Justia Civil Rights Opinion Summaries

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

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