Justia Civil Rights Opinion Summaries

Plaintiff, trustee for the deceased, brought this 42 U.S.C. 1983 action alleging that an officer had used excessive force in violation of the Fourth Amendment when he shot the deceased as he was driving away from a narcotics investigation with the officer being dragged along with the car. The court concluded that the officer's use of deadly force did not violate the deceased's constitutional rights where, among other things, the reckless driving by the deceased in his attempt to escape was a danger to the arresting officers and to any drivers on the roadway and where the officer's use of force under the quickly evolving dangerous actions by the deceased was objectively reasonable under the circumstances as the officer perceived them. The court rejected the trustee's remaining arguments and affirmed the judgment.

T.B.'s parents, on behalf of their autistic child, appealed the district court's finding that the school district did not violate the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to provide a free appropriate public education (FAPE) to T.B., making the parents ineligible for reimbursement for the costs of T.B.'s home-based program. Given the parents' decision to ultimately settle the issue of the adequacy of the proposed individualized education program (IEP), the court questioned whether they could claim, much less successfully show, that the school district failed to provide a FAPE to T.B. Nonetheless, based on the record, the court could not say that T.B.'s home-based program was "reasonably calculated to enable [him] to receive educational benefits." The program was therefore not "proper" within the meaning of the IDEA and the parents were not entitled to reimbursement for the costs associated with it. Accordingly, the court affirmed the judgment.

Plaintiff, a well-known civil rights activist, filed a thirteen-count complaint against defendants after his arrest when he refused to leave a public meeting of the St. Louis School Board. Plaintiff was charged with disturbing the peace and resisting arrest but was eventually acquitted. Plaintiff subsequently appealed his 42 U.S.C. 1983 and 1985 individual and conspiracy claims alleging violations of his Fourth and First Amendment rights. The court held that the district court did not err in granting the police officers qualified immunity where the officers may have relied on inaccurate information but the mistake was objectively reasonable given the chaotic circumstances; all other claims against the police department were summarily dismissed where plaintiff failed to present probative evidence of an unconstitutional policy or custom; the claims against City Counselors David Miller and John Bouhasin, Mayor Francis Slay, and the City of St. Louis were abandoned because plaintiff failed to present arguments challenging the district court's dismissal of the claims; the district court did not err in dismissing plaintiff's First and Fourth Amendment claims against the the School Board and its security officers; and plaintiff failed to establish deprivation of a constitutional right and therefore the court affirmed the dismissal of his section 1983 and 1985 conspiracy claims. Accordingly, the judgment of the district court was affirmed.

While serving a state sentence for first degree criminal sexual conduct, appellant sued two Department of Corrections officials under 42 U.S.C. 1983 for unlawfully imprisoning him 375 days beyond the date on which he became eligible for supervised release. The district court granted summary judgment to the state officials after determining that appellant failed to satisfy the favorable termination requirement of Heck v. Humphrey. Because the court concluded that the district court did not err in determining that appellant's 42 U.S.C. 1983 claims were barred by Heck, the court did not reach any other issue discussed by the parties. Accordingly, the court affirmed the judgment of the district court.

The United States sued defendants, alleging they engaged in a pattern or practice of sex discrimination in the rental of housing. After a jury found for defendants, the district court granted in part defendants' motion for costs and attorneys' fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412, and the government subsequently appealed. In this case, the government brought a single pattern or practice claim. The court held that the district court should have made a single determination about whether the government's suit, as a whole, was substantially justified. The district court improperly considered the case as consisting of ten individual victims' claims for separate assessment, rather than a single pattern or practice claim. Consequently, this error required reversal.

Plaintiff sued his employer, alleging that his termination was the result of interference with and retaliation for his exercise of his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and racial discrimination in violation of 42 U.S.C. 1981. The district court granted summary judgment for the employer and plaintiff appealed. The court affirmed the judgment because plaintiff failed to raise a genuine issue of material fact that the employer's actions were a pretext for discrimination. Plaintiff's testimony that the racially hostile environment had abated since his first lawsuit was settled in his numerous uses of FMLA leave without negative consequences supported the employer's non-discriminatory and non-retaliatory justification for plaintiff's termination.

This case arose when plaintiff and his two business entities commenced action against defendant, alleging statutory and constitutional violations under 42 U.S.C. 1983. In this interlocutory appeal, defendant appealed the district court's denial of his motion for summary judgment on the basis of qualified immunity. The court remanded the case to the district court for a more complete articulation of its analysis of defendant's motion. The court found it difficult to discern from the order whether the district court applied either step of the qualified immunity inquiry to the claims alleged by plaintiff.

Plaintiff sued her former employer for national-origin discrimination and retaliation in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A. The district court granted summary judgment to the employer, dismissing all claims with prejudice. The court held that plaintiff did not present direct evidence of national-origin discrimination in violation of Title VII or MHRA and that her claim was properly analyzed under the McDonnell Douglas framework. Accordingly, the court affirmed the judgment of the district court.

Plaintiff, a licensed Iowa educator, filed suit in Iowa state court against his employer, school officials, and private citizens following his termination. Plaintiff alleged various state-law claims as well as violations of his procedural and substantive due process rights under 42 U.S.C. 1983. On appeal, plaintiff challenged the denial of his motion to remand and the dismissal of his section 1983 claims. The court held that the district court did not err in denying the motion to remand where, based upon the facts of the case, the unanimity requirement was satisfied. The court also held that the district court did not err in dismissing plaintiff's procedural due process claims as unexhausted where he failed to appeal his termination to an adjudicator under Iowa Code 279.17 and in dismissing plaintiff's substantive due process claim where he failed to plausibly plead a substantive due process claim. Accordingly, the court affirmed the judgment.

Plaintiff, a federal inmate, appealed the district court's summary judgment in favor of defendants where his claims arose out of a delayed consultation for his jaw injuries which in turn delayed necessary jaw surgery. The court concluded that summary judgment was not proper as to the physician's assistant (PA) and the physician where plaintiff's painful broken jaw constituted an objectively serious medical need and the record revealed trialworthy issues as to whether the PA and the physician both knew of the serious medical need and were deliberately indifferent to plaintiff's need for prompt treatment. Accordingly, the court affirmed summary judgment as to all defendants except the PA and the physician.