Justia Civil Rights Opinion Summaries

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

Plaintiffs appealed the district court's order granting the District's motion to approve the closure of Wilmot Elementary School and to modify the gifted and talented (GT) requirements for the District. In 1988, plaintiffs filed suit under 42 U.S.C. 1983, alleging race discrimination and other claims. The parties negotiated a settlement and, in 1991, the district court entered a Consent Order disposing of issues remaining in the complaint. In this case, the district court approved closure of Wilmot and modification of the GT program as the proper modification of the Consent Order due to the significant changed circumstances. The court concluded that such modification is suitably tailored where the modifications sought by the school district in light of the (1) demographic changes, (2) decrease in enrollment, (3) cost savings, and (4) educational considerations are in line with the initial Consent Order. Accordingly, the court held that the district court did not abuse its discretion in granting the District's motion to approve closure of Wilmot and to modify the GT requirements. The court affirmed the judgment. View "Mays v. Hamburg Sch. Dist." on Justia Law

After the LPD conducted a high-risk traffic stop of plaintiff, he filed suit against the City and three officers involved in the stop under 42 U.S.C. 1983 for deprivation of his constitutional rights. The district court granted defendants' motion for summary judgment based on qualified immunity. In this case, an officer relied on an incident report that did not contain information sufficient to create reasonable suspicion that plaintiff had already, was, or was about to commit a crime; Nebraska law permits individuals who are at least 18 years old to open carry handguns in public; the City does not restrict an individual's right to open carry except in certain locations; and the mere report of a person with a handgun is insufficient to create reasonable suspicion. The court concluded that an objectively reasonable officer could not reliably conclude that the young man described in the report could not legally possess a firearm. The incident report also did not adequately make out a case that the young man committed assault; the officers' reports reflect that they were responding to the display of a weapon, not a threat against the clerk; and an objectively reasonable police officer would not mistake a 58-year-old bald, double amputee, male for a young adult with hair. Therefore, the court concluded that plaintiff sufficiently alleges a violation of his Fourth Amendment rights. Because the district court erred in granting the officers qualified immunity, the court reversed and remanded for further proceedings. View "Duffie v. City of Lincoln" on Justia Law

Plaintiff filed suit against his former employer, alleging that the company terminated his position and then refused to rehire him because of his age, in violation of federal and Minnesota law. The court affirmed the district court's grant of summary judgment for the employer where plaintiff has not presented a submissible case of age discrimination under Minnesota law. It follows that plaintiff’s claim under the more demanding federal standard fails as well. In this case, plaintiff is understandably frustrated that the employer deviated from written guidelines under which he likely would have been retained as a pharmacist. But plaintiff cannot prevail in this lawsuit by showing sloppy management or arbitrary decisionmaking. The company’s regular practice of ranking all pharmacists together and terminating those with the lowest score is not sufficient evidence of age discrimination to defeat summary judgment. The balance of the evidence does not establish a submissible case. Accordingly, the court affirmed the judgment. View "Noreen v. PharMerica Corp." on Justia Law

Plaintiffs, five members of Whittier Alliance, a private neighborhood organization, filed suit under 42 U.S.C. 1983 against the City and Alliance itself. Plaintiffs claim that the City "commanded and encouraged" the members of the Alliance to adopt an antidefamation bylaw which unconstitutionally restricted the members' First Amendment right to freedom of speech. The district court granted defendants' motion to dismiss for lack of standing and state action. In this case, the antidefamation bylaw restricts plaintiffs' ability as members of the Alliance to vote for the board candidate of their choice, and the antidefamation bylaw prevents plaintiffs from voting for themselves or any other candidates who might be considered malicious critics by the board. The court concluded that plaintiffs have suffered sufficient injury as voting members of the Whittier Alliance; their asserted injury may be traced to the objected bylaw and could be redressed by the relief they seek; and, since they have standing to raise an as applied challenge to the antidefamation bylaw, they may also challenge its overbreadth in a facial challenge. Therefore, plaintiffs have standing to challenge the constitutionality of the bylaw. The court concluded, however, that the adoption of the bylaws did not amount to state action. Accordingly, the court affirmed the judgment. View "Sabri v. Whittier Alliance" on Justia Law

After the school districts sought termination of the Garland County School Desegregation Case Comprehensive Settlement Agreement and relief from the district court’s 1992 order enforcing it, the district court denied the school districts' Rule 60(b)(5) motion. The district court rejected the school districts' argument that the Agreement is no longer just or equitable to give the 1992 order or the Agreement prospective application in light of the repeal of the Arkansas School Choice Act of 1989 (School Choice Act), Ark. Code Ann. 6-18-206 (repealed 2013). The court concluded that the school districts have presented no evidence that they have either fully complied or that there have been changed circumstances in those other areas of the Agreement. Therefore, termination of the entire Agreement would be supported by nothing more than the notion that it is no longer convenient to live with. The court affirmed the judgment. View "W.T. Davis v. Cutter Morning Star Sch." on Justia Law