Justia Civil Rights Opinion Summaries

Plaintiff, then a conductor and now an engineer for Union Pacific Railroad (“Union Pacific”), brought this action under the Americans with Disabilities Act (“ADA”) when Union Pacific refused Plaintiff’s requests that he be allowed to bring his Rottweiler service dog on board moving Union Pacific freight trains as a reasonable accommodation to ameliorate the effects of Plaintiff’s undisputed disabilities, post-traumatic stress disorder (PTSD) and migraine headaches resulting from his prior service in the military. At the end of a week-long trial, the district court denied Union Pacific’s motion for judgment as a matter of law. The jury then returned a verdict for Plaintiff, awarding compensatory but not punitive damages. The district court granted Union Pacific’s renewed motion for judgment as a matter of law, concluding there is no legally sufficient evidentiary basis for the jury’s verdict.   The Eighth Circuit affirmed. The court agreed that “benefits and privileges of employment” (1) refer only to employer-provided services; (2) must be offered to non-disabled individuals in addition to disabled ones; and (3) does not include freedom from mental or psychological pain. Further, the court noted that mitigating pain is not an employer-sponsored program or service. As such, providing a service dog at work so that an employee with a disability has the same assistance the service dog provides away from work is not a cognizable benefit or privilege of employment. View "Perry Hopman v. Union Pacific Railroad" on Justia Law

Two brothers died in a car accident on the way to a school basketball tournament. The brothers were driving to a basketball tournament for their school, Park Christian. The team drove in a three-car caravan: Park Christian's assistant coach and head coach each drove a car of players, with the brothers’ car at the end. During the drive, the head coach cut off a semi-truck, and the semi-truck encroached into the next lane. To avoid a collision, the brothers veered into the median, rolled, and crashed. A Sergeant prepared a Crash Reconstruction Report for the Minnesota State Patrol and found that the brothers’ interaction with the semi-truck caused the accident   Their parents brought claims under 42 U.S.C. Sections 1983 and 1985(2) against Park Christian School, Park Christian administrators, the State of Minnesota, the Minnesota State Patrol, and Minnesota State Patrol officers. The district court dismissed their claims, and Plaintiffs’ appealed. Plaintiffs’ Rule 60.02(b) motion before the state courts alleged that there was a personal connection between the Sergeant and Park Christian which impacted the fairness and impartiality of the Sergeant's investigation and trial testimony   The Eighth Circuit affirmed. The court held that Rooker-Feldman does not apply and that collateral estoppel bars the Section 1983 claim. The court wrote that it is doubtful that the Section 1985(2) claim survives collateral estoppel. But for the purposes of this appeal, the court found that the Section 1985(2) claim fails on the merits. View "Raymond Kvalvog v. Park Christian School, Inc." on Justia Law

After an overnight stay at the Sheraton St. Paul Woodbury Hotel, Plaintiff sued the Schulte Hospitality Group, Inc. for discrimination and unfair reprisal. Plaintiff claimed he was locked out of the main entrance, greeted inhospitably, forced to provide proof of his Marriott-sponsored Bonvoy rewards program membership at check-in, assigned to a room with dirty bedding, required to bring it to the front desk to exchange for clean bedding, forced to change the bedding himself, and denied a request to switch rooms. The district court granted summary judgment to the Hotel because it provided unrebutted, non-pretextual justifications for its treatment of Plaintiff, and he did not show a causal link between his complaint of discrimination and the Hotel’s adverse actions. Plaintiff appealed.   The Eighth Circuit affirmed. The court explained that Plaintiff failed to show that the Hotel’s reasons are pretextual. He has not provided sufficient probative evidence to support a finding that his treatment in the Hotel was so at variance with the treatment expected of premium hotels during the early months of the COVID-19 pandemic. The district court properly granted summary judgment to the Hotel on the MHRA discrimination claim. Further, the court wrote that because Plaintiff cannot show that the Hotel called the police to escort him out of the Hotel because of his complaints, he failed to satisfy the third element of a prima facie case of MHRA unfair reprisal: “that the adverse action was causally linked to the protected conduct.” View "Larry Johnson v. Schulte Hosp. Group, Inc." on Justia Law

Plaintiff saw Defendant, an officer, pointing a firearm at her 12- and 14-year-old sons down the street from their family’s home. When Plaintiff approached to ask what happened, Defendant repeatedly ordered her to “get back.” After Plaintiff questioned the order, Defendant briefly pointed his taser at her. Plainitff then complied with his orders. Her sons were eventually cleared of any wrongdoing. Plaintiff filed a 42 U.S.C. Section 1983 action against Defendant, claiming he used excessive force. The district court granted summary judgment to Defendant on the claim after concluding he was entitled to qualified immunity. Defendant appealed.   The Eighth Circuit affirmed. The court explained that Defendant was placed in a position where he had two possibly armed suspects detained in front of him and a third unknown individual approaching from behind, creating a potentially serious safety risk. Adding to the circumstances, when Defendant ordered Plaintiff to “get back,” she moved to the side, but she did not immediately comply by moving backward. Rather, she questioned the order and moved sideways. Ordered to get back a second time, she again questioned the order and remained where she was until after the taser was drawn. Accordingly, the court wrote that under the totality of the circumstances, Defendant momentarily pointing his taser at Plaintiff to gain control of the scene was not unreasonable. View "Casondra Pollreis v. Lamont Marzolf" on Justia Law

Plaintiff commenced an action under 42 U.S.C. Section 1983, challenging the legality of the search and alleging several federal and state claims against various individuals pertaining to the “repeated, intentional harassment by officers of the Kansas City Missouri Police Department (“KCPD”) over the course of more than three years.” The issue of punitive damages had been raised earlier in the proceedings. During the instructions conference, Plaintiff objected to the district court’s failure to submit instructions on punitive damages, asserting the evidence established the defendants acted with reckless indifference to his constitutional rights. On appeal, Plaintiff contends the district court erred by failing to instruct the jury on punitive damages. He suggests that we should review his alleged error de novo. Without specifying a review standard, Defendant argues the merits of Riggs’ punitive damages claim.   The Eighth Circuit affirmed. The court held that a finding that an officer violated Plaintiff’s constitutional rights establishes liability under Section 1983, but it “does not necessitate a finding of callous indifference warranting punitive damages.” The court wrote that Plaintiff has failed to convince the court that the district court’s failure to sua sponte raise the issue of punitive damages after the verdict was received “seriously affected the fairness, integrity, or public reputation of the judicial proceedings” such that there would be “a miscarriage of justice if left uncorrected.” View "Micah Riggs v. Robert Gibbs" on Justia Law

Plaintiff sued Missouri prison officials under 42 U.S.C. Section 1983, alleging deprivations of his constitutional rights while incarcerated. The officials moved for summary judgment based on qualified immunity, and the district court denied the motion on two sets of claims. The officials appealed a portion of the order.   The Eighth Circuit reversed. The court explained that even assuming for the sake of analysis that Plaintiff enjoyed a clearly established liberty interest in avoiding assignment to administrative segregation, it was not clearly established that he was entitled to the procedures set forth in Wolff v. McDonnell, 418 U.S. 539. Further, the court explained that a reasonable official could have believed that the procedures applied in Plaintiff’s case were constitutionally sufficient. Informal due process requires only “some notice of the reasons for the inmate’s placement . . . and enough time to prepare adequately for the administrative review.” The procedures applied here meet the informal due process standard. The officials gave Plaintiff adequate notice of the reasons for his placement. The notice informed Plaintiff of his rights and identified the alleged victim, the date of the sexual assault, and the prison rule that he allegedly violated. View "James Spann v. George Lombardi" on Justia Law

Plaintiff filed a Section 1983 lawsuit against several defendants, including agents of the Grand Forks Narcotics Task Force (“GFNTF”). Plaintiff alleged two Fourth Amendment violations: (I) the warrant was based upon deliberate falsehood or reckless disregard for the truth -- the use of the informant to develop and generate false evidence incorporated in an affidavit; and (ii) Defendants deprived Plaintiff of a preliminary hearing at which Plaintiff would have been discharged because the warrant was not supported by probable cause. Plaintiff appealed the grant of summary judgment dismissing these claims.   The Eighth Circuit affirmed. The court agreed with the district court that the affidavit provided probable cause to arrest Plaintiff, even if corrected to include the information Plaintiff alleged was recklessly omitted. The court explained that there is no evidence any of the defendants knew about the false “murder-for-hire” allegations when the warrant affidavit was submitted. An agent does not “violate a clearly established constitutional right by omitting information from a warrant application that he does not actually know, even if the reason is his own reckless investigation.” As Plaintiff’s subsequent, lengthy investigation of the informant makes clear, minimal further investigation into the informant’s criminal history would not have exonerated Plaintiff. View "Henry Howe v. Steven Gilpin" on Justia Law

This case started more than fifty years ago when Minnie Liddell sued to desegregate the St. Louis public school system. The NAACP joined the lawsuit, and the State of Missouri (among others) became a defendant. The parties struck a deal that lasted until 1999 when they agreed to end Missouri’s remedial obligations. The Missouri Legislature ratified the parties’ settlement agreement and created a charter-school option. A group of charter schools complained to the Missouri Legislature, which altered the funding formula in 2006. The revised formula, part of Senate Bill 287, is what has led to the current dispute. The St. Louis Public School District and one of the plaintiffs asked the district court to enforce the settlement agreement by having Missouri reimburse it for the special-sales-tax revenue it had lost under the new funding formula. The district court sided with Missouri, and both sides appealed. Plaintiffs continued to believe that the St. Louis Public School District should receive all the special-sales-tax revenue. And Missouri argued that the desegregation-spending condition finds no support in the settlement agreement.   The Eighth Circuit affirmed the district court’s judgment but vacated the part requiring charter schools to spend those funds on “desegregation measures.” The court explained that there has been no “disproportionate adverse financial impact” on the St. Louis Public School District because it never had a right to keep all the special-sales-tax revenue for itself. Moreover, the court rejected the argument that allowing charter schools to spend their money as they see fit is inconsistent with the “purpose” of the settlement agreement. View "Deric Liddell v. State of Missouri" on Justia Law

Plaintiff, a former pretrial detainee in the custody of the Ozark County Sheriff’s Department, filed an action pursuant to 42 U.S.C. Section 1983 claiming that Defendants acted with deliberate indifference to Plaintiff’s serious medical needs by denying him prescription medication. Defendants moved for summary judgment on the basis of qualified immunity. The district court denied the motion.   The Eighth Circuit affirmed. The court explained that Plaintiff has sufficiently demonstrated that Defendants were subjectively aware of but disregarded a serious medical need. The facts construed in the light most favorable to Plaintiff show that the “defendants, who are not medical personnel, substituted their controlled substance ‘policy’ and their schedule for administering or failing to administer medication for that of a treating physician.” Further, Defendants failed to administer or misadministered the medication to Plaintiff despite knowing a doctor prescribed them and despite Plaintiff’s repeated requests for his medication. Construing the facts in the light most favorable to Plaintiff, his “right to adequate treatment was clearly established, and the district court properly denied Defendants qualified immunity. View "Tracy Presson v. Darrin Reed" on Justia Law

This appeal concerns the scope of a landlord’s duty under the Fair Housing Amendments Act of 1988 to make “reasonable accommodations” for the “handicap” of a tenant. The City of Dubuque approved a measure allowing the local public housing authority to provide residents of mobile-home parks with housing choice vouchers that could be used to supplement their rent payments. Under this voucher program, the federal government provides funds to local public housing agencies, which in turn may distribute them to low-income tenants. As the rent on Plaintiff’s lot increased, she received a voucher and sought to use it to supplement her rent payments, but the companies declined to accept the voucher. Plaintiff requested an injunction requiring the companies to accept her housing choice voucher, and she sought damages for alleged emotional distress. Plaintiff also brought claims under state laws.   The Eighth Circuit vacated the injunction. The court concluded that while the statute requires a landlord to make reasonable accommodations that directly ameliorate the handicap of a tenant, the obligation does not extend to alleviating a tenant’s lack of money to pay rent. The court wrote that the term “reasonable accommodation” is not defined in the statute, but it was adopted against the backdrop of a predecessor statute and must be viewed in the context of a law that forbids discrimination “because of a handicap.” View "Suellen Klossner v. IADU Table Mound MHP, LLC" on Justia Law