African-American Homeowners' Civil Rights Suit Against Mortgage Lender, Plus a Civil Rights Suit Against Juvenile Detention Center

Betts v. New Castle Youth Dev. Ctr., 09-3753, concerned a challenge to the district court's grant of summary judgment in favor of the defendants, in plaintiff's 42 U.S.C. section 1983 suit against a state-run juvenile detention center and several of its staff members, claiming various constitutional violations for sustaining a tragic spinal cord injury while attempting to make a tackle during a "pick-up" football at the center.

In affirming the judgment, the court held that the district court correctly granted the summary judgment in favor of the center and its staff in their official capacities because the center is an arm of the state entitled to Eleventh Amendment immunity.  Also, the district court's grant of summary judgment for the individual defendants on the merits of plaintiff's Eighth Amendment claim is affirmed because plaintiff has failed to show a substantial risk of serious harm that violates contemporary standards of decency and failed to show deliberate indifference.  Lastly, the court's adoption of the more-specific-provision rule obviates the need to address plaintiff's Fourteenth Amendment substantive due process claims.

Anderson v. Wachovia Mortgage Corp., 09-2275, concerned a challenge to the district court's grant of summary judgment in favor of defendant, in African-American plaintiffs' suit against Wachovia under 42 U.S.C. section 1981 and various state law claims, claiming that certain conditions imposed on the approvals of their mortgages were racially motivated.  In affirming, the court held that, although the question of whether plaintiffs have made out a prima facie case of discrimination is a close call, plaintiffs have not shown that the mortgage conditions were imposed for discriminatory reasons because they have not undermined defendant's legitimate reasons for imposing the conditions that it did.  The court also held that the district court correctly granted summary judgment on plaintiffs' breach of contract and tortious interference claims, and that the district court acted within its discretion in denying plaintiffs' motion to compel certain discovery.  Lastly, the district court acted within its discretion in remanding plaintiffs' good faith and fair dealing claim to Delaware state court.

Related Resources:

• Full text of Betts v. New Castle Youth Dev. Ctr., 09-3753
• Full text of Anderson v. Wachovia Mortgage Corp., 09-2275