Justia Civil Rights Opinion Summaries

Troy Sampson committed suicide while detained at the Dodge County Jail (DCJ) in Nebraska. Sampson's mother, Sherry Luckert, acting as the personal representative of Sampson's estate, sued Dodge County and jail officials under 42 U.S.C. 1983, claiming they were deliberately indifferent to Sampson's medical needs, thus violating his due process rights. A jury found Dodge County and DCJ's director and nurse (collectively, Appellants) liable and awarded Luckert actual and punitive damages. The district court denied Appellants' motion for judgment as a matter of law, entered judgment in favor of Luckert, and awarded Luckert attorney fees and costs. The Eighth Circuit Court of Appeals reversed the denial of judgment as a matter of law and vacated the awards of damages and attorney fees and costs for Luckert, holding that all Appellants were entitled to judgment as a matter of law, and therefore, it was unnecessary to address their remaining claims.

Plaintiff filed suit under the Federal Tort Claims Act, 28 U.S.C. 2671-2680, alleging that employees of the United States negligently caused significant delay in the proper treatment of leg injuries that he suffered while an inmate at the Federal Correction Institution in Forest City, Arkansas. The district court found that the government was liable and awarded compensatory damages. The government subsequently appealed the amount of damages. The court concluded that an award of $813,000 in this case was generous but the court could not conclude that the decision of the experienced district judge was "monstrous" or "shocking" or that it resulted in a "plain injustice." Therefore, the court affirmed the judgment under the deferential standard of review that applied to an award of damages in a bench trial.

Plaintiff, a Missouri inmate serving life sentences, filed a 42 U.S.C. 1983 action against various MDOC correction officials and medical staff, asserting claims of deficient medical care and treatment, retaliation, and harassment. The district court dismissed the pro se complaint without prejudice, agreeing with defendants that plaintiff failed to exhaust available prison remedies, as required by the Prison Litigation Reform Act of 1995 (PLRA), 42 U.S.C. 1997e(a). The court concluded that some claims were properly exhausted; therefore, the court affirmed in part, reversed in part, and remanded for further proceedings; and the court denied as moot plaintiff's contention that the district court abused its discretion in denying his motion for appointment of counsel in the district court, and his motion for appointment of counsel on appeal.

Plaintiff brought a 42 U.S.C. 1983 action, alleging that his federal and state constitutional rights were violated when defendants unlawfully seized, searched, and detained him. Defendants moved for summary judgment on the basis of qualified immunity. The court concluded that defendants were entitled to consideration by the district court of their claims to qualified immunity as to each of the constitutional claims asserted against them. Therefore, the court remanded the matter to the district court to engage in a full qualified immunity analysis in the first instance.

Plaintiff, an advanced practical nurse at the University, sued the Board of Curators, alleging a violation of the Equal Pay Act, 29 U.S.C. 206(d), claiming that she was paid less than a male who performed substantially equal work under similar work conditions. The district court, over plaintiff's objection, gave the business-judgment instruction and the jury returned a verdict for the Curators. Plaintiff appealed. The court concluded that the business-judgment instruction limited the jury from ruling for plaintiff solely for irrelevant reasons that were not in the proceeding three instructions. Taken as a whole, the instructions correctly stated the law, requiring a verdict for the plaintiff under some circumstances or for the defendant under others. Accordingly, there was no error and the court affirmed the judgment.

Plaintiff appealed the district court's grant of the City's motion for summary judgment on his Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Minnesota Human Rights Act (MHRA), Minn. Stat 636A, claims. The court held that plaintiff was unable to show that the City's justification for not hiring him was not pretext. Consequently, the court affirmed the dismissal of plaintiff's ADA claim because plaintiff had not put forth either direct or indirect evidence that the City regarded him as disabled person due to his knee injury. The court also held that the facts did not show how plaintiff was materially limited in the major life activity of working or regarded as such and therefore, the district court correctly dismissed his MHRA claim.

Defendant was found guilty of twelve counts of providing material support to a designated foreign terrorist organization and one count of conspiring to do so. During trial, the district court cited defendant for criminal contempt for repeatedly failing to stand when the court convened and recessed as required by a pretrial order. After her first failure to stand, defendant objected to the order as violating her right to the free exercise of religion. Defendant subsequently appealed her 20 criminal contempt citations and her 25 day prison sentence, contending that they violated the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb, et seq. The court affirmed defendant's first citation because she knew about the court order in advance, failed to make a formal challenge although she had the opportunity to do so, and knowingly violated the order by failing to rise. Because the district court applied only a First Amendment analysis in regards to her objection to the burden the order placed on her exercise of religion, it never evaluated whether the pretrial order was the least restrictive means to achieve a compelling government interest, as required by RFRA. Thus, the court vacated the subsequent citations and remanded to the district court to evaluate this issue.

Defendants appealed from the district court's denial of summary judgment on the basis of qualified immunity. Plaintiff, an Intake and Placement Director in the Arkansas Department of Human Services, Division of Youth Services (DYS), claimed gender discrimination after being fired for untruthfulness in connection with the release of a youth resident from residential custody. The court reversed, finding that defendants where entitled to qualified immunity because plaintiff had not established a constitutional violation where plaintiff failed to offer evidence that could convince a reasonable jury that defendant Angel's and DYS's stated reason for firing her was pretext for intentional discrimination.

Plaintiff sued his former employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Nebraska Fair Employment Practices Act (NFEPA), Neb. Rev Stat. Ann. 48-1101 et seq. The district court granted defendant's motion for summary judgment on all claims and plaintiff appealed with respect to his ADA and NFEPA claims. The court concluded that plaintiff had not met his burden of demonstrating pretext at the summary judgment stage of his wrongful termination claim where there was no evidence showing that the difference in consequences for plaintiff and a co-worker was a result of anything except their different conduct and different roles in the company. The court also concluded that plaintiff failed as a matter of law to demonstrate the elements necessary to establish a hostile work environment claim. Accordingly, the court affirmed the judgment.

In this Establishment Clause suit, at issue was whether a city commission's adoption of an initiated ordinance that in effect countermanded the commission's earlier decision to remove from municipal property a Ten Commandments monument imbued the monument with an impermissible religious symbolism that had earlier been judicially declared not to exist. The court held that plaintiffs had Article III standing because they could demonstrate injury, causation, and redressability. Accordingly, the court reversed the district court's dismissal of the action and remanded for further proceedings.