Justia Civil Rights Opinion Summaries

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

Plaintiff filed suit under 42 U.S.C. 1983 against a bus driver and the Metropolitan Council after the bus driver kicked plaintiff off the bus for failing to pay the bus fare, allowed passengers to exit the bus and physically remove plaintiff, and accelerated and braked multiple times in an attempt to knock plaintiff off the bus or to scare him away from the front of the bus. Plaintiff alleged that he suffered a bruised thigh, a bruised cheek, and scrapes on both of his hands. The district court granted summary judgment to the bus driver and the Metropolitan Council. Plaintiff appealed the grant of qualified immunity to the bus driver. The court agreed with the district court's application of the intent-to-harm standard, concluding that plaintiff failed to show that the bus driver's actions amounted to substantive due process where it is clear that the bus driver's objective in all of his actions was to remove plaintiff from the bus and to continue driving his route. The bus driver was was not acting in a manner to maliciously or sadistically cause plaintiff physical harm, and the bus driver's actions were related to his legitimate responsibilities of driving the bus. Accordingly, the court concluded that the district court properly granted summary judgment to the bus driver and the court affirmed the judgment. View "Truong v. Hassan" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against two public officials in their official capacities, alleging that the procedures they enforce for placing initiatives on Nebraska state and municipal ballots violate his rights under the First and Fourteenth Amendments, and seeking declaratory and prospective injunctive relief. The district court dismissed all but the Fourteenth Amendment claim against Nebraska Secretary of State John Gale, entered judgment for plaintiff on that claim, enjoined Gale from enforcing certain provisions of the Nebraska Constitution, and awarded plaintiff attorneys' fees and costs. The Supreme Court made clear in Lujan v. Defenders of Wildlife that a wish to engage in future conduct, alone, does not provide the immediacy needed for threatened enforcement of a contested law to constitute injury in fact. The court concluded that plaintiff failed to establish standing to bring his Fourteenth Amendment claim where his interest in placing an initiative on the ballot, even if evidenced by a sworn statement and sample petition filed with Gale, is insufficient to establish an imminent threat of enforcement. Furthermore, plaintiff failed to prove he has standing to assert his interest as a petition signer where there is no evidence that plaintiff is registered to vote. Accordingly, the court vacated that portion of the district court's judgment and remanded with instructions. View "Bernbeck v. Gale" on Justia Law

After plaintiff was terminated from UPS, he filed suit alleging race discrimination. The district court granted summary judgment to UPS. The court affirmed, concluding that the totality of the evidence in this case does not support a finding of unlawful discrimination. Plaintiff has not put forth evidence to rebut UPS's contention that it fired him due to his conduct. The record shows that plaintiff cursed in the workplace, arguably threatened his supervisor, had multiple conflicts with other employees, and disagreed with company efforts to address the problems. Because plaintiff failed to present any evidence to establish that UPS's given reason for his termination was pretextual, the district court did not commit reversible error by concluding that plaintiff failed to show that a material question of fact remains as to pretext. View "Smith v. UPS" on Justia Law

In 1996, Dale Helmig was convicted of first-degree murder of his mother. In 2011, the Missouri Court of Appeals vacated his conviction and gave the State 180 days to retry him. The State declined to retry Helmig. Helmig then filed suit against law enforcement officers and Osage County, Missouri under 42 U.S.C. 1983, alleging that they violated his constitutional right to due process by not disclosing certain materially favorable evidence, fabricating evidence, and conspiring to misuse evidence. The court found no intent or bad faith on behalf of the officers to disclose Brady evidence to the prosecutor or the defense; Sheriff Fowler’s lack of testimony at trial about his limited knowledge of the report at issue when he was never asked about whether the report was or was not substantiated both fails to support a Brady claim and is protected by absolute immunity; and no reasonable juror could infer the existence of a conspiracy to deprive Helmig of a fair trial. Accordingly, the court affirmed the district court's grant of summary judgment to defendants. View "Helmig v. Fowler" on Justia Law