Justia Civil Rights Opinion Summaries

A detainee at the St. Louis County jail, Jovon Mitchell, developed severe symptoms including vomiting, a severe headache, dizziness, difficulty standing and walking, and slurred speech over the course of December 23–25, 2019. Various jail nurses and staff responded to his complaints with minimal or delayed medical care, despite jail policies requiring prompt attention for such symptoms. Jovon was ultimately found unresponsive and died from a stroke after being transferred to a hospital. His brother, Juan Mitchell, filed suit under 42 U.S.C. § 1983, alleging deliberate indifference to Jovon’s serious medical needs by individual medical staff and correctional officers, as well as failure-to-train and unconstitutional policy claims against supervisory staff and St. Louis County. State law claims were also asserted.The United States District Court for the Eastern District of Missouri granted the defendants' motions to dismiss the federal claims for failure to state a claim and declined to exercise supplemental jurisdiction over the state law claims, thereby dismissing them as well. The district court did not address the issue of qualified immunity. Juan Mitchell appealed the dismissal as to certain defendants.The United States Court of Appeals for the Eighth Circuit held that the complaint plausibly alleged deliberate indifference to Jovon’s serious medical needs by three nurses, but not by the physician assistant or correctional officers involved. The Court also found that the failure-to-train claim against St. Louis County was plausibly stated but concluded that the claims against the individual supervisors did not sufficiently allege notice of a pattern of unconstitutional acts. The Court affirmed the dismissal in part and reversed in part, remanding for further proceedings. The Court instructed the district court to exercise supplemental jurisdiction over the state law claims, given the reinstatement of certain federal claims. View "Mitchell v. Saint Louis County" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

The plaintiff, a black woman, worked as a Supervisory Medical Support Assistant at the Kansas City Veterans Administration (KCVA). After her supervisor, Angela Frey, was hired, the plaintiff alleged that Frey harassed her from the outset. The plaintiff was eventually assigned to a different position outside her original office and retired from the KCVA over a year later. She claimed that Frey discriminated against her based on race, retaliated against her for complaining about racial discrimination, created a racially hostile work environment, and constructively discharged her.The United States District Court for the Western District of Missouri granted summary judgment in favor of the KCVA. The district court found that the plaintiff’s allegations regarding denial of training, a negative performance review leading to reassignment, and interference with a job application in Florida were either too vague, unsupported by evidence, or based on inadmissible hearsay. The court also determined that the plaintiff failed to provide evidence of discriminatory intent or a causal link between any protected activity and adverse employment actions. Additionally, the court concluded that the incidents described did not rise to the level of a hostile work environment or constructive discharge.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the grant of summary judgment. The Eighth Circuit held that the plaintiff failed to present sufficient evidence to support her claims of racial discrimination, retaliation, hostile work environment, or constructive discharge under Title VII. The court emphasized that speculation and conclusory statements were insufficient to create a genuine issue for trial and that the conduct alleged did not meet the legal threshold for actionable discrimination or harassment. The judgment of the district court was affirmed. View "Sherman v. Collins" on Justia Law

In the aftermath of protests in St. Louis following the acquittal of a police officer, two individuals attended a demonstration as legal observers. They remained off the interstate highway while protesters marched onto and blocked Interstate 64. After the protesters exited the highway, the observers and the group proceeded together onto Jefferson Avenue. Police, acting on orders to arrest those who had trespassed on the interstate, encircled and arrested the entire group, including the observers, despite their protests that they had not been on the highway. The observers were processed but never charged with any crime.The United States District Court for the Eastern District of Missouri dismissed claims against one officer for lack of timely notice and later granted summary judgment to the remaining officers and the City. The court found the officers were entitled to qualified immunity on the Fourth Amendment unlawful seizure claim, reasoning that it was not clearly established that arresting the observers under these circumstances violated the Constitution. The court also granted qualified immunity on the First Amendment claims, finding the officers had at least arguable probable cause and that the plaintiffs had not shown retaliatory motive. The court rejected the municipal liability claims as well. The plaintiffs appealed only the grant of summary judgment to the officers.The United States Court of Appeals for the Eighth Circuit affirmed. It held that, under precedent, officers had arguable probable cause to arrest the plaintiffs as part of a group that had trespassed, given the practical difficulties of distinguishing individuals in a mass protest. The court also held that the existence of arguable probable cause defeated the First Amendment retaliatory arrest claim. The court concluded that the officers were entitled to qualified immunity on all claims and affirmed the district court’s judgment. View "Kampas v. City of St. Louis, Missouri" on Justia Law

The plaintiff, who worked for a bank that operated a branch inside a public high school, was terminated from her employment after she publicly criticized the local school district’s mask mandate on social media and at school events. The bank’s operation at the school was part of a partnership in which the bank provided funds and services to the school district. The plaintiff’s children attended schools in the district, and she was active in school-related activities. After a series of confrontations and a critical Facebook post about a school board member, the school superintendent communicated with the bank’s branch manager, expressing disapproval of the plaintiff’s conduct and requesting that she be barred from school property. The bank subsequently suspended and then fired the plaintiff, citing her conduct and the school’s ban.The United States District Court for the District of Minnesota granted summary judgment to all defendants, finding that the plaintiff’s First Amendment rights were not violated and that there was insufficient evidence of a conspiracy or tortious interference. The court applied the Pickering balancing test, treating the plaintiff as a government contractor, and found no actionable retaliation. It also found no evidence of a meeting of the minds between the bank and the school district, and held that the superintendent and other officials were entitled to qualified immunity.The United States Court of Appeals for the Eighth Circuit reversed in part and affirmed in part. The court held that the plaintiff was not a government employee or contractor for First Amendment purposes and was entitled to ordinary citizen protections. It found that there was sufficient evidence for a jury to decide whether the superintendent, the bank, and the branch manager retaliated against the plaintiff for protected speech, and whether the superintendent tortiously interfered with her employment. However, the court affirmed summary judgment for the school board chair and the school district, finding insufficient evidence of their direct involvement or policy liability. The case was remanded for further proceedings. View "McNeally v. HomeTown Bank" on Justia Law

Raymond Thompson purchased a custom Harley Davidson motorcycle and paid off all liens, but after the sale, the seller, Nathan Rench, fraudulently obtained a duplicate title, preventing Thompson from registering the motorcycle. Later, two individuals claiming to act for Rench arrived at Thompson’s home with Manchester, Missouri police officers, seeking to recover the motorcycle. The officers, after verifying the duplicate title and registration in Rench’s name, allowed the individuals to take the motorcycle from Thompson’s fenced backyard. Thompson was not home at the time. The next day, after Thompson reported the motorcycle stolen and provided evidence of his ownership, the officers instructed Rench to return the motorcycle, but Rench refused. The motorcycle was eventually recovered after Rench’s arrest.Thompson filed a lawsuit in the United States District Court for the Eastern District of Missouri, alleging that the officers violated his Fourth Amendment rights by entering his property and allowing the removal of his motorcycle, and his Fourteenth Amendment due process rights. He also sought sanctions for the police department’s failure to preserve body and dash camera footage. The district court granted summary judgment to the officers on the basis of qualified immunity, denied Thompson’s motion for sanctions, and denied his motion for partial summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the officers did not violate a clearly established constitutional right by entering Thompson’s backyard or by allowing the motorcycle’s removal, as their actions were consistent with existing Eighth Circuit precedent regarding limited warrantless entries and peacekeeping roles. The court also found no evidence of joint action or coercion by the officers sufficient to establish state action for a due process claim. Finally, the court concluded that the district court did not abuse its discretion in denying sanctions, as Thompson failed to show prejudice from the loss of the recordings. View "Thompson v. Cockrell" on Justia Law

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law

Police officers in Bella Vista, Arkansas, responded to a home shared by the Welters and Hutchins families after a suspected drug overdose, where they found pills, including fentanyl, in areas accessible to children. A week later, another overdose occurred at the same residence, resulting in a fatality while children were present. Months later, officers discovered traces of THC in the home’s trash, and a subsequent search revealed marijuana and drug paraphernalia throughout the house, including a still-smoking bong. During an interview, one parent admitted that adults regularly smoked marijuana in the home, though they tried to keep the children out of the room. Police notified the Arkansas Department of Human Services about possible child endangerment. Shortly after, Detective Wilson and other officers took the minor children for forensic interviews without a warrant, over the parents’ objections, and warned the parents they would be arrested if they interfered. The children were later returned to their parents.The United States District Court for the Western District of Arkansas granted summary judgment to Detective Wilson on the parents’ Fourth Amendment claims, finding she was entitled to qualified immunity. The court determined that the parents had not alleged a violation of their own Fourth Amendment rights and that the claims on behalf of the children did not overcome qualified immunity. The parents appealed, focusing solely on the Fourth Amendment claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that Detective Wilson was entitled to qualified immunity because, under the totality of the circumstances, a reasonable officer could have believed there was reasonable suspicion that the children were in danger. The court also declined to adopt a new standard requiring probable cause and exigent circumstances for such removals, noting that existing precedent did not clearly establish such a right. View "Welter v. Wilson" on Justia Law