Justia Civil Rights Opinion Summaries

After plaintiff's convictions for second-degree murder and first-degree robbery were vacated, plaintiff filed suit against several detectives who investigated the murder. In this interlocutory appeal, the detectives challenge the district court's denial of their motion for summary judgment. Plaintiff moved to dismiss this appeal for lack of jurisdiction. Because the court concluded that the detectives raised the qualified-immunity issue on the face of the papers, the court remanded the case to the district court for consideration of the motion for summary judgment on the basis of qualified immunity. In considering that motion, the court explained that the district court can decide as a preliminary matter whether the detectives discussed the issue of qualified immunity in sufficient detail and with sufficient citations to undisputed record evidence to enable the district court to rule on the matter. View "Ferguson v. Short" on Justia Law

Plaintiff filed suit alleging that her former employer, Trinity Health, and former supervisors violated her rights under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the North Dakota Human Rights Act, N.D. Cent. Code 14-02.4-03(1). The district court granted summary judgment against plaintiff, concluding that she failed to show she was capable of performing the essential functions of her position, and that Trinity did not have a duty to reassign plaintiff to an alternate position. The court concluded, however, that plaintiff produced evidence that she could have performed the essential functions of her position with reasonable accommodation. In this case, plaintiff's written notification that she would be unable to complete the basic life support certification without medical clearance, and her statement that she required four months of physical therapy before completing the certification, could readily have been understood to constitute a request for a reasonable accommodation of her condition. Consequently, there remains a genuine issue of material fact as to whether plaintiff made a request for an accommodation sufficient to trigger Trinity’s duty to engage in the interactive process of identifying a reasonable accommodation. The court reversed and remanded for further proceedings. View "Kowitz v. Trinity Health" on Justia Law

Plaintiff filed suit against his employer, Crete, alleging it violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., by requiring a medical examination and discriminating on the basis of a perceived disability. Crete required its truck drivers with Body Mass Indexes (BMIs) of 35 or greater to get medical examinations to determine whether they had obstructive sleep apnea. When Crete ordered plaintiff to undergo an examination because his BMI was over 35, he refused. The district court granted summary judgment to Crete. The court concluded that the district court property admitted an expert's testimony regarding obesity and obstructive sleep apnea; by the undisputed facts, the sleep study requirement is job-related because it deals with a condition that impairs drivers’ abilities to operate their vehicle; the requirement is also consistent with business necessity; the district court correctly granted Crete summary judgment on the medical-examination claim where Crete carried its burden of showing it defined the class reasonably; and the undisputed evidence shows that Crete suspended plaintiff for refusing to submit to a lawful medical examination, which does not violate the ADA. Accordingly, the court affirmed the judgment. View "Parker v. Crete Carrier Corp." on Justia Law

Plaintiff filed suit against the University of Minnesota, David Andersen, and Ted Swem, alleging sexual harassment under 42 U.S.C. 1983. Swem was a mentor and guide to plaintiff. The district court denied Swem's motion for summary judgment based on qualified immunity. The court determined that it had jurisdiction to review claims raised in this interlocutory appeal based on the purely legal issue of whether the facts, taken most favorably to plaintiff, support a finding that defendant violated her clearly established constitutional rights. On the merits, the court agreed with the district court that Swem is not entitled to qualified immunity and that summary judgment should be denied. Plaintiff has sufficiently shown that Swem’s conduct toward her was unwelcome harassment, and that it was serious enough to alter a term or condition of her employment. She also showed that Swem’s conduct violated a clearly established right, based on the particular facts of this case. Accordingly, the court affirmed the judgment. View "Jenkins v. Swem" on Justia Law

After plaintiff was terminated from her job at ABM, she filed suit against her former employer, alleging that she was unlawfully terminated based on age in violation of the Minnesota Human Rights Act, Minn. Stat. 363A.08. The court concluded that, viewing the evidence in the light most favorable to plaintiff, the district court did not err in granting summary judgment to ABM. In this case, plaintiff did not meet her burden of establishing a genuine issue of material fact that ABM’s proffered legitimate reason for her termination was pretext for age discrimination. View "Haggenmiller v. ABM Parking Serv." on Justia Law

After charges against plaintiff for disorderly conduct and interference with lawful process were dropped, plaintiff filed suit alleging various claims against government officials. The court affirmed the district court's adverse grant of summary judgment on plaintiff's Fourth Amendment claim because the law regarding warrantless misdemeanor arrests for offenses committed outside the presence of the arresting officer is not clearly established under the Fourth Amendment; plaintiff failed to show a violation of any clearly established First and Fourth Amendment right; in regard to claims of unlawful arrest under Minnesota law, the court did not believe that the officers had sufficiently clear knowledge of what was required of them under the circumstances and the officers did not act maliciously or willfully in violating plaintiff's rights; and, likewise, plaintiff's claim under Monell v. Dep’t of Soc. Servs necessarily fails. The court agreed with the district court that the officers are entitled to qualified immunity for plaintiff's federal law claims, official immunity for plaintiff's state law claim, and that plaintiff has not made out a claim under Monell. Accordingly, the court affirmed the judgment. View "Gilmore v. City of Minneapolis" on Justia Law

After plaintiff was convicted of murder and the charges were subsequently dropped when another person confessed to the murder, plaintiff filed a civil damage action against five individuals and Stone County, Missouri, alleging various claims under 42 U.S.C. 1983 and Missouri state law. The district court granted summary judgment and dismissed Stone County, the County Sheriff, and the Sheriff’s criminal investigation supervisor. The court denied the motions of Stone County Prosecutor Matt Selby, lead investigator Karl Wagner, and investigator Orville Choate, who has not appealed, rejecting their claims of absolute, qualified, and official immunity. Selby and Wagner appealed. Plaintiff argues that investigators Wagner and Choate violated his right to due process as defined in Brady v. Maryland. In this case, the district court erred by failing to adopt the more precise mens rea standard adopted in the court's controlling opinion, Villasana v. Wilhoit. Therefore, the district court must apply this controlling standard when the issue again arises on remand, whether before, during, or after trial. The court also concluded that, on this record, it was error to deny Prosecutor Selby qualified immunity because plaintiff failed to present sufficient evidence that Wagner and Selby violated clearly established Fourth Amendment rights of which a reasonable person would have had. Finally, the court concluded that the district court erred in denying Wagner and Selby qualified immunity from the Sixth Amendment damage claim because no section 1983 precedents give these defendants fair and clear warning of what the Constitution requires, and plaintiff failed to put in the summary judgment record evidence of whether defense counsel at trial moved to suppress or exclude testimony by Parker and Pollard because it was obtained in violation of the Sixth Amendment. Accordingly, the court reversed in part and remanded for further proceedings. View "Stewart v. Wagner" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that the City's failure to develop a conflict-of-interest policy led to a violation of his constitutional rights when prosecutors (the Attorneys) filed a criminal complaint against him while simultaneously representing the victim of his alleged crime in separate civil actions. The district court granted the City’s and the Attorneys’ separate motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court dismissed a remaining state law claim under Minnesota’s doctrine of statutory discretionary immunity. The court affirmed the district court's dismissal of the complaint against the Attorneys based on absolute prosecutorial immunity where the development of a conflicts policy and the determination as to what constitutes a conflict of interest would necessarily require legal knowledge and the exercise of related discretion, features to which the doctrine of absolute immunity applies; reversed the district court's finding that the City is absolutely immune from suit on plaintiff's section 1983 claim where municipalities do not enjoy absolute immunity from suit under section 1983; and reversed as to the supplemental state law claims based on the same reasoning. View "Sample v. City of Woodbury" on Justia Law

Plaintiffs filed separate actions against various Minnesota cities, counties, and law enforcement entities alleging violations of the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2724(a). In separate orders, the district court denied in part defendants’ motions to dismiss, including claims by many defendants that they are entitled to qualified immunity. The City of Minneapolis appeals the denial of qualified immunity in the Karasov action, and numerous Minnesota counties appeal the denial of qualified immunity in the Kampschroers action. After the parties briefed these appeals, the court issued its decision in McDonough v. Anoka County, which squarely addressed the issue of qualified immunity. The court concluded that McDonough is controlling precedent. The court also concluded that its decision that the statutory term “obtain” is unambiguous controls defendants' additional argument that the rule of lenity entitles them to qualified immunity. Accordingly, the court affirmed the judgment. View "Kampschroer v. Ramsey County" on Justia Law

Plaintiffs, Minnesota driver's license holders, filed suit against local entities, Law Enforcement Does, Commissioners, and DPS Does, alleging that defendants violated the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2721-2725, by accessing or disclosing personal information from the DPS database without a permissible purpose. The district courts dismissed the actions for failure to state a claim. The present appeals raise issues similar to those presented in the court's opinion in McDonough v. Anoka County and are governed by the court's holding in that case. McDonough discussed the history, purpose, and applicability of the DPPA. The court addressed the individual complaints in this group of cases and affirmed in part, reversed in part, and remanded for further proceedings. View "Ray v. Anoka County" on Justia Law