Justia Civil Rights Opinion Summaries

After plaintiff served 24 years in prison for murder, a Missouri court found that plaintiff's trial had been fundamentally unfair and ordered his release. Plaintiff then filed suit against the St. Louis Board of Police Commissioners and others, alleging, inter alia, that defendants recklessly or intentionally manipulated evidence and conducted suggestive identification procedures. The court concluded that the district court did not err in granting summary judgment on plaintiff's claims that defendants manipulated the investigation or evidence against him or deprived him of a fair trial; plaintiff had not adduced evidence to show that the identification procedure in this case was impermissibly suggestive and the circumstances of the photo identification procedure did not create a very substantial likelihood of irreparable misidentification; the court found no evidence to support a reasonable inference that any of the defendants conspired to frame plaintiff or otherwise deprive him of his constitutional rights; and plaintiff's Monell claims against the Board failed where none of the individual defendants were liable on plaintiff's 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "Burton v. St. Louis Board of Police, et al." on Justia Law

Plaintiff filed suit against the County and others after her son Johnny died from multiple drug intoxication while in the county jail. At issue on appeal was the district court's denial of qualified immunity on summary judgment for the law enforcement officials. The court concluded that Officer Furr did not have subjective knowledge that Johnny required medical attention and that Officer Furr was not deliberately indifferent to Johnny's medical needs. Accordingly, Officer Furr was entitled to qualified immunity. In regards to Officer King, the court concluded that a reasonable officer would have known that a constitutional violation occurred by deliberately disregarding Johnny's serious medical needs in the circumstances Officer King confronted. Accordingly, the district court properly denied Officer King qualified immunity because this constitutional right was clearly established. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Thompson v. King, et al." on Justia Law

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

Plaintiff, a self-described "professing Evangelical Christian," distributed Bibles at the Twin Cities Pride Festival for many years in an exhibitor's booth but in 2009, Twin Cities Pride denied plaintiff's application for a booth. On appeal, plaintiff challenged the district court's denial of his motion for a preliminary injunction against enforcement of a local regulation that restricted literature distribution in a public park during the Festival. The court concluded that plaintiff has shown a likelihood of success on his claim that the literature distribution regulation was not narrowly tailored to serve a significant governmental interest; plaintiff satisfied the irreparable harm requirement; the balance of the equities favored granting the injunction; and the injunction was in the public interest. Accordingly, the court reversed the district court's denial of plaintiff's motion for a preliminary injunction and remanded for further proceedings. View "Johnson v. Minneapolis Park and Rec. Bd." on Justia Law

Plaintiff filed suit under 1983 alleging that police officers violated his constitutional rights by arresting him in his home without first obtaining a warrant to do so. The court concluded that plaintiff demonstrated sufficient facts to show a violation of his Fourth Amendment right to be free from unreasonable searches and seizures; a reasonable officer would have known that at the time plaintiff tried to close the door, he stood within his home and thus could not be pulled therefrom and placed under arrest in the absence of exigent circumstances; and, therefore, the court affirmed the district court's order denying qualified immunity as to Defendant Shearer. The court dismissed for lack of jurisdiction plaintiff's cross appeal challenging the grant of qualified immunity as to Defendants Spiker and Bone where the district court has not issued a final decision and the collateral order doctrine did not apply when a party complains that the district court should not have granted summary judgment based on qualified immunity. View "Mitchell v. Shearrer" on Justia Law

Plaintiff filed suit against Trinity alleging wrongful termination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq.; the North Dakota whistleblower statute, N.D. Cent. Code 34-01-20(1); and N.D. Cent. Code 34-01-04 (the intimidation statute). On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Trinity and the denial of her motion for a default judgment. The court found no abuse of discretion in the district court's denial of plaintiff's motion for summary judgment or default judgment, which asked the court to grant a dispositive discovery sanction against Trinity for its willful pattern of action in failing to comply with the scheduling order. Plaintiff failed to advance any evidence indicating that Trinity did in fact replace plaintiff with someone substantially younger, that she was treated differently than any other similarly situated male employee, that plaintiff engaged in a protected activity under the whistleblower statute, and that there was a private right of action under the intimidation statute. Accordingly, the court affirmed the judgment of the district court. View "Holmes v. Trinity Health" on Justia Law

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law

Plaintiff, aged 76, filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq, and state law, contending that Securitas fired him because of his age. Plaintiff cited evidence that prior to his termination, Securitas supervisors showed age animus through negative comments regarding plaintiff's age. Plaintiff adduced enough evidence to raise genuine doubt as to the legitimacy of Securitas's motive, even if that evidence did not directly contradict or disprove Securitas's articulated reasons for its actions. Accordingly, the court reversed the district court's grant of summary judgment in favor of Securitas, concluding that there were genuine issues of material fact concerning pretext. View "Johnson v. Securitas Security Services" on Justia Law

Plaintiffs filed suit against the city alleging that the city's zoning scheme violated the First and Fourteenth Amendments. The court concluded that the zoning ordinances at issue were content-neutral, time, place and manner regulations subject to intermediate scrutiny; the zoning scheme was narrowly tailored to serve a substantial government interest; and there were reasonable alternative avenues in which plaintiffs could operate an adult entertainment business despite the zoning ordinances. Accordingly, the zoning ordinances did not violate plaintiffs' constitutional rights and the court affirmed the judgment of the district court. View "Peterson, et al. v. City of Florence" on Justia Law

Plaintiff filed suit under Titles I and V of the Americans With Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., against his employer and various state employees, alleging that defendants retaliated against him in response to a prior discrimination suit that he had filed against them. The court dismissed the appeal for lack of jurisdiction because sovereign immunity barred plaintiff's claims for money damages against defendants. View "Lors v. Dean, et al." on Justia Law