Justia Civil Rights Opinion Summaries

Plaintiff sued the University and others under 42 U.S.C. 1983 after her employment was terminated for gross misconduct. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on her due process violation and gender discrimination claims. The court concluded that, assuming plaintiff had a property interest in her continued employment, her due process claim failed because she received all of the process that she was due; regardless of whether defendants deprived plaintiff of a liberty interest in her reputation, she could not establish a due process violation because she did not sufficiently, if at all, request a name-clearing hearing; the district court did not err in finding that plaintiff failed to show direct evidence of discrimination or that defendants' explanation for terminating her was a pretext for gender discrimination. Accordingly, the court affirmed the judgment. View "Floyd-Gimon v. University of Arkansas, et al." on Justia Law

Plaintiff sued his employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623, and the Iowa Civil Rights Act (ICRA), Iowa Code 216.6, alleging that he was discharged from his employment due to his age. The district court granted summary judgment in favor of the employer. The court concluded that, taken together, plaintiff's evidence was sufficient to allow a rational factfinder to find that the employer's proffered reasons for terminating him were pretextual. Plaintiff's evidence was not inconsistent with a reasonable inference of age discrimination and, therefore, the court reversed the grant of summary judgment and remanded for further proceedings. View "Ridout v. JBS USA, LLC" on Justia Law

IRTL challenged the constitutionality of several Iowa campaign-finance laws, an administrative rule, and two forms. The court concluded, inter alia, that IRTL lacked standing to challenge the definitions of "political committee" and "permanent organization" because it faced no credible threat or present or future prosecution; the first two sentences of Iowa Code subsection 68A.404(3), the second sentence of subsection 68A.404(3)(a), the entirety of subsection 68A.404(4)(a), the first and third sentences of Iowa Administrative Code rule 351-4.9(15), and Form Ind-Exp-O were constitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; the first and third sentences of subsection 68A.404(3)(a), the second sentence of Iowa Administrative Code rule 351-4.9(15), the entirety of subsections 68A.404(3)(a)(1) and 68A.402B(3), and Form Dr-3 were unconstitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; and Iowa Code section 68A.503 was constitutional under the First and Fourteenth Amendments. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Iowa Right To Life Committee v. Tooker, et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of U.S. Bank on her claims of discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. The court concluded that summary judgment in favor of U.S. Bank on plaintiff's discrimination claim was proper where the bank had a legitimate, non-discriminatory basis for issuing a written warning and where plaintiff had not met her burden of demonstrating pretext. The court also concluded that summary judgment in favor of U.S. Bank was proper where plaintiff failed to show a causal connection between her protected activity and the bank's alleged adverse employment action. Accordingly, the court affirmed the judgment. View "Muor v. U.S. Bank Nat'l Assoc." on Justia Law

The Committee sued the NCAA for interfering with the University of North Dakota's use of the Fighting Sioux name, logo, and imagery. The district court treated the NCAA's motion to dismiss as a motion for summary judgment and granted summary judgment in favor of the NCAA. The court concluded that the Committee had not shown that the NCAA acted with discriminatory intent; the Committee was not denied due process by the NCAA because, as a nonmember, it was entitled to none from the NCAA; and the NCAA's act neither violated the laws of the land nor plainly violated its own constitution and bylaws. Accordingly, the court affirmed the judgment. View "Spirit Lake Tribe of Indians, et al v. The NCAA" on Justia Law

This interlocutory appeal arose out of the district court's denial of summary judgment on defendants' qualified immunity defenses to plaintiffs' 42 U.S.C. 1983 and Sherman Act, 15 U.S.C. 1-2, claims. The court declined to address the merits of defendants' qualified immunity defense because the district court's analysis denying summary judgment was so scant that the court was unable to discern if the district court even applied both steps of the qualified immunity inquiry to all of the summary judgment claims. Accordingly, the court remanded to the district court for further proceedings. View "Robbins, et al v. Becker, Sr., et al" on Justia Law

Plaintiff filed suit against two deputy officers, in both their individual and official capacities, and against the county after plaintiff was arrested for violating a restraining order. Plaintiff appealed the district court's dismissal of his case with prejudice pursuant to Rule 12(b)(6). The court concluded that the deputies were entitled to qualified immunity on plaintiff's Fourth Amendment claim where the deputies had at least arguable probable cause to arrest plaintiff for the crime of knowingly violating a valid restraining order; even assuming that plaintiff suffered a constitutional deprivation, the district court properly dismissed plaintiff's 42 U.S.C. 1983 claim against the county where he failed to allege facts in his complaint that would demonstrate the existence of a county policy or custom that caused the deprivation; and the deputies, and by extension the county, were entitled to official immunity on plaintiff's false imprisonment claim, and this claim was properly dismissed by the district court. Accordingly, the court affirmed the judgment in all respects. View "Ulrich v. Pope County, et al" on Justia Law

Plaintiffs were each convicted of an offense for which he or she was required to register as a sex offender in Missouri. Each conviction occurred prior to June 30, 2008, when the Missouri Legislature enacted Missouri Revised Statute 589.426 (the Halloween Statute). This appeal stemmed from plaintiffs' challenge to the Halloween Statute. The district court concluded that plaintiffs' claims were moot because there was no reasonable expectation that they would be prosecuted under the Halloween Statute and that consequently plaintiffs no longer had standing to proceed. Thereafter, plaintiffs moved for attorneys' fees and costs as prevailing parties under 42 U.S.C. 1988. The court concluded that the district court's October 27, 2008, order effectively served as a judicial pronouncement without judicial relief and did not confer prevailing party status upon plaintiffs. Because neither basis identified by plaintiffs conferred prevailing party status upon them, the court reversed the district court's grant of attorneys' fees and costs to plaintiffs under section 1988, as well as the district court's amendment of the judgment under Rule 59 to reflect the award of attorneys' fees and costs. Because they were not entitled to attorneys' fees, their appeal of the district court's reduction of fees was dismissed as moot. Further, the district court did not err in determining that plaintiffs lacked standing and in dismissing plaintiffs' second amended complaint for lack of subject matter jurisdiction View "Doe I, et al v. Nixon, et al" on Justia Law

Plaintiff appealed from the district court's grant of summary judgment to a law enforcement officer on plaintiff's 42 U.S.C. 1983 action alleging an excessive use of force claim. The district court determined that the officer had used a reasonable amount of force and that, even if the Taser application constituted excessive force, it was not clearly established at the time that the use of force resulting in only de minimis injuries might violate the Fourth Amendment. The court affirmed, concluding that plaintiff had not set forth sufficient evidence to show that the officer's application of a Taser caused more than de minimis injury. Accordingly, the officer was entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights. Further, the court found no error in the application of the pleading standard set forth in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal. Accordingly, the court affirmed the judgment. View "LaCross v. City of Duluth, et al" on Justia Law

Plaintiff, employed by the CRMC, filed charges of discrimination against her employer after CRMC's placement of her on administrative leave following work-related epileptic seizures and the hiring of a younger technician. Because plaintiff was not a qualified individual to perform the job duties with or without accommodation, the court did not err in granting summary judgment to CRMC based on the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., and Missouri Human Rights Act, Mo. Rev. Stat. 213.010, claims. Plaintiff's age discrimination claims failed for the same reason her disability discrimination claims failed. Accordingly, the court affirmed the judgment. View "Olsen v. Capital Region Medical Center, et al" on Justia Law