Justia Civil Rights Opinion Summaries

Planned Parenthood brought suit against various state officials in Nebraska challenging new requirements to the State's informed consent procedures for abortions. At issue was the district court's denial of NuLife's motions to intervene. The court affirmed the district court's denial of NuLife's motions to intervene as untimely and did not reach the alternative bases relied upon by the district court to deny the motions.

This case arose when defendant denied plaintiff's application for Medicaid benefits on the grounds that she had transferred property in 2005-2006 valued at $340,000. The district court subsequently dismissed plaintiff's 42 U.S.C. 1983 claim against defendants based on the abstention doctrine set forth in Younger v. Harris. Plaintiff appealed, contending that the district court should not have abstained from hearing her claim. Because, under Alleghany Corp. v. McCartney, abstention was appropriate in administrative proceedings like plaintiff's, the court held that the district court did not err in abstaining.

A police sergeant arrested plaintiff without a warrant for running a contest which allegedly violated Minnesota gambling laws. The sergeant later obtained a search warrant and seized several items from the house where plaintiff was running the contest. A reporter broadcasted a news story about the contest and plaintiff's arrest on a local CBS television station. Plaintiff subsequently sued the sergeant and the city of Minneapolis under 42 U.S.C. 1983 for civil rights violations for the arrest and search, and the reporter and CBS for defamation. Both sides moved for summary judgment and the district court granted the motion for defendants. The court held that because plaintiff failed to demonstrate that any of the sergeant's actions violated a constitutional right, he could not deprive the sergeant of qualified immunity, and thus summary judgment was appropriate. Summary judgment was also proper as to the city because municipalities could not be held liable under Section 1983 where plaintiff had not argued on appeal that any municipal policy or custom led to a deprivation of his constitutional rights. The court also held that plaintiff was a limited purpose public figure and it was not reckless disregard for the truth to conclude that plaintiff could face future incarceration related to the contests. The court further held that the district court did not abuse its substantial discretion in denying plaintiff's motion for spoliation sanctions. Accordingly, the judgment of the district court was affirmed.

Plaintiff appealed the district court's adverse grant of summary judgment on his 42 U.S.C. 1983 claim against several prison officials. Plaintiff, a pretrial detainee, was assaulted by three other inmates while he awaited trial. The court held that the evidence presented was insufficient to show that the prison officials knew or disregarded a known risk where plaintiff offered no evidence that the prison officials had any knowledge of any specified danger posed to plaintiff by another inmate in the protective custody pod. The court also held that plaintiff failed to offer evidence that prison officials provided constitutionally inadequate medical treatment. Accordingly, the judgment was affirmed.

Plaintiff filed suit pursuant to 42 U.S.C. 1983, alleging, inter alia, that his approximately 14-year detention in administrative segregation (Ad. Seg.) violated his procedural due-process rights under the Fourteenth Amendment because the periodic reviews of his detention were not meaningful. The district court subsequently found that four of the five defendants had in fact denied plaintiff due process by conducting meaningless Ad. Seg. review hearings and consequently, awarded him $4,846 in nominal damages - $1 for every day that plaintiff lived in Ag. Seg. - but denied plaintiff prayer for punitive damages. Both parties appealed. The court held that the district court did not clearly err in its factual findings as to the meaningfulness of plaintiff's Ad. Seg. reviews and affirmed that portion of the district court's decision. The court also held that plaintiff was entitled to no more than $1 for each procedurally defective Classification Committee hearing. Thus, based on this "per-constitutional-violation" analysis, the court reversed the district court's nominal damages award and remanded for recalculation. The court further held that it could not conclude that the district court abused its discretion on the record and affirmed the district court's denial of compensatory damages. The court finally held that the district court did not err in refusing to award plaintiff punitive damages.

Plaintiff, an Arkansas inmate, brought a 42 U.S.C. 1983 action against several defendants, including the jail administrator of Ouachita County Detention Center. After granting summary judgment to all defendants except the administrator, the district court addressed plaintiff's claim against the administrator on the merits and concluded that the administrator's use of force was necessary to ensure his own safety, the safety of others, and to regain control of the facility. Therefore, the district court dismissed plaintiff's claim with prejudice and plaintiff subsequently appealed. The court held that plaintiff failed to show by a preponderance of the evidence that he was a victim of an unconstitutional excessive use of force; the district court correctly determined that the administrator's twice shoving of plaintiff toward the wall was reasonable in light of the emergent and unsafe circumstances; and a thorough reading of the district court's decision assured the court that the district court did not enforce a minimum level of injury as a legal threshold barring plaintiff's claim. Accordingly, the court affirmed the judgment of the district court.

Appellants, the Libertarian party and three candidates, challenged the constitutionality of North Dakota Century Code 16.1-11-36, contending that the statute as applied to them violated the First and Fourteenth Amendment and the Equal Protection Clause because it prevented appellants' names from appearing on the 2010 general election ballot despite their winning the party's primary. The court held that the burden imposed by the statute was not undue or excessive and the state had a compelling interest in having a minimum vote requirement before a candidate could appear on the general election ballot. Therefore, the court held that N.D.C.C. 16.1-11-36 was not unconstitutional on First or Fourteenth Amendment grounds. Furthermore, because the law applied equally to all candidates and did not result in unequal treatment, the court held that the statute did not violate the Equal Protection Clause. Accordingly, the court affirmed the district court.

Plaintiff brought a claim under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, alleging that his employer engaged in prohibited discrimination by rescinding his offer of promotion on the basis of his perceived limitations. The employer moved for summary judgment, contending, in part, that plaintiff's claim was discharged in the company's Chapter 11 bankruptcy, which had concluded two months after rescission of plaintiff's offer. The district court held that plaintiff's ADA claim was discharged by virtue of his failure to submit a request for payment by the bar date for the majority of administrative expense claims. The court found that plaintiff's claim fit squarely within the definition of liabilities incurred in the ordinary course of business. Therefore, the court held that because plaintiff was not required to file a request for payment of an administrative expense at all, the judgment in favor of the employer was reversed and the case remanded for further proceedings.

Appellant filed suit against four Minneapolis police officers and the City of Minneapolis pursuant to 42 U.S.C. 1983, claiming that the officers used excessive, unreasonable force against her, in violation of the Fourth and Fourteenth Amendments. The court reversed the district court's grant of summary judgment on the excessive force claim and held that there were genuine issues of material fact regarding whether the officers used excessive force against appellant. The court affirmed the district court's dismissal of the section 1983 claims against Officer Carroll because appellant admitted that he did not use excessive force against her. The court agreed with the district court's conclusion that because appellant did not allege any damages, she failed to state a claim under the Minnesota Government Data Practices Act. Minn. Stat. 13.01, subdiv. 1. The court held, however, that the district court failed to consider whether appellant could recover her costs and disbursements in her December 19, 2008 action to compel compliance under Minn. Stat. 13.01, subdiv. 4. Therefore, the court remanded for a ruling on whether appellant was entitled to costs or disbursements under that section of the statute. The court finally held that the district court properly dismissed appellant's common law battery claims against officers as untimely because the two-year statute of limitations period had expired. The court held, however, that appellant presented sufficient evidence to preclude summary judgment on the basis of official immunity on the alleged state tort claims.

Several Arkansas prisoners on death row challenged the state's Method of Execution Act under 42 U.S.C. 1983, arguing that it violated the ex post facto clause and their due process right to access the courts. The court held that the district court properly dismissed the section 1983 claim based on violation of the ex post facto clause. The court also held that the district court was correct to dismiss the section 1983 claim based on lack of access to the courts. The court further held that, while the court agreed that the district court erred in classifying a defendant's habeas petition as "second or successive" because he could not have raised his current claims at the time of his first petition, the dismissal of the petition was harmless error. The court finally held that the district court did not abuse its discretion in denying the Rule 59(e) motion.