Justia Civil Rights Opinion Summaries

Plaintiff filed suit against ATK and several of its employees for race, gender, and age discrimination after the company terminated her employment for elbowing another employee in the back. The district court granted summary judgment to defendants. The court concluded that plaintiff failed to establish a prima facie case of discrimination on the basis of any protected class status because she did not show that ATK treated any similarly situated employees in a disparate manner; plaintiff also did not establish a prima facie case by showing that ATK failed to follow its own policies when investigating the elbowing incident; and even assuming that plaintiff had established a prima facie case, ATK articulated a legitimate nondiscriminatory reason for firing her. Furthermore, the district court also correctly concluded that plaintiff's retaliation claim was not substantiated where she did not prove a causal connection between her follow up email and her termination. Accordingly, the court affirmed the judgment. View "Blackwell v. Baker" on Justia Law

Plaintiff filed suit against Brentwood after he was terminated, alleging race discrimination. A jury awarded plaintiff $1 in nominal damages. Plaintiff then sought equitable relief in the form of reinstatement and front pay. The court affirmed the district court's conclusion that reinstatement was neither possible nor practical where the jury made no findings as to whether plaintiff had in fact violated the safety rules or whether his plant manager's trust concerns were genuine, and that plaintiff had not presented sufficient evidence that he was entitled to front pay. View "Olivares v. Brentwood Indus." on Justia Law

Plaintiff, a financial advisor, filed suit for First Amendment retaliation, against Nebraska financial regulators after they investigated him and his broker-dealer employer around the time a newspaper reported plaintiff made unkind comments about the President of the United States. As a threshold matter, the court concluded that the remedy plaintiffs seeks - declaratory and injunctive relief - is the sort of prospective relief that can be sought in federal court from state officials sued in their official capacities, notwithstanding the state’s sovereign immunity, under Ex Parte Young; the state regulators’ voluntary cessation of their improper inquiries did not moot plaintiff’s case because the department still has regulatory authority over him and the state regulators’ assurances that they know better than to retaliate against him again are not enough to make it absolutely clear that the allegedly wrongful behavior could not reasonably be expected to recur; and the state regulators are mistaken that plaintiff’s requested injunction would be unenforceable and provide no relief. On the merits, the court applied a clear error standard of review and concluded that the district court did not clearly err in finding that even though the regulators targeted plaintiff partly in retaliation for his constitutionally protected political speech, they did not do enough to deter someone of ordinary firmness from continuing to speak. Therefore, plaintiff's claim failed and the court affirmed the judgment. View "Bennie, Jr. v. Munn" on Justia Law

Plaintiffs, two men previously arrested in Ramsey County, filed suit under 42 U.S.C. 1983, contending that the County's collection of all of a detained arrestee's cash upon booking and its related practices violated their Fourteenth Amendment rights. After collecting the cash, the county automatically deducts a $25 booking fee. The county later returns the arrestee’s remaining funds in the form of a prepaid debit card. Joining the Sixth Circuit, the court concluded that the private interest at stake is relatively modest and that the county's interest in collecting the fees at booking is substantial. The county's interest in upfront collection of this fee weighs more heavily than the relatively modest private interests of the arrestees. As written, this policy allows for the correction of any errors inherent in the overinclusive system of upfront collection. In this case, plaintiffs did not plead facts sufficient to establish that Ramsey County’s booking-fee policy fails to pass constitutional muster simply because it provides a post-deprivation remedy instead of a pre-deprivation hearing. The court rejected plaintiffs' contention that post-deprivation process simply cannot suffice. Therefore, the court affirmed the district court's judgment on the pleadings. View "Mickelson v. County of Ramsey" on Justia Law

Plaintiff, as personal representative for the Estate of Jeffry Alan Barton, filed suit under 42 U.S.C. 1983 and the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-105, alleging that Arkansas State Trooper Zachary Owens and other defendants denied Barton medical care, in violation of his Fourth, Eighth, and Fourteenth Amendment rights. The court held that the allegations in the complaint were sufficient to create an inference that Owens was deliberately indifferent to Barton’s need for medical attention; a reasonable officer in 2011 would have recognized that failing to seek medical care for an intoxicated arrestee who exhibits symptoms substantially more severe than ordinary intoxication violates the arrestee’s constitutional rights, all the more so when the surrounding circumstances indicate that a medical emergency exists; and therefore, a reasonable officer would have understood that he was violating Barton's clearly established constitutional rights. Therefore, the court affirmed the district court's denial of qualified immunity to Owens. Likewise, the court also concluded that the complaint alleges facts sufficient to create an inference of malice. Thus, Owens is not entitled to statutory immunity under the ACRA. The court affirmed the judgment. View "Barton v. Owens" on Justia Law

Plaintiff filed suit against the MPRB and the superintendent of the MPRB, asserting claims under 42 U.S.C. 1983 for violations of her First Amendment and equal protection rights, as well as for reprisal and aiding and abetting race and color discrimination under state law. The district court granted in part defendants’ motion for summary judgment and declined to exercise jurisdiction over the remaining state law claims. Plaintiff asserts that the negative performance evaluation, suspensions and write-ups, a performance improvement plan, and refusal to promote her constituted adverse employment actions. Performance ratings that have a negative impact on promotion potential do not constitute an adverse employment action unless the rating actually led to the denial of the promotion. In this case, plaintiff has not offered any evidence that defendants would have chosen her for a promotion absent the comments at issue. The court found that plaintiff has not presented any evidence that the performance evaluations were actually used in the promotion decision or that the comments regarding plaintiff’s protected speech negatively influenced the decision. Furthermore, defendants have proffered non-retaliatory reasons for the alleged adverse employment actions, including plaintiff’s failure to reprimand subordinates appropriately. The court also concluded that the state law claims belongs in state court and the district court did not abuse its discretion in declining to exercise supplemental jurisdiction of the claims. Accordingly, the court affirmed the judgment. View "Wilson v. Miller" on Justia Law

Plaintiff, a citizen and political activist, filed suit against the Township and its clerk, alleging violations of his Minnesota and federal constitutional rights and unlawful retaliation. The district court dismissed the suit. Plaintiff alleged that the Township targeted him specifically and prevented him from viewing and photocopying the type of documents generally available to the public. The court concluded that plaintiff has no cause of action under the Minnesota Constitution because there is no private cause of action for violations of the Minnesota Constitution. Furthermore, the Township did not "create" a common law right by allowing plaintiff and others some access to documents. The court also concluded that plaintiff's First Amendment claim was properly dismissed because the Township did not create a First Amendment right to access all information simply by allowing plaintiff and other members of the public some access to its documents. Finally, plaintiff has failed to show any chilling effect on his constitutional rights, and plaintiff did not engage in protected activity by filing the lawsuit and his claim of retaliation fails. Accordingly, the court affirmed the judgment. View "Eggenberger v. West Albany Township" on Justia Law

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law

Nikko Jenkins killed four people, including Curtis Bradford, three weeks after he was released from prison after serving ten and a half years of a twenty-one year sentence. Plaintiff, Bradford's mother, filed suit under 42 U.S.C. 1981, 1983, and 1988 and state law against the State and the Department of Corrections, and department officials. Plaintiff also filed suit against the county, the city, and CCS. Plaintiff alleged violation of Bradford’s substantive due process rights under the Fourteenth Amendment and state law negligence claims under the Nebraska State Tort Claims Act (STCA), Neb. Rev. Stat. 81-8,209 et seq. The district court granted defendants' motions to dismiss. The court affirmed the district court's dismissal of plaintiff's claims against the city, the county, and CCS because her claims are forfeited. The court also concluded that the district court did not err by dismissing plaintiff's section 1983 claims against the department officials in their individual capacities because there is no general substantive due process right to be protected against the release of criminals from confinement, even if that release violates state law, and the two exceptions to this rule are not applicable in this instance: first, no special relationship exists between the victim and Jenkins; and the state-created exception is inapplicable because Bradford was not a member of a limited, precisely definable group. Finally, plaintiff has forfeited any challenge to the district court's ruling dismissing her state law claims. Accordingly, the court affirmed the judgment in its entirety. View "Glasgow v. Nebraska" on Justia Law

Nikko Jenkins killed four people, including Andrea Kruger, three weeks after he was released from prison after serving ten and a half years of a twenty-one year sentence. Plaintiff, Andrea's husband, filed suit against defendants, alleging deliberate indifference, violation of Andrea’s substantive due process rights under the Fourteenth Amendment, 42 U.S.C. 1983, 1988(a), and state law negligence claims under the Nebraska State Tort Claims Act (STCA), Neb. Rev. Stat. 81-8, 209 et seq. The district court granted the state and department officials' motion to dismiss. Rejecting plaintiff's waiver argument, the court concluded that there is no general substantive due process right to be protected against the release of criminals from confinement, even if that release violates state law, and the two exceptions to this rule are not applicable in this instance: first, no special relationship exists between the victim and Jenkins; and the state-created exception is inapplicable because Andrea was not a member of a limited, precisely definable group. The court also concluded that the district court correctly dismissed the state law claims against the department officials in their individual capacities because the department officials’ actions were taken while they were acting in the scope of their employment; state law claims against the department officials in their official capacities were properly dismissed where the discretionary function exception applied to the department officials' calculation of Jenkins's release date; plaintiff's claim of arithmetic error was not properly pled; the decision not to seek a civil commitment was also a discretionary function; and any mandatory duty to turn over documents was not properly pled. Accordingly, the court affirmed the judgment. View "Kruger v. Nebraska" on Justia Law