Justia Civil Rights Opinion Summaries

Plaintiffs, a fifth grade student and his mother, commenced this action against the St. Louis Board of Education and two nurses, asserting Fourth Amendment and substantive due process claims under 42 U.S.C. 1983 and state law claims for negligence and negligent supervision. The student was administered an H1-N1 shot by a school nurse despite telling the nurse, and presenting a signed parental form confirming, that his mother did not consent to the vaccination. The court held that the district court correctly noted that a local government entity, such as the Board, could not be sued under section 1983 respondeat superior theory of liability; plaintiffs' failure to train claims against the Board were properly dismissed for either failure to plead a plausible claim or failure to state a claim; and claims against Nurse Clark were dismissed because the nurse was acting within her official capacity and had immunity from suit. View "B.A.B., et al v. The Board of Education, et al" on Justia Law

Plaintiff, a female physician of Iranian origin, brought claims under Title VII, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act, Iowa Code ch. 216, alleging discrimination based on her sex, pregnancy, and national origin. The court affirmed the district court's grant of summary judgment to defendant, concluding that plaintiff could not assert a claim under either statute because she was an independent contractor. View "Glascock v. Linn County Emergency Medicine" on Justia Law

Plaintiff filed an eight-count second amended complaint against a police officer; the Kansas City Board of Police Commissioners, an individual, Kona Grill, and Plaza Security, asserting a variety of federal and state claims arising out of his arrest at the Kona Grill. The court concluded that plaintiff's refusal to sign his bar tab gave the officer probable cause to arrest him for theft of restaurant services; the district court correctly granted summary judgment to the officer on plaintiff's excessive-force claim; and plaintiff's state-law claims against the officer failed as a matter of law because the officer had probable cause to arrest plaintiff. The court also held that plaintiff's remaining claims failed as a matter of law. Accordingly, the court affirmed the judgment. View "Royster v. Nichols, et al" on Justia Law

The school district issued 180-day suspensions to twin brothers, the Wilsons, for disruption caused by a website the Wilsons created. The Wilsons filed suit against the school district alleging, among other things, that the school district violated their rights to free speech. At issue was the order granting the Wilsons' motion for a preliminary injunction. The court did not find that the district court made inadequate factual findings; rather, the court concluded that the district court's findings did not support the relief granted. The court held that the Wilsons were unlikely to succeed on the merits under the relevant caselaw. The court also concluded that the district court's findings did not establish sufficient irreparable harm to the Wilsons to justify a preliminary injunction. View "S.J.W., et al v. Lee's Summit R-7 School Dist., et al" on Justia Law

Plaintiffs, wrongly convicted in 1989 for participating in the rape and murder of the victim, individually filed causes of action pursuant to 42 U.S.C. 1983 against defendants, contending that defendants violated their rights to due process by recklessly investigating the murder and by coercing plaintiffs to plead guilty. On appeal, plaintiffs challenged the district court's grant of defendants' motion for summary judgment based on qualified and absolute immunity. The court concluded that the district court erred by failing to grant all reasonable inferences to plaintiffs and that the evidence was sufficient to support plaintiffs' claims that their individual rights to fair criminal proceedings were violated as the result of a reckless investigation and defendants' manufacturing of false evidence. The district court did not err, however, in its determination that there was insufficient evidence to support plaintiffs' claims that their guilty pleas were unconstitutionally coerced. Additionally, the district court did not err in granting absolute immunity to the prosecutor. Accordingly, the court affirmed in part and reversed in part. View "Thomas v. Smith, et al" on Justia Law

Plaintiff filed suit against her employer, alleging discrimination and retaliation claims under 42 U.S.C. 1983; the Arkansas Equal Pay Act, Ark. Code. Ann. 11-4-601; and the Arkansas Civil Rights Act (ACRA), Ark. Code. Ann. 16-123-101 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing all claims. The court affirmed the judgment, concluding that no reasonable factfinder could find that any defendant was guilty of intentional, gender-based wage discrimination when plaintiff's initial salary as a new zoning official was established in November 2006; plaintiff's failure-to-hire claim failed based on undisputed evidence supporting defendants' nondiscriminatory reason for hiring another candidate based on more experience and better qualifications and because plaintiff failed to demonstrate pretext; and plaintiff's remaining claims also failed. View "Hill v. City of Pine Bluff, et al" on Justia Law

Plaintiff appealed the district court's order granting the City of St. Paul's motion for summary judgment and dismissing his disability discrimination claims brought against the City under the anti-discrimination provisions of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132; Section 504 of the Rehabilitation Act of 1973 (Rehabilitation Act), 29 U.S.C. 794; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.12, as well as his claim for negligence. The court affirmed the district court's entry of summary judgment in favor of the City on plaintiff's claims regarding the traffic stop and plaintiff's claims regarding the statement of charges. Because a reasonable jury could conclude that a public service had been initiated and was stopped due to plaintiff's disability, the court reversed and remanded for further proceedings on the post-arrest claim. The court reversed the district court's grant of summary judgment on the City's request for vicarious official liability with respect to the post-arrest interview. Finally, the court affirmed the district court's grant of summary judgment on the negligence per se claim. View "Bahl v. County of Ramsey, et al" on Justia Law

Plaintiffs, including Samantha Hill and Missouri Lieutenant Governor Peter Kinder, acting in his personal capacity, brought this action to challenge various provisions of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 124 Stat. 119. The district court dismissed the suit for lack of standing. Because neither Hill nor Kinder pleaded sufficient facts to establish an injury-in-fact, both plaintiffs lacked standing to sue, and there was no Article III case or controversy. Accordingly, the court affirmed the judgment. View "Kinder, et al v. Geithner, et al" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law

Plaintiff filed suit claiming that UPS discriminated against him based on his gender, sexual orientation, and disability when it failed to hire him as a part-time package handler. The court affirmed the district court's grant of summary judgment in favor of UPS, holding that plaintiff could not prove that UPS discriminated against him because of a protected status of which it was unaware and even if a jury could find that there was discrimination, UPS provided a legitimate non-discriminatory reason for not hiring plaintiff. View "Hunter v. United Parcel Service, Inc." on Justia Law