Justia Civil Rights Opinion Summaries

In 2005, Curtis McGhee and another individual brought claims against the City alleging violations of civil rights sounding in malicious prosecution. The City sought coverage under insurance policies issued by CIC and Columbia. On appeal, the City and McGhee challenged the district court's order granting summary judgment to CIC and Columbia, on CIC's and Columbia's declaratory judgment claims concerning coverage under the various insurance policies. The court concluded that the district court correctly refused to consider and correctly denied additional discovery of extrinsic evidence. The court also concluded that the alleged malicious prosecution and resulting personal injuries occurred when the underlying charges were filed against McGhee in 1977. Therefore, the court affirmed the district court's judgment that the following policies did not afford coverage to the City for the malicious prosecution claims: the two excess liability policies issued by CIC; four of the special excess liability policies issued by Columbia; and the commercial umbrella liability policy issued by Columbia. As to the 1977-78 special excess liability policy issued by Columbia, the court reversed the district court's judgment regarding the applicability of the reasonable expectations doctrine. The court remanded for further proceedings. View "Chicago Ins. Co., et al v. City of Council Bluffs, et al" on Justia Law

Plaintiff, Shirley Phelps-Roper, brought this action under 42 U.S.C. 1983 seeking declaratory and injunctive relief against the State of Missouri after Missouri passed funeral protest laws Mo. Rev. Stat. 578.501 and Mo. Rev. Stat. 578.502. The district court entered a preliminary injunction prohibiting the enforcement of the statutes following this court's decision in Phelps-Roper v. Nixon. The district court later declared both statutes unconstitutional under the First and Fourteenth Amendments and granted Phelps-Roper's motion for summary judgment. Nixon has since been abrogated by the court's recent en banc decision in Phelps-Roper v. City of Manchester, Mo. The court affirmed the district court's judgment to the extent the district court held that section 578.501 violated the Free Speech Clause of the First Amendment; reversed the district court's judgment to the extent it held that section 578.502 was unconstitutional under the Free Speech Clause, severed the term "processions" from section 578.502(3), and held that the remaining provisions of section 578.502 were narrowly tailored time, place, and manner restrictions; and remanded for the district court to address in the first instance Phelps-Roper's alternative challenges that section 578.502 violated the Free Exercise Clause of the First Amendment, the Due Process Clause of the Fourteenth Amendment, and Missouri statutory and constitutional law. View "Phelps-Roper v. Koster, et al" on Justia Law

The City terminated plaintiff's employment after she refused a state trooper's request to take a drug test. Plaintiff sued the City and others, claiming that she was terminated in retaliation for her decision to exercise her Fourth Amendment rights. Even assuming the termination violated plaintiff's Fourth Amendment rights, it was not clearly established at the time of the incident that such an action was unconstitutional, and therefore defendants were entitled to qualified immunity. The court also agreed with the district court that plaintiff's remaining federal claims failed to allege a constitutional violation. The court further held that the district court properly dismissed the official capacity claims and the claims against the City where plaintiff failed to allege facts indicating that the City delegated final policymaking authority to the officials. Finally, because plaintiff did not explain why her Arkansas Civil Rights Act, Ark. Code Ann. 16-123-105(a), claims warranted separate analysis, the district court did not err in dismissing the ACRA claims alongside the 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment. View "Hess v. Abels, et al" on Justia Law

Plaintiffs, patients at the Iowa Civil Commitment Unit for Sex Offenders (CCUSO), filed a complaint under 42 U.S.C. 1983 challenging the placement of video cameras in CCUSO restrooms, and moved for a preliminary injunction to stop their use. The district court denied the motion as to cameras in the dormitory style restrooms but granted a preliminary injunction ordering that cameras in the traditional style bathrooms be pointed at the ceiling or covered with a lens cap. The administrators of CCUSO appealed the district court's grant of the preliminary injunction. The court concluded that by capturing images of patients while they occupy single-user bathrooms, CCUSO violated its patients' reasonable expectation of privacy, thus conducting a search under the Fourth Amendment, irrespective of whether there was some chance that those images would not be viewed. The court agreed with the district court that plaintiffs showed the requisite probability of success on their Fourth Amendment claim; plaintiffs established a threat of irreparable harm; plaintiffs' interests in this case outweighed the injuries that the injunction would inflict on other parties; and there was a greater public interest in protecting the Fourth Amendment rights of plaintiffs and their personal privacy and dignity against unwarranted intrusion by the State. Accordingly, the court affirmed the judgment. View "Arnzen, III, et al. v. Palmer, et al." on Justia Law

Plaintiff argued on appeal that Home Service terminated him contrary to the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and that Home Service breached his contract. The court affirmed the district court's judgment, holding that the district court did not err in granting summary judgment to Home Service, because plaintiff was not qualified to perform an essential function of his job - being DOT qualified to drive a delivery truck - because of his eye injury. The court also held that the district court did not err in granting summary judgment on plaintiff's mileage reimbursement claim and on his bonus claim. Accordingly, the court affirmed the judgment. View "Knutson v. Schwan's Home Service, Inc., et al" on Justia Law

Plaintiff sued the City and her supervisors, claiming that the City's reasons for terminating her were pretextual. The district court granted defendants' motion for summary judgment on all of plaintiff's seven claims. The court affirmed the judgment because there was no evidence or reasonable inference that the City's reasons for terminating plaintiff's employment for failure in performance of her duties were pretextual. View "Brown v. City of Jacksonville, et al" on Justia Law

Plaintiff appealed the district court's dismissal of his complaint, filed in forma pauperis (IFP), for untimely service of process and failure to state a claim. Plaintiff claimed that First Student fired him from his position as a bus driver based on his race, age, disability, seniority rights, and eligiblity for a pay raise. The court vacated the district court's order, remanding for further proceedings, because the court concluded that the complaint stated a claim and because the court could not determine from the record whether the delay in service of process was plaintiff's fault or was attributable to delays by district court staff and the USMS. View "Wright v. First Student, Inc." on Justia Law

Plaintiffs, individually and as parents and next friends of C.S., A.S., and J.S., brought suit against the County under 42 U.S.C. 1983 for violations of their procedural due process rights stemming from their child-protection case. Plaintiffs' complaint related to the notice and hearing requirement of an emergency protective custody hearing. The court concluded that the County lacked any policymaking authority regarding the handling and scheduling of the EPC hearing and formal hearing. Plaintiffs' complaint essentially alleged that Minnesota law, and the state court judge's application of that law - not an independent County policy - caused the procedural due process violations. The County could not be liable to plaintiffs under section 1983 for the violation of their procedural due process rights based on the allegations contained in the complaint. Accordingly, the court affirmed the judgment. View "Slaven, et al v. Engstrom, et al" on Justia Law

Chrylser appealed an adverse jury verdict in favor of plaintiff on a retaliation claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. Plaintiff cross-appealed, claiming that the district court improperly granted a motion for directed verdict on a punitive-damages claim and improperly reduced the attorney's fee award. The court held that the jury instruction on plaintiff's retaliation claim was proper; evidence was sufficient to support the verdict under the MHRA "contributing factor" standard; and the evidence was sufficient to support the jury's economic-damages award. The court affirmed the district court's refusal to submit the punitive damages claim to the jury. Because plaintiff also requested attorney's fees for time spent on post-trial motions and appellate work, however, the court remanded to the district court for consideration of this request, leaving the issue to the district court's discretion. View "Al-Birekdar v. Chrysler Group, LLC" on Justia Law

Plaintiff sued United Systems for sex and disability discrimination after she was terminated. After plaintiff prevailed on both claims, United Systems appealed the district court's denial of its post trial motions for judgment as a matter of law and for remittitur of the mental anguish damages. The court concluded that a legally sufficient basis existed for a reasonable jury to determine that plaintiff had made a showing that she had been discriminated against by her employer. Since the court concluded that the district court did not err in denying United Systems' motion for judgment as a matter of law on plaintiff's sex discrimination claims, the court need not address the denial of the motion on her disability discrimination claims. Considering precedent and the record made in this case, the court could not conclude that the award of $100,000 to plaintiff was monstrous, shocking, or grossly excessive. Accordingly, the district court did not manifestly abuse its discretion in denying the motion for remittitur. View "Hudson v. United Systems of Arkansas, Inc." on Justia Law