Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment to defendants in a 42 U.S.C. 1983 action brought by plaintiff, an Iowa Department of Corrections inmate, alleging that defendants violated his Eighth Amendment rights by acting with deliberate indifference to his serious medical needs and safety. Plaintiff claimed that defendants delayed treatment for a sore on his right foot, allowing it to become a major medical crisis resulting in a below-the-knee amputation.The court concluded that plaintiff failed to provide evidence from which a trier of fact could draw an inference that defendants provided care that was grossly inappropriate or intentional maltreatment. In this case, plaintiff's unsupported medical conclusions cannot create a question of fact about whether defendants' medical decisions were reasonable, negligent, grossly negligent, or so ineffective as to be criminally reckless, rising to the level of deliberate indifference. The court explained that, without medical evidence, no reasonable jury could conclude that the providers were deliberately indifferent to his serious medical need. View "Redmond v. Kosinski" on Justia Law

Petitioner, an Arkansas prisoner under a sentence of death for capital murder, petitioned for habeas corpus in the federal district court. In a previous appeal, the Eighth Circuit affirmed the dismissal of several claims, but remanded for further proceedings on four claims alleging ineffective assistance of counsel under the Sixth Amendment. The court also remanded for further proceedings on petitioner's claim that he is ineligible for the death penalty, due to intellectual disability, under the Eighth Amendment and the rule of Atkins v. Virginia, 536 U.S. 304 (2002). On remand, the district court rejected the Atkins claim, but granted relief on two of the ineffective-assistance claims and set aside petitioner's sentence. Both parties appealed.The Eighth Circuit reversed the grant of relief based on alleged ineffective assistance of counsel. In this case, petitioner's federal claim that trial counsel failed to obtain a timely psychological evaluation of him was presented in the state postconviction court and defaulted when he declined to appeal on that ground. As such, the procedural default cannot be excused based on alleged ineffectiveness of state postconviction counsel. Likewise, the third claim cannot be excused based on alleged ineffectiveness of state postconviction counsel. The court affirmed the denial of relief under the Eighth Amendment, concluding that the district court considered the Atkins claim under both the DSM-IV-TR and DSM-V criteria, reached the same conclusion based on each, and thus there was no legal error. The court rejected petitioner's remaining challenges to the district court's analysis of his intellectual functioning, including additional indicia of intellectual disability, expert and witness testimony, adaptive strengths and weaknesses, and adaptive functioning deficits. View "Sasser v. Payne" on Justia Law

Plaintiffs, ten former University of Minnesota football players, appealed the dismissal of their Amended Complaint against the University and two University officials, asserting a variety of claims arising out of the University’s investigation of a complaint of sexual assault and harassment by another student, Jane Doe. Plaintiffs are African-American males who alleged that the University targeted them on the basis of their sex and race and unfairly punished them in response to Jane's accusations. The district court dismissed all claims.The Eighth Circuit concluded that plaintiffs' complaint alleged a number of circumstances which, taken together, are sufficient to support a plausible claim that the University discriminated against plaintiffs on the basis of sex. In this case, plaintiffs alleged that the University was biased against them because of external pressures from the campus community and the federal government, and plaintiffs alleged historical facts that reinforce the inference of bias in this specific proceeding. Therefore, the court reversed the district court's dismissal of plaintiffs' Title IX discrimination claims.The court affirmed the district court's dismissal of the Title IX claims for retaliation where plaintiffs did not plausibly allege that their request for a Student Sexual Misconduct Subcommittee hearing was tantamount to a complaint of sex discrimination, and even if a request for a hearing made by a person accused of sexual misconduct could amount to protected activity, the Amended Complaint did not plausibly plead prima facie retaliation claims. The court also affirmed the dismissal of the race discrimination claims where the Amended Complaint did not plausibly allege a comparator similarly situated to plaintiffs in all relevant aspects; affirmed the dismissal of plaintiffs' due process claims where plaintiffs failed to exhaust the existing procedures for appealing the University's disciplinary decision and failed to allege prehearing deprivations or deprivation of protected property or liberty interests in violation of due process; and affirmed the dismissal of the contract and negligence claims on Eleventh Amendment grounds. View "John Does 1-2 v. Regents of the University of Minnesota" on Justia Law

The Eighth Circuit affirmed the district court's sua sponte grant of judgment as a matter of law to defendants in an action brought by plaintiff against prison officials, alleging that they failed to protect him from his fellow inmates after he was labeled a snitch.Even assuming the court agreed with plaintiff that Federal Rule of Civil Procedure 50(a) requires a motion, the court did not think that requirement is clear or obvious under its case law. The court concluded that the district court did not err in directing a verdict in favor of the five defendants who were not on the Classification Committee. In this case, plaintiff cannot show that defendants acted with deliberate indifference by entrusting the decision to the Classification Committee—the prison's selected arbitrator. The court explained that, even if they disagreed with the choice, there is nothing to suggest that four of the defendants had any power to circumvent the ruling of the Classification Committee and it was a close call with the fifth defendant. Finally, the court concluded that the district court did not abuse its discretion by denying plaintiff's motions for continuance by ensuring an expeditious disposition of the case and while affording significant time to allow plaintiff to prepare. View "Axelson v. Watson" on Justia Law

After defendant, a police officer, shot plaintiff in the course of investigating a potential domestic disturbance, plaintiff filed suit under 42 U.S.C. 1983, alleging violations of the Fourth and Fourteenth Amendments.The Eighth Circuit affirmed the district court's denial of defendant's motion for summary judgment on plaintiff's excessive force claim, agreeing with the district court that genuine issues of material fact precluded a grant of qualified immunity. Construing the disputed record in plaintiff's favor, the court concluded that a jury could conclude that no reasonable officer would have thought deadly force was necessary in that moment to protect plaintiff's wife from imminent danger. Furthermore, plaintiff's demeanor and conduct are in dispute. In this case, defendant opened the door and instantaneously shot plaintiff. Therefore, under these circumstances, no reasonable officer would have believed that he had probable cause to use deadly force. Furthermore, plaintiff's right to be free from excessive force under these circumstances was also clearly established at the time. View "Banks v. Hawkins" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, a police officer, used excessive force against him during a traffic stop. A jury found in favor of plaintiff, awarding compensatory and punitive damages. Defendant appealed.The Eighth Circuit concluded that, viewing the facts in the light most favorable to the verdict, defendant's prolonged use of his taser was not an objectively reasonable use of force. In this case, although plaintiff initially resisted defendant's attempts to remove him from the car, he did not physically hit or verbally threaten defendant. Furthermore, plaintiff, who was 17 years old at the time, posed at most a minimal safety threat to defendant. The court also concluded that plaintiff's right to be free from excessive, prolonged use of a taser was clearly established at the time. Accordingly, the court affirmed the district court's denial of defendant's motion for judgment as a matter of law on the prolonged taser claim.The court rejected defendant's evidentiary claims of error, concluding that the district court did not abuse its discretion in admitting testimony from a vocational rehabilitation expert and testimony from an economist based on the vocational expert's opinion. Finally, the court concluded that the district erred in reducing the punitive damages award. While the court concluded that the district court correctly found that the jury's initial punitive damages award was disproportionate, the court disagreed that the reduced award of $236,500 sufficiently reflected the reprehensibility of defendant's conduct. In this case, the 9:1 ratio comports with due process while achieving the statutory and regulatory goals of retribution and deterrence. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Masters v. Runnels" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against the Board of Regents of the University of Minnesota, alleging that the University constructively terminated her and subjected her to a hostile work environment. Plaintiff, the head coach of the women's cross-country and track-and-field teams, resigned after the University threatened to terminate her following an outside-law-firm's investigation into her alleged misconduct.The court concluded that, although plaintiff's factual allegations show the University treated her and her teams differently from other coaches and teams, the complaint does not plausibly give rise to the inference of discrimination on the basis of sex as the reason for her termination. Furthermore, even if the stated reason for her termination was pretextual, she has not stated a claim for relief that is plausible on its face. The court also concluded that plaintiff's allegations, though perhaps describing vile or inappropriate behavior, do not rise to the level of actionable hostile work environment as a matter of law. View "Warmington v. Board of Regents of the University of Minnesota" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's action against numerous companies for violating the Missouri Merchandising Practices Act (MMPA) through their marketing of men's and women's antiperspirants. Plaintiff alleges that Conopco, Inc.—doing business as Unilever—discriminates based on gender in pricing two Dove product lines.The court concluded that plaintiff mistakes gender-based marketing for gender discrimination where she ignores the fact that the different scents, packaging, and labels make the products potentially attractive to different customers with different preferences. Because preference-based pricing is not necessarily an unfair practice, the MMPA does not prohibit defendants' pricing here. View "Schulte v. Conopco, Inc." on Justia Law

The Eighth Circuit affirmed the district court's pretrial rulings in a 42 U.S.C. 1983 action brought by plaintiff after he was assaulted by a group of prison guards. The court concluded that the district court did not err in declining to admit a letter regarding one of the defendants, which discusses an incident that occurred more than two years after what happened in this case, because the letter contained other information which had no connection with the alleged assault of plaintiff and which had the potential to prejudice all defendants. Likewise, the court reached the same conclusion regarding the report. The court also concluded that the district court did not abuse its discretion in refusing to give plaintiff's proposed, adverse-inference instruction regarding one of the defendant's non-participation, because it would have misstated the law, likely misled the jury, and unfairly prejudiced the remaining defendants. View "Trotter v. Shipley" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Atrium in an action brought by plaintiff, a former employee, alleging race discrimination, failure to promote, and hostile work environment in violation of the Iowa Civil Rights Act (ICRA). Absent further instruction from the Iowa Supreme Court to the contrary, the court will continue to apply the McDonnell Douglas framework to ICRA discrimination claims at summary judgment.Under the McDonnell Douglas framework, the court concluded that plaintiff failed to present evidence of any situation in which a white Atrium employee took a hotel room out of service, made a key to it, and then allowed unregistered guests to gain possession of the key, without being fired as a result. Furthermore, there is no evidence of white Atrium employees engaging in comparably serious misconduct without experiencing similarly harsh employment consequences. Therefore, the court concluded that plaintiff has not shown that similarly situated employees outside of his protected class were treated more favorably than him after engaging in similar misconduct. The court also concluded that summary judgment on the failure to promote claim was warranted where plaintiff failed to present evidence showing that Atrium's stated reason for declining to promote him was pretextual. Finally, plaintiff's hostile work environment claim failed because he failed to show that he experienced the workplace as abusive or that he felt that the harassment was so severe that it in effect altered the terms of his employment. View "Carter v. Atrium Hospitality" on Justia Law