Justia Civil Rights Opinion Summaries

Plaintiff filed a 42 U.S.C. 1983 action, alleging violations of his Fourteenth Amendment due process rights as a civilly-committed resident of the Missouri Sex Offender Treatment Center (MSOTC). On appeal, plaintiff challenged the district court's adverse judgment entered after a six-day bench trial. The court held that plaintiff had Article III standing to challenge the treatment program and use of the "Restriction Table" or "Restriction Area;" the issue of whether disruptions in the treatment violated plaintiff's constitutional rights was not moot; and the court also rejected plaintiff's remaining standing and mootness arguments. The court also held that the district court was correct that plaintiff did not have a fundamental due process right to sex offender treatment; although the treatment defendant received was less than ideal and perhaps even inadequate, it was not so lacking as to shock the conscience; and therefore, plaintiff failed to prove his substantive due process claim. The court also rejected plaintiff's argument that MSOTC's use of the Restriction Table and later use of the Restriction Area violated his Fourteenth Amendment due process rights. Finally, the decision to deny the imposition of sanctions was not an abuse of discretion.

Under a contract with the ADC, GTL provided telephone services to ADC inmates and pays ADC 45% of GTL's gross revenues. Plaintiff, an inmate, commenced this 42 U.S.C. 1983 action against GTL and ADC officials alleging that the elevated telephone charges he must pay by reason of the contract violated his First Amendment free speech rights because he would call family members outside the prison more frequently if calls were less expensive. The court held that ADC had no First Amendment obligation to provide any telephone service and it had no obligation to provide that service at a particular cost to users; the Constitution did not prohibit charging prisoners for essential prison services, at least in the absence of showing that the result was a severe deprivation of a fundamental right; and the district court properly conducted a four-factor Turner test but correctly noted that "[i]t was not at all clear that the Turner framework applies."

The EEOC alleged that under Product Fabricators' drug policy, Product Fabricators made unlawful medical inquiries of employees, failed to keep confidential their medical information, and discharged a shear operator employee because of his disability and/or as a result of an unlawful application of the drug policy - all in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a). The district court subsequently rejected a proposed decree to ensure compliance with the ADA on the ground that the EEOC did not identify a basis for the court to continue jurisdiction over the case for two years. The court concluded that the district court gave no consideration to the strong preference for settlement agreements as a means of protecting the federal interest in employment discrimination cases, or to the fact that jurisdiction was a usual component of such agreements, in part due to its deterrent effect. The district court also improperly gave significant weight to Product Fabricators' contention that its acts of discrimination were insufficiently widespread to justify continuing jurisdiction in the face of the EEOC's allegations. As a result, the district court did not explain why continuing jurisdiction was not fair, reasonable, and adequate, and thus abused its discretion.

Plaintiff loaned her car to her son, who was arrested for driving the car while under the influence of alcohol. As part of the arrest, the officer seized the car. She received notice that the car was subject to forfeiture under Minnesota law, Minn. Stat. 169A.63 subd. 1(i). Her "innocent owner" defense was successful. She then filed a purported class action against the city, asserting federal claims under the Takings and Due Process Clauses of the Fifth Amendment and the Unreasonable Seizure Clause of the Fourth Amendment. She also asserted Minnesota state constitutional claims. The district court granted summary judgment to the city on the basis that the Minnesota State Patrol, not the city, seized the car. The Eighth Circuit affirmed, finding the claims barred by res judicata because they could have been litigated in the state court proceeding.

Plaintiff, a white male, employed as a forklift operator, supported another employee's racial discrimination claim by testifying that he also routinely failed to sign a forklift checkout sheet and had never been disciplined. After an investigation, two operators were determined to be the individuals signing the checkout sheet on behalf of other employees and were issued disciplinary warnings; plaintiff was not disciplined. Plaintiff subsequently had a conflict with another employee that resulted in multiple complaints by fellow workers. The company terminated his employment for "violations of company policies, including ... creation of a hostile and intimidating work environment and engaging in unsafe work practices." The union filed a grievance but decided not to pursue it. The district court rejected his suit under 42 U.S.C. 1981 and alleging defamation on summary judgment. The Eighth Circuit affirmed, holding that plaintiff failed to prove pretext.

In 2006, petitioner was convicted of three counts of delivery of cocaine and was sentenced as a habitual offender to three consecutive terms of 60 years. The state court of appeals affirmed and petitioner did not appeal. After the state court denied a subsequent petition seeking post-conviction relief, the state supreme court dismissed an appeal on November 13, 2008. He filed a petition for writ of habeas corpus on November 13, 2009, believing that the statute of limitations, 28 U.S.C. 2244(d), had not been triggered until his post-conviction appeal had been dismissed. The district court dismissed the petition as untimely. The Eighth Circuit affirmed. Direct review of the conviction was complete on December 26, 2007. The time period was tolled during the pendency of a post-conviction Rule 37 petition, from January 22, 2008, to November 13, 2008. On November 14, 2008, the statute of limitations resumed running. Petitioner cannot show that he had been pursuing his rights diligently.

Plaintiffs, individually and on behalf of their son, sued, inter alia, the Isanti County Deputy Sheriff in his individual and official capacity under 42 U.S.C. 1983 and relevant state law, seeking damages for alleged injuries suffered when the deputy entered their home without a warrant. The deputy was dispatched to plaintiffs' home to conduct a "welfare check on a five-year-old son and an intoxicated mother." The jury returned a verdict in favor of the deputy and the district court denied plaintiffs' motion for a new trial. On appeal, plaintiffs sought a new trial, arguing that the district court gave erroneous jury instructions and made erroneous evidentiary rulings. The court held that the district court did not err in instructing the jury on who bore the burden of proof; in instructing the jury on the emergency aid exception; in admitting the preliminary breath test result for the limited purpose of determining the reasonableness of the deputy's actions after he administered the test; and in excluding the proffered testimony of a subsequent home-entry incident involving the deputy. Accordingly, the judgment was affirmed.

This civil action arose out of events that occurred on the first day of the 2008 Republican National Convention in St. Paul, Minnesota. 32 people filed suit under 42 U.S.C. 1983 against six police officers and the City of St. Paul, alleging violations of their rights under the First and Fourth Amendments. Plaintiffs subsequently appealed the dismissal of their claims against five officers and the City. The court affirmed the district court's conclusion that the officers were entitled to qualified immunity for the seizures; the record did not show that any defendant directly used force against any plaintiff; and Sergeant Axel Henry was entitled to qualified immunity. The court also held that the district court correctly granted summary judgment for the officers on plaintiffs' claims that the officers arrested them in retaliation for exercising their First Amendment rights. The court further held that the district court correctly granted summary judgment in favor of the City where a Senior Commander's actions were not sufficient to impose liability on the City.

In an appeal from the district court's dismissal of a 42 U.S.C. 1983 action on grounds of standing and Younger v. Harris abstention, plaintiff argued that it had standing to assert various constitutional claims and that the district court also erred in abstaining in deference to the pending state-court actions regarding whether the minor children of the members of the church were neglected or abused. Defendants contended that the district court relied on abstention only with respect to the individual plaintiffs and that the church did not have standing to assert claims alleging a deprivation of its own federal rights much less those of its individual members. The court agreed that the district court applied abstention with respect to individual plaintiffs, and that it dismissed the church solely for lack of standing. Without reaching the question of standing at the pleading stage, however, the court affirmed because the court's analysis of Younger abstention with respect to the two individual plaintiffs was equally applicable to the church.

Plaintiffs sued their employer, alleging that they had been subjected to sexual and racial discrimination harassment by their supervisor in violation of Title VII of the Civil Rights Act of 1964. The district court granted the employer's motion for summary judgment, concluding that it was entitled to the affirmative defense for supervisor harassment recognized in Burlington Industries, Inc. v. Ellerth and Faragher v. City of Boca Raton. The court agreed with the district court that the employer had established both parts of the Ellerth-Faragher affirmative defense as a matter of law and affirmed summary judgment on that basis.