Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's grant of summary judgment to the Red Cross on her claims, inter alia, of race discrimination and retaliation. The court concluded that plaintiff failed to establish a prima facie case of race discrimination based on the Red Cross' decision not to promote her and based on the failure to train her; the decision to suspend and terminate plaintiff was not a result of race discrimination but, rather, because plaintiff failed to meet her employer's legitimate expectations; even if plaintiff was able to show that she had met her employer's legitimate expectations, she failed to show that similarly situated employees committed the same conduct but were treated differently. The court concluded that the district court did not err in granting Red Cross summary judgment on the retaliation claim where plaintiff failed to establish a prima facie case of retaliation because plaintiff failed to raise a genuine issue of material fact to show a causal link between her protected activity and the adverse employment actions taken against her. Finally, the court concluded that the district court did not err in granting the Red Cross summary judgment on plaintiff's outrage claim. View "Robinson v. American Red Cross" on Justia Law

Plaintiff, a victim of sexual assault while in pretrial detention in jail, filed suit under 42 U.S.C. 1983 and pendent state law, alleging claims against those he considered responsible for the assault. At issue in this interlocutory appeal are plaintiff's Fourteenth Amendment failure to train claims against the sheriff and the jail administrator. The court denied plaintiff's motion to dismiss the appeal for lack of jurisdiction because the court had jurisdiction over the case under the collateral order doctrine. On the merits, the court concluded that plaintiff's failure to train and supervise claims must be judged by Farmer v. Brennan's subjective deliberate indifference standard where plaintiff must prove that the prison officials personally knew of the constitutional risk posed by their inadequate training or supervision and proximately caused him injury by failing to take sufficient remedial action. The court concluded that the district court's findings of fact adequately supported the district court's legal conclusion that the administrator was not presently entitled to qualified immunity on plaintiff's claim that the administrator failed to train a jailer regarding the jail's policy to lock the cell doors overnight. The court found nothing but speculation, conjecture, or fantasy to rebut the sheriff's testimony that he did not know of the substantial risk posed by the administrator's failure to train the jailer. Accordingly, the court affirmed the denial of qualified immunity to the administrator, reversed the denial of qualified immunity to the sheriff, and remanded for further proceedings. View "Walton v. Dawson, et al." on Justia Law

Plaintiff, a former inmate, filed suit under 42 U.S.C. 1983 against the State and the Iowa Board of Parole, alleging violations of his constitutional rights based on defendants' failure to conduct in-person parole interviews. The court agreed with the district court that plaintiff failed to exhaust administrative remedies under the Prison Litigation Reform Act of 1995, 42 U.S.C. 1997e(a), and dismissal of his complaint was proper. Accordingly, the court affirmed the judgment of the district court. View "Martin v. State of Iowa, et al." on Justia Law

Plaintiff filed suit against the city, alleging claims under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 701; and the Arkansas Civil Rights Act (ACRA), Ark. Code 16-123-107. Both parties appealed the judgment of the district court. The court concluded that a reasonable juror could find that plaintiff could perform the essential functions of the job for which he interviewed and that plaintiff presented sufficient evidence to support an inference of a retaliatory motive on the part of the city. Accordingly, the court affirmed the district court's denial of the city's motion for judgment as a matter of law on the FMLA retaliation claim. The court affirmed the district court's grant of the city's motion for judgment as a matter of law on plaintiff's ACRA disability-discrimination claim where plaintiff introduced no evidence to demonstrate that the city knew about his conditions when he sought to be rehired; affirmed the district court's vacatur of the jury's award for emotional-distress where the ACRA claim submitted to the jury did not provide a basis for the jury's award of emotional-distress damages; and reversed the denial of liquidated damages because the city cited no evidence in support of the district court's finding that it acted in good faith in refusing to rehire plaintiff and the court could find none. View "Jackson v. City of Hot Springs" on Justia Law

South Dakota Native American inmates filed suit against defendants claiming that a tobacco ban substantially burdened the exercise of their religious beliefs in violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc-1(a). The court concluded that the record amply showed that the inmates have satisfied their burden. That some Native Americans practicing the Lakota religion would consider red willow bark a sufficient alternative to tobacco did not undermine the decision of the district court. Even assuming that defendants' ban on tobacco furthered compelling government interests in security and order, the ban was not the least restrictive means of achieving that interest. The court concluded that the scope of the district court's remedial orders extended no further than necessary to remedy the violation of inmates' rights under RLUIPA. Accordingly, the court affirmed the district court's grant of injunctive relief in all respects. View "Native American Council, etc., et al. v. Weber, et al." on Justia Law

Plaintiff, a prison inmate, filed suit asserting various claims, including 42 U.S.C. 1983 claims alleging violations of the First and Fourteenth Amendments, that prison officials wrongfully censored and confiscated his mail. The court concluded that when an official properly and timely files a motion for dismissal or for summary judgment asserting qualified immunity, the official was entitled to a ruling on the issue of qualified immunity. As such, the district court must issue a reviewable ruling before requiring the officials to progress further in litigation at the district court. Therefore, the court reversed the district court's order converting the officials' motion to dismiss into a motion for summary judgment; vacated the district court's partial denial of the officials' motion for summary judgment; and remanded with instructions for the district court to decide, consistent with this opinion, whether the officials were entitled to qualified immunity on the pleadings under Rule 12(b)(6). View "Payne v. Britten, et al." on Justia Law

Plaintiff filed suit against the City, several officers, the State of Iowa, the director of the Iowa Department of Corrections (Baldwin), the Curt Forbes Residential Center, and manager of the Residential Center (McPherson), alleging claims under 42 U.S.C. 1983 and several state-law negligence claims. Plaintiff was shot three times by Angenaldo Bailey. The court concluded that a reasonable jury could not conclude that Officer Mueller acted recklessly or in a conscience-shocking manner by declining to arrest Bailey before the investigation proceeded the next day; plaintiff's claim against Officers Owens, Ropp, and Crippen failed because nothing the officers did - or did not do - established either a state-created danger or special relationship that imposed on them an affirmative duty to protect plaintiff from third-party harm; the evidence did not support a finding that Officers Owens, Ropp, or Crippen were deliberately indifferent to plaintiff's injuries; and because plaintiff cannot establish a constitutional violation by any of the individual City Defendants, the district court properly granted summary judgment to the City. Plaintiff's due process claims against the State Defendants rested on distinct factual allegations about whether those parties exposed her to harm by failing to take steps in response to Bailey's repeated violations of a protective order. Even if the factual record had been fully developed on those claims, plaintiff had no opportunity to make legal arguments in support of her position. Therefore, the court affirmed the district court's grant of summary judgment for the City Defendants, reversed the grant of summary judgment for the State Defendants, and remanded for further proceedings. View "Montgomery v. City of Ames, et al." on Justia Law

Plaintiff filed suit against defendants, alleging claims of unlawful sexual harassment and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., and the Iowa Civil Rights Act, Iowa Code 216.6. On appeal, defendants challenged the jury verdict in favor of plaintiff, arguing that they were entitled to a new trial. Defendants argued that the district court erred in overruling their objection to improper rebuttal closing argument by plaintiff's counsel, and then abused its discretion in denying defendants' post-trial motion because this argument, while improper, was not sufficiently prejudicial to warrant a new trial. Counsel made emotionally-charged comments at the end of rebuttal closing argument, referencing her own sexual harassment during law school and assurances to the jury that her client testified truthfully about past sexual abuse. The court concluded that the timing and emotional nature of counsel's improper and repeated personal vouching for her client, using direct references to facts not in evidence, combined with the critical importance of plaintiff's credibility to issues of both liability and damages, made the improper comments unfairly prejudicial and required that the court remand for a new trial. Accordingly, the court reversed the district court's judgment and remanded for further proceedings. View "Gilster v. Primebank, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that state officials in the WRDCC's Offenders Under Treatmet Program (OUTP) violated his rights under the First Amendment. Plaintiff, as an atheist, participated in OUTP, which "had required meetings [and] invoked religious tenets by using the serenity prayer and religious meditations." Plaintiff eventually left the program and believed that he was denied an early release on parole for failure to complete OUTP. The court concluded that whether plaintiff's withdrawal from the program was indeed voluntary or was the result of coercion was yet to be determined; therefore, dismissal on this ground was premature; plaintiff has pled facts sufficient to state a claim that a parole stipulation requiring him to attend and complete a substance abuse program with religious content in order to be eligible for early parole violated the Establishment Clause of the First Amendment; and plaintiff has pled facts sufficient to show that the personal involvement required for Defendants Crawford and Salsbury to bear section 1983 liability. As to Defendant Burgess, at this stage of the litigation, he has not. Accordingly, the district court erred in dismissing plaintiff's complaint and the court remanded for further proceedings. View "Jackson v. Nixon, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 after she was terminated by the law school of Hamline University. Plaintiff alleged that the university, the dean, and the president of the St. Paul Police Federation (SPPF) conspired with the St. Paul Police Department to deny her constitutional right to freedom of speech. The court concluded that plaintiff did not plead sufficient facts that a police officer was acting under color of state law; plaintiff did not plead sufficient facts about the University or the Dean to demonstrate that they participated in a concerted action to terminate plaintiff; concerning leave to amend, plaintiff has not plausibly alleged a meeting of the minds between the Department, the SPPF, and the University; and the district court properly ruled that adding the SPPF would be futile. Accordingly, the court affirmed the judgment of the district court. View "Magee v. Trustees of Hamline University, et al." on Justia Law