Justia Civil Rights Opinion Summaries

Philander Smith College fired Plaintiff after she referred to a student as “retarded” for using a cell phone during class. She sued for sex discrimination, retaliation, and breach of contract. After granting summary judgment to the college on the first two claims, the district court declined to exercise supplemental jurisdiction over the third.   The Eighth Circuit affirmed. The court held that Plaintiff has not put forward sufficient evidence of pretext. So summary judgment marks the end of the road for her sex-discrimination claim. Further, the court reasoned that even if the conditions were intolerable, in other words, Plainitff’s own role in provoking these incidents undermines the claim that the college created a workplace full of discriminatory intimidation, ridicule, and insult. Moreover, the court explained once Plaintiff’s federal claims were gone, the district court had no obligation to exercise supplemental jurisdiction over Plaintiff’s Arkansas breach-of-contract claim. View "Patricia Walker-Swinton v. Philander Smith College" on Justia Law

Plaintiff, a Minnesota prisoner, sued several officials of the Minnesota Department of Corrections, alleging that they violated his constitutional rights by failing to protect him from an attack by a fellow inmate. The district court granted summary judgment for the officials. Defendant appealed the dismissal of his Eighth Amendment claims.   The Eighth Circuit affirmed. The court agreed with the district court that the evidence is insufficient to show that any of the defendant officials subjectively concluded that Plaintiff faced a substantial risk of serious harm and then failed to respond reasonably to it. The unrebutted evidence is that the two voting officials on the incompatibility committee considered incident reports and other relevant information but decided that the situation did not rise to the level of incompatibility—that is, they concluded that the evidence did not indicate a risk of serious bodily injury to an offender. This means that the officials did not draw the subjective inference that there existed a substantial risk of serious harm to Plaintiff. The officials predicted incorrectly, but they were not deliberately indifferent for the purposes of the Eighth Amendment. View "David Hodges v. Minnesota Dept. Corrections" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment to Defendant, Baptist Health, on her sex-discrimination, retaliation, hostile work environment, constructive-discharge, and negligent-retention claims. After the individual defendant was dismissed as a defendant, Baptist Health moved for summary judgment, and the district court granted its motion.   The Eighth Circuit affirmed. The court first explained that here, Plaintiff presented no evidence that Baptist Health intended to force her to quit. Rather, the record indicates that Baptist Health tried to retain Plaintiff by giving her paid administrative leave, offering to relocate her to a different location, and offering to transfer her to a new department. Thus, the district court did not err in granting summary judgment to Baptist Health on this claim.   Second, the court held that Plaintiff’s sex-discrimination and retaliation claims fail because she has not suffered an adverse employment action. Baptist Health offered for Plaintiff to keep her same job at any one of three locations or to transfer departments. The court wrote that Plaintiff has not shown that transferring to another department would produce a material employment disadvantage.   Third, the court found that the district court did not err in granting summary judgment to Baptist Health on this claim because there is no evidence that the alleged discrimination was based on sex. Finally, the court found that the evidence does not suggest that Baptist Health subjected her to any unreasonable risk of harm. View "Courtnay Bell v. Baptist Health" on Justia Law

Plaintiff fled when Defendant police officer stopped him based on an outstanding warrant for fifth-degree theft. At the nearby police station, Plaintiff briefly refused to obey Defendant’s command to exit the squad car and proceed to the station for booking. When the handcuffed Plaintiff finally exited the car and stood up, Defendant struck him with his fist on the back of the head and neck. Plaintiff brought this action for excessive force under 42 U.S.C. Section 1983 and asserted pendent Iowa state law claims for tortious assault and battery. The district court granted summary judgment dismissing both claims on the ground that the force used was objectively reasonable. Alternatively, the court ruled that Church was entitled to qualified immunity on the federal Section 1983 claim because any constitutional violation was not clearly established. Plaintiff appealed.   The Eighth Circuit concluded that genuine issues of disputed facts preclude a determination, on this summary judgment record, of whether the alleged unlawful use of excessive force was objectively reasonable and, if not, whether the violation was clearly established at the time of the incident in question. Accordingly, the court reversed the dismissal of all claims, including Plaintiff’s pendent state law claims. View "Derek Westwater v. Kevin Church" on Justia Law

While in jail, Plaintiff clawed at his own eye with enough force to tear it out. Plaintiff sued nearly everyone involved, including St. Charles County, under 42 U.S.C. Section 1983. The district court concluded that none of the individuals involved had violated his Fourth, Eighth, or Fourteenth Amendment rights. Nor, in the absence of a constitutional violation or a county-wide custom of unconstitutional conduct, was St. Charles County liable for his injuries. The question is whether qualified immunity is available to those who may have prevented the injury.   The Eighth Circuit affirmed the district court’s judgment. The court explained that the record is devoid of evidence that the Officer and Sergeant consciously disregarded a serious medical need. And even if the Nurse’s failure to administer Plaintiff’s medications approached criminal recklessness, the court wrote, it cannot say that the law was so “clearly established” that she was on “fair notice” she was violating it. Further, Plaintiff cannot point to any court that has held that an officer was deliberately indifferent because he placed a pepper-sprayed inmate in a new cell with a sink. View "Jamie Leonard v. Steven Harris" on Justia Law

The decedent, while detained at the Washington County Jail (“WCJ”), committed suicide by jumping from a height. Plaintiff, as trustee for the decedent’s next of kin, brought an action under 42 U.S.C. Section 1983 against Washington County and WCJ employees. The individual Defendants appealed the district court’s denial of qualified immunity. At issue is whether the uncontroverted measures taken by WCJ were so inadequate as to be deliberately indifferent to the decedent’s risk of suicide.   The Eighth Circuit reversed. The court reasoned that a review of the undisputed evidence demonstrates that the preventative measures taken by WCJ were not so inadequate as to constitute deliberate indifference. C400 was specifically designated to hold suicidal inmates for close observation. This area had cameras and large windows, allowing for constant observation of the decedent. Further, neither the history of jump attempts at WCJ nor the correctional officers’ failure to report the decedent’s earlier effort to climb the stairs raises a material fact question, given the few jump attempts that have occurred at WCJ over the course of several years and that inmates climb C400’s stairs for innocent reasons. Further, because there is no cognizable constitutional violation, there is no basis for Monell liability. View "Lisa Brabbit v. Frank Capra" on Justia Law

Officers in an armored police vehicle shot tear gas at three people near the scene of a protest in downtown St. Louis. The district court concluded that all three had a First Amendment retaliation claim.   The Eighth Circuit affirmed in part, reversed in part, and remanded. The court agreed that one Plaintiff has a valid First Amendment retaliation claim, but qualified immunity shields the officers from the claims brought by the others. Two of the Plaintiffs claimed that the First Amendment covers what they did, which was to observe and record police conduct during the St. Louis protest. The court wrote that even if it were to assume they are correct, observing and recording police-citizen interactions was not a clearly established First Amendment right in 2015. Further, in regard to Plaintiffs’ peaceful-assembly theory. The court reasoned even if the officers “unreasonably believed” that the group was refusing to comply with their earlier directions to disperse, their official orders—not retaliatory animus—caused them to use the tear gas.   However, in regard to the third Plaintiff, the court explained at this stage, there is enough evidence to establish the “personal involvement” of everyone in the armored vehicle. To be sure, Plaintiff could not see who launched the tear gas canister. But with multiple “officers present,” the jury could find that each one of them participated in the decision or that one did it “while the others failed to intervene.” Under these circumstances, the claims against the individual officers can proceed. View "Sarah Molina v. Daniel Book" on Justia Law

Defendant appealed a judgment of the district court committing him to the custody of the Attorney General for medical care and treatment under 18 U.S.C. Section 4246. The court found that Defendant presently suffered from a mental disease or defect as a result of which his release from custody posed a substantial risk of bodily injury to another person or serious damage to the property of another.   The Eighth Circuit affirmed, concluding that the findings underlying the commitment were not clearly erroneous. The court explained that the district court’s finding that Defendant posed a substantial risk to persons or property was adequately supported in the record. The court relied on the unanimous recommendation of the experts. The experts observed that the most reliable predictor of future violence is past violence, and they detailed Defendant’s history of random and unpredictable violent actions. The court further found that the parties have not made a sufficient showing to justify sealing the briefs in this appeal. View "United States v. Dewayne Gray" on Justia Law

Plaintiff filed a 42 U.S.C. Section 1983 lawsuit stemming from her son’s death while under the supervision of employees at an Arkansas jail. She alleged that Defendants were deliberately indifferent to her son’s serious medical needs. The district court denied Defendants’ motion for summary judgment based on qualified immunity.   The Eighth Circuit reversed. The court explained that it disagreed with the district court’s opinion that a layperson would recognize seizure-like activity as a serious medical need that one of the Defendant’s deliberately ignored. The court reasoned that a reasonable jury could not conclude from this description of events that Defendant was aware of a serious medical need. Second, a reasonable officer would not necessarily infer that seizure-like activity in these circumstances required him to take additional action. The decedent was behaving normally at booking, though very thirsty and reportedly under the influence of methamphetamine. It isn't unreasonable to believe that whatever medical episode he experienced during transport (if he actually experienced one) had fully resolved itself by the time Defendant encountered him.   Further, the court explained that in these circumstances, Defendants can't be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments. And even though the decedent was obviously sick, recognizing that someone is sick is not the same as knowing that he is receiving inadequate care from a trained medical professional. View "Donna Reece v. S. Williams" on Justia Law

Appellant brought a variety of state and federal claims against the City of Waynesville (the City), the Waynesville Police Department (WPD), WPD Chief, WPD Officers, and Pulaski County Prosecutor (collectively, Appellees). The district court dismissed most of Appellant’s claims pursuant to Federal Rule of Civil Procedure 12(b)(6), and later granted the Appellees’ motion for summary judgment on Appellant’s remaining claims. Appellant appealed the grant of summary judgment. Appellant conceded that his unreasonable seizure and conspiracy-to-cause-false-arrest claims do not involve the officer. Additionally, Appellant clarified that his appeal of the unreasonable search claim is limited to “the district court’s determination about the computer and home searches.”   The Eighth Circuit affirmed. The court held that, at minimum, it was objectively reasonable for the police Chief and Officer to believe that Appellant had committed or was committing a violation of Mo. Rev. Stat. Section 455.085.2, Mo. Rev. Stat. Section 565.090.1 or Mo. Rev. Stat. Section 565.225.2-3. Accordingly, arguable probable cause exists, meaning that it was not clearly established that arresting Appellant on these facts would violate his right to be free from unlawful seizure. Thus, the court affirmed the district court’s grant of summary judgment on Appellant’s unreasonable-seizure claim because Appellees are entitled to qualified immunity.   Further, the court concluded that reasonable suspicion supported the search of Appellant’s house. Moreover, because there is only one minor inaccuracy in the otherwise thorough search warrant affidavit for Appellant’s computer, and the issuing judge found that there was enough evidence to support a finding of probable cause, that judgment is entitled to deference on appeal. View "Dennis Ryno v. City of Waynesville" on Justia Law