Justia Civil Rights Opinion Summaries

Plaintiff, a Missouri inmate currently in custody at the Northeast Correctional Center (“NECC”), filed a pro se Section 1983 action against multiple defendants, claiming deliberate indifference to his serious medical needs and retaliation for filing grievances. The district court granted Plaintiff’s motion to proceed in forma pauperis on his individual capacity claims against Defendant, an employee of the Missouri Department of Corrections serving as food service manager at NECC during the time in question. After discovery, Defendant moved for summary judgment dismissing Plaintiff’s Complaint. As noted, Defendant argued that summary judgment was warranted because undisputed facts show that Defendant was not responsible for discontinuing Plaintiff’s Renal Diet.   The Eighth Circuit vacated a portion of the district court’s order granting summary judgment in favor of Defendant. The court explained that Defendant asserted exhaustion as an affirmative defense in his separate answer to Plaintiff’s complaint. In granting summary judgment, the district court did not consider exhaustion because it did not address Plaintiff’s 2015-2018 interference and retaliation claims. Thus, that issue remains open on remand. View "Kenneth Charron v. Larry Allen" on Justia Law

Defendant was convicted of five offenses related to trafficking methamphetamine. He filed a post-conviction motion for a new trial, alleging a violation of the court’s trial procedure order and a Brady violation. The district court denied the motion and sentenced Defendant to 295 months in prison. He appealed, challenging the denial of his motion and the substantive reasonableness of his sentence.   The Eighth Circuit affirmed. The court explained that there is nothing in the record reflecting what one of the government’s witnesses learned or whether it affected his testimony, another witness’s testimony, or Defendant’s rights. As a result, Defendant’s argument that he was prejudiced by the still-undefined discussion is baseless, and the district court did not abuse its discretion by denying the motion for a new trial.   Next, Defendant argued that the DEA affidavit is favorable evidence because it provides a basis for impeaching Defendant’s cellmate and because it suggests that someone else, was responsible for trafficking drugs. The court held that because the evidence is immaterial to the outcome of the case, the Government’s failure to disclose the DEA affidavit was not a Brady violation. Accordingly, the district court did not err in denying the motion for a new trial.   The court further concluded that the district court did not abuse its discretion by denying Defendant’s request for a downward variance. The court addressed Defendant’s arguments, considered all relevant factors, and concluded that a downward variance was not justified. View "United States v. Jason Corey" on Justia Law

Plaintiffs, filed suit against Arkansas, patrolman in his individual capacity.  Plaintiffs pleaded claims under 42 U.S.C. Section 1983, alleging that the patrolman had violated their constitutional right to be free from unreasonable searches and seizures. Plaintiffs also sued the Wynne police chief, and the mayor, in their individual capacities, for failing to supervise the patrolman.   Defendants moved for summary judgment based on qualified immunity. The district court denied the motion. The Eighth Circuit reversed. The court held that Defendants are entitled to qualified immunity unless their actions violated a constitutional right that was clearly established. The court concluded that Plaintiff has not set forth evidence showing that the patrolman is responsible for the alleged Fourth Amendment violations.   Further, Plaintiffs allege that the Police Chief and Mayor are liable for the patrolman’s alleged unconstitutional acts because they had received notice of his behavior and failed to stop it. A supervising officer may be liable for the actions of his subordinates when “he (1) had ‘notice of a pattern of unconstitutional acts committed by subordinates’; (2) was deliberately indifferent to or tacitly authorized those acts; and (3) failed to take ‘sufficient remedial action’; (4) proximately causing injury to” the plaintiffs. Here, no evidence in the record supports a finding that either the Chief or Mayor subjectively knew of and deliberately disregarded a substantial risk of unconstitutional harms posed by the patrolman. View "Dana Harrison v. Brodie Faughn" on Justia Law

City Union Mission is a Kansas City, Missouri nonprofit organization located near Margaret Kemp Park that provides food, shelter, employment, and a Christian discipleship program to poor and homeless individuals. A Missouri law prohibits persons convicted of certain sex offenses (Affected Persons) from being present in or loitering within 500 feet of any public park containing playground equipment. After the Jackson County Sheriff’s Office informed City Union Mission that the statute prohibited some of its guests from being present within 500 feet of the park, even when receiving City Union Mission’s charitable services, City Union Mission filed suit, bringing 12 claims against the Jackson County Sheriff’s Office, Jackson County, and the Sheriff in his official capacity (collectively, the County), as well as one claim against the Sheriff in his individual capacity. The State of Missouri (the State) intervened, and the district court dismissed City Union Mission’s 12 claims against the County and granted summary judgment on City Union Mission’s claim against Sheriff Sharp in his individual capacity, finding that Sheriff Sharp was entitled to qualified immunity.   The Eighth Circuit affirmed and concluded that City Union Mission’s claims seeking broad injunctive relief prohibiting Sheriff Sharp and Jackson County from “enforcing or threatening to enforce” Section 566.150 against City Union Mission or Affected Persons are moot. Further, City Union Mission did not direct the court to any case that clearly establishes its constitutional right to provide services to Affected Persons within 500 feet of a park with playground equipment. View "City Union Mission, Inc. v. Mike Sharp" on Justia Law

Kansas City Officer (“Officer”) shot and killed the victim during a foot chase. Family members of the victim filed suit and the district court concluded that the Officer was entitled to both qualified and official immunity. In addition to contesting the grant of summary judgment on appeal, Plaintiffs argued they should receive a trial on their claims against the Kansas City Board of Police Commissioners and the other municipal officials named in their complaint.   In evaluating the family’s excessive-force claim against the Officer, the Eighth Circuit affirmed the district court’s decision. The court explained that the key issue requires answering whether the officer’s actions violated a constitutional right and then whether the right was clearly established. The court reasoned that the Supreme Court has explained that “the focus” of the clearly-established-right inquiry “is on whether the officer had fair notice that [his] conduct was unlawful.” Kisela v. Hughes, 138 S. Ct. 1148 (2018). Here, “judged against the backdrop of the law at the time of the conduct,” a reasonable officer would not have had “fair notice” that shooting the victim under these circumstances violated the Fourth Amendment.     Additionally, to prevail in this case under Kisela, the family would need to establish “the right’s contours were sufficiently definite that any reasonable official in the defendant’s shoes would have understood that he was violating it.” Here, the family failed to show that the Officer acted in bad faith or with malice. Finally, there is not enough evidence to find that the municipal defendants liable under a deliberate indifference theory. View "N.S. v. Kansas City Board of Police" on Justia Law

Plaintiff sued her former employer, the University of Minnesota, under the Americans with Disabilities Act (“ADA”), for discrimination based on her disability, failure to provide a reasonable accommodation for her disability, and retaliation. The district court granted summary judgment to the University.The Eighth Circuit affirmed the district court’s ruling. The court first addressed whether Plaintiff met her burden to show that the University failed to provide a reasonable accommodation; specifically, whether Plaintiff qualified for any alternative positions. The court held that Plaintiff did not meet her burden, reasoning that she did not submit the job posting, the job title, or any evidence of the duties or requirements of any position.Further, the court addressed whether the University failed to engage in the interactive process. The court concluded that there is no genuine dispute of material fact about whether the University acted in good faith to make reasonable accommodations for Plaintiff. The University offered to help Plaintiff find a new job many times and considered adopting technologies to help Plaintiff perform her job duties. Once the University realized Plaintiff could not be accommodated in her current position, an employee from the job center reached out to Plaintiff to schedule a meeting about vacant positions. But Plaintiff cancelled it, and the rescheduled meeting could not take place because Plaintiff went on full-time medical leave. Moreover, even if the University did not use good-faith efforts, Plaintiff needed to show that she “could have been reasonably accommodated but for the employer’s lack of good faith.” View "Jessica Ehlers v. University of Minnesota" on Justia Law

Defendants, Des Moines Police Department officers, lacking probable cause, took relatives of a stabbing victim to the station and held them for over three hours during which time the victim died. The district court denied qualified immunity, ruling for the family on their claims of illegal seizure and false arrest.   The Eighth Circuit affirmed the district court’s denial of qualified immunity. The court held both the duration and the nature of the seizure at issue exceeded the bounds of the Constitution.   The court reasoned that officers are entitled to qualified immunity unless (1) the evidence, viewed in the light most favorable to the plaintiffs, establishes a violation of a constitutional or statutory right, and (2) the right was clearly established at the time of the violation, such that a reasonable official would have known that his actions were unlawful.  Here, the officers seized the family against their will and without probable cause. There was no “reasonable ground” for the officers’ action.   The court concluded that there was no minimally-intrusive Terry stop and the detention was the most intrusive means of questioning survivors after a violent crime. Further, officers of the Des Moines Police Department were on notice that they could not detain someone for questioning against their will, even in a homicide investigation, absent probable cause.  The same evidence establishes the officers’ violation of sec. 1983 and the Fourth Amendment establishes a violation of the Iowa Constitution. View "Crysteal Davis v. Trevor Spear" on Justia Law

Plaintiff claims his former employer, the Transit Authority of the City of Omaha (“Metro”), discriminated against him based on his disability and retaliated against him for engaging in protected activity. Metro appeals the district court’s denial of its motion for judgment as a matter of law.Defendant argues that Plaintiff did not disclose the witness as an expert and it only learned the witness was a LIMHP at her trial deposition. The court reasoned that under Rule 26, non-retained experts are subject to less stringent disclosure requirements than retained experts. Further, the contents of the witness’ testimony were disclosed at the beginning of the case. Plaintiff provided what he thought was accurate information at the time of initial disclosures. Thus, the district court did not abuse its discretion in admitting the witness’s testimony because she testified as a treating practitioner only.The court affirmed the district court’s denial of its motion for judgment as a matter of law or a new trial on both the ADA and ADEA claims. Taken together, the evidence supports a reasonable inference that Plaintiff’s disability was a motivating factor in Metro terminating him. Finally, under the plain language of the ADA, the district court did not err in awarding attorney’s fees. View "John Gruttemeyer v. Transit Authority" on Justia Law

Plaintiff arrived at Becker County Jail in Minnesota with a number of physical ailments, two weeks later he was taken to the hospital and subsequently diagnosed with acute myeloid leukemia. Plaintiff filed an action against Becker County Jail (“BCJ”) and its personnel, claiming deliberate indifference to his medical needs, failure to provide adequate training to corrections officers, and negligence. The district court held that Defendants were entitled to qualified immunity. Plaintiff filed an amended complaint under 42 U.S.C. Sec. 1983, alleging Defendants violated his rights under the Eighth and Fourteenth Amendments and claims under Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978).On appeal, the court reasoned that qualified immunity “shields government officials from liability when their conduct does not violate clearly established constitutional rights of which a reasonable person would have known.” The court found no violation of the Eighth or the Fourteenth Amendments because the undisputed facts do not provide sufficient proof that the defendants acted with deliberate indifference to Plaintiff’s medical needs nor do they show intentional denial or delay in access to medical care. The court reasoned that Plaintiff gave mixed signals as to the severity of his pain. Because medical professionals failed to grasp the seriousness of his condition, prison staff without medical training could not have been expected to do so. Further, because the individual Defendants are entitled to official immunity, Becker County is entitled to the same immunity. View "Kyle Rusness v. Becker County, Minnesota" on Justia Law

Plaintiff alleges that while he was detained at a detention center, officers subjected him to severe racial harassment, including the use of racial epithets, multiple times per day. He filed several internal grievances, but each was rejected. Plaintiff alleges the grievances were rejected because of his race. Plaintiff challenges the district court’s grant of summary judgment to Defendants. He also argues that the court should have construed his pleadings to include claims for retaliation and violations of the Minnesota Human Rights Act.Plaintiff argues that his summary judgment evidence and other evidence available in the record was sufficient to establish a genuine dispute of material fact. Plaintiff identifies three “buckets” of relevant evidence: (1) his counter-affidavits; (2) the internal grievance forms filed with the adult detention center; and (3) other non-summary judgment evidence available in the record.The court found that the evidence does not raise a genuine dispute that either officer was personally involved in racial harassment or discrimination at the detention center. Plaintiff's statement fails to identify any direct or circumstantial evidence that would demonstrate the denial was racially motivated. Further, Plaintiff failed to obtain sworn testimony or documentary evidence asserting specific facts to help prove his claim. The court held that Plaintiff’s summary judgment evidence is insufficient to establish a genuine dispute of material fact that Defendants were personally involved in racial discrimination or harassment. Thus, Plaintiff cannot demonstrate that either officer’s conduct violated his Fourteenth Amendment rights, and both are entitled to qualified immunity View "Wilbert Glover v. Matt Bostrom" on Justia Law