Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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Plaintiff, a former employee at Nebraska State College System’s (NSCS) Peru State College, brought Equal Pay Act and Title VII claims against NSCS after she received a terminal contract in 2018. The district court granted summary judgment in favor of NSCS on all of Plaintiff’s claims, and Plaintiff appealed.   The Eighth Circuit affirmed the ruling. The court explained that the parties do not dispute that another employee was paid more for the same position from when Plaintiff and the other employee were hired until Plaintiff’s promotion in 2017; thus, it is undisputed that Plaintiff set forth a prima facie case. The parties dispute, however, whether NSCS satisfied its burden to prove that the pay differential was based on a factor other than sex. The court agreed with the district court that NSCS met its burden. NSCS offered sufficient evidence that the other employee received a higher salary because he had significantly more experience than Plaintiff.Further, the court wrote that while Plaintiff maintains that her being hired before the other employee demonstrates her superior experience. This assumption is erroneous, as Plaintiff conflates Peru State’s hiring and salary decisions. Finally, even if Plaintiff proves causation, Plaintiff failed to put forth evidence demonstrating pretext in response to NSCS’s legitimate reason for issuing her a terminal contract. View "Ronicka Schottel v. Nebraska State College System" on Justia Law

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This class action arises out of claims by commercial truck drivers who assert that they were not paid proper amounts while working for Werner Enterprises, Inc., and Drivers Management, LLC, (collectively Defendants) as part of Defendants’ Student Driver Program. In a previous appeal, we considered Defendants’ challenge to a jury verdict in favor of Philip Petrone and others (collectively, Plaintiffs) on some of Plaintiffs’ claims, concluding that the district court erred in amending the scheduling order to allow Plaintiffs to submit an expert report past the disclosure deadline without good cause.   Because the expert evidence was integral to the jury’s verdict, the Eighth Circuit determined that this error was not harmless, and vacated the judgment. The case returned to the court after the district court, on remand, entered judgment in favor of Defendants. The court then vacated the judgment. The court explained that read in its entirety, the decision left the door open for the district court to consider how to proceed in light of the Circuit Court’s ruling that the district court should not have granted the motion to amend the scheduling order. The court explained that its mandate thus did not direct the district court to affirmatively find in Defendants’ favor, and their suggestion to the contrary is without merit.   Finally, while the district court properly determined that Plaintiffs could not present evidence of damages through summary evidence pursuant to Rule 1006, it failed to conduct an analysis pursuant to Rule 37(c)(1) and failed to address Plaintiffs’ request for appointment of an expert pursuant to Rule 706. View "Philip Petrone v. Werner Enterprises, Inc." on Justia Law

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The North Dakota Department of Corrections and Rehabilitation took full custody of a young girl, A.A.R., from her parents and placed her at the Dakota Boys & Girls Ranch, a private psychiatric facility. After only a few months there, A.A.R. committed suicide. Her parents sued the Ranch and its employees under 42 U.S.C. Section 1983. The district court dismissed the Complaint, concluding that Plaintiffs failed to state a plausible claim that the Defendants were state actors under Section 1983.   The Eighth Circuit reversed and remanded. The court held that when North Dakota took custody of A.A.R., it had a constitutional duty to provide adequate medical care to her. The court explained that Plaintiffs were legally required to comply with DJS’s choices and could not remove her from the Ranch The district court violated the motion-to-dismiss standard when it concluded that the Complaint, read in conjunction with the May 2018 Order, contains “no factual allegations that the only medical care A.A.R. could have received was that provided by the State of North Dakota.” Further, assuming North Dakota’s constitutional obligation to provide A.A.R.’s medical treatment, the Ranch became a state actor. Thus Plaintiffs state a plausible claim against it under Section 1983. The court further explained that Plaintiffs also state a plausible claim against the Ranch’s employees. Defendants do not contest that a finding of state action by the Ranch establishes state action by its employees. Because Plaintiffs plausibly allege the Ranch was a state actor, its employees were too. View "Manda Roberson v. The Dakota Boys & Girls Ranch" on Justia Law

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Defendant drove drunk through the White Earth Indian Reservation. Local residents tried to stop him, but he struck and pinned one of them, N.V., under his car. A jury convicted Defendant of assault with a dangerous weapon and assault resulting in serious bodily injury. The district court varied upward from the Guidelines and sentenced Defendant to 80 months on each count, to run consecutively.   Defendant appealed, arguing that: (1) he was too drunk to have the specific intent to assault N.V.; (2) he ran over N.V. in self-defense; (3) his convictions violate the Double Jeopardy clause; and (4) his sentence was substantively unreasonable. Because those arguments are meritless.   The Eighth Circuit affirmed. The court held that there was enough evidence for a reasonable factfinder to conclude that Defendant intended to assault N.V. The jury’s verdict was supported by evidence that: Defendant aimed his car at local residents; he attempted to jump the curb three times; he stomped on N.V.’s head after hitting him with his car, and police described his responses afterward as logical. Further, the court wrote that the jury had significant evidence that Defedenadnt was not acting in self-defense. Moreover, the court explained that Defendant’s Double Jeopardy clause argument is foreclosed by both Supreme Court and Eighth Circuit precedent. Finally, the court saw no abuse of discretion in the district court’s sentence. View "United States v. Kevin Doerr" on Justia Law

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Plaintiff was severely injured when his motorcycle crashed into a police SUV while he was fleeing from police. Plaintiff sued the City of Plumerville, Arkansas (the “City”), and its police officer for use of excessive force. The district court granted summary judgment to the City and the officer.   The Eighth Circuit affirmed. The court explained that claims against local police for excessive force during a seizure are analyzed under the Fourth Amendment’s reasonableness standard. The court wrote it consistently held deadly force is not unreasonable where an officer has probable cause to believe that the suspect poses a threat of serious physical harm, either to the officer or others. The court held that the undisputed evidence reveals that the police officer had probable cause to believe Plaintiff’s flight threatened the lives of innocent bystanders as well as police. Accordingly, the court held that the officer’s actions were reasonable. Moreover, the court found that the severity of the officer’s use of force was mitigated by the opportunity the officer gave Plaintiff to avoid the collision.   Finally, the court explained that it assesses the reasonableness of deadly force for Fourth Amendment purposes from the seizing officer’s perspective at the time of the incident. The court found that based on the police officer’s knowledge at the time when he was forced to make a quick judgment, the court concluded the Fourth Amendment’s reasonableness standard gave the officer more leeway than would have the Morrilton police officers. View "Christopher Lankford v. City of Plumerville, Arkansas" on Justia Law

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This case involves allegations that a teacher restrained, secluded, and abused her students as a teacher in a special education classroom. The students’ parents sued the teacher, along with Aberdeen School District (“ASD”) and a host of its administrative officials, on their children’s behalf under 42 U.S.C. Section 1983. The district court denied the teacher’s assertion of qualified immunity from claims for infringing the Fourth and Fourteenth Amendment rights of three students, identified as A.A., B.B., and C.C.   The Eighth Circuit affirmed the denial of qualified immunity for the teacher on the students’ Fourth Amendment claims to the extent held above. In all other respects, the court reversed the denial of qualified immunity for the teacher and the remaining ASD officials. The court explained that it found four violations of clearly established Fourth Amendment rights: (1) secluding A.A. in the little room before February 4, 2016; (2) secluding B.B. in the calm-down corner using dividers; (3) grabbing B.B.’s arms to push him into the swimming pool; and (4) pinning C.C. down to strip his clothes off. The teacher is not entitled to qualified immunity for those violations but is for all other unreasonable seizure allegations. However, the court wrote, the remaining generalized assertions of physical and verbal abuse fail to meet the high bar required for a substantive due process violation. View "Jane Doe v. Becky Guffin" on Justia Law

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A jury convicted Defendant of possession with intent to distribute methamphetamine and conspiracy to distribute methamphetamine in violation of 21 U.S.C. Sections  841(a)(1) and 846. He appealed the district court’s denials of his motion to suppress evidence, his motion to strike a juror for cause, and his motion to admit a portion of a video recording.   The Eighth Circuit affirmed Defendant’s convictions. Defendant argued that the seizure and detention of the lockboxes was unreasonable under United States v. Place, 462 U.S. 696 (1983). But “Place had nothing to do with the automobile exception and is inapposite.” See Acevedo, 500 U.S. at 578 (noting that the Supreme Court has consistently “explained that automobile searches differ from other searches” and has denied the applicability of cases that “do not concern automobiles or the automobile exception” to cases involving the automobile exception). Therefore, the district court did not err in denying Defendant’s motion to suppress. Further, the court wrote there was no abuse of discretion because the juror stated that she could remain fair and would listen to the detective’s testimony before deciding if she believed it. Finally, Defendant claimed that the “partial recording and the Government’s characterization of it . . . gave a misleading and unfair understanding of the meaning of Defendant’s statement to the jury.” But he offers no explanation of how the recording was misleading. View "United States v. Shaun Farrington" on Justia Law

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Plaintiff worked at the University of Arkansas-Pulaski Technical College (“UAPTC”). In April 2018, Plaintiff requested and received leave under the Family and Medical Leave Act (“FMLA”) to care for her mother who had cancer. After being notified that her position would be eliminated in an upcoming reorganization she applied for a different position. The hiring committee led by Defendant interviewed Plaintiff and five other candidates. After the interview, the committee hired another applicant to whom Defendant had given a more favorable interview score.   Plaintiff sued the Board of Trustees of the University of Arkansas, members of the Board of the Trustees in their official capacities, the hiring committee director in his official and individual capacities, and UAPTC. Among other claims, she alleged that the hiring committee director violated the FMLA by discriminating and retaliating against her.   The district court denied the summary-judgment motion in relevant part, rejecting the hiring director’s qualified immunity defense on the ground that “qualified immunity is not available to defendants on an FMLA claim.” The Eighth Circuit remanded the case to the district court for consideration of the motion for summary judgment on the basis of qualified immunity. The court explained that the district court’s rejection of the hiring director’s qualified-immunity defense was based on a misreading of our statement in Darby v. Bratch. The court construed the statement in Darby about qualified immunity to mean that the FMLA clearly established the violative nature of the particular conduct in that case, not that qualified immunity can never be available on an FMLA claim. View "Rebecca Sterling v. Board of Trustees" on Justia Law

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Plaintiff, a woman with severe autism, and her mother, filed an employment discrimination lawsuit against Menards. Plaintiff's mother, who was also a plaintiff in the suit, arranged to have a job coach help Plaintiff obtain employment. However, despite the coach being willing to help Plaintiff through her orientation, Menards did not allow the coach to be present. After orientation, Plaintiff signed an arbitration agreement without the opportunity to show it to her job coach. Ultimately, Plaintiff was terminated and filed this case.Menards moved to compel arbitration. The district court denied Menards' request, resulting in this appeal.On appeal, the Eighth Circuit held that the fact Plaintiff's mother was appointed as Plaintiff's conservator did not necessarily mean that Plaintiff lacked the ability to enter into the contract. However, the court held that the record was not sufficiently developed to determine whether the facially valid contract was revocable under the void contract defense. Thus, the Eighth Circuit vacated the district court's order denying the motion to compel arbitration, and remanded to the district court for further proceedings. View "Mary Triplet v. Menard, Inc." on Justia Law

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Plaintiff was removed from a political rally and arrested for violating a St. Louis, Missouri ordinance that prohibits disturbing the peace. After Plaintiff was acquitted of that charge in state court, he brought claims against, as pertinent to this appeal, three St. Louis Metropolitan Police Department officers. The district court granted summary judgment in favor of the officers, and Plaintiff appealed.   The Eighth Circuit affirmed holding that it was objectively reasonable for the officers to mistakenly believe, under the totality of the circumstances that Plaintiff was engaged in acts or conduct inciting violence or intended to provoke others to violence. The court explained that two of the officers had arguable probable cause to arrest and then initiate prosecution against Plaintiff meaning that it was not clearly established that doing so would violate Plaintiff’s right to be free from unlawful seizure, malicious prosecution, or First Amendment retaliation. Thus, the court affirmed the district court’s grant of qualified immunity to those officers. Further, the court wrote that the district court properly granted qualified immunity to the remaining officer because it was not clearly established that initiating prosecution against Plaintiff would violate his Fourth Amendment right to be free from malicious prosecution or his corresponding right under Missouri law. View "Rodney Brown v. Matthew T. Boettigheimer" on Justia Law