Justia Civil Rights Opinion Summaries

Lamar Catchings, a 20-year-old pretrial detainee, died from undiagnosed acute leukemia while in custody at the St. Louis County Buzz Westfall Justice Center in February 2019. His mother, Tashonda Troupe, filed a 42 U.S.C. § 1983 lawsuit against St. Louis County and numerous jail officials, medical staff, and correctional officers, alleging deliberate indifference to her son’s serious medical needs and failure to train or supervise the staff responsible for his care.The United States District Court for the Eastern District of Missouri dismissed the claims against most defendants at the pleading stage, citing qualified immunity and insufficient factual allegations. The court found that many of Troupe’s allegations were based on “information and belief” and lacked specific factual support. The district court allowed the claim against defendant Anthony Young, a practical nurse, to proceed, but dismissed the claims against other defendants, including correctional officers and medical staff, for lack of sufficient allegations of personal involvement or knowledge of Catchings’s condition.The United States Court of Appeals for the Eighth Circuit reviewed the case and addressed whether Troupe’s “upon information and belief” allegations were sufficient to state a claim. The court held that such allegations are permissible if the facts are within the possession and control of the defendants or based on factual information that makes the inference of culpability plausible. The court found that Troupe’s allegations met this standard and reversed the district court’s dismissal of claims against certain defendants, including Swims, Beard, Oliver, Doucette, and Murphy. The court affirmed the dismissal of claims against Mohler and Williams and partially reversed the dismissal of claims against the County, allowing the failure-to-train-or-supervise claim to proceed. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Troupe v. St. Louis County, Missouri" on Justia Law

On September 1, 2016, law enforcement officers conducted narcotics raids at a home and shop in Pulaski County, Arkansas. During the raid, officers found contraband in both locations, and an officer shot and injured Lloyd St. Clair, who was holding a shotgun. Lloyd and other occupants of the home and shop filed a lawsuit under § 1983, alleging violations of their Fourth Amendment rights by the officers and the City of Little Rock.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The plaintiffs appealed the decision, arguing that there were genuine disputes of material fact regarding the existence of two separate search warrants and the justification for no-knock entries.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the record included two valid search warrants signed by a state judge, and there was no genuine dispute of material fact regarding their existence. The court also determined that the officers had reasonable suspicion to justify the no-knock entries based on videos of Amy St. Clair shooting firearms, which were seen by Officer Kalmer before the raids.Regarding Lloyd's excessive force claim, the court held that the use of deadly force by Officer Thomas was reasonable, as Lloyd admitted to pointing a gun at Thomas. The court also affirmed the district court's grant of summary judgment on the municipal liability claim, as there was no underlying constitutional violation by the city employees.The Eighth Circuit affirmed the judgment of the district court, upholding the summary judgment in favor of the defendants. View "Davenport v. City of Little Rock" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

Donterious Stephens was present when Officer Juanita Mills arrested his mother, Mary Stephens, at her workplace. Donterious approached the scene and asked Officer Mills why his mother was being arrested. Officer Mills warned him not to walk up on her, and Donterious complied by standing back. After Mary was placed in a police vehicle, Donterious's father, Warren Stephens, was also arrested. Donterious then spoke to Officer Mills again, and she ordered his arrest. Donterious was arrested but not charged. Mary Stephens and another plaintiff sued Officer Mills, alleging that Donterious's arrest was unlawful.The United States District Court for the Eastern District of Arkansas denied Officer Mills's motion for summary judgment based on qualified immunity, finding that there were genuine issues of material fact regarding whether Donterious's arrest was lawful. Officer Mills appealed this decision, arguing that the undisputed material evidence showed she did not violate Donterious's rights.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied the motion to dismiss the appeal for lack of jurisdiction. The court held that Officer Mills did not have actual or arguable probable cause to arrest Donterious for obstructing government operations. The court found that Donterious's mere presence at the arrest scene and his questioning of Officer Mills did not provide probable cause for his arrest. The court affirmed the district court's denial of summary judgment and qualified immunity for Officer Mills, concluding that Donterious's actions did not amount to obstruction under Arkansas law. View "Willis v. Mills" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

In 2015, Shirley Carter was found dead in her home from gunshot wounds. Jason Carter, her son, was later found civilly liable for her wrongful death. Following this, Iowa Division of Criminal Investigation Agent Mark Ludwick and Marion County Deputy Sheriff Reed Kious arrested Jason for first-degree murder. However, Jason was acquitted in a jury trial. Jason then filed a 42 U.S.C. § 1983 action against Ludwick and Kious, alleging violations of his constitutional and state-law rights during the investigation of his mother's murder.The United States District Court for the Southern District of Iowa dismissed Jason's complaint, granting Ludwick and Kious qualified immunity on all federal claims and ruling that Jason failed to state a claim for his state law claims. The court also dismissed Marion County from the suit, as Jason did not allege a pattern of unconstitutional conduct.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Ludwick and Kious were entitled to qualified immunity. The court found that Jason failed to plausibly allege a constitutional violation for false arrest, as the arrest was conducted pursuant to a facially valid warrant. The court also held that Jason's claim of evidence concealment did not constitute a clearly established constitutional violation. Additionally, the court ruled that Jason's failure-to-investigate claim did not meet the threshold for a substantive due process violation. The court also affirmed the dismissal of Jason's state law claims for malicious prosecution and abuse of process, noting the presence of probable cause and the lack of improper motive. View "Carter v. Ludwick" on Justia Law

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law

Petra Brokken sued her employer, Hennepin County, alleging religious discrimination under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), and wrongful discharge under Minnesota’s Refusal of Treatment statute. Brokken claimed that the County's Covid-19 vaccine and testing policy conflicted with her religious beliefs. After initially granting her a religious exemption, the County revised its policy, threatening termination and loss of accrued benefits if she did not comply. Brokken retired under duress and subsequently filed her lawsuit.The United States District Court for the District of Minnesota dismissed Brokken's claims. The court ruled that she failed to plead an adverse employment action, did not plausibly plead religious beliefs conflicting with the County’s policy, and that the MHRA does not provide a cause of action for failure to accommodate religious beliefs. Additionally, the court found that Minnesota’s Refusal of Treatment statute does not create a private right of action.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of the wrongful discharge claim under Minnesota’s Refusal of Treatment statute, agreeing that it does not create a private right of action. However, the court reversed the dismissal of Brokken’s Title VII and MHRA claims. The appellate court held that Brokken plausibly pled an adverse employment action and sufficiently alleged that her religious beliefs conflicted with the County’s policy. The court also recognized that the MHRA provides protection against failures to accommodate religious beliefs. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Brokken v. Hennepin County" on Justia Law

Clayton Stewart was involved in a police incident where Officer Victor Garcia of the Jonesboro, Arkansas police department tased him while he was climbing a fence. Stewart fell and was paralyzed as a result. Stewart filed a 42 U.S.C. § 1983 action against Garcia, Jonesboro Chief of Police Rick Elliot, and the City of Jonesboro, alleging violations of his Fourth and Fourteenth Amendment rights. The district court granted summary judgment in favor of the defendants on all claims, and Stewart appealed.The United States District Court for the Eastern District of Arkansas granted summary judgment to the defendants, finding no genuine disputes of material fact that would preclude summary judgment. Stewart argued that Garcia lacked probable cause to arrest him, used excessive force, and was deliberately indifferent to his medical needs. He also claimed that Elliot was liable as Garcia’s supervisor and that the police department’s policies were unconstitutional.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Garcia had at least arguable probable cause to arrest Stewart for misdemeanor assault and fleeing. Regarding the excessive force claim, the court found that while tasing Stewart in an elevated position could be considered deadly force, Stewart’s right to be free from such force was not clearly established at the time of the incident, entitling Garcia to qualified immunity. On the deliberate indifference claim, the court concluded that although a reasonable jury could find Garcia was aware of Stewart’s serious medical needs, Stewart failed to show that the right was clearly established, granting Garcia qualified immunity. The court also affirmed the dismissal of the supervisory liability claim against Elliot and the municipal liability claim against the City of Jonesboro, finding no evidence of a pattern of unconstitutional acts or inadequate policies. The Eighth Circuit affirmed the district court’s judgment in full. View "Stewart v. Garcia" on Justia Law