Justia Civil Rights Opinion Summaries

Plaintiff filed suit against her supervisor, individually and in her official capacity as an employee of the Arkansas Department of Human Services, alleging that the supervisor violated the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. Plaintiff also alleged claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and claims against the Department under the Rehabilitation Act, 29 U.S.C. 701 et seq. The court concluded that plaintiff's FMLA claims failed because she was not an eligible employee under the FLMA and she had been employed for less than 12 months; plaintiff's FLSA claim failed because she did not plead adequately that the supervisor violated the statute; because plaintiff could not perform the essential functions of her position, with or without reasonable accommodation, she failed to create a genuine issue for trial on a claim of discrimination under the ADA; and there was no genuine issue for trial on plaintiff's claim of unlawful retaliation. Accordingly, the court affirmed the district court's dismissal of the FMLA and FLSA claims and the district court's grant of summary judgment on the ADA and Rehabilitation Act claims. View "Hill v. Walker" on Justia Law

Plaintiff filed suit against Riceland, alleging retaliatory discharge after being a witness in an internal investigation into a complaint about a manager. A jury subsequently awarded plaintiff approximately $60,000 in compensatory damages and back pay in regards to his 42 U.S.C. 1981 claim. The court concluded that the district court properly denied Riceland's motion for judgment where the evidence was sufficient for the jury to find retaliation; the district court properly dismissed plaintiff's Title VII claim where, even if plaintiff had properly preserved this claim on appeal, the claim was untimely; it was not necessary to address the district court's grant of summary judgment on plaintiff's state law claim because the state statute would not entitle plaintiff to any additional relief beyond his section 1981 claim; the district court did not abuse its discretion in denying plaintiff's motion for a new trial on punitive damages; and the district court did not abuse its discretion by denying plaintiff's request for reinstatement. Accordingly, the court affirmed the judgment of the district court. View "Sayger v. Riceland Foods, Inc." on Justia Law

Plaintiff filed suit against her former supervisor and employer, the Department, for statutory and constitutional violations. The court concluded that it had jurisdiction over the supervisor's appeal where the supervisor challenged the sufficiency of plaintiff's pleadings to state 42 U.S.C. 1983, Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., interference and retaliation claims. The court also concluded that plaintiff failed to state a section 1983 claim for gender discrimination where her conclusory assertion that she was discharged under circumstances similarly situated men were not imported legal language couched as factual allegations and failed to raise a right to relief above the speculative level. Accordingly, the district court erred in denying the supervisor's motion to dismiss the claim. Further, the district court erred in denying the supervisor's motion to dismiss the FMLA entitlement claim and the FMLA discrimination claim. The court remanded for the district court to consider whether to allow plaintiff to amend her pleadings. Finally, the court, declining to exercise pendant jurisdiction, did not have jurisdiction to hear the Department's appeal. View "Hager v. Arkansas Dept. of Health, et al." on Justia Law

Plaintiff, her husband, and their jointly owned company filed suit under 42 U.S.C. 1983 against two employees of the Department (Hansen and Watkins), alleging violations of their due process rights. Plaintiffs argued, inter alia, that the Department failed to provide plaintiff with actual notice of her placement on the disqualification list and deprived all the plaintiffs of due process. The court could find no authority or "general constitutional rule" requiring Hansen and Watkins to provide plaintiff final oral notice or request written confirmation of her termination in addition to the notice and opportunity for hearing they had already provided. Therefore, the court concluded that placing plaintiff on the disqualification list was not a deprivation of due process rights. Accordingly, Hansen and Watkins were entitled to qualified immunity on the individual capacity claims against them. Plaintiff's remaining claim was without merit. The court affirmed the judgment of the district court. View "Foster, et al. v. MO Dept. of Health and Senior Servs., et al." on Justia Law

Plaintiff filed a civil rights action under federal and state law against members of the sheriff's office, including the arresting officer, after he was arrested on suspicion of violating a weapons possession statute. At issue on appeal was the district court's denial of the arresting officer's motion for summary judgment on plaintiff's false arrest claim. Under Arkansas Supreme Court precedent, a reasonable officer would understand a violation of Ark. Code Ann. 5-73-120(a) was predicated upon a person having "a purpose to employ the handgun, knife, or club as a weapon against a person." The court affirmed, agreeing with the district court that the arresting officer was not entitled to qualified immunity because there was a genuine issue of material fact as to whether he had probable cause to arrest plaintiff. View "Stoner v. Watlingten" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the Arkansas State Police and a state trooper, claiming that the trooper used excessive force when arresting him after a high-speed chase. The court affirmed the district court's grant of summary judgment to the Arkansas State Police on the basis of sovereign immunity. Plaintiff had no cognizable claim for prospective injunctive relief against the trooper in his official capacity and plaintiff's claim was barred on the basis of sovereign immunity. However, the court could not conclude that the trooper's use of force once out of view of the dash camera was objectively reasonable as a matter of law. Rather, a reasonable jury could find that the severity of plaintiff's injuries demonstrated excessive force, particularly the trooper's decision to strike defendant using a metal flashlight after plaintiff was already on the ground and allegedly complying with the trooper's demands. Accordingly, the court reversed the district court's grant of qualified immunity to the trooper and remanded for further proceedings. View "Coker v. Arkansas State Police, et al." on Justia Law

Plaintiff, the first African-American circuit court judge elected in Phillips County, Arkansas, filed suit under 42 U.S.C. 1983 against the commission and officials during the disciplinary proceedings against him. The district court denied plaintiff's request for a temporary restraining order and stayed proceedings in accordance with the Younger abstention doctrine. The state disciplinary proceedings ended with a decision by the Arkansas Supreme Court. The district court then granted the commission and officials' Rule 12(b) motion to dismiss, finding no justifiable federal controversy. The court concluded that Defendant Stewart, Executive Director of the commission, was entitled to absolute prosecutorial immunity as to plaintiff's claims for damages on the first cause of action; plaintiff had no justiciable claim for damages against any defendant in the second cause of action where plaintiff's allegations amounted to nothing more than a state law defamation claim and the district court did not abuse its discretion; and plaintiff's requests for declaratory and injunctive relief were moot. Accordingly, the court affirmed the judgment of the district court. View "Simes, II v. Arkansas Judicial D. & D. Comm, et al." on Justia Law

Plaintiff and his parents filed suit against the District alleging violations of section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794 and 794a, and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the District. The court affirmed the judgment of the district court because plaintiff failed to present evidence of bad faith or gross misjudgment by the District. View "B.M., et al. v. So. Callaway R-II School Dist." on Justia Law

After plaintiff was arrested on suspicion of passing a forged $100 bill, she sued two police officers under 42 U.S.C. 1983. Plaintiff alleged that the officers violated her Fourth Amendment right against arrest without probable cause. The court affirmed the district court's grant of summary judgment to the officers because, based on the totality of the circumstances, the officers had arguable probable cause to arrest plaintiff. The officers' conduct did not show plain incompetence or a knowing violation of the law. Accordingly, the officers were entitled to qualified immunity. View "Clayborn v. Struebing, et al." on Justia Law

After 15-year-old B.K. was barred from showing livestock at 4-H exhibitions, B.K.'s father filed suit under 42 U.S.C. 1983 against the unincorporated 4-H Association and two 4-H officials. The district court granted preliminary injunctive relief from the claimed denial of B.K.'s constitutional right to procedural due process. The court inferred that 4-H membership and participation was a "right or status" open to all South Dakota children interested in a career in agriculture, subject to reasonable, non-discriminatory terms; the record clearly demonstrated that the ban deprived B.K. of the opportunity to participate in a public program that was important to her education and career development and from which she obtained significant personal income; and, therefore, the district court did not abuse its discretion in concluding that B.K. had a fair chance of proving that defendants published a defamatory ruling that deprived her of a right or status conferred by state law and that she was entitled to the constitutional protection of the Due Process Clause. Further, B.K. was not afforded minimal procedural due process protection; there was a sufficient showing of the threat of irreparable injury; and the balance of the equities and the public interest supported the issuance of the injunction. Accordingly, the court affirmed the judgment of the district court. View "Kroupa v. Nielsen, et al." on Justia Law