Justia Civil Rights Opinion Summaries

The case centers on Keith Carnes, who was convicted of first-degree murder and armed criminal action for the killing of Larry White in Kansas City, Missouri, in 2005. The prosecution relied primarily on eyewitness testimony from Lorianne Morrow and Wendy Lockett, which conflicted with physical evidence. Carnes was sentenced to life in prison and served eighteen years. In 2022, the Supreme Court of Missouri granted Carnes habeas relief, finding the state had violated Brady v. Maryland by failing to disclose material evidence, and Carnes was released. The state dismissed the charges.Carnes subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Missouri. He alleged that certain detectives and a prosecutor had violated his constitutional rights through the fabrication of evidence, suppression of exculpatory evidence, and a reckless investigation. He also brought claims for malicious prosecution and unlawful pretrial detention. The district court granted summary judgment for most defendants but denied summary judgment for Detectives Robert Blehm and Avery Williamson on the reckless investigation claim, and for Blehm on the suppression of evidence claim. Prosecutor Amy McGowan’s motion for summary judgment on qualified immunity, prosecutorial immunity, and official immunity was also denied.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment. The court held that a reasonable factfinder could determine the detectives acted recklessly by relying on witness testimony that contradicted physical evidence and by failing to pursue alternative suspects, thus violating Carnes’s right to fair criminal proceedings. It further held that Prosecutor McGowan was not entitled to absolute immunity or qualified immunity where a genuine dispute existed about whether she coerced a witness and suppressed evidence before probable cause. The court affirmed the district court’s denial of summary judgment. View "Carnes v. Blehm" on Justia Law

Minnesota State Troopers stopped Ricky Cobb, II during the early morning hours for driving without headlights. Shortly after the stop, Trooper Seide learned Cobb was wanted for a felony violation of a protective order. Seide, along with Trooper Londregan and another officer, received instructions from the Ramsey County Sheriff’s Office to arrest Cobb. When the troopers attempted to take Cobb into custody, he refused to exit his vehicle and shifted his car into drive, causing the vehicle to move forward with one trooper partially inside. In response, Trooper Londregan shot Cobb, who then drove a short distance before his car was stopped by the troopers. Cobb was removed from the vehicle and died at the scene.The United States District Court for the District of Minnesota reviewed the case after Nyra Miller-Fields, representing Cobb’s estate, brought a lawsuit under 42 U.S.C. § 1983. The suit alleged that the troopers’ actions constituted an unreasonable seizure and excessive force in violation of the Fourth and Fourteenth Amendments. The district court considered body and dash camera evidence and granted the troopers’ motion to dismiss on the basis of qualified immunity, concluding that the troopers’ conduct did not violate clearly established constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The court held that the troopers had reasonable suspicion to extend the stop and probable cause for Cobb’s arrest based on the protective order violation. It further held that the use of deadly force by Trooper Londregan did not violate a clearly established constitutional right in the specific context of this case, given the immediate risk to officer safety. The Eighth Circuit concluded that the troopers were entitled to qualified immunity and affirmed the dismissal of the claims. View "Miller-Fields v. Londregan" on Justia Law

The plaintiffs, a Black family residing in Nebraska, visited the Kiewit Luminarium, an institution operated by Omaha Discovery Trust. They paid the full admission price for entry in February 2024. The Luminarium had a policy granting free admission to registered members of federally recognized Native American tribes and their household members. After learning of this policy, the plaintiffs sought a refund for their tickets, which was denied. They then filed suit, alleging that the policy constituted unlawful racial discrimination in violation of federal civil rights statutes and the Nebraska Consumer Protection Act.The United States District Court for the District of Nebraska reviewed the complaint after the defendant moved to dismiss. The district court granted the motion to dismiss on all claims. It reasoned that the Luminarium’s policy distinguished based on tribal membership, which is a political classification rather than a racial one. As a result, the court concluded the plaintiffs failed to state a claim for race discrimination under the relevant federal statutes and that their Nebraska Consumer Protection Act claim failed for the same reason.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit affirmed the district court’s judgment. The appellate court held that membership in a federally recognized tribe is a political classification, not a racial one, relying on Supreme Court and circuit precedent. The court determined the plaintiffs did not plead facts showing they were discriminated against because of their race. Because their claims under 42 U.S.C. §§ 2000a, 2000a-2, 1981, and 1982, as well as under the Nebraska Consumer Protection Act, all depended on a showing of racial discrimination, the Eighth Circuit affirmed dismissal of all claims. View "Nare v. Omaha Discovery Trust" on Justia Law

Angela Prichard endured months of harassment and stalking from her ex-husband, Christopher, including threats, vandalism, and surveillance. Despite multiple reports to police and both temporary and permanent restraining orders—each of which mandated Christopher’s arrest for violations—law enforcement officers did not take significant protective action. After a period away from her home, Angela returned despite warnings from the Chief of Police. A week later, Christopher fatally shot her. He was subsequently convicted of her murder. Angela’s family, including her sons, then sued the City of Bellevue and three police officers, alleging that the failure to protect Angela violated federal constitutional rights and Iowa law.The United States District Court for the Northern District of Iowa dismissed the complaint, determining that neither federal nor Iowa law created a duty for law enforcement to protect Angela from private violence under these circumstances. The court also denied the family’s post-judgment motion to amend their complaint, finding it was untimely and would have been futile because the proposed amendments did not present sufficient factual matter to plausibly state a claim.Reviewing the case, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that substantive due process under the United States Constitution does not impose an affirmative duty on the government to protect individuals from private violence, consistent with the Supreme Court’s decision in DeShaney v. Winnebago County Department of Social Services. The court also concluded that Iowa’s no-contact order statute does not create a private right of action against law enforcement for failing to enforce such orders. The court further rejected the family’s other state law claims, including those brought under the Iowa Slayer Statute and for intentional infliction of emotional distress, finding the facts alleged did not support those causes of action. The court found no abuse of discretion in denying leave to amend the complaint. View "Close v. City of Bellevue Iowa" on Justia Law

During protests opposing the Dakota Access Pipeline in November 2016, Sophia Wilansky was severely injured when police fired an aerial warning munition that struck her arm. Earlier that night, officers had ordered Wilansky and another protester to disperse from a barricade on a closed bridge, warning that they would use less-lethal munitions if the order was ignored. When Wilansky and the other protester did not comply, officers fired various less-lethal munitions. After Wilansky began retreating, she was struck by the aerial munition, causing permanent injury to her left hand and forearm.Following the incident, Wilansky filed two lawsuits in the United States District Court for the District of North Dakota. She alleged, under 42 U.S.C. § 1983, that county and state officers used excessive force in violation of the Fourth and Fourteenth Amendments and that Morton County maintained unconstitutional policies or customs. During the litigation, the district court struck certain new allegations and defendants from one complaint and ordered Wilansky to file an amended complaint. Wilansky then filed a second lawsuit with additional allegations against the stricken defendants. The district court ultimately dismissed both cases with prejudice.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgments. The court held that Wilansky did not sufficiently plead that the officers’ actions amounted to a clearly established Fourth Amendment seizure, nor did her allegations meet the “shocks the conscience” standard required for a Fourteenth Amendment claim. The court further held that she failed to establish a pattern of unconstitutional conduct by Morton County as of the date of her injury. Finally, the Eighth Circuit concluded that the district court did not abuse its discretion in dismissing the claims with prejudice. View "Wilansky v. Morton County, North Dakota" on Justia Law

A registered nurse developed a serious medical condition, Complex Regional Pain Syndrome, after a workplace injury while working for her employer. This condition caused chronic pain and other debilitating symptoms. In 2016, after her doctor advised that vaccines could aggravate her condition, her employer granted her a permanent medical exemption from certain vaccines. In 2021, she began working 100% remotely in a non-patient-facing role. Later that year, the employer instituted a mandatory COVID-19 vaccination policy, with exemptions available for medical reasons. She applied for a medical exemption, providing supporting documentation from her health providers, but her request was denied without explanation. Despite further communication and clarification of her remote work status, her employer maintained its denial and placed her on unpaid leave for noncompliance.The United States District Court for the District of Minnesota granted summary judgment for the employer. The district court concluded that compliance with the COVID-19 vaccination policy was an essential job function and that the requested exemption was not related to her disability. The court also found the employer had made a good faith effort to assist her in seeking an accommodation.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that there were genuine issues of material fact regarding whether the nurse was a qualified individual under the ADA, whether she suffered an adverse employment action because of her disability, and whether the employer failed to engage in the interactive process or provide a reasonable accommodation. The court clarified that exemptions from vaccination requirements are accommodations, not essential job functions, and that the employer did not meet its burden to show undue hardship in allowing her to continue remote work. The court remanded the case for further proceedings. View "Klimek v. CentraCare Health System" on Justia Law

While incarcerated at a Missouri correctional center, Corey Coffelt exhibited significant mental health challenges, including diagnoses of substance-induced mood disorder with psychosis and a history of suicide attempts. Despite being prescribed psychiatric medications, Coffelt’s medication administration was inconsistent in the weeks preceding his death. On February 4, 2022, Coffelt was placed in administrative segregation, partly for safety concerns. Although his mental health conditions were noted, a nurse practitioner determined suicide watch was not necessary. Two days later, Coffelt died by suicide in his segregation cell. The corrections officers on duty were responsible for conducting visual checks per facility policy, but Coffelt was found deceased approximately an hour after he was last seen alive.In the United States District Court for the Eastern District of Missouri, Coffelt’s parents brought state wrongful death and federal civil rights claims against several corrections officers. The officers moved to dismiss, asserting official immunity on the state claim and qualified immunity on the federal deliberate indifference claim. The district court denied the motions, finding that the complaint plausibly alleged a ministerial duty under facility policy for the wrongful death claim and sufficient facts for the § 1983 deliberate indifference claim, allowing both to proceed.The United States Court of Appeals for the Eighth Circuit reviewed the denial of immunity de novo. It held that the cell check policy required some officer discretion and was not a purely ministerial duty; therefore, official immunity barred the state wrongful death claim. Regarding the § 1983 claim, the court concluded that the complaint did not sufficiently allege the officers had actual knowledge of a substantial suicide risk or acted with deliberate indifference. The Eighth Circuit reversed the district court’s denial of both official and qualified immunity and remanded the case for further proceedings. View "Headley v. Ognenovski" on Justia Law

In the early morning hours of March 11, 2019, a police officer in Siloam Springs, Arkansas, stopped Christopher Lockhart, a licensed bail bondsman and private investigator, after observing Lockhart’s vehicle touch the centerline while driving below the speed limit. During the stop, the officer noted Lockhart’s slow and slurred speech, bloodshot and glassy eyes, droopy eyelids, and apparent confusion. Lockhart performed poorly on field sobriety tests and admitted to recent use of prescription pain medication. Although a subsequent blood test showed no alcohol, and a Drug Recognition Expert concluded Lockhart was not impaired but rather had medical issues, the officer arrested him for driving while intoxicated (“DWI”) and related offenses. The charges were later dismissed, and Lockhart was found not guilty on the DWI charge after no evidence was presented at trial.Lockhart filed suit in the United States District Court for the Western District of Arkansas against the City of Siloam Springs and several employees, asserting constitutional and state law claims, including false arrest and malicious prosecution. The district court granted summary judgment on most claims but allowed the false arrest claim against the officer and the malicious prosecution claim against the city to proceed. On a previous appeal, the United States Court of Appeals for the Eighth Circuit upheld the denial of summary judgment for the malicious prosecution claim but reversed as to the Fourth Amendment claim, remanding for further consideration of whether probable cause supported the arrest.In the current appeal, the United States Court of Appeals for the Eighth Circuit held that Officer Ware was entitled to qualified immunity on the false arrest claim because, under the undisputed facts, he had probable cause to arrest Lockhart for DWI. The court reversed the denial of summary judgment for the officer, remanded for entry of judgment in his favor, and dismissed the city’s appeal on the malicious prosecution claim, declining to revisit its prior decision. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

While detained at the McLean County Detention Center, Dirk Alan Christianson developed a severe leg infection that ultimately resulted in the amputation of his leg above the knee. During his incarceration, Christianson sought medical attention several times and was treated both within and outside the jail, including being evaluated by a jail nurse and a family nurse practitioner. After displaying symptoms such as fever and pain, Christianson was transported to an outside clinic where he was evaluated, tested, and given instructions for follow-up. His condition deteriorated over the next several days, leading to hospitalization, a diagnosis of necrotizing fasciitis, and amputation.Christianson brought suit in the United States District Court for the District of North Dakota against McLean County, jail officials, medical staff, and the outside clinic, asserting claims under 42 U.S.C. § 1983 for deliberate indifference to serious medical needs, Monell municipal liability, and state law medical malpractice. The district court dismissed the Monell and medical malpractice claims, granted summary judgment to all defendants on the deliberate indifference claims, and denied Christianson’s motion to amend his complaint to identify and add John Doe defendants.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that Christianson failed to allege facts sufficient to support municipal liability under Monell, as the complaint did not set forth a specific policy or widespread custom causing constitutional harm. The court also determined that the evidence did not support claims of deliberate indifference by the sheriff, jail nurse, or family nurse practitioner, finding no facts showing that these individuals knew of and disregarded a serious medical need. Additionally, the court ruled that Christianson’s motion to amend was untimely and properly denied, and that dismissal of the John Doe defendants was appropriate. Finally, the court affirmed dismissal of the state law medical malpractice claim, concluding that the required expert affidavit was not timely served. View "Christianson v. McLean County" on Justia Law

A police officer in Williston, North Dakota, stopped a driver after observing an illegal turn late at night on New Year’s Eve. Noticing signs of alcohol intoxication, the officer conducted field-sobriety tests. During a subsequent interaction, the driver became argumentative and declined to answer whether he would agree to an additional alcohol screening. At that point, according to the complaint, the officers forcefully grabbed the driver without warning, commanded him to put his hands behind his back, and—assisted by a second officer—took him to the ground and handcuffed him. The driver alleges he suffered physical injuries and emotional harm as a result and sued both officers for using excessive force in violation of his Fourth Amendment rights.The United States District Court for the District of North Dakota granted the officers’ motion to dismiss, holding that their use of force was de minimis and, in the alternative, that it was objectively reasonable. The district court relied on dash-camera and body-camera footage, finding the videos consistent with the pleadings.Reviewing the case on appeal, the United States Court of Appeals for the Eighth Circuit applied a de novo standard to the motion to dismiss. The appellate court found that the video evidence did not conclusively contradict the plaintiff’s allegations regarding the severity of force or the absence of resistance. The court further held that, under clearly established law, force is least justified against nonviolent misdemeanants who do not actively resist arrest or pose a threat. Since the complaint alleged facts that, if true, would constitute a violation of clearly established rights, and the video evidence did not refute those allegations, the Eighth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Young v. Keyes" on Justia Law