Justia Civil Rights Opinion Summaries

Plaintiff filed suit against Chipotle, alleging claims under the Minnesota Human Rights Act (MHRA), Minn. State. 363A et seq., for reprisal, age discrimination, and sexual orientation discrimination. On appeal, plaintiff challenges the district court's grant of summary judgment on his reprisal claim. Chipotle claims that he was discharged due to declining work effort and performance. The court concluded that plaintiff failed to raise a genuine issue of material fact as to whether Chipotle’s stated reason for terminating his employment was pretextual. Therefore, the district court correctly determined that his reprisal claim under the MHRA fails as a matter of law and the court affirmed the judgment. View "Sieden v. Chipotle Mexican Grill, Inc." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against defendants for unlawful arrest and excessive force. The district court denied summary judgment on the basis of qualified immunity for Defendants Hansen, Dirkes, and Rybak. In this case, plaintiff was arrested for obstructing a police officer and resisting arrest. The court concluded that Officer Hansen had arguable probable cause to arrest plaintiff for obstructing a police officer. When plaintiff initially approached Hansen to ask about his son's arrest, Hansen ordered plaintiff to step back, but plaintiff disobeyed Hansen's unequivocal instructions to leave. Plaintiff lingered and refused to comply with Hansen's instructions. The court also concluded that Officer Dirkes is entitled to qualified immunity from plaintiff's unlawful arrest claim and excessive force claims where Dirkes did not violate a constitutional right by executing the takedown and by using the taser. Finally, the court concluded that the law was not clearly established that the use of an arm bar in this context constitutes excessive force, and thus Rybak is entitled to qualified immunity. Accordingly, the court reversed the district court’s decision denying Officer Hansen, Officer Dirkes, and Trooper Rybak qualified immunity and remanded for further proceedings. View "Ehlers v. Dirkes" on Justia Law

Plaintiffs filed suit challenging Mo. Rev. Stat. 311.070.4(10) and its regulations, which detail the information alcohol manufacturers, wholesalers, distributors, and retailers can include in their advertisements. Plaintiffs alleged a violation of their freedom of speech under the First Amendment because the challenged provisions prohibit truthful, non-misleading commercial speech and restrict the free flow of truthful information to potential customers. Plaintiffs also claim that the provisions are inconsistently enforced. The district court granted defendants' motion to dismiss. The court reversed, concluding that the amended complaint included sufficient allegations that the challenged provisions did not directly advance the substantial interest of promoting responsible drinking and the amended complaint included more than sufficient information to plead the challenged restrictions are more extensive than necessary. The court found it clear that there are reasonable alternatives to the challenged restrictions Missouri could have enacted that are less intrusive to plaintiffs’ First Amendment rights. Finally, plaintiffs have pled that the provisions unconstitutionally compel speech and association. View "Missouri Broadcasters Association v. Lacy" on Justia Law

Semmie John Guenther, Jr., filed an administrative charge with the EEOC, alleging that his former employer, Griffin Construction, discriminated against him on the basis of his disability, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. When Guenther passed away while his charge was pending, the special administrator of his estate filed suit on his behalf when he received the EEOC right-to-sue letter. The district court dismissed the action based on Ark. Code Ann. 16-62-101(a)(1) and found the claim had abated. The court held that federal common law does not incorporate state law to determine whether an ADA claim for compensatory damages survives or abates upon the death of the aggrieved party. The court joined its sister circuits that have allowed the individual’s estate to bring and maintain a suit for compensatory damages under the ADA in place of the aggrieved party. Therefore, Guenther’s ADA claim for compensatory damages survived his death and Griffin Construction is not entitled to judgment on the pleadings. The court reversed and remanded for further proceedings. View "Guenther v. Griffin Construction Co." on Justia Law

After plaintiff was released from a twenty-year period of commitment when a jury found him responsible by reason of insanity, he filed suit against various psychologists, psychiatrists, and other employees, alleging medical malpractice under Nebraska state law. Plaintiff also alleged violation of his constitutional rights to be free from unnecessary confinement and free from retaliation for seeking access to courts. The court concluded that the district court did not err by dismissing the medical malpractice claim where plaintiff failed to comply with the requirements set forth by Nebraska's State Tort Claims Act (STCA), Neb. Rev. Stat. 81-8, 209 et seq. Assuming that Nebraska waived its sovereign immunity, plaintiff still failed to bring the suit in the district court of the county in which the act or omission occurred pursuant to the STCA. In regard to the district court's dismissal of the unnecessary confinement claim, the court concluded that plaintiff only alleged defendants' actions were negligent or, at worst, grossly negligent. Therefore, defendants are entitled to qualified immunity where actions that are merely negligent or grossly negligent do no implicate the protections of the Due Process Clause. Finally, the court affirmed the district court's dismissal of plaintiff's retaliation claim where plaintiff failed to address the claim in his opening brief. View "Montin v. Moore" on Justia Law

Plaintiffs, detainees at the Cole County Detention Center, filed two putative class actions, one for current detainees and one for former ones, alleging that the laundry policy violates the Eighth and Fourteenth Amendments to the United States Constitution and corresponding provisions of the Missouri Constitution. The laundry policy allows guards and cellmates to see detainees naked while the detainees' one set of jail-issued clothing is being washed every few days. The detainees are given a bed sheet and a blanket. The court concluded that this practice constitutes more than a de minimis deprivation, and this practice is not related to a legitimate government interest. Therefore, the laundry policy is unconstitutional and the district court erred in dismissing the complaint. Finally, because the district court based its qualified immunity ruling on the perceived lack of a constitutional violation, the district court also erred as to this issue. Accordingly, the court reversed the dismissal and remanded for further proceedings. View "Ingram v. Cole County" on Justia Law

Class plaintiffs, civilly committed sex offenders, filed suit against Minnesota state defendants, bringing a facial and as applied challenge to 42 U.S.C. 1983. Plaintiffs claim that their substantive due process rights have been violated by Minnesota’s Civil Commitment and Treatment Act (MCTA), Minn. Stat. Ann. 253D.07(1)-(2), and by the actions and practices of the managers of the Minnesota Sex Offender Program (MSOP). The district court found for plaintiffs and entered an expansive injunctive order. The court concluded that the actions and statements that plaintiffs claimed of do not establish judicial bias; plaintiffs have standing to challenge the MCTA, and Heck v. Humphrey and the narrow Rooker-Feldman bar do not apply to this action; the proper standard of scrutiny to be applied to plaintiffs’ facial due process challenge is whether MCTA bears a rational relationship to a legitimate government purpose; the district court applied an incorrect standard in considering plaintiffs’ as-applied substantive due process claim; the extensive process and the protections to persons committed under MCTA are rationally related to the State’s legitimate interest of protecting its citizens from sexually dangerous persons or persons who have a sexual psychopathic personality, and thus the statute is facially constitutional; and plaintiffs have failed to demonstrate that any of the identified actions of the state defendants or arguable shortcomings in the MSOP were egregious, malicious, or sadistic as is necessary to meet the conscience-shocking standard, and thus plaintiffs' as-applied due process violation claims fail. Accordingly, the court reversed and vacated the order, remanding for further proceedings. View "Karsjens v. Johnson Piper" on Justia Law

Plaintiff filed suit, alleging claims under 42 U.S.C. 1981 and state law negligence, against Harbor Freight after a Harbor Freight manager accused plaintiff of stealing from the store earlier in the day. The district court dismissed the section 1981 claim for failure to plead a state action, and declined supplemental jurisdiction on the state law claim. The court concluded that the district court did not err in dismissing the section 1981 claim because the court was bound by Youngblood v. Hy-Vee Food Stores, Inc.'s state action requirement and defendant did not plead state action in the complaint. Furthermore, the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over defendant's state law claims once the district court dismissed the claim over which it had original jurisdiction. View "Elmore v. Harbor Freight Tools USA, Inc." on Justia Law

Plaintiff filed suit against Medtronic for disability discrimination and retaliation under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq. The district court granted summary judgment to Medtronic. The court agreed with the district court that there does not exist a strong enough causal connection sufficient as a matter of law to establish a prima facie case of discrimination under the ADA and MHRA. The court also concluded that plaintiff's retaliation claim fails because there is no evidence of a retaliatory motive on Medtronic's part to support a showing of causation even under a mixed-motive standard. In this case, Medtronic had cause to terminate plaintiff due to her performance issues. Plaintiff presented no evidence that any purported statements she made motivated Medtronic's decision to terminate her, and her rejection of Medtronic's proposed settlement agreement is not an activity protected under the ADA. Accordingly, the court affirmed the judgment. View "Oehmke v. Medtronic, Inc." on Justia Law

Plaintiff filed suit against two correctional officers, Smith and Merriett, under 42 U.S.C. 1983. Plaintiff alleged that the officers used excessive force when they administered pepper spray to gain plaintiff's compliance with orders to submit to wrist restraints. The district court granted summary judgment for the officers. The court concluded that the evidence does not clearly refute the district court's finding that Officer Smith did not intentionally administer pepper spray to plaintiff's genitals; the district court did not clearly err in deciding the decision to use pepper spray was not pretext to punish plaintiff and instead the use of force was in direct response to plaintiff's refusal to comply with the orders to submit to restraints in preparation to be removed from and returned to his cell; and plaintiff's claim of intentional infliction of emotion distress was rejected where plaintiff has failed to show that Officer Smith's sole intent in acting was to cause emotional distress. View "Ward v. Smith" on Justia Law