Justia Civil Rights Opinion Summaries

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

In 2009, Hobbs and her husband pled guilty to aggravated identity theft and conspiring to commit bank fraud. Hobbs was sentenced to 56 months’ imprisonment and five years’ supervised release. Her husband was sentenced to 80 months’ imprisonment and five years’ supervised release. They were ordered jointly to pay approximately $18,000 in restitution. In 2016, probation moved to revoke her supervised release, alleging four violations of her release conditions: Hobbs moved from her registered address without telling her probation officer; she failed to submit to a required urinalysis; she left her job without telling her probation officer; she stopped making restitution payments the month her husband was released. Hobbs admitted the violations. The government asked that her release be modified rather than revoked, with a condition of “no contact with her husband.” The court expressed concern that Hobbs’s violations were connected to her husband’s release and imposed a sentence of 30 days’ imprisonment and the condition: The defendant shall have no direct, indirect, or electronic contact with codefendant and husband, Jack Hobbs, during her term of supervised release. The Eighth Circuit vacated the condition as a “sweeping restriction on her important constitutional right of marriage.” View "United States v. Hobbs" on Justia Law

Plaintiffs filed suit against the City, alleging that the City violated their rights under the Columbia City Charter, the Missouri Constitution, and the First and Fourteenth Amendments to the U.S. Constitution by interfering with their participation in a municipal referendum process to repeal two ordinances passed by the City Council in connection with a student housing development project proposed by Opus. The district court granted summary judgment to the City. The court concluded that the City did not violate plaintiffs' rights by enacting Ordinance B while Referendum A was pending; the district court did not err in granting summary judgment to the City on plaintiffs' claims involving the issuance of the Opus project permits; plaintiffs have not established a violation of their First Amendment rights where neither the referendum process itself nor the City’s conduct in responding to the referendum process interfered in any way with the message plaintiffs sought to communicate, restricted their ability to circulate either referendum petition, regulated the content of their speech, or infringed on their ability to communicate with other voters or the manner by which they could so communicate; the court also rejected plaintiffs' claim that the City violated their rights under the Fourteenth Amendment by depriving them of protected liberty and property interests without due process of law; and there is no constitutional right at stake in the referendum process, and thus conditioning the repeal of Ordinance A on abstaining from the referendum process cannot be unconstitutional. In this case, the City complied with all relevant provisions set forth in the City Charter. Accordingly, the court affirmed the judgment. View "MacMann v. Matthes" on Justia Law

After Carleton J. Wallace was fatally shot by a police officer, Wallace's estate filed suit under 42 U.S.C. 1983 against defendants, alleging excessive force in violation of the Fourth Amendment. The district court denied the officer summary judgment on the basis of qualified immunity, but granted summary judgment to the chief of police and the city. The officer appeals. The court concluded that, under the totality of the circumstances, the record does not establish that the officer's use of deadly force was reasonable as a matter of law. In this case, viewing the evidence in the light most favorable to the estate, Wallace did not pose an immediate and significant threat of serious injury to the officer or bystanders because he may not have committed any violent felony, the physical struggle was minimal, and he was not "holding a firearm" when he attempted to flee. Viewing the facts in the light most favorable to the estate, a reasonable fact finder could thus conclude that the seizure violated a clearly established constitutional right. Accordingly, the court affirmed the judgment. View "Wallace v. Cummings" on Justia Law

Plaintiff, who is of Turkish and Kurdish descent, filed suit under 42 U.S.C. 1983, alleging that Officers Mathews and Collins arrested him on account of his ethnicity, in violation of the Fourteenth Amendment’s Equal Protection Clause. Officers Matthews and Collins came upon plaintiff while investigating a report of a suspicious person casing the neighborhood. Plaintiff matched the description. The district court granted summary judgment on the claims of selective enforcement and failure to intervene against Officers Matthews and Collins. The court affirmed the judgment and concluded that plaintiff failed to establish that the enforcement had a discriminatory effect and that the enforcement had a discriminatory purpose. View "Gilani v. Matthews" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983 against Vermillion Police Department (VPD) officers, alleging violations of their First and Fourth Amendment rights. Given the totality of the circumstances, the relatively low .02 BAC limit under the minor DUI statute, and the absence of judicial decisions interpreting that statute, the court found that the officers had at least arguable probable cause to believe that Plaintiff Callissa Schaffer had violated SDCL 32-23-21. Therefore, the court concluded that the officers are entitled to qualified immunity with respect to plaintiffs' claim that officers violated Callissa's Fourth Amendment right to be free from unreasonable seizures. Likewise, the officers are entitled to qualified immunity with respect to plaintiffs' claim that the officers deprived Callissa of her Fourth Amendment right to be free from unreasonable searches when she was frisked before being placed in the patrol car. The court also concluded that Officer Foley is entitled to qualified immunity on plaintiffs' claim that he deprived Callissa of her Fourth Amendment right to be free from unreasonable searches because he purposefully misrepresented facts in his affidavit for a search warrant. In this case, plaintiffs failed to show that any of the omissions at issue were intentional or reckless. Finally, the court concluded that the officers are also entitled to qualified immunity on Jill Schaffer's claim that the officers retaliated against her for engaging in speech protected by the First Amendment, and Chief Betzen is entitled to summary judgment on both the official capacity and individual capacity claims. Accordingly, the court affirmed the judgment. View "Schaffer v. Beringer" on Justia Law

Plaintiff filed suit against the City, alleging violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621-634, and 42 U.S.C. 1983. Plaintiff alleged that he was terminated from his job on account of his race and age after being employed by the City for twenty-seven years. The court affirmed the district court's grant of the City's motion for summary judgment. The court concluded that the district court did not err in setting aside the entry of default judgment where the City's delay in filing its answer was excusable and there was no bad faith or intentional effort to delay on the City's part; plaintiff failed to identify no similarly situated employee outside plaintiff's protected class who was treated more favorably by the City, and thus the inference-of-discrimination element of plaintiff's prima facie case has not been established on this basis; plaintiff failed to identify any biased comments made by a decisionmaker that might establish an animus-based inference of discrimination; there has been no showing that the City failed to follow any applicable policy in making the decision to fire plaintiff and no inference of discrimination has been established on this basis; and the City consistently cited insubordination as its reason for firing plaintiff, and thus there is no record-based shifting-reasons basis for an inference of discrimination. Accordingly, the court concluded that plaintiff failed to substantiate his claims of race and age discrimination with sufficient probative evidence to permit a rational trier of fact to find in his favor. The court affirmed the judgment. View "Grant v. City of Blytheville, Arkansas" on Justia Law

Plaintiffs, a group of drivers, filed suit against the City and Gatso, alleging that the Automatic Traffic Enforcement (ATE) system violates their right to procedural due process, their fundamental right to travel, Iowa Code 602.6101, and causes unjust enrichment for the City and Gatso. The City contracted with Gatso to install and operate the ATE system. The district court dismissed plaintiffs' claims. The court concluded that the district court did not err by determining that plaintiff Hughes lacks Article III standing where he does not allege that he has incurred any costs to mitigate or avoid the threat of ATE enforcement, or that the threat of an ATE citation is sufficiently imminent, and plaintiff Mazgaj lacks third party standing where he failed to show a hindrance to his wife’s ability to protect her own interests. The court concluded, however, that plaintiff Lee's claims are ripe where he was found guilty of violating the ordinance and no further factual development is necessary. Thus, Lee has the hardship of citation and the cost of litigation. The court further concluded that the district court never had jurisdiction of Hughes and Mazgaj’s claims and therefore their claims should be remanded to state court. Plaintiffs Robinson, Sparks, Northrup, Yarpezeshkan, French, and Stimpson have established standing to bring procedural-due-process claims. However, these plaintiffs failed to state a violation of their procedural due process rights. The court rejected plaintiffs' claims that the system violated their substantive rights, Equal Protection claim, and unjust enrichment claim. Because the City’s appeal of the IDOT’s ruling is still pending, this claim is not ripe. Therefore, the district court should dismiss without prejudice the drivers’ state-law claims based on the alleged violation of IDOT rules. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Hughes v. City of Cedar Rapids" on Justia Law