Justia Civil Rights Opinion Summaries

Plaintiff, a Missouri inmate, filed suit under 42 U.S.C. 1983, alleging that Missouri Department of Correction officials violated his constitutional rights when they censored his Chinese-language mail and denied him the ability to place telephone calls to China. The district court granted summary judgment to the officials. The court concluded that the restrictions were reasonably related to legitimate penological interests - specifically, security. The court also concluded that both the mail and telephone regulations were neutral and plaintiff had alternative means of communicating with outsiders. Furthermore, he also retained the ability to make domestic calls, send correspondence in English, and receive visitors; the Constitution does not require the State to bear the burden of paying for translation in any event; plaintiff has not demonstrated that there is a readily available alternative that would have eased the restriction on his ability to communicate without imposing financial burdens on the State; and thus the district court correctly rejected plaintiff's First Amendment claim based on the periods where he could neither correspond in Chinese nor international phone calls. The officials, a fortiori, did not violate Yang’s rights during periods when he could correspond in Chinese, but was prohibited from placing international telephone calls. Finally, there is no evidence that differential treatment of foreign-language mail was motivated by race or national origin or that the treatment of Chinese-language mail was a pretext for discrimination. Plaintiff's due process claim was rejected. Accordingly, the court affirmed the judgment. View "Yang v. MO Dep't of Corr." on Justia Law

Plaintiff filed a pro se complaint against the Department, alleging a sexual harassment claim based on hostile work environment and a retaliation claim. The district court dismissed the complaint under Rule 12(b). In support of her sexual harassment claim based on hostile work environment, plaintiff alleges seven incidents of harassment by two different men over a nearly three-year period. The court found as a matter of law that plaintiff's complaint failed to show harassment so severe or pervasive that they satisfy the high threshold for a sexual harassment claim based on hostile work environment. The court also found that plaintiff's purported "direct evidence" of retaliation fails as a matter of law for lack of causation where she failed to plausibly allege that the retaliation was a but-for cause of the Department's adverse action. Accordingly, the court affirmed the judgment. View "Blomker v. Jewell" on Justia Law

Plaintiff, a former police captain, filed suit against the City and city officials under 42 U.S.C. 1983, alleging that the City violated her constitutional right to due procedural process in violation of the Fourteenth Amendment by terminating her employment. The district court granted in part and denied in part defendants' motion for summary judgment. The district court denied the defense of qualified immunity asserted by Chief Burton in response to plaintiff's procedural due process claim. Chief Burton appealed. The court concluded that it lacked jurisdiction to review the denial of qualified immunity because genuine issues of material fact exist regarding Chief Burton's role in the termination of plaintiff. Accordingly, the court dismissed the appeal. View "Bramblet v. City of Columbia, MO" on Justia Law

Plaintiff, an Iowa prison inmate, filed suit under 42 U.S.C. 1983 against prison officials for deliberate indifference to his serious medical need. Plaintiff alleged that Director Baldwin and Dr. Deol were deliberately indifferent to his need for dentures, and sought declaratory and injunctive relief, as well as compensatory and punitive damages. The district court granted Director Baldwin and Dr. Deol's motion for summary judgment. For the purposes of this appeal, the court will assume that plaintiff suffered from an objectively serious medical need. However, the court concluded that plaintiff failed to establish that Director Baldwin and Dr. Deol deliberately disregarded his need for dentures. The undisputed facts show that the delay in providing plaintiff with dentures was caused by a turnover or shortage of dentists in the prison. The undisputed facts also show that over the time that plaintiff waited for dentures, the IDOC made efforts to secure additional dental staff. Finally, Dr. Deol and Director Baldwin neither created the shortage of dentists nor the general issues with recruitment and retention. Accordingly, the court affirmed the judgment. View "Cullor v. Baldwin" on Justia Law

After MFA formed a campaign committee less than 30 days before the November 4, 2014, election and violated Missouri law section 130.011(8), MFA filed suit against the executive director of the Missouri Ethics Commission (MEC), in his official capacity, seeking to declare unconstitutional the 30-day formation deadline. The district court granted a temporary restraining order, but after the election, dismissed MFA’s suit as not ripe. The court concluded that MFA has Article III standing to challenge section 130.011(8) on First Amendment grounds where MFA’s self-censorship is objectively reasonable; although the 2014 election has passed, this case is not moot where MEC can at any time implement its policy and assess the fee for violation of the formation deadline in section 130.011(8) and, in the alternative, this action is not moot under the “capable of repetition yet evading review” exception to mootness; and MFA’s case is ripe for review where MFA asserts the harm of self-censorship, based on its compliance with section 130.011(8). Accordingly, the court reversed and remanded for further proceedings. View "Missourians for Fiscal Accountability v. Klahr" on Justia Law

Plaintiff filed suit against Siemens, her former employer, alleging unlawful discrimination based on race in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq. Plaintiff, an African American, was terminated as part of a reduction in force. The district court granted summary judgment to Siemens. The court concluded that the district court did not err by proceeding to the McDonnell Douglas analysis because the evidence, viewed in the light most favorable to plaintiff, does not show a genuine issue of material fact as to Siemens’ liability under a cat’s paw theory. Under the McDonnell Douglas analysis, the court concluded that there is no evidence in the record to support a finding of pretext as to the actual decisionmaker. Accordingly, the court affirmed the judgment. View "Cherry v. Siemens Healthcare Diagnostics" on Justia Law

After a halfway house resident, Angenaldo Bailey, seriously injured plaintiff when he broke into her house, plaintiff filed suit against the City of Ames, several Ames police officers, the Center, John McPherson (the Center’s manager), the State of Iowa, and John Baldwin (the director of the Iowa Department of Corrections). On remand, the district court granted summary judgment for McPherson, Baldwin, the Center, and the State. The court affirmed the judgment, concluding that there is no evidence in the record that McPherson knew about Bailey’s history of abusing plaintiff or her telephone call to the Center on the afternoon of the shooting; McPherson cannot be held liable under 42 U.S.C. 1983 for constitutional violations of a subordinate based on a respondeat superior theory; there is insufficient evidence to show that McPherson’s subordinates at the Center were deliberately indifferent to a known or obvious substantial risk of harm to plaintiff when they authorized Bailey to visit the Hy-Vee store; plaintiff has not established that McPherson or employees of the Center created a new danger to plaintiff or increased the danger that Bailey posed to her, because the danger to plaintiff existed before Bailey resided at the Center and would have continued to exist thereafter; plaintiff's claim against Baldwin failed for insufficient evidence where he had no personal involvement in the Center and cannot be held liable under a respondeat superior theory; and the Eleventh Amendment bars plaintiff’s claims against the State and the Center, because the State and its agencies are immune from suits for damages. Accordingly, the court affirmed the judgment. View "Montgomery v. City of Ames" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and state law, alleging that Officer Buchanan violated his rights under the Fourth Amendment by entering his home unlawfully and by using excessive force against him during an arrest. Plaintiff also alleged that the City was liable for maintaining an unconstitutional policy governing its officers. The district court concluded that Buchanan was entitled to qualified immunity on the federal claims, plaintiff failed to present any evidence supporting his claim against the City, and the state law claims had no merit. The court concluded that the scenario confronting Buchanan was close enough to the line of a valid entry that he is entitled to qualified immunity. In this case, when the officer arrived at the residence, plaintiff had been drinking, he was upset and knocked over a chair as he rose to approach Buchanan, and Buchanan heard yelling from both an adult and children. Under these circumstances, a reasonable officer in Buchanan’s position could have concluded that there were reasonable grounds to believe that a person in the residence was in need of immediate aid. Therefore, the entry did not violate plaintiff's rights. The court also concluded that Buchanan is entitled to qualified immunity on plaintiff's excessive force claim where it was not clearly established at the time that an officer violated the rights of an arrestee by applying force that caused only de minimis injury. Finally, the district court properly dismissed plaintiff's claim that the City maintained an unconstitutional policy where he failed to present evidence that the City’s policy directed Buchanan to act unconstitutionally or otherwise caused a deprivation of plaintiff’s rights. Accordingly, the court affirmed the judgment, including the dismissal of the state law claims. View "Shultz v. Buchanan" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the jail nurse, jail administrator, and the City, after he was arrested during an altercation with his nephew and had sustained an injury to his hand. The court concluded that the district court properly granted summary judgment to the jail nurse on plaintiff's deliberate indifference claim where the nurse treated plaintiff's hand, mere negligence on the part of the nurse does not support a claim of deliberate indifference, and where plaintiff's attorney conceded that no medical evidence existed in the record to support the claim that the five-day delay in medical care caused plaintiff to suffer a detrimental effect. The court also concluded that the district court properly entered judgment for the administrator where, even if plaintiff could show that the administrator knew of his injury due to her job as jail administrator and that it was her responsibility to schedule appointments with a doctor for those on the list, the summary judgment record is devoid of any verifying medical evidence that the delay in treatment caused plaintiff to suffer a detrimental effect to his hand. Finally, the district court properly entered judgment on the pleadings against the municipal defendants. Accordingly, the court affirmed the judgment. View "Corwin v. City of Independence, MO" on Justia Law

Plaintiff, an African American man, filed suit against his employer, John Deere, alleging race discrimination and harassment in employment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act of 1965 (ICRA), Iowa Code 216.1 et seq. The district court granted summary judgment to John Deere. The court concluded that, even if the court assumed that plaintiff ultimately suffered an adverse employment action, plaintiff has failed to demonstrate any evidence that race was a motivating factor in John Deere's decision to discipline plaintiff. In this case, strong evidence supported John Deere's conclusion that plaintiff failed to follow instructions and ran scrap. Therefore, plaintiff's race discrimination claim failed. In regard to the race harassment/hostile work environment claim, the court concluded that the district court did not err in granting summary judgment to John Deere in light of plaintiff's reliance on incompetent and inadmissible evidence. The unsworn and unattested statements purportedly from plaintiff’s co-workers and plaintiff’s related interrogatory answers do not meet the standards of FRCP 56(c)(4). Accordingly, the court affirmed the judgment. View "Banks v. John Deere & Co." on Justia Law