Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's holding that University employees violated InterVarsity's First Amendment rights and denial of qualified immunity. In this case, the University deregistered InterVarsity as a Registered Student Organization based on the University's determination that InterVarsity had violated the University's Policy on Human Rights by requiring its leaders to subscribe to certain religious beliefs.The court agreed with the district court that the University's policy was reasonable and viewpoint neutral, but not as applied to InterVarsity. The court explained that the University's choice to selectively apply the policy against InterVarsity suggests a preference for certain viewpoints over InterVarsity's. Furthermore, these rights were clearly established at the time of the violation. View "Intervarsity Christian Fellowship/USA v. University of Iowa" on Justia Law

On remand from the Supreme Court in light of Caniglia v. Strom, 593 U.S. ---, 141 S. Ct. 1596 (2021), the Eighth Circuit affirmed the district court's grant of summary judgment for the officers and the City in this action under 42 U.S.C. 1983 and Minnesota state law.The court concluded that it was well established at the time that the community-caretaking exception was a standalone doctrine that could justify the officers' warrantless entry into a home. In the circumstances here, the court concluded that the officers' warrantless entry did not violate plaintiff's Fourth Amendment rights under the then-extant community-caretaking jurisprudence. Therefore, the officers were entitled to qualified immunity with respect to the Fourth Amendment warrantless-entry claim.In regard to plaintiff's claim that the officers violated her Fourth Amendment right to be free from unreasonable seizures when they seized her for a mental-health evaluation, the court affirmed summary judgment and concluded that probable cause of dangerousness is the standard that must be met for a warrantless mental-health seizure to be reasonable under the Fourth Amendment. Furthermore, assuming the officers lacked probable cause here, they may still be entitled to qualified immunity given the ambiguity in the court's case law about the requisite standard. Finally, the officers are entitled to qualified immunity because their actions did not violate clearly established law under the lower reasonable-belief standard some of the court's precedents suggested was the requisite standard.In regard to plaintiff's claim of retaliatory arrest, the court affirmed summary judgment because no reasonable jury could conclude that retaliatory animus was a but-for cause of plaintiff's arrest. In regard to plaintiff's claim that the City's policy concerning seizures for emergency mental-health evaluation was facially unconstitutional, the district court affirmed summary judgment because the policy requires probable cause that the person is a threat to self or others. The court rejected plaintiff's inadequate-training claim and concluded that the officers were entitled either to statutory or official immunity on the state law claims. View "Graham v. Barnette" on Justia Law

Plaintiff filed suit against Union Pacific in Missouri state court, alleging age discrimination, constructive discharge, and hostile work environment claims under the Missouri Human Rights Act (MHRA). Plaintiff also filed suit against Missouri resident Foster B. McDaniel, claiming that McDaniel aided and abetted Union Pacific in its discriminatory acts. After Union Pacific removed to federal court, the district court granted McDaniel's motion to dismiss and denied plaintiff's motion to remand. The district court later granted Union Pacific's motion for summary judgment on plaintiff's hostile work environment claim.The Eighth Circuit affirmed, concluding that the district court did not err in dismissing McDaniel on the basis of fraudulent joinder because plaintiff's complaint failed to make a colorable claim that McDaniel directly oversaw or was actively involved in discrimination. The court also concluded that the district court did nor err in determining plaintiff did not administratively exhaust his constructive discharge claim. Finally, the court concluded that the district court did not err in granting Union Pacific summary judgment on plaintiff's hostile work environment claim because plaintiff failed to establish age-related harassment sufficiently severe or pervasive to establish the existence of a hostile work environment. View "Henson v. Union Pacific Railroad Co." on Justia Law

Plaintiff filed suit challenging the constitutionality of a traffic ordinance in St. Louis. Plaintiff's claims arose from her attendance at an event called the Women's March in 2017 where she was arrested for failing to move to the sidewalk. An officer arrested her for violating section 17.16.275 of the Revised Code of St. Louis, which prohibits obstructing traffic. After the charges were dismissed, plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of the ordinance under the First and Fourteenth Amendments.The Eighth Circuit reversed the district court's grant of plaintiff's motion for partial summary judgment. The court concluded that the St. Louis ordinance does not forbid all expressive activities on streets and sidewalks. Instead, it merely forbids a person to position herself in a way that obstructs the reasonable flow of traffic. Therefore, plaintiff has not established that the ordinance unduly restricts free speech in light of the City's legitimate interest in regulating traffic. The court also concluded that the ordinance is not void for vagueness and thus is not unconstitutional on its face. The court further concluded that the ordinance is not unconstitutional as applied to plaintiff where the record does not support a conclusion that police invidiously discriminated against plaintiff based on her speech by selectively enforcing the traffic ordinance. The court remanded with directions to enter judgment for the City. View "Langford v. City of St. Louis" on Justia Law

Plaintiff filed suit challenging the constitutionality of Arkansas' limits on which candidates can appear on its general-election ballot, Ark. Code 7-7-101. After the district court entered judgment upholding the challenged provisions, plaintiff appealed. While the appeal was pending, the 2020 general election came and went.The Eighth Circuit dismissed plaintiff's appeal as moot, concluding that the "capable-of-repetition-yet-evading-judicial-review" exception to mootness did not apply. The court explained that plaintiff's interest in this case was predicated on his status as an Independent candidate; without such a candidacy, the challenged provisions do not apply to him. However, plaintiff's 2020 Independent candidacy has ended and he has not indicated whether he intends to run as an Independent again. Therefore, this case is no longer "live." Furthermore, plaintiff has failed to show that he is reasonably likely to be subject to the challenged statutory provisions again. View "Whitfield v. Thurston" on Justia Law

Plaintiff filed suit against defendant, asserting claims of First Amendment retaliation and Fourth Amendment unreasonable seizure under 42 U.S.C. 1983 and claims under the Arkansas Civil Rights Act (ACRA), for violating rights secured by Article II, 6, 8, 9, and 15 of the Arkansas Constitution. Plaintiff's claims stems from his arrest by defendant for disorderly conduct after plaintiff yelled an expletive at him from a moving vehicle.The Eighth Circuit affirmed the district court's judgment, concluding that the district court did not err by dismissing plaintiff's ACRA claim because plaintiff presented no evidence on summary judgment that defendant acted maliciously; the district court did not err in regards to its punitive damages rulings where plaintiff failed to produce sufficient evidence that defendant's conduct warranted the imposition of punitive damages, and plaintiff's trial testimony failed to establish facts meeting the punitive-damages standard; the district court did not abuse its discretion in denying plaintiff's motion for a new trial; and the district court did not abuse its discretion in awarding attorney's fees in this nominal damages case. View "Thurairajah v. Cross" on Justia Law

Plaintiff filed suit alleging that he was injured during the course of an arrest made by defendant, an officer, at a college board meeting. After the district court denied defendant's motion for summary judgment based on qualified immunity, defendant filed this interlocutory appeal.The Eighth Circuit dismissed the appeal based on lack of jurisdiction, concluding that material factual disputes that are incapable of being resolved on this record are at the heart of defendant's arguments. The court explained that, in order to reach defendant's "legal argument" that he responded reasonably and did not violate clearly established law, the court would have to exceed its jurisdiction and cast aside the district court's factual findings, analyze the factual record, and resolve genuine factual disputes against the non-moving party. View "Taylor v. Caples" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the City of Ferguson, alleging violations of his First, Fourth, and Fourteenth Amendment rights. Plaintiff's claims stemmed from nine citations he received from the officer at a park. The district court found that the officer was not entitled to qualified immunity and thus denied defendants' joint motion for summary judgment.After determining that it had jurisdiction, the Eighth Circuit vacated the district court's order denying defendants' joint motion for summary judgment and remanded so that the district court may further consider the officer's asserted entitlement to qualified immunity. In this case, when discussing plaintiff's Fourth Amendment seizure claim, the district court commenced its analysis by citing case law that outlined the general legal standards for probable cause and reasonable suspicion, but it largely failed to apply this case law, or more analogous cases, to plaintiff's version of the facts. Furthermore, the district court failed to conduct the materiality inquiry by framing legal questions as factual ones; the court was unable to discern whether the district court applied the clearly established prong at all, much less conducted a "thorough determination;" the district court defined the relevant law at too high a level of generality to conduct a proper clearly established analysis; and the district court's excessive force analysis fails to identify a specific right or factually analogous cases. Finally, the court dismissed the City's appeal for lack of jurisdiction. View "Watson v. Boyd" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action alleging claims of wrongful arrest and wrongful detention. After responding to a 911 call reporting an assault and robbery, officers arrived at an apartment complex and conducted a brief investigation, arresting plaintiff and two others for second degree robbery. During the continuing investigation after plaintiff's arrest, the police department obtained surveillance video that demonstrated that plaintiff was not in the victim's apartment at the time of the assault and robbery. Prosecutors later dropped the charges against plaintiff. The district court denied defendants' motion for summary judgment based on qualified immunity.The Eighth Circuit reversed, concluding that the record supports the conclusion that the officers had arguable probable cause to arrest plaintiff for the assault based on the victim's identification of plaintiff as one of his attackers. In this case, the record evidence does not create a factual dispute, and thus the officers are entitled to qualified immunity on the unlawful arrest claim. In regard to plaintiff's claim that defendants wrongful detained him, the court noted that this decision was not made by the named defendants but, rather, by the city prosecuting attorney. Therefore, the court concluded that plaintiff lacked standing to pursue his claim against the named defendants. View "Ngong Garang v. City of Ames" on Justia Law

The Eighth Circuit affirmed the district court's judgment in an action brought by plaintiffs, on behalf of their son, Tanner, who was arrested when he was 15 years old on charges that were later dismissed. Plaintiffs alleged violations of 42 U.S.C. 1983 and Iowa state law stemming from the officers' arrest of Tanner after he was accused of sexual assault. The court concluded that the officers had probable cause to arrest Tanner and were therefore entitled to summary judgment on the Fourth Amendment claim. The court explained that, when the officers arrested Tanner, they had probable cause to believe that he had committed the crime of third-degree sexual abuse under Iowa law.The court also affirmed the district court's grant of summary judgment on the Fourteenth Amendment claims, concluding that nothing in the officers' statements or actions indicates that they acted recklessly as they investigated the allegations against Tanner. Finally, because the officers had probable cause for the arrest, the court concluded that plaintiffs' state law claims for false arrest and malicious prosecution fail and defendants were entitled to summary judgment on the claims. View "Walz v. Randall" on Justia Law