Justia Civil Rights Opinion Summaries

Plaintiff, a medical doctor certified in internal medicine, filed suit against Mayo after he was terminated. The court concluded that the district court properly dismissed plaintiff's claim under Minnesota's Vulnerable Victims Act, Minn. Stat. 626.557, subdiv. 3(a), where plaintiff failed to report the violations at issue and his conclusory allegations do not show compliance with the internal reporting procedure; the district court properly dismissed plaintiff's defamation claim where Mayo's motive and occasion for making the allegedly defamatory statements were proper and the criticisms were based on reasonable care; the court rejected plaintiff's Emergency Medical Treatment and Active Labor Act (EMTALA), 42 U.S.C. 1395dd(b)(1), claim because EMTALA claims do not apply to patients who are stabilized, and plaintiff had already stated that the patient at issue had been stabilized; assuming without deciding plaintiff established prima facie cases under the Minnesota Whistleblower Act, Minn. Stat. 181.932, subdiv. 1, and EMTALA or that he engaged in protected conduct under the False Claims Act, 31 U.S.C. 3730(h), Mayo established legitimate non-discriminatory grounds for the termination and plaintiff failed to establish that his employment termination was pretext for retaliation or motivated solely by his reports of Minnesota Whistleblower Act, EMTALA, or False Claims Act violations; and the district court did not abuse its discretion in denying plaintiff's motion for reconsideration of the district court's order striking his overlength 51-page declaration, and in denying plaintiff's Rule 56(d) motion to defer summary judgment for additional discovery. Accordingly, the court affirmed the judgment. View "Alaa E. Elkharwily, M.D. v. Mayo Holding Co." on Justia Law

Plaintiff filed suit against various municipalities and their employees under the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2721-25, alleging that these employees had improperly accessed her personal data on different occasions. On appeal, defendants that were denied qualified immunity challenged the district court's judgment. The court concluded that defendants' entitlement to sovereign immunity hinges on factual questions regarding the circumstances under which they accessed plaintiff's personal information. The record does not foreclose the possibility that the officers accessed plaintiff's data for a purpose not permitted by the DPPA. Therefore, the court lacked jurisdiction to reassess this factual dispute in the context of an interlocutory appeal. Accordingly, the court dismissed the appeal. View "Mallak v. Runde" on Justia Law

The Estate of Robert Jason Johnson, who was killed in a motorcycle and car accident, filed suit against the St. Louis Board of Police, various police board officials, and three police officers, alleging civil rights violations stemming from the police’s handling of the accident. The district court dismissed the police board and the police board officials from the case and granted summary judgment in favor of the three police officer defendants. The court concluded that, because the record contains no evidence that defendants materially falsified the accident report or failed to conduct a constitutionally-required investigation, the district court properly granted summary judgment to defendants on the substantive due process claim. The court's conclusion that the accident report was not materially false is also sufficient to dispose of the estate’s claims for violation of the Equal Protection Clause and conspiracy to violate civil rights. Finally, the district court did not abuse its discretion in denying the motion for sanctions where the district court viewed both parties partially at fault, and considered the dispute at issue to be a scheduling matter better resolved by the parties themselves than by the court. Accordingly, the court affirmed the judgment. View "A.J. v. Tanksley" on Justia Law

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