Justia Civil Rights Opinion Summaries

Plaintiff brought suit against his employer, the City of O'Fallon, alleging, among other things, that the city retaliated against him for exercising his right to free speech guaranteed by the United States and Missouri Constitutions. Plaintiff's free speech claim alleged that the city retaliated against him for the comments made in his report to the Board of Alderman by failing to promote plaintiff, by failing to follow internal procedures while investigating him, and by taking negative personnel actions against him. Defendant's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634, and Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213.055, claims alleged that the city failed to promote plaintiff because of his age. The district court granted summary judgment in favor of the city. The court held that the district court did not err in granting summary judgment in favor of the city on plaintiff's free speech claims; plaintiff failed to meet his burden under the MHRA and summary judgment was properly granted on this claim; summary judgment was properly granted on the ADEA claim; and his Missouri Workers' Compensation Act, Mo. Rev. Stat. 287.780 claim. Accordingly, the court affirmed the judgment. View "Buehrle v. City of O'Fallon, Missouri" on Justia Law

Plaintiff, an inmate of the Missouri Department of Corrections, filed suit under 42 U.S.C. 1983, alleging that his transfer, detention, and involuntary medication violated his due process rights. The court concluded that plaintiff need only be found gravely disabled before he could be involuntarily medicated; plaintiff's involuntary medication for a clinical necessity did not violate Missouri Department of Corrections Policy IS12-6.1; and plaintiff's procedural rights were not violated where Policy IS12-6.1 closely followed Washington's policy approved in Washington v. Harper and where, before his forced treatment, plaintiff was given notice of his due process hearing, was present at it, was permitted to cross-examine witnesses, and a neutral decisionmaker made the decision. Accordingly, the court affirmed the judgment.

Plaintiff sued her employer alleging disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Iowa Civil Rights Act (ICRA), Iowa Code 216 et seq. Because plaintiff was unable to perform the essential functions of her position, with or without reasonable accommodation, she failed to make a prima facie showing of discrimination under the ADA. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued Missouri prison officials under 42 U.S.C. 1983 for refusing to feed him for several days while he was restrained. A jury returned a verdict for the prison officials, which plaintiff appealed. The court held that the district court erred in not submitting a nominal damages instruction to the jury where the lack of nominal damages instruction had a probable effect on the verdict. Accordingly, the district court abused its discretion and the judgment was reversed and remanded.

Plaintiff sued his employer, Trinity, alleging that Trinity discriminated against him on the basis of his son's disabilities, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. He also alleged a violation of his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court affirmed the district court's grant of summary judgment, holding that the district court did not err in applying the honest belief rule; plaintiff failed to show that his termination was based on pretext or a discriminatory motive; and plaintiff failed to present sufficient evidence of an FMLA violation. Trinity proffered a legitimate nondiscriminatory reason for the termination - it believed that plaintiff violated company policy by encouraging a work slowdown - and plaintiff presented insufficient evidence to show that the explanation was pretextual.

Patients, civilly committed to the Minnesota Sex Offender Program (MSOP), brought suit under 42 U.S.C. 1983 against DHS officials and DOC officials, alleging that various MSOP policies and practices relating to Patients' conditions of confinement were unconstitutional. The district court granted summary judgment to DHS officials and DOC officials on all of Patients' claims and Patients appealed, raising ten assertions of error. The court rejected Patients' claims and affirmed the summary judgment.

Plaintiff sued St. Louis County and three of its police officers - Lane Hollandsworth, Stephen Deen, Sr., and Jack Webb - under 42 U.S.C. 1983, alleging that they violated his constitutional rights by causing his wrongful conviction for rape and delaying his exoneration. After dismissing the County from the case, the district court granted summary judgment to the individual defendants, dismissing all claims with prejudice. The court affirmed, holding that, even assuming Hollandsworth caused some degree of suggestiveness in the photo lineup, it did not violate plaintiff's constitutional rights; there was no material issue of fact whether Hollandsworth knew that the December 4, 1982, incident was exculpatory evidence and tried to suppress the evidence; and therefore, the district court did not err in granting summary judgment to Hollandsworth. The court also held that Deen did not violate defendant's due process rights by conducting an impermissibly suggestive live lineup. Further, the court held that the district court did not err in granting summary judgment to Webb where there was no evidence in the record that Webb signed a false affidavit. Finally, the district court did not err in denying the motion for leave on the basis of futility and the district court did not abuse its discretion in denying plaintiff's motion to alter or amend its judgment.

CEF, a local chapter of an international non-profit organization that conducted weekly "good news clubs" (GNC) for children, appealed the district court's denial of a preliminary injunction against the district. Due to concerns about the "prayer and proselytizing," which occurred at GNC meetings, CEF was informed that it would be removed from the district's after-school enrichment program effective in the 2009-2010 school year. The court held that the district court abused its discretion in denying the preliminary injunction. CEF had a high likelihood of success on the merits of its First Amendment claim. The likely First Amendment violation further meant that the public interest and the balance of harms (including irreparable harm to CEF) favored granting the injunction. Therefore, the court reversed and remanded for further proceedings.

Plaintiff and his wife brought this action under 42 U.S.C. 1983, alleging that a city police officer employed excessive force when he shot plaintiff eight times. The court held that the district court properly granted summary judgment in favor of the officer on plaintiff's 1983 claim where the officer acted objectively reasonable under the circumstances. The district court ruled that if plaintiff sought to hold the city liable for the officer's alleged state-law torts, then the officer was entitled to official immunity, and the city was thus entitled to vicarious official immunity. The court agreed with this conclusion and affirmed the judgment.

TYBE, a daycare center in St. Louis, Missouri, sued the Missouri Department of Health and Senior Services (DHS), alleging federal civil rights and state law violations because DHS denied TYBE's license renewal request. On appeal, TYBE challenged the district court's grant of summary judgment on its due process claims and its state-law tortious interference claim. The court held that TYBE had not demonstrated that it had a clearly established property interest in renewal of its license and therefore defendants were entitled to qualified immunity. The court also held that, if TYBE had a legitimate claim of entitlement to operate during the revocation review period, this right was not clearly established, and any injury to TYBE's reputation, by itself, would not trigger any protectable liberty interest. Therefore, defendants were entitled to qualified immunity regarding the challenged statements. The court rejected TYBE's claims that defendants deprived it of due process by failing to make an initial settlement offer to TYBE in conjunction with the license denial review proceedings. The court further held that TYBE was not deprived of any due process rights by a DHS employee's motion to dismiss TYBE's complaint. Finally, TYBE's tortious interference claim failed as a matter of law. Accordingly, the court affirmed the judgment.