Justia Civil Rights Opinion Summaries

Plaintiff filed suit against current and former members of the Missouri State Highway Patrol, alleging that adverse employment actions were taken against him in retaliation for his protected First Amendment speech.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that plaintiff's non-testimonial speech was not entitled to First Amendment protection. In this case, although it was undisputed that plaintiff spoke as a private citizen and his speech was of public concern, the highway patrol has shown sufficient evidence of disruption to the efficiency of its operations. Under the Pickering balancing test, the court held that the factors weighed in favor of the highway patrol's interest in efficiency and indicated that plaintiff's speech activity was more likely than not impeding his ability to perform his job duties as a police officer. Therefore, defendants were entitled to qualified immunity regarding plaintiff's speech to the family of the victim of a drowning accident, on social media, and to the news reporter. The court also held that the remaining testimonial speech was not a substantial or motivating factor in the adverse employment actions against plaintiff. Finally, plaintiff's civil conspiracy and failure to supervise claims failed as a matter of law. View "Henry v. Johnson" on Justia Law

Ali shot and killed three people during an attempted robbery in Minneapolis. He was given three consecutive life sentences, each permitting his early release after 30 years so that Ali must remain in prison for at least 90 years. Relying on recent Supreme Court precedent, Ali argued that the Eighth Amendment forbids life-without-parole sentences for juvenile defendants unless they are irreparably corrupt and that a sentencing court must conduct a hearing to consider the juvenile defendant’s youth as a mitigating factor before imposing a life-without-parole sentence. Ali claimed his sentence was the “functional equivalent” of life-without-parole. The Minnesota Supreme Court rejected Ali’s argument. The Eighth Circuit affirmed the denial of Ali’s petition for habeas relief under 28 U.S.C. 2254. Ali’s case is distinguishable from the Supreme Court cases; Ali received three life sentences for three separate murders, each permitting possible release. Ali does not face a life-without-parole sentence and the Supreme Court has not “clearly established” that its ruling apply to consecutive sentences functionally equivalent to life-without-parole. View "Ali v. Roy" on Justia Law

Plaintiff filed suit against the city and others, seeking damages and injunctive and declaratory relief under 42 U.S.C. 1983, alleging unlawful arrest, detention, and prosecution, and the setting of an excessive cash-only bond that plaintiff was unable to pay due to indigency.The Eighth Circuit affirmed the district court's dismissal of the section 1983 claims and held that the municipal judge was entitled to absolute judicial immunity from plaintiff's arrest and detention damage claims based on an invalid warrant issued by the court clerk; the judge's practice of setting a bond schedule conditioning the pretrial release of persons accused of municipal ordinance violations was a judicial act within his jurisdiction to which judicial immunity attaches; and the district court correctly concluded that the clerk was entitled to quasi-judicial immunity. Even if the court considered the judge's judicial bond practice to be part of municipal custom or usage, the court would still affirm the dismissal of the claim because there was no evidence of deliberate indifference to plaintiff's rights as an indigent arrestee. Finally, the court held that there was insufficient evidence for a reasonable jury to find a meeting of the minds between defendants on the conspiracy claim. View "Hamilton v. City of Hayti" on Justia Law

Plaintiff filed suit against the city under 42 U.S.C. 1983, alleging that it had jailed her without inquiring into whether she had the means to pay the fines imposed and without appointing counsel for her. The district court dismissed plaintiff's claims on the ground that a judgment in her favor would necessarily imply the invalidity of her conviction or sentence under Heck v. Humphrey, 512 U.S. 477, 487 (1994).The Eighth Circuit affirmed the dismissal of plaintiff's claims, although on different grounds. The court held that the judicial decisions of a duly elected judge are not the kind of decisions that expose municipalities to section 1983 liability. Furthermore, neither the city council nor the mayor has the power to set judicial policy for Arkansas district court judges or the power to ratify their decisions even if the city's policymakers knew of the judge's conduct and approved of it. In this case, the court held that the district court did not err by dismissing plaintiff's claims about the district court's failure to inquire into her indigency and failure to appoint counsel, along with her related, derivative claims about the practices in the Sherwood District Court. View "Williams v. City of Sherwood" on Justia Law

The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining the enforcement of Ark. Code Sec. 7-6-203(b)(1), which provides that candidates can only accept contributions within two years of an election. Plaintiff, who wished to donate to candidates running for state office in Arkansas's 2022 election, alleged that this blackout period violates her First Amendment rights.The court held that plaintiff alleged Article III standing because the allegations in her complaint and affidavit established that she intended to engage in a course of conduct arguably affected with a constitutional interest, but proscribed by a statute, and that there was a credible threat of prosecution if she donated to a candidate. The court also held that the district court correctly determined that, at this early stage of the litigation, plaintiff was likely to succeed on the merits, because Arkansas failed to show how the blackout period advances its anti-corruption interest. View "Jones v. Jegley" on Justia Law

In this interlocutory appeal, the Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer who stopped, frisked, and handcuffed a person who had been watching another police officer perform traffic stops. The court agreed with the district court that genuine issues of material fact preclude the officer from receiving qualified immunity at this stage. In this case, under Walker v. City of Pine Bluff, 414 F.3d 989 (8th Cir. 2005), the officer violated plaintiff's clearly established right to watch police-citizen interactions at a distance and without interfering. View "Chestnut v. Wallace" on Justia Law

Plaintiff, an assistant professor at Macalester College, filed suit against the college after she was terminated for violating the college's policies on student-teacher relationships.The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims for discriminatory discharge based on disability under section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act, and the Minnesota Human Rights Act (MHRA). The court held that plaintiff's claim regarding the departing provost was raised for the first time on appeal and therefore could not be considered by the court; the district court did not abuse its discretion in ruling that plaintiff's motion to amend her complaint to add claims under the Family Medical Leave Act was untimely and futile; and, even if plaintiff made a prima face case of discrimination, the court concluded on de novo review that the college articulated a legitimate, non-discriminatory reason for terminating plaintiff based on her sexual relationship with a former student. Finally, the court held that plaintiff's claim for failure to accommodate her disability under section 504 failed as a matter of law. View "Naca v. Macalester College" on Justia Law

A Missouri statute and two regulations that regulate retail advertising by alcohol producers and distributors violated the First Amendment right to free speech. The Eighth Circuit held that, although the statute on its face does not restrict speech, its practical operation restricts speech based on content and speaker identity, and thus the statute implicates the First Amendment. Furthermore, Missouri's authority under the Twenty-First Amendment cannot save the statute from its First Amendment implications.Under the Central Hudson test, the court held that Missouri has not demonstrated that the harm of undue influence is real or that the Statute alleviates this harm to a material degree. Furthermore, Missouri has also failed to prove that the Statute’s speech restriction as applied is not more extensive than necessary to serve its interest. Like the statute, the court held that the regulations failed to meet Central Hudson's third and fourth prongs. View "Missouri Broadcasters Assoc. v. Schmitt" on Justia Law

Plaintiff filed an amended complaint seeking damages under 42 U.S.C. 1983, alleging that each individual defendant violated his constitutional right to procedural due process under the Fourteenth Amendment when the local animal shelter, after a five-day holding period, put a stray dog up for adoption and spayed the dog before delivering it to the adopting family. Defendants did not know that the stray dog was plaintiff's young German Shepherd, which boasts world champion lineage and had escaped from plaintiff's back yard two weeks earlier.The Eighth Circuit held that the district court failed to devote sufficient attention to whether plaintiff had a protected procedural due process property interest and if so, the nature and extent of that interest. The court agreed with the Supreme Court of Arkansas that affirmative pre-deprivation notice is not constitutionally required in this situation, when an animal shelter holds a stray dog for more than five days and then adopts out and spays the dog after the owner fails to file a claim. The court also held that plaintiff failed to prove that each individual defendant's conduct violated his right to procedural due process. Therefore, the court reversed the district court's order insofar as it denied summary judgment to the individual defendants acting in their individual capacities, remanding with directions. View "Lunon v. Botsford" on Justia Law

Vianney appealed the district court's summary judgment rulings on their Religious Land Use and Institutionalized Persons Act (RLUIPA) claims, Missouri Religious Freedom Restoration Act (Missouri RFRA) claim; and inverse condemnation claim under Missouri's Constitution.The Eighth Circuit affirmed as to the RLUIPA claims, holding that the city's lighting and sound regulations did not substantially burden, rather than merely inconvenienced, Vianney's religious exercise. In this case, Vianney has not demonstrated that a requirement that it avail itself of alternatives would substantially burden its religious exercise, and the record demonstrated that Vianney was not treated less favorably than other schools. The court also affirmed as to the inverse condemnation claim, holding that Missouri courts have held that the reasonable exercise of a city's police power does not constitute a taking and the regulations here did not impose unusually restrictive limitations. However, the court vacated as to the Missouri RFRA claim, because the district court abused its discretion in deciding this state law claim on the merits after granting the city summary judgment on the RLUIPA claims. Accordingly, the court remanded to the district court with instructions to dismiss the claim without prejudice. View "Marianist Province of the U.S. v. City of Kirkwood" on Justia Law