Justia Civil Rights Opinion Summaries

Plaintiff filed suit against his employer, Optomec, alleging that he was terminated on account of his age in violation of the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01 et seq. The court affirmed the district court's grant of summary judgment in favor of Optomec because plaintiff failed to establish a prima facie case of age discrimination. The court reasoned that, even if he had, there was insufficient evidence to suggest the lawful reason Optomec gave for its decision was pretext for an underlying unlawful motive. In this case, Optomec's reasons for firing plaintiff was that he lacked the skill set and potential Optomec wanted from lab technicians to account for the company's anticipated growth. Accordingly, the court affirmed the judgment. View "Nash v. Optomec, Inc." on Justia Law

Plaintiffs filed suit against the Minnesota Secretary of State and others, challenging a statute prohibiting the wearing of political insignia at a polling place, Minnesota Statute 211B.11. This court reversed the dismissal of plaintiffs' as-applied First Amendment claim in Minnesota Majority v. Mansky, 708 F.3d 1051, 1059 (8th Cir. 2013). The district court, on remand, granted summary judgment for defendants. The court concluded that the statute and Policy are viewpoint neutral and facially reasonable. The court noted that the statute and Policy prohibit more than election-related apparel. The court explained that, even if Tea Party apparel was not election-related, it was not unreasonable to prohibit it in a polling place. In order to ensure a neutral, influence-free polling place, all political material was banned. In this case, EIW offered nothing to rebut evidence that the Tea Party has recognizable political views. The court concluded that the district court properly granted summary judgment because no reasonable trier of fact could conclude that the statute and Policy as applied to EIW violated its First Amendment rights. Accordingly, the court affirmed the judgment. View "Minnesota Voters Alliance v. Mansky" on Justia Law

Plaintiff John Young and the Commission entered into a Prosecutor/County Lease Agreement covering plaintiff's office building. After the Commission passed an ordinance that mandated that every resident of the county be assigned a permanent 911 address, John and Georgetta Young filed suit alleging claims centered on their contention that defendants retaliated against them for their address complaints. On appeal, plaintiffs challenge the district court's holding that defendants were protected by legislative immunity or, in the alternative, by qualified immunity. The court concluded that the district court correctly ruled that the Commissioners were entitled to legislative immunity for denying plaintiff's budget request, terminating the Agreement, and ceasing the $350.00 monthly rental payments. Furthermore, the district court properly found that the Commissioners are entitled to qualified immunity as to their request that the state attorney general review the legality of the Agreement. Accordingly, the court affirmed the district court's grant of summary judgment for the Commissioners. View "Young v. Mercer County Commission" on Justia Law

Ramon Mendoza, a naturalized United States citizen, challenged the district court's grant of summary judgment for ICE agent Justin Osterberg, the County, the County employees, and Sheriff Davis on numerous claims based on an improper immigration detainer that was issued and later withdrawn. The detainer was withdrawn once Osterberg confirmed that Mendoza was not in fact Ramon Mendoza-Gutierrez, an aggravated felon. The court concluded that Osterberg had arguable probable cause to issue the ICE detainer and was entitled to qualified immunity on plaintiff's Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics claim; the sheriff was entitled to qualified immunity because he had no direct participation in the alleged violations; there was no violation of Mendoza's constitutional rights and the County employees are entitled to qualified immunity; the district court properly granted summary judgment for Sheriff Davis and the County on plaintiff's claims of supervisory and municipal liability under 42 U.S.C. 1983 where employees received instructive memorandum and on-the-job training; the actions in this case cannot reasonably be attributed to a defective governmental policy or custom; even if there were no policies or training on how to handle ICE detainers, there was no constitutional violation; there was no Fifth Amendment due process violation; and there was no evidence of defendants' conspiracy in violation of section 1984(3). Accordingly, the court affirmed the judgment. View "Mendoza v. Davis" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging violations of his constitutional and statutory rights by defendants. Plaintiff also sought certification of a class action suit against the United States Attorney General on behalf of African-Americans in Arkansas subjected to equal protection and due process violations. The district court granted summary judgment in favor of defendants. Plaintiff alleged that the AG Defendants violated his due process rights when they accessed his sealed trial records. The district court concluded, however, that none of the actions taken by the AG Defendants amount to a brutal abuse of power. In this case, the AG Defendants acted reasonably, particularly in light of Arkansas caselaw allowing the use of expunged records to impeach testimony when the actual innocence of the witness has not been shown. Because the AG Defendants' conduct failed to shock the conscience, no substantive due process violation occurred. Furthermore, because plaintiff had no state-created liberty interest created by the Arkansas expungement statute for the AG Defendants to violate, the AG Defendants were entitled to qualified immunity on the procedural due process claim. The court rejected plaintiff's defamation claim against Attorney General McDaniel because he is entitled to absolute legislative immunity. Finally, plaintiff's Brady v. Maryland claims, brought under 42 U.S.C. 1983, are time-barred. Accordingly, the court affirmed the judgment. View "Buckley v. Ray" on Justia Law

After the Iowa State University (ISU) student chapter of the National Organization for the Reform of Marijuana Laws (NORML ISU) had several of its trademark licensing requests denied because its designs included a cannabis leaf, two members of the student group filed a 42 U.S.C. 1983 action, alleging various violations of their First and Fourteenth Amendment rights. The district court granted plaintiffs summary judgment in part and entered a permanent injunction against defendants. The court concluded that plaintiffs suffered an injury in fact in their individual capacities, and that they therefore have standing to bring this action. The court reasoned that plaintiffs' allegations that ISU violated their First Amendment rights by rejecting their designs and therefore preventing their ability to spread NORML ISU's message are sufficient to establish an injury in fact. The court also concluded that qualified immunity is not an issue here because this appeal solely concerns plaintiffs' request for injunctive relief; the district court did not err by concluding that defendants violated plaintiffs' First Amendment rights because defendants engaged in viewpoint discrimination and did not argue that their administration of the trademark licensing program was narrowly tailored to satisfy a compelling governmental interest; and NORML ISU's use of the cannabis leaf does not violate ISU's trademark policies because the organization advocates for reform to marijuana laws, not the illegal use of marijuana. Accordingly, the court affirmed the judgment. View "Gerlich v. Leath" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging, inter alia, excessive force after a police officer, Robert Hinman, shot him. The district court granted summary judgment to Officer Hinman, Chief Stuart Thomas, and the City of Little Rock. The court noted the tragic nature of the events where plaintiff was trying to defuse a situation where his former schoolmate had pulled out a gun and pointed it at a crowd. Plaintiff was in possession of the gun because he had taken it away from his schoolmate. Plaintiff was shot several times and is now paralyzed from the neck down. The court held that Officer Hinman's use of deadly force was objectively reasonable and the district court did not err in granting his motion for summary judgment based on qualified immunity. In this case, the officer instructed plaintiff to stop but plaintiff did not hear him, plaintiff continued to run toward another officer with the gun in plaintiff's hand, and plaintiff was two to three feet from the other officer before Officer Hinman fired his gun. Because the court concluded that Officer Hinman did not violate plaintiff's constitutional rights, the court rejected plaintiff's claims against Chief Thomas and the City. Accordingly, the court affirmed the judgment. View "Malone v. Hinman" on Justia Law

Plaintiff filed suit against the Civic Center and the City after his lease for a concession stand was terminated and his property was seized. Plaintiff alleged municipal liability based on the decision of the policymaker. The court explained that the district court must identify the final policymaker in accordance with South Dakota state law and local Rapid City ordinances. Because the district court failed to do so in this case, the jury rendered a verdict against defendants that lacked a legally sufficient basis. Therefore, the court reversed the district court's ruling on the Civic Center's renewed motion for judgment as a matter of law, vacated the jury's verdict, and remanded for a new trial. View "Soltesz v. Rushmore Plaza Civic Center" on Justia Law

Plaintiff filed suit against the Department of Corrections and related parties after he injured himself while using industrial equipment in the workshop of a Minnesota correctional facility. The district court dismissed plaintiff's claims for violations of his civil rights under the Eighth and Fourteenth Amendments, and for negligence of prison employees. At issue are plaintiff's Eighth Amendment claims against the individual defendants based on qualified immunity. The court concluded that, even assuming, without deciding, that plaintiff's assignment to operate the beam saw with no safety guards and no formal training presents an objective risk of serious harm, plaintiff has not alleged facts sufficient to show that officials were deliberately indifferent to that risk. In this case, the allegations fail to create the inference that officials had actual knowledge of those safety risks at the time in question. The court further explained that the absence of safety equipment or procedures and an awareness of similar injuries fail to show the officials were deliberately indifferent to the risk of harm posed to plaintiff by the beam saw. Therefore, the officials are entitled to qualified immunity. Finally, the court rejected plaintiff's claim that he is entitled to discovery. Accordingly, the court affirmed the judgment. View "Kulkay v. Roy" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, against Regents and the University, seeking damages and injunctive relief after he was discharged based on sexual harassment allegations. The court concluded that because plaintiff did not sufficiently plead a pre-termination procedural due process violation, exhaustion of state remedies is required to proceed on his post-termination claim; plaintiff has not sufficiently alleged that proceeding with the Office of Conflict Resolution (OCR) hearing would have been futile; and thus plaintiff's section 1983 procedural due process claims were properly dismissed. Accordingly, the court affirmed the judgment. View "Raymond v. Board of Regents of the University of Minnesota" on Justia Law