Justia Civil Rights Opinion Summaries

After Jerome Goode led police on a twenty-five-mile car chase, the chase ended in his death and the deaths of passengers Lavoy Steed and Leon Haywood. Steed's next friend filed a 42 U.S.C. 1983 action against Missouri State Troopers Fowler and Ashby, alleging that the traffic stop that precipitated the chase and an attempt to halt Goode's vehicle with spike strips were unconstitutional seizures in violation of the Fourth Amendment.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the troopers, concluding that Trooper Fowler had probable cause to stop the vehicle where dashcam footage shows the vehicle going close to ninety miles per hour. Even assuming that the trooper misinterpreted the speed reading, he would still be entitled to qualified immunity because he had at least arguable probable cause to believe the vehicle was speeding. The court also concluded that the record clearly establishes that the troopers did not apply physical force by trying to use the spike strips, and thus there was no seizure. View "Steed v. Missouri State Highway Patrol" on Justia Law

The Eighth Circuit affirmed the district court's denial of the officers' motion for summary judgment in a 42 U.S.C. 1983 action brought by plaintiff, who had been arrested at a protest, alleging violations of his First and Fourth Amendment rights and conspiracy to violate his rights, and under Missouri state law. Plaintiff and his wife were documentary filmmakers who were covering protests in downtown St. Louis, Missouri, following Officer Jason Stockley's acquittal of charges arising from the death of Anthony Lamar Smith.The court concluded that, viewing the evidence in the light most favorable to plaintiff, a reasonable jury could conclude that Officer Biggins used excessive force during plaintiff's arrest, that he acted with an "actual intent to cause injury" to plaintiff, and that his use of excessive force was done in retaliation for plaintiff's First Amendment activity. Therefore, the district court did not err in denying summary judgment based on qualified immunity to Officer Biggins on plaintiff's First and Fourth Amendment claims, nor did the district court err in denying summary judgment based on official immunity to Officer Biggins on plaintiff's state law assault and battery claim. The court declined to consider the officers' argument concerning application of the intracorporate conspiracy doctrine because it was raised for the first time on appeal. View "Burbridge v. Biggins" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer unlawfully arrested him and used excessive force during the arrest. Plaintiff's claims stemmed from an incident where the officer issued tickets to him for illegal parking and resisting arrest. Plaintiff pleaded guilty to illegal parking by signing the ticket at the police station, and the City later dismissed the charge of resisting arrest.The Eighth Circuit affirmed the denial of summary judgment on plaintiff's unlawful arrest claim where there is a genuine dispute of material fact about whether the officer entered plaintiff's home without a warrant to effect the arrest. In regard to plaintiff's separate Fourth Amendment claim premised on the alleged use of excessive force, the court concluded that the officer is entitled to qualified immunity because an officer could reasonably believe that plaintiff was resisting arrest. The court explained that, under the circumstances, it was not clearly established at the time that officers were forbidden to use force, including a taser, to arrest a suspect who resisted, ignored instructions, and walked away from the officer. The court noted that any damages that plaintiff suffered because of his arrest are subsumed within his unlawful arrest claim. Therefore, even without a freestanding claim for use of excessive force, plaintiff may recover any damages that he suffered from the officer's use of a taser if plaintiff succeeds on his claim alleging unlawful arrest based on an unjustified entry into the home. View "Gerling v. Waite" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Walmart in an action brought by plaintiff, alleging age discrimination under the Iowa Civil Rights Act (ICRA). The court assumed that plaintiff met his prima facie burden under the McDonnell Douglas standard, but concluded that Walmart offered a legitimate, non-discriminatory reason for terminating his employment, the violation of the Hazardous Materials Endorsement policy while on a Third Written (a policy meaning he could be fired if disciplined again). The court also concluded that plaintiff's evidence was insufficient to allow a reasonable juror to find that Walmart's proffered reason for firing him was pretextual. View "Gardner v. Wal-Mart Stores, Inc." on Justia Law

Plaintiffs, parents of LD, filed suit against the school district and others after their daughter LD, a 13-year-old, 7th grade student, was sexually abused by her teacher, Brian Robeson.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the school district and the principal. The court concluded that plaintiffs failed to present any evidence that the principal had actual notice of the abuse, and the principal and the school district were entitled to summary judgment on plaintiffs' Title IX and 42 U.S.C. 1983 claims. The court also concluded that the district court did not err by granting summary judgment in favor of the school district and principal on plaintiffs' Nebraska Political Subdivisions Tort Claims Act where plaintiffs' claim arose out of Robeson's sexual assault of LD, an intentional tort to which the Act's intentional tort exception applies. The court further concluded that the district court did not err in granting summary judgment in favor of the principal on plaintiffs' aiding and abetting intentional infliction of emotional distress claim where nothing in the record, even when viewed in the light most favorable to plaintiffs, indicates that the principal encouraged or assisted Robeson in inflicting emotional distress on LD.The court joined its sister circuits in finding that there is no right to a jury trial on the issue of damages following entry of default judgment. The court affirmed the district court's order denying plaintiffs' request for a jury trial on the issue of damages against Robeson. Finally, the court affirmed the $1,249,540.41 amount of damages awarded against Robeson. View "KD v. Douglas County School District No. 001" on Justia Law

Plaintiff, a tenured professor, filed suit against the University, a faculty union, and the Board of Trustees, alleging First and Fourteenth Amendment violations. Plaintiff claimed that the designation of IFO as plaintiff's exclusive representative violates the First Amendment by wrongly compelling her to speak through and associate with an entity with which she disagrees. Plaintiff also claimed that granting preferences to IFO members to serve on meet-and-confer committees discriminates against her and others who declined to associate with the union.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. Because plaintiff properly concedes that the district court correctly rejected her compelled-speech claim (Count I) under Minnesota State Board of Community Colleges v. Knight, 465 U.S. 271 (1984), the court affirmed the district court's grant of summary judgment on her Count 1 claims. Furthermore, the district court correctly rejected plaintiff's invitation to read Count II as an unconstitutional-conditions claim for three reasons: first, the complaint's text does not support this reading; second, there are inconsistencies in plaintiff's filings; and plaintiff's claim that IFO's meet-and-confer rights under Minnesota law discriminate against her associational preferences is similar to Knight. Finally, the court concluded that the district court did not abuse its discretion in denying plaintiff's request for leave to amend her complaint, which she made in her Rule 59(e) motion to vacate the judgment. View "Uradnik v. Inter Faculty Organization" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the Commission in an action brought by plaintiff, alleging that the Commission discriminated against her in violation of Title VII. Plaintiff argues that her suspension, probation, and termination were discrimination based on race and national origin. The Commission stated that plaintiff's termination was due to failure to comply with requests to provide company passwords to agency programs and documents. The court concluded that plaintiff did not show evidence of pretext or that she could satisfy the McDonnell Douglas burden-shifting framework before the district court or in her opening brief, and thus she cannot prove a circumstantial case of discrimination. View "Towery v. Mississippi County Arkansas Economic Opportunity Commission, Inc." on Justia Law

The Eighth Circuit held that the district court did not abuse its discretion in granting preliminary injunctions enjoining enforcement of the Gestational Age Provisions and the Down Syndrome Provision of Missouri House Bill 126. The Gestational Age Provision provides, in relevant part, that "no abortion shall be performed or induced upon a woman at eight weeks gestational age or later, except in cases of medical emergency." The Down Syndrome Provision prohibits abortions if the provider "knows that the woman is seeking the abortion solely because of a prenatal diagnosis, test, or screening indicating Down [s]yndrome or the potential of Down [s]yndrome in an unborn child."As a preliminary matter, the court concluded that RHS has standing because the provisions at issue directly target physician conduct and put physicians at risk of civil and criminal sanctions. The court concluded that the Gestational Age Provisions do not merely have "the incidental effect of making it more difficult or more expensive to procure an abortion" before viability. Rather, the Gestational Age Provisions are bans, and the court agreed with the district court that RHS is likely to succeed on the merits of this claim. The court also concluded that, unlike a regulation, the Down Syndrome Provision does not set a condition that—upon compliance—makes the performance of a pre-viability abortion lawful, thus preserving the constitutional right to elect the procedure. Rather, it bans access to an abortion entirely. Therefore, RHS is likely to succeed on the merits of its challenge to the Down Syndrome Provision. The court concluded that the remaining Dataphase factors - irreparable harm, balance of hardships and public interest - also supported the grant of the preliminary injunction. View "Reproductive Health Services of Planned Parenthood of the St. Louis Region, Inc. v. Parson" on Justia Law

The Eighth Circuit affirmed the district court's judgment following a jury verdict in favor of the City on plaintiff's claim of hostile work environment based on religion. At issue is whether the district court abused its discretion in precluding plaintiff from introducing testimony and a report by the City's retained but non-testifying expert psychiatrist who had conducted an independent medical examination of plaintiff.The court concluded that the expert's report would have been cumulative with other testimony regarding causation and damages, and any discussion of damages was immaterial because the jury never reached that issue. Therefore, the exclusion did not result in fundamental unfairness in the trial of the case, and the court need not consider whether the district court abused its substantial case management and discovery discretion in excluding the expert's independent medical examination report and testimony, an issue the court has not previously addressed. View "Cooper v. City of St. Louis, Missouri" on Justia Law

HRDC filed suit against Baxter County under 42 U.S.C. 1983, alleging that the Jail's postcard-only policy violates HRDC's First Amendment right to communicate with Jail inmates. HRDC also alleged that the Jail's rejection of HRDC's mailings violated HRDC's Fourteenth Amendment procedural due process rights to notice and an opportunity to appeal the Jail's decisions. The district court initially granted partial summary judgment in favor of HRDC. After a bench trial, the district court held that the postcard-only policy was reasonably related to legitimate penological goals and did not violate HRDC's First Amendment rights. The district court awarded HRDC four dollars in nominal due process damages for its four discrete August 2016 mailings.The Eighth Circuit affirmed the due process ruling and concluded that the district court did not err in granting only nominal damages where HRDC failed to prove actual injury flowing directly from the technical due process violation in August 2016. The court vacated the First Amendment ruling where the district court made no finding of fact regarding whether HRDC proved its assertion that the postcard-only policy results in "a de facto total ban" on Jail inmates accessing HRDC's materials. The court explained that it is necessary for the court to have a finding on what, if any alternative means are available to HRDC to exercise its First Amendment interest in access to prisoners. Therefore, the court remanded for further proceedings. View "Human Rights Defense Center v. Baxter County, Arkansas" on Justia Law