Justia Civil Rights Opinion Summaries

Someone shot a St. Louis fire captain and his passenger. The fire captain described the shooter as a “black male,” once on a 911 call right after the shooting, again when responding officers arrived on the scene, and again to an officer at the hospital. He did not give that description to Detective Bowles, who investigated the case. Bowles focused his attention on the Hartman brothers, who are white. Nearby cameras had captured them driving in the area and then stopping shortly before the shooting. Based on this evidence, Detective Bowles requested multiple search and arrest warrants. The paperwork Bowles submitted omitted the fact that the fire captain had described the shooter as black.The brothers were eventually released and sued Bowles, citing the Fourth Amendment, 42 U.S.C. 1983. The Eighth Circuit affirmed the dismissal of the suit. A detective 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. To succeed, the Hartmans had to show that Bowles omitted facts “with the intent to make, or in reckless disregard of whether they make, the affidavit misleading.” Bowles is entitled to qualified immunity. View "Hartman v. Bowles" on Justia Law

Isaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings. View "Torres v. Coats" on Justia Law

Plaintiff was diagnosed with a reducible ventral hernia while detained awaiting trial at the Greene County Justice Center in Missouri. Although his hernia could be repaired through surgery, Plaintiff was unable to prepay the fee required by the outside surgeon and thus the hernia was not repaired during his detention.   Plaintiff filed suit under 42 U.S.C. Section 1983 against the Greene County Sheriff’s Department and its contract healthcare service provider, Advanced Correctional Healthcare, Inc. (ACH), as well as several individuals employed by those entities (collectively, jail officials). Plaintiff claimed that the jail officials were deliberately indifferent to his serious medical need. The district court granted summary judgment in favor of Defendants.   The Fourth Circuit affirmed the grant of summary judgment. The court explained that to establish deliberate indifference Plaintiff was required to show (1) that he suffered from an objectively serious medical need and (2) that the jail officials had actual knowledge of that need but deliberately disregarded it. The court explained that Plaintiff submitted no medical or expert evidence that any delay in his hernia repair surgery created any excessive risk or harm. Plaintiff argued that his own claims of pain and suffering constitute the verifying medical evidence needed to show harm from the delay. Without corroborating evidence of symptoms, however, self-reported assertions of pain are insufficient to survive summary judgment.   Further, despite Plaintiff’s subjective reports of pain, objective observations did not indicate that he was in severe pain or forced to limit his activities. Thus, the court held that Plaintiff has not demonstrated that jail officials disregarded a known risk to his health. View "Michael Hancock v. Jim Arnott" on Justia Law

The Eighth Circuit affirmed the district court’s approval of a settlement between Defendant Monsanto and Plaintiffs. The court held that the district court did not abuse its discretion in concluding the notice to the class was sufficient or in concluding that payment to class members of 50% of the average weighted retail price of the items they purchased fully compensated the class members.    Plaintiffs filed suit pleading multiple claims arising out of the allegedly deceptive labeling of Roundup products manufactured by Monsanto. The parties agreed to a total Common Fund. They agreed that Monsanto would not object to Plaintiffs’ counsel seeking 25% of that amount as an attorney’s fee. Class members who filed claims were to receive 10% of the average retail price for the product(s) they bought, and any remaining funds after the costs of administration would be distributed cy pres. The parties executed a Second Corrected Class Action Settlement Agreement that made four changes to the initial agreement.   Appellant, a party injured by Roundup, made three objections to the settlement, all of which she renewed on appeal. First, she argued that the district court should have (1) required the parties to take additional steps to identify additional class members and (2) increased the pro-rata portion of the Common Fund up to 100% of the weighted average retail price. The court held the district court did not abuse its discretion in concluding that notice to the class was sufficient in light of the comprehensive notice plan and the estimated results from the claims administrator.Further, the court wrote that cy pres distribution of residual funds pursuant to the settlement agreement neither constitutes speech by any individual class member nor infringes on their First Amendment rights. View "Lisa Jones v. Anna St. John" on Justia Law

Following a traffic stop during which Plaintiff was cited for driving with an open liquor bottle in his car, he filed suit against the Des Moines Police Department officers involved in the stop Officers as well as the City of Des Moines Chief of Police, and the City of Des Moines (collectively “Defendants”), alleging claims under state and federal law for violation of his constitutional rights.   The district court granted summary judgment in favor of Defendants and denied Plaintiff’s request to certify questions to the Iowa Supreme Court and his motion for reconsideration. Plaintiff argued that the district court erred in granting summary judgment to the officers based on qualified immunity on his federal and state claims for an unreasonable seizure.   The Eighth Circuit affirmed the district court’s ruling. The court wrote that because Plaintiff failed to raise a genuine issue of material fact as to whether the officers unreasonably prolonged the stop, the district court did not err in granting summary judgment on the basis of qualified immunity to the officers on this claim.   Next, Plaintiff asserted that the district court erred in granting summary judgment to the officers based on qualified immunity on his federal and state claims for racial profiling. The court affirmed holding that because Plaintiff failed to show that the officers were motivated in any part by Plaintiff’s race, the court need not conclusively resolve this issue to determine that Plaintiff failed to raise a genuine issue of material fact necessary. View "Courtney Saunders v. Kyle Thies" on Justia Law

On remand, the Supreme Court directed the Eighth Circuit to “to employ an inquiry that clearly attends to the facts and circumstances” of the incident between Plaintiffs’ son and the officers in considering whether the officers used unconstitutionally excessive force or, if they did, whether the Plaintiffs’ son’s right to be free of such force in these circumstances was clearly established at the time of his death.   The court affirmed the district court’s ruling and concluded that the officers are entitled to qualified immunity because the right in question was not clearly established at the time of Plaintiffs’ son’s death and the City is not liable for a policy of deliberate indifference in the absence of a clearly established constitutional right.   The court explained that the Supreme Court has never addressed whether prone restraint generally, or a particular use of prone restraint, more specifically, is unconstitutional. And the Supreme Court has never answered the question of whether a right may be clearly established without a Supreme Court case specifically recognizing it. Thus, assuming, as the Supreme Court has, that a court of appeals decision may constitute clearly established law, the precedent in this area is insufficient to demonstrate that the facts, in this case, show a violation of a clearly established right of a detainee to be free from prone restraint while resisting.   Thus, the Plaintiffs’ son’s right to be free from prone restraint while engaged in ongoing resistance, even where officers applied force to various parts of his body, including his back, was not clearly established in 2015 when the incident occurred. View "Jody Lombardo v. City of St. Louis" on Justia Law

In response to the COVID-19 pandemic, Minnesota Governor Tim Walz declared a state of “peacetime emergency” and began issuing executive orders (EOs) intended to combat the spread of the virus. The EOs limited which types of businesses could continue operations and, later, specified the capacities at which those businesses could operate. Plaintiffs, three Minnesota businesses and their respective owners, suffered financial losses during the COVID-19 pandemic while these EOs were in effect. Plaintiffs brought an Equal Protection Clause claim against Governor Walz and Minnesota’s Attorney General, in their official capacities and a Takings Clause claim against Governor Walz in his individual capacity, which the district court dismissed.   The Eighth Circuit affirmed the dismissal. The court found that in 2020, the law was not clearly established such that Governor Walz would have understood that his issuance of the challenged EOs violated Plaintiffs’ constitutional right to just compensation for a government taking. The court explained that Plaintiffs have not offered anything that supports their hypothesis that Governor Walz will, first, declare a second peacetime emergency and, then, will issue additional EOs—specifically, EOs like 20-74 that, in their view, treat them differently than other, similarly situated businesses and impede them from conducting their businesses as they wish. The court further wrote that it need not parse through whether or not a taking occurred, however, because even assuming that a taking did occur, whatever its type, Plaintiffs have offered nothing to support their contention that, in 2020, the law was clearly established such that Governor Walz would have understood that his EOs constituted a taking. View "Glow In One Mini Golf, LLC v. Tim Walz" on Justia Law

Plaintiffs appealed the district court’s grant of summary judgment on the basis of qualified immunity to Iowa Department of Human Service (DHS) employees (collectively, “Defendants”) on Plaintiffs’ claim for damages under 42 U.S.C. Section 1983 for violation of their right to due process. Specifically, Plaintiffs alleged that Defendants failed to afford them an opportunity to be heard on child abuse allegations prior to issuing a founded child abuse report and placement on the Iowa Child Abuse Registry (Registry).   On appeal, Plaintiffs contended the district court erred in concluding that the right to be informed of child abuse allegations and an opportunity to respond to such allegations prior to issuing a founded child abuse report and placement on the Registry was not clearly established. The Eighth Circuit affirmed the district court’s grant of summary judgment to Defendants on the basis of qualified immunity. The court held that Plaintiffs have not proven that the law was clearly established such that Defendants should reasonably have been expected to know that the interim finding of founded child abuse pending the interviews of the Plaintiffs violated their right to due process. View "Billie Hovick v. Darci Patterson" on Justia Law

Plaintiff sued Defendant, a law enforcement officer employed by the United States Immigration and Customs Enforcement agency (ICE). Martinez claims that Sasse violated her rights under the Fourth Amendment by effecting a seizure through the use of excessive force. Sasse moved for judgment on the pleadings and argued that she was entitled to qualified immunity. denied the motion, reasoning that Martinez’s allegations stated a claim for the violation of a clearly established right.   The Eighth Circuit reversed and remanded the case with directions to dismiss the Fourth Amendment claim against Defendant. The court concluded that Plaintiff has not adequately pleaded that Defendant violated a clearly established right, because it was not clearly established as of June 2018 that Defendant’s alleged push was a seizure under the Fourth Amendment. Accordingly, Defendant is entitled to qualified immunity. The court explained that although the claim here alleges the use of excessive force, the parties dispute the threshold question of whether Defendant seized Plaintiff at all within the meaning of the Fourth Amendment. Plaintiff argues that Defendant effected a seizure when she pushed Plaintiff to the ground before locking the doors to the ICE facility. Defendant maintains, however, that when an officer’s use of force is designed only to repel a person from entering a facility, there is no seizure. On that view, Plaintiff may have a tort claim against Defendant for assault or battery if the officer used unjustified force, but Defendant did not violate the Fourth Amendment. View "Andrea Martinez v. Ronnet Sasse" on Justia Law

Plaintiff a former part-time employee of the City of Cedar Falls, brought an action against the City of Cedar Falls and certain city officials after her 2018 termination, alleging interference with and retaliation for the exercise of her rights under the Family and Medical Leave Act (FMLA) and claims of age discrimination, disability discrimination, hostile work environment, and retaliation under the Iowa Civil Rights Act (ICRA). The district court granted summary judgment in favor of Defendants on all of Plaintiff’s claims, and she appealed.
The Eighth Circuit affirmed. The court explained that it need not consider the substantive elements of the claim because Plaintiff has failed to demonstrate that she sustained any recoverable damages and it is undisputed that she did not seek any form of equitable relief.   Second, as to the retaliation claim, the court applied the McDonnell Douglas burden-shifting framework, which requires a plaintiff to make a prima facie showing of retaliation before the burden shifts back to the employer to offer a legitimate, non-discriminatory reason for its actions. Here, Plaintiff has failed to put forth any evidence of the kind that would demonstrate pretext. She offered nothing more than disagreement with the statements contained in the disciplinary reports. In the absence of any factual record demonstrating that these documented performance deficiencies were inaccurate, Plaintiff has failed to meet her burden of demonstrating pretext. Finally, Plaintiff has failed to show that the final three disciplinary reports were part of the same unlawful employment practice—harassment based on her age and disability. View "Michelle Brandt v. City of Cedar Falls" on Justia Law