Justia Civil Rights Opinion Summaries

CSI, which won a contract to perform road work on state highways across three Minnesota counties, filed a 42 U.S.C. 1983 action against Mahnomen County and its Engineer, Jonathan Large, after Large stopped two of CSI's trucks for exceeding the posted weight limit on the road on which they were traveling.The Eighth Circuit affirmed the district court's grant of summary judgment on the constitutional claims, concluding that, under the unique circumstances of this case, it was not clearly established that Large, a county engineer tasked with oversight of all county roads, could not prevent trucks that he had reason to believe were operating above the posted weight limit from passing over and damaging the roadway or could not call law enforcement to investigate compliance with the new, reduced weight restrictions. The court also concluded that it was not clearly established at the time that defendants could not change the weight restrictions in response to CSI's stated intentions to use the road despite the fact it had not been designated as a haul road or that the engineer could not seek law enforcement's assistance in investigating the trucks' weights. Furthermore, because CSI's complaint failed to allege any policy or custom of the county related to the engineer's conduct, claims against the county failed. Finally, the court concluded that the district court properly granted summary judgment in favor of defendants on CSI's state law claim for tortious interference with contract, and the engineer did not exercise the dominion and control over plaintiff's trucks required to support a trespass to chattel claim. View "Central Specialties, Inc. v. Large" on Justia Law

The Eighth Circuit concluded that the district court did not err in determining plaintiffs' 42 U.S.C. 1983 claims for false imprisonment and unlawful search and seizure are time barred under Arkansas's three-year personal injury statute of limitations. In this case, the alleged Fourth Amendment violations -- false imprisonment and seizure of property based on fabricated evidence -- occurred before legal process began and are time-barred, despite plaintiffs' claim that the unlawful seizures continued even after the criminal charges were nolle prossed. The court rejected plaintiffs' contention that the district court improperly applied summary judgment standards in granting defendants' Federal Rule of Civil Procedure 12(b)(6) motions to dismiss and in denying plaintiffs' motion to vacate or set aside the dismissal. Rather, the court concluded that the district court did not abuse its discretion in declining to vacate or set aside its initial dismissal order because plaintiffs failed to state plausible section 1983 malicious prosecution claims under controlling Eighth Circuit precedent. View "Martin v. Julian" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to defendant, a police officer, on a motion to dismiss an unlawful seizure claim based on his shooting two dogs during a residential security check. Accepting the complaint's allegations as true, the court concluded that the officer did not act reasonably in shooting the dogs. In this case, defendant shot both dogs when they presented no imminent danger and were not acting aggressively. Furthermore, it was clearly established that an officer cannot shoot a dog in the absence of an objectively legitimate and imminent threat of harm to himself or others. The court rejected defendant's contention that the court should consider other materials because the materials defendant wishes the court to consider, when properly viewed, do not settle whether the shootings were objectively reasonable. View "LeMay v. Mays" on Justia Law

For budget reasons, St. Cloud State University shut down six of its sports teams, including women's tennis and Nordic Skiing teams. Female student-athletes brought a Title IX discrimination action. 20 U.S.C. 1681(a). The district court preliminarily enjoined cutting the women's teams, concluding the University failed to comply with Title IX requirements in its allocation of athletic participation opportunities and treatment and benefits for student-athletes.The Eighth Circuit reversed in part and remanded. The court upheld findings that the University uses a tier system for dividing particular teams, offering different levels of support to each tier. The University violated Title IX by not providing equitable participation opportunities for men and women. The district court erred, however, by requiring the University to provide equitable treatment and benefits “among the tiers of support,” and by mandating steps toward eliminating the unequal distribution of “participation opportunities among the tiers” rather than analyzing the institution's programs as a whole. View "Portz v. St. Cloud State University" on Justia Law

Plaintiff filed suit challenging the South Dakota State Penitentiary's pornography policy under the First and Fourteenth Amendments. Plaintiff named as defendants four South Dakota corrections officials in their official capacities. The district court granted in part and denied in part the parties' motions for summary judgment.In regard to plaintiff's as-applied challenges, the Eighth Circuit applied the Turner v. Safely, 482 U.S. 78 (1987), factors and concluded that the district court erred in granting summary judgment for plaintiff on his claim that the policy is unconstitutional as applied to two erotic novels because defendants were within their discretion to censor these books. However, the district court properly granted summary judgment for plaintiff on his claim that the policy is unconstitutional as applied to the art book and nine pictures of Renaissance artwork.In regard to plaintiff's facial challenges, the court dismissed as moot plaintiff's claim that the prohibition on nudity is overbroad, but plaintiff's claim that the prohibition on sexually explicit content is overbroad remains a live case or controversy based on the court's reversal of the district court's ruling on his as-applied challenges regarding the erotic novels. The court read the policy in light of the doctrine of constitutional avoidance and concluded that plaintiff failed to show that the policy's prohibition on sexually explicit content is "substantially overbroad." The court concluded that although plaintiff's resolution of plaintiff's as-applied challenges does not moot his claim that the policy's prohibition on sexually explicit content is overbroad, this claim fails on the merits. Finally, the court dismissed as moot plaintiff's request for coercive sanctions, denied his request for compensatory sanctions, and denied plaintiff's request for sanctions for defendants' alleged violations of the district court's orders. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Sisney v. Kaemingk" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against University officials, alleging that the University's then-existing events policy was unconstitutional facially and as applied to them under the First and Fourteenth Amendments. In this case, after Students for a Conservative Voice (SCV) brought Ben Shapiro to speak at the University, officials rejected various proposed venues for the event, citing security concerns. Ultimately, the officials approved a smaller, more remote venue than what SCV had requested.The Eighth Circuit concluded that SCV's facial challenges and requests for injunctive relief are now moot and that plaintiffs lack standing to maintain their as-applied claim. The court explained that the University's "Large Scale Event Process" policy had been replaced with a new "Major Events" policy, which was more detailed and pertains to the entirety of the University's campus, and plaintiffs failed to show that it is "virtually certain" that the prior policy will be reenacted. In regard to plaintiffs' as-applied claim, they have failed to show that the policy was in fact applied to them. The court stated that the record reflects that the officials' decisions were independent of the Large Scale Event Process and made within the scope of each officials' position at the University, but plaintiffs' complaint presents no First Amendment challenge to the officials' actions apart from the application of the now repealed policy. Accordingly, the court vacated the district court's orders with respect to those claims and remanded with instructions to dismiss without prejudice. View "Young America's Foundation v. Kaler" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to officers in a 42 U.S.C. 1983 action alleging that plaintiff's constitutional and state-law rights were violated when he was arrested for committing capital murder and abuse of a corpse. In this case, the officers moved for summary judgment, contending, pursuant to Messerschmidt v. Millender, 565 U.S. 535 (2012), that the prosecuting attorney's approval of the warrant affidavit entitles them to qualified immunity. The court concluded that the district court properly denied the second motion for summary judgment, which was based entirely on Messerschmidt and asserted reliance on counsel. The court explained that, given the prosecutor's testimony, a rational jury could find that the officers did not rely on her informed legal advice in making the challenged omissions or statements in the affidavit. View "Wheeler v. Kidder" on Justia Law

On a well-lit summer evening in a Des Moines neighborhood with community-reported drug crimes, police officers Minnehan and Steinkamp lawfully stopped Haynes for suspected (mistaken) involvement in a drug deal. The exceedingly polite and cooperative exchange between the three did not make either officer view Haynes as a safety risk. Haynes could not find his driver’s license but shared three separate cards bearing his name. Steinkamp then handcuffed him. While the polite interaction continued, the cuffs stayed on. They also stayed on after a clean frisk and a consensual pocket search. They stayed on after the officers declined Haynes’s invitation to search another pocket and Haynes’s car. The officers declined another squad car’s offer to help.The district court rejected, on summary judgment, Haynes’s Fourth Amendment claims. 42 U.S.C. 1983. The Eighth Circuit reversed. Handcuffs constitute “greater than a de minimus intrusion,” their use requires the officer to demonstrate that the facts available to the officer would warrant a man of reasonable caution in believing that the action taken was appropriate. Here, the officers failed to point to specific facts supporting an objective safety concern during the encounter. Minnehan and Steinkamp had fair notice that they could not handcuff Haynes without an objective safety concern. View "Haynes v. Minnehan" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment based on qualified immunity in a 42 U.S.C. 1983 action brought by a pretrial detainee against prison officials, alleging violation of his constitutional rights when he was denied visitation with his children due to a blanket policy of prohibiting detainees from visitations by minor children. The court determined that its case law up to now has not necessarily made clear that the prison officials violated plaintiff's constitutional rights by enforcing the blanket prohibition on visitation with minor children, and thus qualified immunity was appropriate to protect defendants from liability.However, the court noted that the time is ripe to clearly establish that such behavior may amount to a constitutional violation in the future. The court joined the Seventh Circuit in holding that prison officials who permanently or arbitrarily deny an inmate visits with family members in disregard of the factors described in Turner v. Safely, 482 U.S. 78 (1987), and Overton v. Bazzetta, 539 U.S. 126 (2003), have acted in violation of the Constitution. View "Manning v. Ryan" on Justia Law

In an action arising from a constitutional challenge to Missouri's remedial parole review process for individuals sentenced to mandatory life without the possibility of parole for homicide offenses committed as juveniles, a class of Missouri inmates who were sentenced to mandatory life without parole for such juvenile homicide offenses filed suit claiming that Missouri's parole review policies and practices violate their rights to be free from cruel and unusual punishment and their rights to due process of law under the U.S. Constitution and the Missouri Constitution. The district court granted summary judgment in favor of plaintiffs.The Eighth Circuit agreed with the district court that Missouri's policies and practices, when implemented and considered in combination, worked to deprive plaintiffs of their Eighth Amendment right to a meaningful opportunity to obtain release based upon demonstrated maturity and rehabilitation. The court explained that, because the parole review process in place under Senate Bill 590 failed to adequately ensure that juveniles whose crimes reflect only transient immaturity—and who have since matured—will not be forced to serve a disproportionate sentence, it violated the Eighth Amendment.The court affirmed the order of the district court determining that the parole review process of SB 590 violated plaintiffs' Eighth Amendment rights, and affirmed the order determining that Missouri cannot use a risk assessment tool in its revised parole proceedings unless it has been developed to address the unique circumstances of the JLWOP Class. The court vacated the order regarding appointment of counsel and remanded for further proceedings. Finally, the court denied plaintiffs' motion to strike. View "Brown v. Precythe" on Justia Law