Justia Civil Rights Opinion Summaries

Plaintiffs, groups interested in electoral and government reform, sued Minnesota, challenging the constitutionality of Minnesota's Election Day Policy and Minn. Stat. 211B.11, subd. 1, which banned the wearing of any political insignia to a polling place. On appeal, plaintiffs challenged the dismissal of their First Amendment and Equal Protection claims. The court held that plaintiffs have failed to state a facial claim under the First Amendment under Minn. Stat. 211B1.11, subd. 1. The court reversed and remanded the as-applied First Amendment claim to the district court so that it could properly analyze the motion as a request for summary judgment through application of the standards articulated in Rule 56 and to give the parties sufficient opportunity to create an acceptable record. The court held that plaintiffs have failed to allege that Minnesota caused selective enforcement of the facially neutral statute and Policy and has therefore failed to state an equal protection claim. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Minnesota Majority, et al v. Mansky, et al" on Justia Law

Plaintiff filed claims against the county and its officials alleging unlawful suspension and discharge, sex discrimination, retaliation, violation of her procedural and substantive due process rights, and civil conspiracy. The court held that plaintiff's claims were not time barred under Tyler v. University of Arkansas Board of Treasurers; plaintiff had suffered tangible job detriments in the form of her suspension and terminations, but plaintiff failed to show that her rejection of her supervisor's advances caused that detriment; plaintiff could not establish a prima facie case of a hostile work environment because she did not allege sufficiently severe or pervasive conduct; plaintiff's allegations of different treatment were insufficient to establish a prima facie case of discrimination; plaintiff failed to establish the requisite causal relationship to show a violation of the First Amendment in respect to her EEOC charge and her complaints about her supervisor; and plaintiff did not articulate how the county and its officials violated her Fourteenth Amendment rights of due process and equal protection. Accordingly, the court affirmed the district court's grant of summary judgment to the county and its officials. View "Butler v. Crittenden County, Arkansas, et al" on Justia Law

Plaintiffs, on behalf of their son, brought this action under 42 U.S.C. 1983 and the Missouri Constitution, alleging that the district, the superintendent, the principal, and the sheriff violated the son's constitutional rights by briefly separating him from his backpack during a drug dog exercise in his high school. The district court granted summary judgment to the district, its officials, and the sheriff. The court concluded that the brief separation of the son and his belongings was reasonable and did not deprive him of a constitutionally protected right and therefore, the district court properly granted summary judgment to the district and its officials. The court also held that the sheriff was not liable under section 1983 in his individual or official capacity where he did not participate in the drug procedure at the school, there was no evidence that the sheriff failed to train or supervise the deputies who conducted the drug dog surveys, and there was no evidence that the sheriff's office should have believed that its procedures or actions were likely to result in a constitutional violation. Accordingly, the court affirmed the judgment. View "Burlison, et al v. Springfield Public Schools, et al" on Justia Law

Plaintiff, who is visually impaired, filed suit against BNSF, alleging that BNSF retaliated against him for reporting a safety violation and that BNSF discriminated against him based on his disability. The district court granted summary judgment in favor of BNSF on the whistleblower claim, and the jury found in favor of BNSF on the discrimination claims. The court held that plaintiff's whistleblower claim was untimely and summary judgment should have been granted on that ground; the district court did not err in excluding as irrelevant the evidence of plaintiff's safety complaint; sufficient evidence supported the jury's finding that plaintiff could not perform the essential functions of the locomotive machinist position with or without reasonable accommodation; and the district court did not abuse its discretion in denying plaintiff's motion to set aside the order awarding costs. View "Hohn v. BNSF Railway Co." on Justia Law

Plaintiff, an inmate, filed suit against Correctional Officers Branch, Blair, Williford, Fox, Clubbs, and Parsons, in their official and individual capacities under 42 U.S.C. 1983, alleging excessive force and deliberate indifference to his medical needs in violation of the Eighth Amendment and retaliation in violation of the First Amendment. Correctional Officers appealed the district court's denial of their motion for summary judgment based on qualified immunity with respect to the individual capacity claims. The court affirmed the portion of the district court's order which denied qualified immunity with respect to plaintiff's deliberate indifference claim against Branch for the delay in allowing plaintiff to wash off the pepper spray, the retaliation claim against Clubbs for the retaliatory death threats, and the retaliation claim against Blair. The court reversed the portion of the district court's order which denied qualified immunity with respect to the excessive force claim against Blair, Williford, Fox, and Parsons, the deliberate indifference claim against Blair for the treatment of plaintiff's wrist, and the retaliation claim against Clubbs for filing a false conduct violation. The court remanded for further proceedings. View "Santiago v. Blair, et al" on Justia Law

Plaintiffs, the legal guardians and conservators of their adult son, sued the City and an investigator with the police department, alleging deprivation of the son's constitutional and statutory rights. The district court granted summary judgment to defendants and plaintiffs appealed. The court held that the district court correctly granted summary judgment to the investigator where his behavior during the interrogation did not shock the conscience, the adequacy of the investigation did not shock the conscience, the investigation was not in retaliation, and the "charging decision" did not shock the conscience. The district court correctly granted summary judgment to the city where plaintiffs have not alleged a pattern of similar constitutional violations. In regards to plaintiffs' section 504 of the Rehabilitation Act, 29 U.S.C. 794, and Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, claims, no reasonable jury could conclude that defendants failed to make reasonable accommodations for the son's disability. Accordingly, the court affirmed the judgment. View "Folkerts v. City of Waverly, et al" on Justia Law

Plaintiffs sued the deputies of Woodbury County, Iowa, and the County under 42 U.S.C. 1983 and Iowa law. The deputies and the County subsequently appealed the district court's denial in part of their motion for summary judgment. The court held that Defendant McCrystal was not entitled to summary judgment based on qualified immunity from Plaintiff Small's claim of unlawful arrest; McCrystal was not entitled to summary judgment based on qualified immunity from Small's claim of excessive force; the deputies were not entitled to summary judgment based on qualified immunity from plaintiffs' claim of unlawful arrest of the Warrant Plaintiffs, retaliatory inducement to prosecute, and conspiracy under section 1983; and the deputies' appeal of the denial of summary judgment on the malicious prosecution, abuse-of-process claim, and civil conspiracy claim were dismissed for lack of jurisdiction. Accordingly, the court affirmed the judgment. View "Small, et al v. McCrystal, et al" on Justia Law

Plaintiff sued her former employer, SatCom, alleging violations of the Minnesota Whistleblower Act (MWA), Minn. Stat. 181.932; Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; common law of wrongful termination, and Fair Labor Standards Act, 29 U.S.C. 201 et seq. Although plaintiff succeeded in establishing a prima facie case of retaliation where three of her reports constituted a protected activity, the court affirmed the district court's grant of summary judgment in favor of SatCom because SatCom had a legitimate, non-retaliatory reason for terminating plaintiff. Because the district court's McDonnell-Douglas analysis was sufficiently thorough to encompass plaintiff's claims under the Reporting Clause and Opposition Clause of the MWA, plaintiff was not entitled to reversal on this basis. Accordingly, the court affirmed the district court's grant of summary judgment in favor of SatCom. View "Wood v. SatCom Marketing, LLC, et al" on Justia Law

Plaintiff asserted wrongful termination claims against the WCRA, alleging disability discrimination and retaliation in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; and the Minnesota Whistleblower Act, Minn. Stat. 181.932. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing these claims. The court held that there was no evidence giving rise to an inference that the WCRA terminated her because of her medical condition; plaintiff had no claim of ADA retaliation because she did not engage in protected activity by complaining about disability discrimination; the court doubted that the supervisor's alleged harassment of plaintiff and intimidating management style created a hostile work environment; plaintiff's claim that the WCRA failed to provide reasonable accommodations for her disability failed because she never requested or otherwise adequately informed the WCRA of the need for additional accommodations; plaintiff's Whistleblower Act claim was without merit because there was no evidence plaintiff was terminated because she engaged in statutorily protected conduct; and plaintiff's contention that the district court abused its discretion by excluding certain affidavits was without merit because any error was harmless. Accordingly, the court affirmed the judgment. View "Lenzen v. Workers Compensation Reinsurance Assoc." on Justia Law

Plaintiff, a retired military police officer, sued the city and its former police chief under 42 U.S.C. 1983. Plaintiff claimed that the police chief used excessive force when he, without identifying himself as a police officer and dressed in street clothes, charged at plaintiff. The court held that, because there was enough evidence of a Fourth Amendment seizure, the court need not decide whether a reasonable jury could find the police chief's conduct shocked the conscience in violation of the Fourth Amendment; a reasonable jury could find that the police chief was an overzealous police officer who used excessive force and unreasonably caused plaintiff severe injuries; and the police chief was not entitled to qualified immunity. The court also held that plaintiff could not establish that the police chief was - as a matter of Missouri law - a final policymaker for the city. Because no reasonable jury could find the city liable under section 1983, the district court correctly granted the city's motion for summary judgment. Accordingly, the court affirmed in part, reversed in part, vacated and remanded for further proceedings. View "Atkinson v. City of Mountain View, et al" on Justia Law