Justia Civil Rights Opinion Summaries

Plaintiffs Tiffaney Whitt, on behalf of her minor children, and Jeremiah Parker, Whitt’s adult son, filed a lawsuit against Kearney School District and Durham School Services, L.P., due to racial harassment experienced by Parker and his siblings on a school bus operated by Durham. Plaintiffs alleged a 42 U.S.C. § 1981 claim against Durham, asserting they were third-party beneficiaries of the contract between Kearney and Durham, which required safe, harassment-free transportation.The United States District Court for the Western District of Missouri denied Durham’s motion to dismiss and motion for summary judgment, which challenged the validity of Plaintiffs’ § 1981 claim. Durham then filed a motion to compel arbitration based on an arbitration clause in its contract with Kearney. The district court denied this motion, concluding that Durham waived its right to enforce the arbitration clause by not raising it earlier in the litigation. Durham appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Durham knew of its right to arbitrate, as it possessed the contract containing the arbitration clause, and acted inconsistently with that right by engaging in extensive litigation and discovery before filing the motion to compel arbitration. The court also noted that the district court’s consideration of prejudice to Plaintiffs, although erroneous, did not affect the substantial rights of the parties. The appellate court rejected Durham’s argument that it could not have known to seek arbitration until the district court’s summary judgment ruling and found that Durham’s actions were inconsistent with preserving its right to arbitrate. The court also denied Plaintiffs’ request to adopt a process for certifying interlocutory appeals as frivolous and their request for costs under Fed. R. App. P. 38. View "Parker v. Durham School Services, L.P." on Justia Law

Dewey Austin Barnett, II, acting pro se, sued a Missouri county and a jail administrator, Brenda Short, alleging that they refused to allow him to have a Bible while he was in administrative segregation at the Jefferson County jail. Barnett claimed that the lack of a Bible caused him anxiety, stress, and depression, and led him to feel guilt and shame. He sought damages and injunctive relief. Barnett attached a grievance and a letter to his complaint, detailing his requests for a Bible and the jail's responses.The United States District Court for the Eastern District of Missouri dismissed Barnett's case. The court held that Barnett's RLUIPA claim could not succeed because RLUIPA does not permit plaintiffs to recover money damages, and his request for injunctive relief was moot due to his transfer to another facility. The court also dismissed Barnett's § 1983 claim, stating that he did not adequately plead Short's personal involvement in the decision to deprive him of his Bible and that the decision did not substantially burden his free exercise of religion. Additionally, the court dismissed the § 1983 claim against the county, explaining that Barnett failed to allege a policy of denying Bibles to inmates in administrative segregation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed in part and reversed in part. The court held that RLUIPA permits claims for damages against the county, as "appropriate relief" includes damages. However, the court concluded that RLUIPA does not allow claims for damages against individuals in their personal capacities. The court also found that Barnett sufficiently alleged Short's personal involvement and that the deprivation of a Bible for a month substantially burdened his religious exercise. The court remanded the case for further proceedings on the RLUIPA claim against the county and the § 1983 claim against Short. View "Barnett v. Short" on Justia Law

Jeremy Young was convicted by a jury of possessing an unregistered firearm and being a felon in possession of a firearm. He was also convicted by a separate jury of assaulting a federal officer. Young received a total sentence of 84 months’ imprisonment and 3 years of supervised release. He appealed, challenging the Government’s use of peremptory strikes against Native American venirepersons, the district court’s decision to admit certain evidence as res gestae, and the sufficiency of the evidence at both trials.The United States District Court for the District of South Dakota denied Young’s Batson challenges, finding the Government’s reasons for striking the Native American jurors to be legitimate and race-neutral. The court also admitted excerpts of Young’s recorded interview with Agent Kumley, where Young discussed his plans to transport methamphetamine, as relevant res gestae evidence. The jury found Young guilty on all counts.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court found no clear error in the district court’s Batson analysis, noting that the Government provided race-neutral reasons for striking the jurors and that Young failed to demonstrate pretext. The court also upheld the admission of the recorded interview, agreeing that it provided relevant context for Young’s possession of the shotgun. Finally, the court concluded that the evidence was sufficient to support Young’s convictions, as the jury reasonably found that Young had both actual and constructive possession of the firearm and that he intentionally assaulted Sergeant Antoine. View "United States v. Young" on Justia Law

Isak Aden's ex-girlfriend called 911 on July 2, 2019, reporting that Aden had pointed a gun at her and ordered her to drive. She escaped, and Aden fled into a wooded area. Officers found Aden holding a gun to his head and began negotiating with him. Despite multiple attempts to get him to surrender, Aden refused and moved closer to his gun. Officers devised a tactical plan involving flashbangs and foam bullets to disorient Aden and arrest him. When the plan was executed, Aden reached for his gun, and officers fired lethal rounds, resulting in his death.The United States District Court for the District of Minnesota partially denied the defendants' motion for summary judgment, finding that the officers were not entitled to qualified or official immunity and that the City of Eagan could be liable under Monell. The court dismissed some claims but allowed others to proceed, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the officers' actions were reasonable under the circumstances and that they did not violate Aden's constitutional rights. The court held that the officers were entitled to qualified immunity because their use of force was not excessive. The court also found that the City of Eagan was not subject to Monell liability because there was no constitutional violation by the officers. Additionally, the court held that the officers were entitled to official immunity under Minnesota law, and thus, the City of Eagan was also entitled to vicarious official immunity.The Eighth Circuit reversed the district court's partial denial of summary judgment and remanded the case for entry of summary judgment based on qualified and official immunity. View "Aden v. City of Eagan" on Justia Law

Betty Grooms, a Missouri clerk of court, filed a lawsuit under 42 U.S.C. § 1983 against Alice Bell and Judge Steven Privette, alleging violations of her First Amendment rights through discrimination and retaliation, and violations of her substantive due process rights. Grooms, a Republican, had defeated Bell, a Democrat, in an election for Circuit Clerk. Bell, who retained her job under Grooms, later married Privette, a Republican judge. Tensions arose when Bell and Privette were uncooperative with Grooms, leading to Bell's resignation and announcement to run for Circuit Clerk. Privette ordered Grooms to prepare detailed spreadsheets, which he repeatedly rejected, and initiated a contempt prosecution against her, which was eventually dismissed by the Missouri Supreme Court.The United States District Court for the Western District of Missouri dismissed Grooms's claims, ruling that the defendants did not violate her clearly established First Amendment rights and did not violate her substantive due process rights. The court found that the defendants' actions did not constitute adverse employment actions under clearly established law and that Grooms did not suffer a serious deprivation of a protected interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Bell and Privette were entitled to qualified immunity on the First Amendment claim, as Grooms failed to show that their actions constituted adverse employment actions under clearly established law. Additionally, the court found that Grooms's substantive due process claim was inadequate, as she did not demonstrate a serious deprivation of a protected interest. The court concluded that the defendants' conduct did not shock the conscience and did not violate Grooms's substantive due process rights. View "Grooms v. Privette" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

Plaintiff filed suit against an Arkansas state police officer, alleging that the officer used excessive force by pepper spraying and choking him in the course of arresting him for taking eight pairs of shorts from a department store. The district court denied the officer qualified immunity. The Eighth Circuit held that a jury could find that the officer used an unreasonable amount of force when he pepper sprayed plaintiff. In this case, the officer used force on a non-resisting, non-fleeing individual suspected of a completed, non-violent misdemeanor. The court explained that, while some use of force was reasonable here, it was not reasonable to immediately use significant force. The district court erred in concluding that plaintiff's right not to be pepper sprayed was clearly established. The court also held that defendant unreasonably used excessive force by choking plaintiff, and plaintiff's right to be free from such force was clearly established at the time. Therefore, the district court correctly denied qualified immunity on the chocking claim. The court affirmed in part, reversed in part, and remanded. View "Tatum v. Robinson" on Justia Law

The district court granted in part petitioner's motion to vacate his drug-related conviction and sentence under 28 U.S.C. 2255, based on ineffective assistance of counsel. The district court ordered the government to reoffer an earlier plea deal. The Eighth Circuit held that the district court clearly erred in finding that petitioner suffered from mental illness that impaired his ability to understand legal advice and make reasoned decisions; the district court erred in finding that counsel should have known that petitioner was not able to understand legal advice or make reasoned decisions; the district court's finding that counsel's communication style did not mesh well with petitioner's difficulties did not provide a basis for ineffective assistance of counsel; the district court did not err in finding counsel deficient in failing to explain the safety-valve exception; and the district court erred in directing the government to reoffer the five-year deal. Accordingly, the court vacated and remanded for the district court to determine whether petitioner was prejudiced by the safety-valve advice. View "Davis v. United States" on Justia Law

Petitioner appealed the denial of his 28 U.S.C. 2255 motion to vacate, set aside, or correct his criminal sentence. Petitioner was sentenced under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), based on predicate offenses for possession with intent to distribute crack cocaine and two Nebraska felony convictions for making terroristic threats (one as a juvenile and one as an adult). The Eighth Circuit affirmed and held that the Nebraska statute qualifies under the ACCA force clause; an act of juvenile delinquency cannot qualify as a violent felony under any clause of the ACCA, including the residual clause, unless the court first determines that it involved the use or carrying of a firearm, knife, or destructive device; that question is completely separate from the question of whether the juvenile conviction is an enumerated offense or qualifies under the force clause; the court sua sponte determined that petitioner's claim that his juvenile offense did not involve the use or carrying of a firearm, knife, or destructive device is procedurally defaulted; and even if the theoretical possibility exists that the Nebraska statute could encompass threats only to property, petitioner has not demonstrated a realistic probability that Nebraska would apply the statute in that manner. View "Fletcher v. United States" on Justia Law