that the case was not moot, the DC Circuit affirmed and held that the district court did not abuse its discretion in certifying a class consisting of pregnant unaccompanied minors in the government's custody. On the merits, the court held that, under binding Supreme Court precedent, a person has a constitutional right to terminate her pregnancy before fetal viability, and the government cannot unduly burden her decision. Consequently, these controlling principles dictate affirming the district court's preliminary injunction against the government's blanket denial of access to abortion for unaccompanied minors.The court vacated in part and remanded to the extent that the preliminary injunction barred disclosure to parents and others of unaccompanied minors' pregnancies and abortion decisions. The court held that this portion of the preliminary injunction warranted further explication to aid appellate review. View "J.D. v. Azar" on Justia Law
Davis v. District of Columbia
Plaintiffs, 47 former longtime employees of the District Child and Family Services Agency who were mostly African American, filed suit alleging claims that their terminations were unlawfully discriminatory on the basis of age and race. At issue on appeal, were the race-based claims.The DC Circuit generally affirmed the district court's grant of summary judgment on plaintiff's race-based claims, but reversed as to one issue. The court held that nothing in Title VII suggests that the practices an employer uses to effectuate the adverse employment action of layoffs, whether or not dubbed a reduction in force, are exempt from disparate-impact scrutiny. Accordingly, the court reversed the "particular practice" holding and the accompanying denial of class certification, remanding for further proceedings. The court affirmed the district court's decisions with respect to plaintiffs' challenge to the college degree requirement the Agency added to one job category, and the applicability of estoppel to certain individual plaintiffs' claims. View "Davis v. District of Columbia" on Justia Law
DuBerry v. District of Columbia
Plaintiffs, former correctional officers that had separated from service in good standing, sought to invoke the Law Enforcement Officers Safety Act (LEOSA) so that they could be able to carry concealed firearms as "qualified retired law enforcement officers." Plaintiffs filed suit under 42 U.S.C. 1983, seeking declaratory and injunctive relief to require the District to recognize them as "qualified retired law enforcement officers" for purposes of the Act.In DuBerry I, the DC Circuit found that the Act's plain text, purpose, and context show that Congress intended to create a concrete, individual right to benefit individuals like plaintiffs and that is within the competence of the judiciary to enforce. Therefore, the court held that plaintiffs had sufficiently alleged that the federal right they seek to enjoy has been unlawfully deprived by the District of Columbia to be remediable under section 1983.On remand, the district court granted summary judgment for plaintiffs. The court affirmed the district court's judgment on remand and held that the law of the case doctrine controls the disposition of the District's principle argument that plaintiffs lacked the proper identification and thus have no enforceable right that is remediable under section 1983. Rather, the court held that the Act creates an individual right to carry that is remediable under section 1983. The court also held that the District's causation argument was meritless. View "DuBerry v. District of Columbia" on Justia Law
Posted in:
Civil Rights, Constitutional Law
Libertarian National Committee v. FEC
The LNC filed suit alleging that the Federal Election Campaign Act (FECA), which imposes limits on both donors and recipients of political contributions, violates its First Amendment rights. This case stemmed from a dispute regarding how the LNC can spend the $235,000 Joseph Shaber left to it when he passed away. The LNC argued that FECA violates its First Amendment rights in two ways: first, by imposing any limits on the LNC's ability to accept Shaber's contribution, given that he is dead; and second, by permitting donors to triple the size
of their contributions, but only if the recipient party spends the money on specified categories of expenses.The DC Circuit held that the current version of FECA—both its application of contribution limits to Shaber's bequest and its use of a two-tiered contribution limit—has achieved a constitutionally permissible balance. Although the court denied the Commission's motion to dismiss for lack of standing, the court rejected LNC's constitutional challenges on the merits. View "Libertarian National Committee v. FEC" on Justia Law
Haynes v. District of Columbia Water and Sewer Authority
After plaintiff was eliminated as part of a reorganization from his job of nearly 30 years, he filed suit against DC Water, alleging claims under various federal and D.C. civil rights statutes. The DC Circuit affirmed the district court's grant of summary judgment in favor of DC Water, holding that petitioner's Americans with Disabilities Act and DC Human Rights Act claims were time-barred; plaintiff failed to exhaust his administrative remedies prior to bringing his Title VII and Age Discrimination in Employment Act claims; it was within the district court's discretion to conclude that further discovery on plaintiff's only potentially viable claim—the one brought under 42 U.S.C. 1981—was unwarranted, given the lack of detail in plaintiff's Federal Rule of Civil Procedure 56(d) declaration; and summary judgment on plaintiff's section 1981 claim was appropriate given the record before the district court. View "Haynes v. District of Columbia Water and Sewer Authority" on Justia Law
Figueroa v. Pompeo
At the second prong of the McDonnell Douglas framework, an employer must proffer admissible evidence showing a legitimate, nondiscriminatory, clear, and reasonably specific explanation for its actions. Plaintiff filed suit alleging that one aspect of the Department's promotion process had a disparate impact on Hispanic and Latino candidates who applied for the position he sought, and that the Secretary in 2008 denied him a promotion because of his Hispanic ethnicity. The district court granted summary judgment in favor of the Secretary.The DC Circuit affirmed in part and held that plaintiff's disparate impact claim lacked merit where there were no genuine issues of material fact and plaintiff failed to establish causation as a matter of law. However, the court held that the district court misapplied the second step of the McDonnell Douglas framework as to the disparate treatment claim by accepting the Department's vague reason for the denial of the promotion. In this case, none of the presented evidence sheds light on how the selection boards applied the core precepts to defendant's case. Accordingly, the court reversed in part, vacated the denial of plaintiff's cross-motion in part, and remanded for further proceedings. View "Figueroa v. Pompeo" on Justia Law
Barker v. Conroy
This case arose when a member of the House of Representatives asked the House-appointed Chaplain, Father Patrick J. Conroy, to invite Daniel Barker—a former Christian minister turned atheist—to serve as guest chaplain and deliver a secular invocation. After Conroy denied the request, Barker filed suit alleging that Conroy unconstitutionally excluded him from the guest chaplain program because he is an atheist.The DC Circuit affirmed the district court's dismissal of Barker's Establishment Clause claim. The court held that, although Barker had Article III standing to challenge his exclusion from the program, he failed to state a claim upon which relief could be granted. The court held that Marsh v. Chambers, 463 U.S. 783 (1983), and Town of Greece v. Galloway, 572 U.S. 565, 570 (2014), leave no doubt that the Supreme Court understands our nation's longstanding legislative-prayer tradition as one that, because of its "unique history," can be both religious and consistent with the Establishment Clause. The court noted that, although the Supreme Court has warned against discriminating among religions or tolerating a pattern of prayers that proselytize or disparage certain faiths or beliefs, it has never suggested that legislatures must allow secular as well as religious prayer. Therefore, in the sui generis context of legislative prayer, the court held that the House does not violate the Establishment Clause by limiting its opening prayer to religious prayer. View "Barker v. Conroy" on Justia Law