Justia Civil Rights Opinion Summaries

Plaintiff brought suit against the University alleging that the University, as her former employer, violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12112, 12203, by refusing to accommodate her mental and physical disabilities and by responding to her requests for accommodation with hostile actions that caused her constructive discharge. The court agreed with the district court that the University lacked the capacity to be sued under state law and Rule 17(b) of the Federal Rules of Civil Procedure. Therefore, the court affirmed the district court's grant of summary judgment without reaching the merits of plaintiff's ADA claims. View "Lundquist v. University of SD Sanford" on Justia Law

A jury found in favor of plaintiff in his employment-discrimination suit under the Missouri Human Rights Act (MHRA), section 213.010 of the Missouri Revised Statutes, against Kaman. Both parties appealed. The court held that plaintiff made a submissible case for punitive damages by providing clear and convincing proof from which a reasonable factfinder could conclude that Kaman acted with evil motive or reckless indifference when it retaliated against him; the $500,000 in punitive damages that the jury awarded plaintiff did not violate due process; the district court did not did not err in refusing to grant a new trial on plaintiff's discrimination and retaliation claims; and the district court did not abuse its discretion in restricting plaintiff's recovery of attorneys' fees. Accordingly, the court affirmed the judgment. View "Trickey v. Kaman Industrial Technologies Corp." on Justia Law

Plaintiff sued the former Mayor of the City of Russelville and the members of the Russellville City Council in federal district court, alleging age and race discrimination. Defendants subsequently filed an interlocutory appeal, seeking a reversal of the district court's denial of legislative immunity. The court concluded that defendants were entitled to legislative immunity where defendants not only eliminated plaintiff's position, but also instantaneously created a seemingly identical position. In the present case, control over the position at issue moved from the Mayor to the City Council, a quintessential legislative decision. View "Leaphart v. Williamson, et al" on Justia Law

Because Creighton University failed to provide what plaintiff, who had a serious hearing impairment, considered necessary and reasonable accommodations, he brought this action under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12182, and section 504 of the Rehabilitation Act, 29 U.S.C. 794. The court concluded that the district court erred by disregarding plaintiff's affidavit, the "independent documentary evidence" offered in its support, and all respects of the record before it; the evidence produced in this case created a genuine issue of material fact as to whether Creighton University denied plaintiff an equal opportunity to gain the same benefit from medical school as his non disabled peers by refusing to provide his requested accommodations; and therefore, the district court's grant of summary judgment to Creighton University should be reversed and the case remanded. The court need not consider Creighton University's argument on cross appeal that the district court erred by denying its request for costs without providing a rationale for doing so. View " Argenyi v. Creighton University" on Justia Law

Plaintiff brought this action under 42 U.S.C. 1983, alleging that his constitutional rights were violated while he was detained at Faulkner County Detention Center (FCDC). The court held that, in the circumstances presented in this case, defendants' refusal to grant plaintiff's request for additional toilet paper did not violate any clearly established right. Accordingly, defendants were entitled to qualified immunity. Therefore, the order denying qualified immunity was reversed and the case was remanded to the district court for the entry of an appropriate order. View "Stickley v. Byrd, et al" on Justia Law

Plaintiff sued her former employer, the Third Judicial District, and its current and former directors under 42 U.S.C. 1983, claiming that the employer fired her in violation of the First Amendment. The district court denied defendants' motions for summary judgment based on qualified immunity. The court dismissed the appeal for lack of jurisdiction where qualified immunity was not a defense available to a governmental entity and its current director in his official capacity. Further, the remaining defendant was deceased and was not a proper party on appeal. View "Campbell v. State of Iowa, et al" on Justia Law

Plaintiffs alleged that their autistic son was not provided a free appropriate public education (FAPE) by the school district as required by the Individuals with Disabilities Act (IDEA), 20 U.S.C. 1400 et seq. The court affirmed the district court's holding that the school district had provided a FAPE for the child and allowed his parents meaningful participation in the development of his behavior and educational plans. View "M.M., et al v. Dist 0001 Lancaster Co. School" on Justia Law

Plaintiff commenced this lawsuit after he was terminated from his employment at Arkansas State University, asserting procedural due process claims under 42 U.S.C. 1983 against the Vice-Chancellor and Director-of-Instruction in their official and individual capacities. Plaintiff alleged that the officials provided constitutionally inadequate pretermination process and sought damages and injunctive relief. The court concluded that reasonable school officials would not have known that the officials' conduct violated plaintiff's clearly established due-process rights and therefore reversed the district court's denial of qualified immunity. View "Sutton v. Bailey, et al" on Justia Law

Plaintiff brought suit against defendants, Deputy United States Marshals, amongst others, alleging retaliation for exercising his free speech rights under the First Amendment, and violations of his rights to due process and to be free from excessive force. Defendants appealed the district court's denial of their motion for summary judgment based on qualified immunity and their subsequent motions to amend or alter the order denying their motions for summary judgment. The court vacated the denial of summary judgment and remanded to the district court for a more detailed consideration and explanation of the validity of defendants' claims of qualified immunity. View "Solomon v. U.S. Marshal Thomas, et al" on Justia Law

Plaintiff sued the City and several city officials in their official capacities under 42 U.S.C. 1983 and 1988, challenging a city ordinance prohibiting outdoor smoking on certain public property. The court held that the right to smoke was not a fundamental right and the district court did not err in dismissing plaintiff's due process claim. The court also held that because plaintiff did not plead facts plausibly indicating that smokers constituted a suspect or quasi-suspect class, the district court did not err in dismissing his equal protection claim. Because the city's health-based justification was sufficient, the court held that plaintiff's claim that the law failed rational basis review was properly dismissed. The court rejected plaintiff's remaining constitutional claims and affirmed the judgment. View "Gallagher v. City of Clayton, et al" on Justia Law