Justia Civil Rights Opinion Summaries

Plaintiff, a member of the Westboro Baptist Church, filed suit in 2006 against Missouri state and state officials after the Missouri General Assembly enacted statewide restrictions on pickets and protests near funerals and funeral processions. In 2014, Missouri appealed the statute at issue while plaintiff's Rule 59(e) motion remained pending in district court. In this appeal, plaintiff challenged the district court's adverse judgments on her due process claim as well as the court's award of attorneys' fees. The court vacated the district court's judgment on the due process claim and remanded with instructions to dismiss her claim as moot. In regard to the attorneys' fees, the court concluded that the district court's 2/14th calculation was an abuse of discretion because its arithmetically simplistic fee calculation did not accurately reflect her degree of success of her interrelated claims. Moreover, even if the court accepted the district court's basic mathematical approach, its 2/14th calculation is inaccurate because it did not address whether it counted consent judgments, mooted claims, and dismissed claims as prevailing, neutral, or unsuccessful claims. Accordingly, the court reversed the district court's award of attorneys' fees. View "Phelps-Roper v. Koster" on Justia Law

This case stemmed from a government investigation of Mountain Pure's bottling facility. Mountain Pure and its employees filed suit against defendants, government agents, under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging violations of their Fourth Amendment rights. The district court granted summary judgment for defendants. The court concluded that the district court did not err in granting Defendants Roberts and Spradlin summary judgment on Mountain Pure's excessive force claim, nor did the district court err in granting the agents summary judgment on Mountain Pure's claim alleging unlawful seizure of its property. In regard to the individual employees' arguments that the district court erred in granting summary judgment against them on their claims alleging unlawful detention, unlawful seizure of their property, and excessive force, the court concluded that: the detention of the employees during the execution of the search warrant was reasonable where detaining the employees prevented them from fleeing in the event that incriminating evidence was found and ensured that they would be present to assist with the completion of the search such as by opening locked file cabinets to avoid the use of force, and detention of the employees in the break room was not particularly intrusive; the length of the detentions here was reasonable given that the search took nearly twelve hours and the government had a legitimate interest in detaining the employees during the search; the employees' argument that qualified immunity should not apply in Roberts' and Spradlin's case is rejected where there is no evidence showing that the interrogations at issue prolonged the employees' detentions beyond a reasonable time; Roberts and Spradlin did not act unreasonably in detaining them incommunicado by denying them access to telephones; the district court did not err in concluding that qualified immunity barred the employees' claims alleging an unlawful seizure of their property; and the district court did not err in granting summary judgment for Roberts and Spradlin on Bush, Morgan, and Stacks' excessive force claims. Accordingly, the court affirmed the judgment. View "Mountain Pure v. Roberts" on Justia Law

Plaintiff, an inmate at USMCFP, filed suit alleging that defendant was deliberately indifferent to his serious medical needs by failing to respond in a timely manner when the artery comprising his dialysis access port ruptured. The court affirmed the district court's grant of summary judgment to defendant on plaintiff's deliberate indifference claim where plaintiff provided no evidence showing that any delay in treatment had a detrimental effect; the district court did not err in denying plaintiff additional time for discovery; and the district court did not err in denying plaintiff's motion for leave to amend his complaint because amendment would be futile. Accordingly, the court affirmed the judgment in its entirety. View "Jackson v. Riebold" on Justia Law

Higgins and the Union filed suit under 42 U.S.C. 1983 and Missouri law against the District, alleging violations of the United States and Missouri Constitutions and state law. The district court dismissed the federal claims under Rule 12(b)(6) and declined to exercise jurisdiction as to the state law claims. The court concluded that the Union does not have standing in this case to pursue its claims on behalf of its members. In regard to Higgins, the court concluded that Higgins failed to state an equal protection claim where the District explicitly reserved the right to award the contract at issue in its best interest, and to select a bidder other than the lowest. The court also concluded that Higgins failed to state a claim for deprivation of due process where, under Missouri law, an unsuccessful bidder obtains no property right in the award of a construction contract, and Higgins failed to state a violation of the First Amendment where it does not provide any plausible account of how the District interfered with Higgins's ability to associate with the Union or with its employees who are members of the Union. Accordingly, the court affirmed the judgment. View "Higgins Electric, Inc. v. O'Fallon Fire Protection Dist." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and 1985 against the City, code inspector Peterson, and chief code inspector Denker, and various other defendants, alleging federal and state constitutional violations, and that defendants conspired to deter her from seeking judicial relief from their conduct and to deprive her of equal protection of the law and equal privileges and immunities under the law. The district court granted defendants' motion to dismiss. The court concluded that plaintiff's allegations of sexual harassment against Peterson failed to state a claim of municipal liability under section 1983; plaintiff failed to state a claim with respect to the alleged actions of Denker and the unidentified Jane and John Does - either in connection with her sexual harassment claim against Petersen or as an independent claim that these defendants violated her federally protected rights; and plaintiff failed to state a claim independent of Petersen’s alleged sexual harassment. Because plaintiff’s complaint contained no facts showing that Denker or any unnamed City employee violated her constitutional rights, the court did not reach whether Denker, as chief code inspector, was a policymaking official or whether his role in the alleged conduct permits an inference that the City adopted a policy targeting plaintiff. Further, plaintiff failed to allege a conspiracy under section 1985 because the City could not conspire with itself through its agents acting within the scope of their employment. Accordingly, the court affirmed the judgment. View "Kelly v. City of Omaha" on Justia Law

Plaintiff filed suit against defendants, alleging employment discrimination and retaliation in violation of federal laws. The district court granted summary judgment in favor of defendants. The court agreed with the district court that plaintiff's failure to disclose her claims in her Chapter 13 bankruptcy proceedings judicially estopped her from pursuing them. Accordingly, the court affirmed the judgment. View "Van Horn v. Martin" on Justia Law

Plaintiff filed suit against defendants under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; 42 U.S.C. 1981, 1983; and state law. On appeal, plaintiff challenged the dismissal of his retaliation claim. Because the court can resolve this appeal on other grounds, the court left for another day whether a defense based on a failure to exhaust administrative remedies may effectively be waived. On the merits, the court agreed with the district court that plaintiff has failed to establish direct evidence of retaliation. Under the McDonnell Douglas framework, the court concluded that plaintiff failed to demonstrate that the reasons given for his termination were pretextual. In this case, plaintiff failed to identify any causal connection between his desire to promote an African American staff member and his termination, and had therefore failed to establish a prima facie case of retaliation. Plaintiff does not dispute that defendants offered a legitimate, non-discriminatory reason for his termination. Accordingly, the court affirmed the judgment. View "Hutton v. Maynard" on Justia Law

Demien, the unsuccessful bidder for the construction of a new firehouse, filed suit against the District under 42 U.S.C. 1983, alleging that the District violated federal and state constitutional rights, as well as state law, in the bidding process. The district court dismissed the complaint. The court concluded that it need only determine whether Damien has Article III standing under Federal law and not whether Damien has standing under Missouri law. Determining that Demien has Article III standing, the court concluded that Demien has abandoned its claims under the First Amendment by failing to argue them before the district court, and that Demien failed to allege that the District deprived Demien of any entitlement, and so it failed to state a claim under the Fourteenth Amendment Due Process Clause. The court concluded that, under Missouri law, there is no property right to the lowest bidder, and standing to bring a state court claim of deprivation of property rights does not establish a protected property interest. In this case, the District stated that it may accept the lowest bid, but does not need to. Accordingly, the court affirmed the judgment. View "Demien Construction Co. v. O'Fallon Fire Protection Dist." on Justia Law

Plaintiff, an inmate with PTSD, filed suit against defendants under 42 U.S.C. 1983, alleging violations of his constitutional rights because defendants were indifferent to his medical needs, and that defendants retaliated against him by transferring him to TSCI and by reclassifying him. In this interlocutory appeal, defendants challenged the district court's denial of summary judgment based on qualified immunity. In this case, the record shows that defendants met plaintiff's medical needs beyond the minimum standard required where they were aware of his medical needs and took steps to meet those needs. The court concluded that there was no deprivation of plaintiff's Eighth Amendment rights because plaintiff cannot show that defendants acted with deliberate indifference; plaintiff has no First Amendment claim because none of plaintiff's activities were protected and none of defendants' actions were retaliatory; and there is no cognizable Fourteenth Amendment claim because there has been no constitutional violation. Accordingly, the court reversed the judgment and dismissed the case. View "Saylor v. Randy Kohl, M.D." on Justia Law

Plaintiff, a white man, filed suit against officials of the St. Louis Police Department, alleging race discrimination and conspiracy to discriminate when an African-American woman was chosen for the position in which plaintiff applied. A jury found in favor of plaintiff on his claims against three of his superiors (Defendants Muxo, Harris, and Isom). Defendants appealed. The court concluded that materially different working conditions provided sufficient evidence to support the conclusion that plaintiff suffered an adverse employment action. Because there were “probative facts to support the verdict,” the district court did not err by denying defendants' motion for judgment as a matter of law on plaintiff’s discrimination claims. The court also concluded that a reasonable jury could find evidence of a conspiracy to deprive plaintiff of his constitutional claims. Accordingly, the court affirmed the judgment. View "Bonenberger v. St. Louis Metro. Police Dept." on Justia Law