Justia Civil Rights Opinion Summaries

Appellant Attorney Kezhaya represented The Satanic Temple, Inc., in its lawsuits against the City of Belle Plaine, Minnesota. The Temple sued the City, claiming that the City opened a limited public forum for a Christian monument, but closed the forum to exclude a Satanic monument. The City sought $33,886.80 in attorney’s fees incurred by responding to the complaint in the second lawsuit and preparing the motion for sanctions. The court determined that the rates charged by the City’s counsel were reasonable but observed that a portion of the work was duplicative of the first lawsuit and that the issues unique to the second lawsuit were not complex, novel, or difficult. The court thus reduced the requested amount by fifty percent and ordered the Temple’s counsel to pay the City $16,943.40 under Rule 11(c). Kezhaya appealed the sanctions order. He argues that the district court abused its discretion by (i) imposing sanctions, (ii) failing to consider non-monetary sanctions, and (iii) granting an arbitrary amount of sanctions.   The Eighth Circuit affirmed. The court explained that under the circumstances, it disagreed with Kezhaya’s contention about the righteousness of a second lawsuit. For the claims dismissed “without prejudice” in the first lawsuit, Kezhaya and the Temple made a strategic choice to seek leave to amend the complaint to correct the deficiencies identified in the dismissal order. Further, the court found that even if the City’s insurance carrier ultimately paid the fees, the fees were “incurred” for the motion and could be awarded under Rule 11(c)(2). View "Matthew Kezhaya v. City of Belle Plaine" on Justia Law

Plaintiff sued the Director of the Arkansas Division of Workforce Services (“DWS”) in her official capacity, alleging discrimination on the ground of national origin under Title VI of the Civil Rights Act. The district court entered summary judgment in favor of the Director.   The Eighth Circuit affirmed. Plaintiff insists her prima facie case is strong enough to establish pretext. However, the court wrote that even if Plaintiff had presented a prima facie case of intentional discrimination, she has nonetheless failed to carry her burden under McDonnell Douglas of showing the reasons for her bureaucratic troubles were a pretext for intentional discrimination. Plaintiff also argued the district court erred by rejecting her alternative request to apply a deliberate indifference standard when analyzing her Title VI claim. However, the court wrote that even assuming for the sake of argument that the deliberate indifference standard applies, in light of the court’s conclusion under McDonnell Douglas, Plaintiff fails to raise a genuine issue of material fact under the “high standard” of deliberate indifference. View "Maria Murguia v. Charisse Childers" on Justia Law

Plaintiff sued Defendant, a corrections officer, under 42 U.S.C. Section 1983, alleging a violation of his constitutional rights while Plaintiff was a detainee at a jail in Minnesota. Defendant moved for summary judgment based on qualified immunity. The district court denied the motion.   The Eighth Circuit affirmed. The court explained that qualified immunity protects governmental officials from suit under 42 U.S.C. Section 1983 unless a plaintiff shows that the official’s alleged conduct violated a clearly established right of the plaintiff. The court wrote that because Plaintiff was a detainee at the time of the incident, his relevant constitutional rights arise under the Due Process Clause of the Fourteenth Amendment. Defendant argued that he did not violate Plaintiff’s clearly established right under the Fourteenth Amendment. He maintains that no constitutional violation occurred because “manual contact with a detainee’s genitals may be necessary as part of a search.” The court explained that as a general proposition, it is clearly established that “the sexual assault of an inmate by a guard violates the inmate’s constitutional rights.” The court explained that right is violated when a government official’s conduct is so egregious “that it may fairly be said to shock the contemporary conscience.” Plaintiff asserts that Defendant subjected him to a strip search and, without legitimate penological justification, grasped his naked penis, squeezed it hard, and gestured. Viewing the facts in the light most favorable to Plaintiff, a jury could find that the alleged conduct constituted sexual abuse or assault. View "Wilbert Glover v. R. Paul" on Justia Law

L.W.’s appendix ruptured during her incarceration, and she subsequently died from sepsis. Plaintiff, as special administrator of L.W.’s estate, filed suit against the county in which L.W. was incarcerated, as well as against the individuals involved in her incarceration and medical care, alleging civil rights claims under 42 U.S.C. Section 1983 and tort claims under state law. The medical malpractice claim against the jail physician, Defendant, went to trial. Defendant moved for judgment as a matter of law at the close of Plaintiff’s evidence. The district court granted the motion. The jury returned a verdict for Plaintiff and awarded $1.3 million in damages. The district court granted Defendant a credit against the verdict for the value of the settlement, amending the judgment to $800,000. Defendant appealed the denial of judgment as a matter of law on the medical malpractice claim. Plaintiff appealed the grant of judgment as a matter of law on the punitive damages claim, as well as the grant of credit against the verdict.   The Eighth Circuit affirmed. The court explained that it does not believe that the court’s decision to preclude the use of legal terms like “reckless” would have had any bearing on its decision to grant judgment as a matter of law on punitive damages. The court explained that it does not matter that separate wrongdoings caused L.W.’s injuries. UCATA does not focus on the cause of the injury or the policy reason for imposing liability. It focuses on the injury, which Plaintiff has alleged is the same for the Section 1983 claims as it is for the medical malpractice claim View "Christine Turner v. Garry Stewart, M.D." on Justia Law

After being passed over for a superintendent role, Plaintiff sued her employer, Pulaski County Special School District (“PCSSD”), and its board members for discrimination and retaliation in violation of Title VII and 42 U.S.C. Section 1981. A jury found in her favor on her Title VII and Section 1981 retaliation claims and awarded damages, including punitive damages. Defendants appealed the district court’s denial of their motion for judgment as a matter of law and the punitive damages award. Plaintiff cross-appeals the district court’s denial of her request for front pay, additional back pay, and equitable relief.   The Eighth Circuit vacated the judgment. The court explained that, as a whole, the evidence demonstrates that she believed she reported the disparity in the facilities as part of her duty to oversee compliance with Plan 2000, which sought to rectify discrimination against students in public education. The court explained that it does not rule out that the disparity in the facilities could affect employees too, there is simply no evidence here that Plaintiff believed she was complaining about a discriminatory employment practice. Thus, a jury could not conclude that Plaintiff had a good faith belief that she was reporting a discriminatory employment practice. View "Janice Warren v. Mike Kemp" on Justia Law

Officers shot and killed Brian Quinones-Rosario as he approached officers with the knife drawn. His widow as trustee, sued the officers and their employing municipalities. She alleged an excessive use of force that resulted in an unreasonable seizure under the Fourth and Fourteenth Amendments. The district court concluded that the officers did not commit a constitutional violation, and granted judgment for the officers and the municipalities. Plaintiff appealed.   The Eighth Circuit affirmed. The court explained that the use of force “must be judged from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight.”. Applying those principles, and viewing the facts in the light most favorable to Quinones, the court concluded that the officers’ use of force was objectively reasonable. The court explained that Quinones-Rosario posed an imminent threat of death or serious physical injury to the officers. He aggressively wielded a knife that he refused to drop despite repeated commands to do so. He then charged at the officers with the knife. One officer deployed a non-lethal taser against him, but it had no effect. The officers reasonably believed that Quinones-Rosario posed a serious threat to their safety. The officers fired more rounds when Quinones-Rosario survived the first round of shots and continued to approach the officers with the knife. The court concluded that their actions were a reasonable defensive response under the circumstances. View "Ashley Quinones v. City of Edina, MN" on Justia Law

Plaintiffs placed their child AMS at a private academy after the Chamberlain School District did not meet AMS’s needs. A state hearing examiner decided that Chamberlain violated federal law and awarded Plaintiffs costs associated with AMS’s placement at the academy. The district court affirmed.  The Eighth Circuit affirmed. Chamberlain argued that Plaintiffs weren’t eligible to remove the case from state court to federal court because they weren’t “defendants” under 28 U.S.C. Section 1441(a). The court explained that while Plaintiffs initially sought to recover from Chamberlain, their status changed when Chamberlain sought the state court’s review of the hearing examiner’s decision. At that point, Chamberlain became the plaintiff for removal purposes. Thus, because Plaintiffs were defendants, they were allowed to remove, so the district court didn’t err in denying remand. Further, the court explained that giving due weight to the outcome of the administrative proceedings, it concludes that Chamberlain denied AMS a FAPE. View "Judith Steckelberg v. Chamberlain School District" on Justia Law

In 2008, Taney County, through its Planning Commission, issued Emerald Pointe a permit to develop a gated community with private roads. Emerald Pointe subsequently began construction of the project. In 2016, the Planning Commission issued a stop-work order, demanding Emerald Pointe comply with requirements for certain public improvements. Emerald Pointe appealed to the Taney County Board of Adjustment (“BOA”), arguing the requirements did not apply to the permit. The BOA denied the appeal, and Emerald Pointe filed suit against the Planning Commission and BOA in the Circuit Court of Taney County, seeking judicial review of the stop-work order pursuant to Missouri Revised Statute Section 64.870. Emerald Pointe filed a lawsuit under Section 1983 for damages incurred while a stop-work order was in place. The district court dismissed the case after finding the suit barred by res judicata. Emerald Pointe appealed.
The Eighth Circuit affirmed. The court wrote that it applies Missouri res judicata law because the final judgment was issued by a Missouri court. Emerald Pointe could have brought the Section 1983 claim in the state court case. Emerald Pointe argues a Section 1983 claim could not have been added to the request for judicial review of the stop-work order under Missouri Revised Statute Section 64.870. Section 64.870 is the exclusive remedy for challenging the issuance of a stop-work order. However, nothing precludes a plaintiff from adding an additional claim to the state court case for judicial review. View "Emerald Pointe, LLC v. Taney County Missouri" on Justia Law

Plaintiff was held in pretrial custody at the Pulaski County Regional Detention Facility (the Jail) in Little Rock, Arkansas, for five weeks. After he was released, Plaintiff filed a suit for damages against a Pulaski County official, alleging deliberate indifference to his medical needs, unconstitutional conditions of confinement, and disability discrimination. The district court granted summary judgment to the defendant on all of Plaintiff’s claims.   The Eighth Circuit affirmed summary judgment on Plaintiff’s Section 1983 deliberate indifference and conditions-of-confinement claims. But because triable issues remain on Plaintiff’s disability discrimination claim under the ADA and ACRA, the court reversed and remanded for further proceedings. The court explained that the record shows that Plaintiff indeed submitted “grievances” to the Jail complaining, for example, that he could not “stand up,” that he lacked help “changing or cleaning” himself, and that he could not “transfer to a toilet [and] back to the chair.” Moreover, at least one of Plaintiff’s disabilities—his paraplegia and the concomitant need for accommodations—was “obvious.” Thus, a genuine issue of fact exists regarding whether the Jail was on notice that Hall needed accommodations. Further, the court wrote that A viewing the evidence in the light most favorable to Plaintiff, a reasonable factfinder could conclude that the Jail failed to provide him with meaningful access to beds, toilets, and the identified medical care services. View "Carlos Hall, Sr. v. Eric Higgins" on Justia Law

The Board of Trustees of the Nebraska State Colleges (“NSCS”) appealed from a jury verdict finding it acted with deliberate indifference after Jane Doe (“Doe”) was sexually assaulted while attending Chadron State College (“Chadron”). On appeal, NSCS raised three claims: (1) the Title IX claim fails as a matter of law; (2) the district court erred when it admitted the expert testimony of Dr. Charol Shakeshaft; and (3) the district court erred in awarding attorney’s fees. We begin with NSCS’s paramount claim that, as a matter of law, it was not deliberately indifferent after Doe reported being sexually assaulted.   The Eighth Circuit reversed and remanded with directions that the district court enter judgment in favor of NSCS and vacated the award of Doe’s attorney fees. The court explained that viewing the evidence in a light most favorable to the jury’s verdict, the uncontradicted evidence demonstrates that Chadron acted promptly—nearly immediately—upon learning of the assault. Chadron issued a mutually binding no-contact order between Doe and the accused, which was served on the accused at the end of his police interview. Chadron verified that the two students did not share the same classes and promptly initiated an investigation to determine what happened. Chadron interviewed Doe, explained the investigatory process to her, banned the accused from Andrews Hall, and accommodated Doe academically. Further, the court held that Doe cannot show a causal nexus between Chadron’s actions and the sexual assaults or harassment. View "Jane Doe v. Board of Trustees of the Nebraska State Colleges" on Justia Law