Justia Civil Rights Opinion Summaries

Appellants, on behalf of their disabled daughter, appealed the district court's finding that the Fort Osage R-1 School District ("school district") offered the daughter a free appropriate public education ("FAPE") within the meaning of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, et seq., for the 2006-2007 school year. Appellants sought reimbursement for their costs of placing their daughter at a private facility during the school year. The court held that the district court did not err in concluding that the school district offered the daughter a FAPE and that the Individualized Education Plan put forward by the school district did not suffer from any procedural error. Accordingly, the court affirmed the judgment of the district court.

Appellant appealed from the district court's grant of summary judgment in favor of his former employer on his claims of race discrimination, hostile work environment, and termination as a result of retaliation in violation of Title VII of the Civil Rights Act of 1964, 41 U.S.C. 2000e-2000e-17, and the Minnesota Human Rights Act, Minn. Stat. 363A.15 ("MHRA"). The court held that the district court correctly determined that the former employer was entitled to summary judgment on the harassment/hostile work environment claim where appellant failed to establish the threshold of actionable harm necessary to constitute a hostile work environment. The court also held that the district court correctly granted summary judgment on appellant's claims that he was fired on the basis of his race, and treated less favorably than similarly-situated white employees on the job where appellant presented no direct evidence that his termination or alleged lack of training or job change opportunities were racially motivated. The court held, however, that the district court erred in granting summary judgment on appellant's retaliation claims where he had produced sufficient evidence of retaliation.

Plaintiffs sued defendant, their former employer, for age discrimination in violation of the Age Discrimination in Employment Act ("ADEA"), 29 U.S.C. 623(a), and the Minnesota Human Rights Act ("MHRA"), Chapter 363A. At issue was whether the district court properly granted summary judgment for defendant. The court affirmed summary judgment and held that defendant articulated legitimate non-discriminatory grounds for plaintiffs' terminations and plaintiffs failed to show that the reasons were pretexts for age discrimination because defendant maintained a consistent explanation for the termination-shifting client needs and an anticipated reduction in workload and profitability.

Plaintiff received disability insurance benefits under the Social Security Act 42 U.S.C. 301 et seq., between September 1994 and March 2004. After an investigation, the Social Security Administration ("SSA") notified plaintiff that she was ineligible for disability benefits because her employment income had exceeded SSA limits and determined that she was required to repay more than $60,000 in over paid benefits. At issue was whether the district court properly entered judgment for the SSA and denied plaintiff's waiver of over payment recovery and affirmed the ALJ's conclusion that it lacked authority to consider plaintiff's new argument contesting the amount of the overpayment itself. The court held that plaintiff failed to meet the administrative exhaustion requirement because she did not timely challenge her overpayment. Accordingly, since no final decision was made, the district court lacked jurisdiction under 42 U.S.C. 405(g) to consider plaintiff's challenge to the overpayment. The court also held that plaintiff was not entitled to a waiver of overpayment recovery because substantial evidence showed that she was not without fault in causing the overpayment and that the ALJ properly found that plaintiff knew or should have known that her work information was material because of her agreement to report such work in her benefit applications. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued defendants, including the police officer that shot him, alleging violations of 42 U.S.C. 1983 and various state law theories. At issue was whether the district court erred by denying the officer's motion for summary judgment on plaintiff's section 1983 claim, concluding that the facts established a violation of the Fourth Amendment and that the law was clearly established at the time of the shooting. The court concluded that it was not clearly established as of the time of the shooting that an officer in Missouri could effect a seizure under the Fourth Amendment without subjectively intending to do so. Therefore, the district court erred in denying the officer's motion for summary judgment on plaintiff's Fourth Amendment claim without considering the officer's subjective intent. Accordingly, the court vacated the section 1983 claim and remanded for further proceedings regarding the officer's subjective intent.

Plaintiff sued defendant under the Minnesota Human Rights Act ("MHRA"), Chapter 363A, alleging that defendant terminated her and took other adverse employment actions against her because she made complaints of discrimination. At issue was whether the district court properly granted summary judgment in favor of defendant on plaintiff's retaliation claims. The court affirmed summary judgment and held that plaintiff failed to create a triable issue of fact regarding whether defendant retaliated against her for reporting alleged discrimination where defendant articulated a non-discriminatory ground for plaintiff's termination, violation of a work rule, in which plaintiff failed to show pretext for retaliation.

Claimant appealed the district court's judgment upholding the Commissioner of Social Security's denial of her application for disability insurance. Appellant raised several issues of error on appeal. The court held that a certain physician's post-hearing letter did not contain any additional information and was not relied upon in the decision making process, and its receipt did not violate claimant's due process rights; that the ALJ did not err in finding claimant retained the residual functional capacity to perform certain kinds of low-stress work; that there was no error in the decision not to order a consultative examination regarding claimant's mental impairments; and that a hypothetical question posed to the Vocation Expert adequately addressed impairments supported by the record. Accordingly, the court affirmed the judgment where substantial evidence on the record as a whole supported the ALJ's decision.

Appellant brought an action against three law enforcement officers pursuant to 42 U.S.C. 1983 alleging that the officers violated his rights under the Fourth Amendment by using excessive force against him during and shortly after his arrest. At issue was whether the district court properly concluded that appellant's failure to show greater than de minimus injury was fatal to his claim and dismissed his complaint. The court affirmed the district court's summary judgment motion and held that a citizen could prove an unreasonable seizure based on an excessive use of force without necessarily showing more than de minimus injury. The court held, however, that the officers were entitled to qualified immunity because their alleged actions did not violate clearly established law in August 2005. The court further held that the district court did not abuse its discretion in denying appellant's motions for sanctions and motion for appointment of counsel.

Appellants, David Torgerson and Jami Mundell, sued the City of Rochester ("city") alleging, respectively, disparate-treatment discrimination based on national origin and based on gender when the city decided not to hire them as firefighters. Appellants claimed that the city violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2000e-17, and the Minnesota Human Rights Act ("MHRA"), Minn. Stat. 363A.01-.41. Torgerson also sued under 42 U.S.C. 1981. At issue was whether the district court properly granted summary judgment in favor of the city. As a preliminary matter, the court held that summary judgment was not disfavored, was designed for every action, and there was no employment discrimination case exception. The court affirmed summary judgment and held that appellants failed to present direct evidence of gender or national origin discrimination against them in violation of Title VII; appellants made a prima facie case of discrimination but the city advanced nondiscriminatory grounds for its hiring decisions and appellants failed to show the grounds were pretexts for discrimination; the fact that appellants and hired candidates had relatively similar qualifications did not create a material issue of fact as to pretext. The court also held that Torgerson's section 1981 claim was properly dismissed where he alleged he was discriminated against based on national origin, not race.

Appellant brought a 42 U.S.C. 1983 action against appellees, the captain of a detention center and two officers of the county sheriff's department, alleging use of excessive force. At issue was whether the district court erred in finding appellant's version of events incredible; whether the captain violated appellant's Fourth Amendment rights when attempting to use an arm-bar maneuver to subdue appellant; and whether the officers violated appellant's constitutional rights by failing to intervene when the captain attempted the arm-bar maneuver. The court affirmed the district court's factual findings and proceeded to analyze the court's legal conclusions. The court held that the captain did not violate appellant's Fourth Amendment rights where it was reasonable for him to believe that appellant constituted a threat to his safety and his efforts to subdue appellant were a reasonable use of force. Therefore, because the captain did not use excessive force, appellant's claims regarding the officers also failed.