Justia Civil Rights Opinion Summaries

Under Michigan abortion law, a minor may bypass the parental-consent requirement by obtaining a court order granting the right to self-consent (for mature minors) or judicial consent (for “best interests” minors). When the plaintiff sought to apply for judicial bypass, the defendant hadn’t heard of the process and told the plaintiff to come back later. Plaintiff sued the defendant in her individual and official capacities under 42 U.S.C. § 1983, alleging that defendant’s refusal to allow her to apply for a judicial bypass without parental notification violated her Fourteenth Amendment rights. The district court denied the motion when the defendant moved for summary judgment, invoking quasi-judicial and qualified immunity.Before the Eighth Circuit, the defendant claimed she acted at the direction of the Associate Circuit Judge (“Judge”). The Judge testified that he did not recall telling the defendant not to accept the application without parental consent. The circuit court concluded there was a genuine issue of material fact regarding the Judge’s practice of giving pre-filing directions. Further, the is a clearly established right to apply for a judicial bypass. Thus the circuit court declined to address the defendant’s other arguments regarding qualified immunity. View "Jane Doe v. Michelle Chapman" on Justia Law

Minnesota Governor Walz (“Walz”) signed an executive order mandating a statewide residential eviction moratorium. Heights Apartments, LLC (“Heights”), a property owner of residential units, challenged the executive orders, raising First Amendment, Fifth Amendment, and Fourteenth Amendment claims under Section 1983.The court found that the plaintiffs met the two-prong test to determine whether a state has impermissibly interfered with a contract. However, the court held that Heights has failed to allege a cognizable Petition Clause claim because the only potential remedy is damages; Heights has not pleaded damages that are somehow unique to its Petition Clause claim.Heights alleged it was deprived of its expected return on investment in the form of rental income. These alleged damages are sufficient to plausibly give rise to a Fifth Amendment takings claim. Finally, Heights has alleged violations of various rights that trigger protections under other constitution amendments; however, it has failed to plausibly plead a substantive due process violation. Thus, Heights has plausibly argued constitutional claims under the Contract Clause and Takings Clause. The court reversed the dismissal of those two claims and remanded for further proceedings. View "Heights Apartments, LLC v. Tim Walz" on Justia Law

The Eighth Circuit reversed the district court's adverse grant of summary judgment in favor of Metro Transit in an action brought by plaintiff, who is blind and deaf, alleging claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Minnesota Human Rights Act (MHRA). In this case, plaintiff's claims stemmed from 150 complaints he made regarding bus operators' failure to stop at T-Signs and announce the bus route. The court concluded that the record contains evidence sufficient to raise a genuine issue of material fact as to whether Metro Transit provided meaningful access to disabled bus riders. The court stated that, at trial, the DOT regulations cited by plaintiff are admissible as evidence that the jury may consider and weigh when determining whether he has met his burden of demonstrating that he was denied meaningful access to Metro Transit's services. View "Segal v. Metropolitan Council" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment in favor of Bi-State in an action brought by plaintiff under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court concluded that the district court did not abuse its discretion in determining that plaintiff's claims regarding federal transportation regulations were barred by judicial estoppel where his position on summary judgment is inconsistent with the position he took on Bi-State's motion for a judgment on the pleadings; he persuaded the district court that he was not pursuing a private right of action under the federal regulations; and allowing him to take an inconsistent position would give him an unfair advantage in the litigation.The court rejected plaintiff's argument that the district court erred when it determined his claims were barred by the previous settlement agreement and, alternatively, granted summary judgment to Bi-State on the merits. The court concluded that, even assuming the agreement does not bar plaintiff's claims, those claims would still fail because he cannot demonstrate that Bi-State denied him meaningful access to its services. In this case, plaintiff has not shown he was denied an opportunity to access the same services as non-disabled riders. Finally, the court concluded that it lacked jurisdiction to review the denial of plaintiff's motion to amend the complaint. View "Gustafson v. Bi-State Development Agency" on Justia Law

After a jury found plaintiff not guilty of a drug trafficking offense, he filed a civil rights action against two police officers alleging they conspired to include false statements in an affidavit of probable cause executed shortly after his arrest.The Eighth Circuit affirmed the district court's grant of the motion to dismiss based on qualified immunity where the affidavit provided arguable probable cause for plaintiff's arrest even without the allegedly false statements at issue. The court concluded that the uncontested portions of the affidavit show officers knew at the time that plaintiff repeatedly had been with the targets of their investigation close in time to cocaine sales. Viewed in totality through the lens of common sense, the court stated that the affidavit with the alleged falsehoods removed still supports probable cause. The court affirmed the dismissal of all plaintiff's claims as they are derivative of the probable cause argument. View "Allen v. Monico" on Justia Law

Plaintiff filed suit against Morton County and North Dakota state officials under 42 U.S.C. 1983, alleging that a violation of his First, Fourth, and Fourteenth Amendment rights related to an incident where law enforcement officials shot plaintiff with lead-filled bean bags while he was protesting.The Eighth Circuit concluded that, although plaintiff's First Amendment retaliation claims are not Heck barred, they are subject to dismissal under Federal Rule of Civil Procedure 12(b)(6) on the merits. In this case, the nonconclusory allegations in the complaint do not give rise to a plausible inference that the officers who allegedly shot and arrested plaintiff acted out of retaliatory animus. However, the court concluded that the district court erred in dismissing the excessive force claims against the officers who shot plaintiff under the Fourth Amendment, as the complaint asserted use of more than de minimus force when plaintiff did not threaten anyone, flee, or resist arrest and the law was clearly established. The court stated that, if the allegations in his complaint are true, then Morton County law enforcement engaged in a persistent pattern of excessive force against peaceful protestors that was tacitly authorized by Sheriff Kirchmeier and that led to plaintiff's injury. Furthermore, Sergeant Kennelly is liable for the violation of plaintiff's Fourth Amendment rights because he failed to intervene. Finally, plaintiff's equal protection claims were properly dismissed where he failed to allege facts showing that otherwise similarly situated non-Native Americans were treated more favorably than he was. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Mitchell v. Kirchmeier" on Justia Law

The Eighth Circuit affirmed the district court's denial of the landlords' motion for a preliminary injunction in an action challenging the Minneapolis City Council's enactment of Ordinance No. 244.2030 under the Fifth Amendment's Takings Clause and the Fourteenth Amendment's Due Process Clause (and similar provisions of the Minnesota Constitution). The Ordinance requires landlords to evaluate applicants for rental housing by either (1) "inclusive screening criteria" or (2) "individualized assessment."The court concluded that the landlords have neither demonstrated a physical-invasion taking nor a Penn Central taking. The court stated that, due to the individualized assessment option, the Ordinance is a restriction on the landlords' ability to use their property, not a physical-invasion taking. Furthermore, the district court properly ruled that the landlords offered nothing but conclusory assertions of economic impact and interference with investment-backed expectations. Finally, the Ordinance withstands rational basis review where it does not infringe a fundamental right and where the government had a legitimate purpose in ameliorating problems that often prevent people from finding housing. View "301, 712, 2103 and 3151 LLC v. City of Minneapolis" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer in an action brought by Marquis Jones's estate, alleging claims under state and federal law after a police officer shot and killed Jones while he was running away from a traffic stop. In this case, the court agreed with the district court that there are two genuine disputes of material fact for the jury: first, whether the officer saw Jones drop the gun when he ordered him to; and second, whether the officer was unreasonable in believing Jones was taking a firing position rather than surrendering. The court stated that, if, construing the evidence most favorably to the estate, the officer knew Jones was unarmed, then shooting him violated a clearly established constitutional right. View "Williams v. City of Burlington" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a petition for writ of habeas corpus under 28 U.S.C. 2241 challenging petitioner's conviction for distributing heroin resulting in death of another person. The court concluded that the district court lacked jurisdiction over petitioner's section 2241 petition because he failed to establish that section 2255 was inadequate or ineffective. In this case, petitioner's impediment to relief was existing caselaw, not the remedy provided by section 2255. Furthermore, because the saving clause enacted by Congress only provides relief when section 2255's remedy itself is inadequate or ineffective, the district court lacked jurisdiction over petitioner's section 2241 petition. Without jurisdiction over the section 2241 petition, the district court could not entertain the petition and therefore did not abuse its discretion in denying petitioner an evidentiary hearing. View "Crayton v. United States" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of First Care in an action brought by plaintiffs, alleging that First Care unlawfully terminated them from their positions at an assisted-living facility. First Care claimed that plaintiffs were terminated because, as mandatory reporters, they had failed to immediately report observed abuse.The court concluded that plaintiffs failed to allege a claim of retaliation under Neb. Rev. Stat. 48-1114(1)(c) where they have failed to identify any demand by First Care to engage in an unlawful action. The court also concluded that plaintiffs' race discrimination claims under 42 U.S.C. 1981, Title VII, and Neb. Rev. Stat. 48-1104(1) failed because plaintiffs ultimately failed to identify a similarly situated comparator. Finally, the court concluded that plaintiffs failed to raise a genuine issue for trial regarding the district court's exclusion of investigator notes and reports on hearsay grounds. View "Walker v. First Care Management Group, LLC" on Justia Law