Justia Civil Rights Opinion Summaries

Plaintiff, an inmate at the ADC, filed suit under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), as well as the First and Fourteenth Amendments, seeking injunctive relief against ADC officials for allegedly refusing to provide him with a daily serving of "halal" meat in accord with his personal religious beliefs.The Eighth Circuit reversed the district court's grant of an injunction in favor of plaintiff, holding that he failed to exhaust his administrative remedies as required by the PLRA. In this case, plaintiff was required to exhaust ADC's proper grievance procedures regardless of the forms of relief potentially available under the Religious Diet Policy. Furthermore, the court rejected plaintiff's contention that the Religious Diet Policy was, in and of itself, a proper and complete grievance procedure. View "Muhammad v. Mayfield" on Justia Law

The Eighth Circuit reversed the district court's denial of a deputy's motion for summary judgment in a 42 U.S.C. 1983 action, alleging that the deputy used excessive force while arresting plaintiff. The court held that the deputy did not violate a clearly established right of plaintiff under the Fourth Amendment, and thus he was entitled to qualified immunity. In this case, it was not clearly established at the time that a deputy was forbidden to use a takedown maneuver to arrest a suspect who ignored the deputy's instruction to "get back here" and continued to walk away from the officer. View "Kelsay v. Ernst" on Justia Law

The Eighth Circuit affirmed the district court's judgment upholding the constitutionality of an Arkansas zoning law that prevents adult-oriented businesses from opening within 1,000 feet of schools and other places frequented by children. The court held that Adam and Eve, an adult toy superstore, has not engaged in speech and therefore cannot state a claim under the First Amendment. In this case, Adam and Eve disavowed any express conduct; cited no authority that selling sexually-oriented devices was speech; and expressly and repeatedly rejected that it was an adult-oriented business similar to those found in prior precedent, each of which engaged in protected speech.The court also held that the zoning law was not unconstitutionally vague and does not violate equal protection. The court held that a plaintiff whose conduct is clearly proscribed cannot raise a successful vagueness claim under the Due Process Clause of the Fifth Amendment for lack of notice, and a substantial portion of Adam and Eve's business involves selling items the statute reaches. Finally, Adam and Eve failed to show that the Act treated it differently than similarly situated entities or lacked a rational basis. View "Adam and Eve Jonesboro, LLC v. Perrin" on Justia Law

The Eighth Circuit held that the district court erred in denying summary judgment based on qualified immunity to the officer who shot and killed the decedent during a police chase. The court held that the district court failed to meet it threshold duty to make a thorough determination of the officer's claim of qualified immunity, and thus the case must return to the district court for a second look. Therefore, the court vacated and remanded. The court also remanded for reconsideration of the officer's claim of official immunity. View "N.S. v. Thompson" on Justia Law

The Eighth Circuit affirmed the district court's grant of Warren Unilube's motion for summary judgment in an action brought by plaintiff, alleging a race-based claim under Title VII of the Civil Rights Act. Under the McDonnell Douglass framework, the court held that plaintiff made a prima facie case of discrimination because he was a member of a protected group and was terminated. Furthermore, he was qualified for his position.However, the court held that the employer articulated a legitimate, nondiscriminatory reason for plaintiff's discharge based on plaintiff's performance related deficiencies. Finally, the court held that plaintiff failed to demonstrate that Warren's reasons for his termination were pretextual. View "Beasley v. Warren Unilube, Inc." on Justia Law

Plaintiff filed suit against the City, the police chief, and the city administrator, alleging that plaintiff was terminated without due process and in retaliation for his exercise of First Amendment free speech rights. The district court denied defendants' motion for qualified immunity.The Eighth Circuit held that, even if plaintiff were terminated in retaliation for his speech, defendants did not violate a clearly established statutory or constitutional right of which a reasonable person would have known. Furthermore, the disputed facts did not preclude summary judgment because the dispute did not affect the outcome of the suit under the governing law. In this case, defendants could reasonably conclude that plaintiff was speaking solely as an aggrieved police officer and without constitutional protection. Furthermore, plaintiff failed to establish a deprivation of a liberty interest, because he did not show that he was stigmatized by the stated reasons for his discharge and that the statements were made public. Therefore, plaintiff failed to demonstrate a constitutional violation, and the police chief and administrator were entitled to summary judgment. Finally, because plaintiff failed to demonstrate a deprivation of a property or liberty interest, his claims against the City also failed. However, this ruling did not necessarily resolve the city's liability in the retaliation claim. Accordingly, the court reversed in part, affirmed in part, and remanded. View "Mogard v. City of Milbank" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment and award of attorney's fees, expenses, and costs to plaintiffs, in an action brought under the Americans with Disabilities Act (ADA). Plaintiffs, two individuals with hearing impairments and two organizations, filed suit seeking injunctive and declaratory relief, including mandated captions at all performances for which the Fox Theater received a captioning request two weeks in advance, publicity that captions were available along with a way to request them, and sale of tickets to deaf and hard-of-hearing patrons by non-telephonic means.The court held that the Fox did not provide meaningful access to individuals with hearing impairments and that plaintiffs' claims were not subject to the undue burden defense. In this case, one captioned performance per run of a show denied hearing impaired persons an equal opportunity to gain the same benefit as persons without impairments and denied them meaningful access to benefits the Fox provided. The court noted, however, that if the volume of captioning requests in the future rises to the level of an undue burden on the Fox, nothing precludes Fox Associates from bringing its own lawsuit and seeking to modify the district court's order in this case. The court also held that the district court did not abuse its discretion in failing to reduce its award of attorney's fees based on partial litigation success; in setting an hourly rate of $450; and in declining to reduce its fee award further for inefficiency. View "Childress v. Fox Associates, LLC" on Justia Law

Plaintiff filed a pro se complaint alleging a 42 U.S.C. 1983 claim against MDOC, the warden of OCC, and a former probation and parole officer at the OCC, alleging that he was unlawfully deprived of his liberty as a result of statements made by the former probation and parole officer to a local state court. The district court granted the warden and the officer absolute and qualified immunity, and plaintiff appealed the assistance of pro bono counsel.The Eighth Circuit affirmed and held that plaintiff's complaint failed to contain sufficient allegations to overcome qualified immunity with regard to any statement the probation officer made to the state court before the court issued the order requiring plaintiff to be detained further. Furthermore, the complaint did not provide any other reason that either the warden or the probation officer violated a clearly established constitutional right. View "Sandknop v. O'Connell" on Justia Law

The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining North Dakota Senate Bill 2289, which regulates relationships between manufacturers and farm equipment dealers. The court held that the State has not carried its burden of showing a significant and legitimate public purpose underlying Senate Bill 2289. Therefore, the district court did not err in concluding that the manufacturers were likely to succeed on the merits of their Contract Clause claim. In this case, the manufacturers cannot reasonably be said to have had a fair and appreciable warning of an impending intervention into their agreements. View "Association of Equipment Manufacturers v. Burgum" on Justia Law

The Eighth Circuit affirmed the district court's denial of a 28 U.S.C. 2255 habeas corpus petition, seeking relief from a mandatory minimum sentence imposed in 2008. The court held that petitioner's 2014 motion was time-barred under section 2255(f)(4). In this case, the issuance of the Commission's 2011 Report was what triggered petitioner's duty to act with diligence, and he failed to do so because he did not file until almost three years later. View "Ingram v. United States" on Justia Law