Justia Civil Rights Opinion Summaries

Plaintiff filed suit against the city building inspector under 42 U.S.C. 1983, alleging violations of his First Amendment rights. The district court granted summary judgment to defendant and the city, dismissing plaintiff's suit with prejudice. The court affirmed, concluding that, while the inspector was acting inappropriately, he did not violate plaintiff's First Amendment rights where the potential chilling effect of the inspector's instruction to a city employee to call the police when plaintiff wanted to file a grievance against the inspector was mitigated by the fact that the other city employees present did not echo the inspector's attitude. View "Scheffler v. Molin, et al." on Justia Law

Plaintiff, a Missouri inmate, appealed the district court's dismissal of an action alleging that defendants violated section 504 of the Rehabilitation Act of 1973 (RA), 29 U.S.C. 701, and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq, by the way they handle his medical needs. The court affirmed the dismissal of the individual-capacity claims against Defendants Lange and Logan, prison officials, because they could not be sued in their individual capacities under the ADA or the RA; affirmed the dismissal of the claims against the medical doctors and CMS because those claims were based on medical treatment decisions which could not form the basis of a claim under the RA or ADA; reversed the dismissal of claims for injunctive relief against Lange, Logan, the State of Missouri and MDOC that were not based on medical treatment decisions; remanded damages claims against the State of Missouri and the MDOC under the ADA, and against the MDOC under the RA, because some of defendants' alleged behavior could violate the Eighth and Fourteenth Amendments; affirmed the dismissal of the unnamed medical doctors and CMS, and the individual capacity claims against Lange and Logan; reversed the dismissal of injunctive relief claims against the state defendants that were not based on medical treatment decisions; reversed the dismissal of damages claims against the State of Missouri and the MDOC; and remanded for further proceedings. The court denied plaintiff's appellate motions. View "Dinkins v. Correctional Medical Services" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and Minnesota state law, alleging that officers violated her Constitutional rights when they arrested her. The court concluded that the officer's decision to arrest plaintiff for violating Minnesota's open-container law was reasonable, even if the flask found under her seat was empty. The officer was reasonable in viewing the time of day, plaintiff being non-cooperative, and plaintiff repeatedly asking to urinate as additional factors sufficient for probable cause to arrest for constructive possession. The officer's conduct did not show plain incompetence or a knowing violation of the law. Therefore, the officer was entitled to qualified immunity and the court affirmed the judgment of the district court. View "Branch v. Gorman, et al." on Justia Law

Plaintiff, an involuntarily committed patient at the Iowa Civil Commitment Unit for Sexual Offenders (CCUSO), filed suit under 42 U.S.C. 1983 alleging that defendant, a nurse practitioner at CCUSO, provided him constitutionally deficient medical care. The district court denied defendant's motion for summary judgment on the basis of qualified immunity. The court concluded that the district court erred in analyzing plaintiff's claim under the professional judgment standard. Instead, where a patient's Fourteenth Amendment claims were for constitutionally deficient medical care, the court applied the deliberate indifference standard from the Eighth Amendment. Because the district court applied the wrong constitutional standard in denying qualified immunity, the court remanded to the district court to apply the deliberate indifference standard in the first instance. View "Scott v. Benson, et al." on Justia Law

Plaintiffs, African American officers who worked in a state penitentiary, filed suit under 41 U.S.C. 1981 and 1983 against supervisors for race based harassment and retaliation. On appeal, the officers challenged the district court's dismissal of their claims against Lieutenants Stoner, Haney, and Runge and against Sergeants Miles and Furby. The court concluded that the evidence revealed acts, comments, and inaction by Sergeant Miles sufficient to make out prima facie harassment claims against him, which must be reinstated and remanded; there was insufficient evidence of harassment by the other supervisors and therefore the claims against Lieutenant Stoner, Runge, and Haney, and Sergeant Furby were affirmed; the retaliation claims by supervisors were affirmed; and Sergeant Miles has not shown that he was entitled to qualified immunity on the officers' harassment claims, nor have Lieutenants Stoner and Haney shown they were entitled to qualified immunity on the retaliation claims of Officer Ellis. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Ellis, et al. v. Houston, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that a police detective used excessive force when arresting him for disorderly conduct. On appeal, the detective appealed the district court's judgment in favor of plaintiff. The court concluded that the district court did not abuse its discretion in allowing plaintiff to voluntarily dismiss his official capacity claims where plaintiff was unable to introduce evidence adequate to support such claims; the district court did not abuse its discretion in ruling on the question concerning whether the officers "could have just left the scene;" the district court did not commit plain error by allowing plaintiff to elicit testimony regarding alternative courses of action; and the district court did not abuse its discretion in instructing the jury on the use of excessive force by using a modified version of instruction 4.40 from the Eighth Circuit Manual of Model Civil Jury Instructions. View "Retz v. Seaton" on Justia Law

Plaintiff filed suit under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and Arkansas state law, alleging various claims against her former employers. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the employers on her claims of sex discrimination, hostile work environment, constructive discharge, and retaliation. The court concluded that plaintiff did not produce sufficient evidence to demonstrate that she suffered an adverse employment action and that she received different treatment because of her sex; considering the totality of the circumstances, plaintiff failed to establish that an incident related to a workplace disagreement permeated the workplace and thus had not established a prima facie case of hostile work environment; plaintiff failed to establish a case of constructive discharge where, inter alia, the record reflected that the employers sought to retain her as an employee; and plaintiff failed to establish a case of retaliation. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employers on plaintiff's claims. View "Rester v. Media, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against Jackson County, Missouri and employees in its detention center. On appeal, plaintiff challenged the dismissal of his First Amendment claims. The court concluded that there was a genuine dispute of material fact as to whether the supervisor's removal of plaintiff from the trustee program in 2009 was motivated by the lawsuit he had filed against her in 2006; as to whether plaintiff would have been transferred from H module to D module but for his use of the grievance process; and as to whether two certain employees took adverse action against plaintiff by obstructing his access to the grievance process. Accordingly, the court reversed the district court's grant of qualified immunity to defendants, remanding for further proceedings. View "Spencer v. Jackson County Missouri, et al." on Justia Law

Plaintiff filed suit against her former employer, Metro, alleging that her supervisor had sexually harassed her in violation of Title VII, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Metro. The court concluded that the supervisor's alleged conduct was not so severe or pervasive as to alter the terms and conditions of plaintiff's employment and, therefore, affirmed the district court's grant of summary judgment on plaintiff's hostile work environment claim. The court concluded, however, that plaintiff presented genuine issues of fact as to whether the supervisor was motivated by sex and whether he intentionally and proximately caused her termination. Accordingly, the court reversed the district court's grant of summary judgment on this quid pro quo harassment claim. View "McMiller v. Metro" on Justia Law

Plaintiff filed suit against his former employer, the Secretary of State, in his official capacity, and other state defendants. Plaintiff claimed race discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., 42 U.S.C. 1983, and the Equal Protection Clause of the Fourteenth Amendment. The district court denied the state defendants' motion for summary judgment on the race discrimination and retaliation claims; concluded that plaintiff could pursue his Title VII claims against all defendants but that the Eleventh Amendment barred his section 1983 claims against the Secretary and his claims for monetary damages against the Secretary and Chief Hedden in their official capacities; denied Chief Hedden qualified immunity; and denied summary judgment to the state defendants as to mitigation of damages and punitive damages but granted summary judgment to the state defendants on the section 1981 claims, hostile work environment claims, and claim of deprivation of a protected property or liberty interest. The court affirmed the district court's judgment in all respects, except the court reversed its denial of qualified immunity to Chief Hedden on plaintiff's 1983 equal-protection retaliation claim. The right to be free from retaliation was clearly established as a First Amendment right and as a statutory right under Title VII; but no clearly established right exists under the equal protection clause to be free from retaliation. View "Burton v. Arkansas Secretary of State, et al." on Justia Law