Justia Civil Rights Opinion Summaries

Plaintiff filed suit against the sheriff and sheriff's deputies, alleging that they violated his constitutional right to be free from unreasonable searches and seizures and his right to due process.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that the deputies were entitled to qualified immunity because a reasonable officer could believe that the location of the keys to a seized vehicle was reasonably related to the suspected crime because it could provide evidence that plaintiff himself placed the car on the property rather than someone else; the seizure of antique handguns, guns in unopened boxes, and holsters were covered under the second warrant authorizing the seizure of any and all handguns in plaintiff's home; the second warrant was sufficiently particular; the sheriff was entitled to summary judgment on claims against him in his individual capacity and in his official capacity; and plaintiff had an adequate state court remedy to obtain the return of the seized items. View "Thiel v. Korte" on Justia Law

Within two months after plaintiff filed suit against Holiday seeking declaratory and injunctive relief for violations of Title III of the Americans with Disabilities Act, Holiday remedied the violations. Three months later, plaintiff filed an amended complaint.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Holiday, holding that the post-suit alterations mooted plaintiff's accessibility claims. Furthermore, because there was no fair notice of the flared-sides issue, the disputed measurements are not a genuine issue of material fact. The court also held that the district court correctly ruled that nominal damages are not available under Title III of the ADA, and that requesting them does not affect mootness. View "Hillesheim v. Holiday Stationstores, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of prison officials in a 42 U.S.C. 1983 action brought by plaintiff, alleging violation of his due process rights in connection with discipline imposed on him. The court held that the conditions of confinement that plaintiff faced during administrative segregation and upon his transfer to the Iowa State Penitentiary did not amount to an atypical and significant deprivation when compared to the ordinary incidents of prison life.The court held that the transfer to a higher security facility alone is insufficient to establish an atypical and significant hardship, and thus the court must examine the conditions of confinement. In this case, plaintiff failed to set forth facts describing his conditions of confinement while in administrative segregation and disciplinary detention. Furthermore, plaintiff's reference to his loss of employment, wages, security classification, security points, and inmate tier status upon his transfer did not amount to atypical and significant hardship under precedent. View "Smith v. McKinney" on Justia Law

Plaintiff, a former detainee at the detention center, filed suit against the sheriff and nurse, alleging that defendants delayed his access to adequate medical treatment for a serious condition while he was detained.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that there was insufficient evidence to support a submissible case. In this case, the nurse's actions demonstrated concern for plaintiff's condition and showed repeated efforts to make arrangements for surgery. Even if the nurse could be second-guessed for not acting more aggressively when the doctor's office delayed, her handling of the situation was at most negligent and does not amount to deliberate indifference that violates the Due Process Clause. Because plaintiff has not presented sufficient evidence that the nurse was deliberately indifferent to his serious medical needs, it follows that the sheriff did not violate plaintiff's rights by supposedly turning a blind eye to his complaints about the nurse. Likewise, claims against defendants in their official capacities, which are treated as claims against the municipality, failed for lack of a constitutional violation. View "Morris v. Cradduck" on Justia Law

Plaintiff filed suit against UND Law under Title II of the Americans With Disabilities Act of 1990 (ADA), alleging that UND Law discriminated against him because of his mental illness when it rejected his admission application.The Eighth Circuit affirmed the district court's grant of summary judgment to UND Law, holding that plaintiff failed to show that UND Law's legitimate, nondiscriminatory reason for rejecting plaintiff's application was pretext for discrimination. The court reasoned that UND Law's holistic approach to application reviews did not discriminate against plaintiff in determining that he would not be a good fit for UND Law. In this case, plaintiff had dropped out of law school three times, had a very low undergraduate GPA, and submitted out-of-date recommendation letters. View "Power v. University of North Dakota School of Law" on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to dismiss plaintiff's action alleging a claim under the Americans with Disabilities Act (ADA). The court held that the district court erred by dismissing plaintiff's claim where plaintiff's allegations were sufficient to state a claim based on the statutory elements of the ADA. In this case, plaintiff has plausibly alleged that defendant refused to consider rehiring him because of his disability. The court also held that plaintiff's request for leave to amend was not futile and should have been granted. View "Cook v. George's, Inc." on Justia Law

Plaintiff, a former police officer, filed a 42 U.S.C. 1983 action against the city and the chief of police, alleging unlawful retaliation for exercising his First Amendment right to participate in a media interview, deprivation of his right to pretermination process, and violation of his rights under the North Dakota Constitution.The Eighth Circuit affirmed the district court's grant of defendants' motion for summary judgment. The court held that the district court properly granted summary judgment on the First Amendment claim where plaintiff failed to prove his speech as a public employee was protected by the First Amendment. In this case, the district court found that plaintiff was not speaking as a citizen in a local news interview; plaintiff's speech during the interview was not on a matter of public concern because his asserted desire was to clear the name of his Facebook alias, which was a purely private interest; and even assuming plaintiff was a citizen commenting on a matter of public concern, his speech at the interview was not First Amendment protected, because it created great disharmony in the workplace, interfered with plaintiff's ability to perform his duties, and impaired his working relationships with other employees. The court also held that plaintiff was not deprived of his right to due process, and declined to exercise supplemental jurisdiction over the state law claims. View "Nagel v. City of Jamestown" on Justia Law

After plaintiff was sexually assaulted by a deputy acting within the scope of his employment with the sheriff's office, she filed claims of unreasonable search and seizure, equal protection, due process, supervisory liability, and municipal liability under the Civil Rights Act, 42 U.S.C. 1983.The Eighth Circuit reversed the district court's denial of qualified immunity and summary judgment in favor of the sheriff. The court held that the sheriff was entitled to qualified immunity, because prior instances of sexual misconduct were not similar in kind or sufficiently egregious in nature to demonstrate a pattern of sexual assault against members of the public by deputies. Therefore, a reasonable officer in the sheriff's position would not have known that he needed to more closely supervise his deputies, including defendant, or they might sexually assault a member of the public. Furthermore, a reasonable supervisor in the sheriff's position would not know that a failure to specifically train defendant not to sexually assault a woman would cause defendant to engage in that behavior. View "McGuire v. Cooper" on Justia Law

Plaintiffs, a group of pretrial arrestees who were detained in St. Louis jails, filed a 42 U.S.C. 1983 action, challenging the constitutionality of the procedures by which defendants, state and city officials, set money bail.The Eighth Circuit reversed the district court's grant of plaintiffs' motion for class certification and entry of a preliminary injunction enjoining the enforcement of any monetary condition of release resulting in detention. In this case, the district court resorted to the extraordinary remedy of injunctive relief without adequately considering the new rules and their implementation. The district court abused its discretion by interjecting the power of the federal government into the Missouri Supreme Court's attempt to police its own lower courts, without contemplating what this would mean for federal-state relations. On remand, the district court should consider the effect of the rule changes on the question of whether a preliminary injunction served the public interest in comity between the state and federal judiciaries, as well as the necessity of an injunction. View "Dixon v. City of St. Louis" on Justia Law

The Eighth Circuit affirmed the district court's denial of a third successive federal habeas corpus petition challenging petitioner's state law murder conviction. The court held that the district court did not err in finding that it lacked jurisdiction to hear the petition because he failed to establish by clear and convincing evidence it was more likely than not that no reasonable jury would have found him guilty beyond a reasonable doubt. Because petitioner failed to make out a colorable claim under 28 U.S.C. 2254(e)(2)(B), he was not entitled to an evidentiary hearing. View "Rhodes v. Smith" on Justia Law