Justia Civil Rights Opinion Summaries

Plaintiff, a 7 year old elementary school student, filed a 42 U.S.C. 1983 suit against KCPS, Officer Craddock, and Principal Wallace for violations of his rights under the Fourth and Fourteenth Amendments. Plaintiff's claims arose when he was handcuffed in school after an outburst in the classroom against a classmate that was incessantly teasing him. The district court determined that disputed material facts precluded dismissal of the student's claim against the officer and principal, and denied summary judgment to KCPS.The Eighth Circuit held that neither the officer nor the principal violated the student's constitutional rights, and they were entitled to qualified immunity on plaintiff's claim of unreasonable seizure and excessive force. In this case, a reasonable officer could conclude that, based on the student's recent resistance, keeping him in handcuffs for 15 minutes until a parent arrived was a reasonable course of action and was necessary to prevent him from trying to leave and posing harm to himself. Furthermore, the principal's failure to intervene and have the officer remove the handcuffs was reasonable in light of her previous experience with the student. Even if the reasonableness of the officer and the principal's actions were questionable, the student could not show that a reasonable official would have been on notice that their conduct violated a clearly established right. The court also held that, because there was no violation of the student's constitutional rights, the student's municipal liability claims failed. Therefore, the court reversed the district court's denial of summary judgment for the officer, principal, and KCPS, remanding for entry of summary judgment in their favor on the student's claims. View "K.W.P. v. Kansas City Public Schools" on Justia Law

Plaintiff filed suit against the police chief, the city, and other public officials, alleging violations of the Driver's Privacy Protection Act (DPPA). After the police chief admitted liability for six violations of the Act, the jury awarded plaintiff punitive damages. The district court ruled that plaintiff failed to present sufficient evidence that the city was directly liable for the violations, but authorized the jury's finding that the city was vicariously liable for the police chief's actions.The Eighth Circuit affirmed and held that the district court did not abuse its discretion by ruling that plaintiff's proposed class failed to satisfy the numerosity requirement of Federal Rule of Civil Procedure 23(a) and the predominance requirement of Rule 23(b)(3); the district court properly refused to entertain direct liability against the city where the police chief acted for personal reasons, not under the auspices of official policymaking authority, and thus his actions did not represent a policy of the city; the district court correctly construed the civil action provisions of the Act to incorporate background tort-related rules of vicarious liability; the district court did not abuse its discretion in excluding certain evidence at trial; and the district court did not err in declining to award requested costs. The court rejected plaintiff's remaining claims and denied the city's motion to strike portions of plaintiff's appendix and brief. View "Orduno v. Pietrzak" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendant's motion for summary judgment in an action challenging the decision of the Pine Bluff Arsenal (PBA) not to hire plaintiff. Under the McDonnell Douglas burden-shifting framework, the court held that plaintiff failed to show that PBA's reasons for hiring other candidates were pretextual. In this case, no reasonable factfinder could conclude that the decision to hire other candidates was motivated by race, where such a conclusion would require speculation because plaintiff has not produced sufficient evidence to raise a reasonable inference of discrimination. View "Farver v. McCarthy" on Justia Law

Plaintiff filed suit against NPC, seeking declaratory and injunctive relief for alleged violations of the Americans with Disabilities Act (ADA), and corresponding ADA Accessibility Guidelines (ADAAG). Plaintiff, who has cerebral palsy and requires a wheelchair for mobility, alleged that NPC's restaurant failed to make its place of public accommodation fully accessible to persons with disabilities.The Eighth Circuit held that plaintiff's parking lot violations claim was moot, because NPC corrected the access aisles the month after plaintiff filed his complaint. The court also affirmed the dismissing of the three other claims, because plaintiff lacked standing to challenge the remaining architectural barriers. In this case, he never entered the building at issue and never suffered any injury. The court held that the district court erroneously concluded that plaintiff had standing to challenge all of the alleged barriers and thus dismissed the case with prejudice. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Dalton v. NPC International, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the employer in an action brought by plaintiff, alleging claims under Title VII of the Civil Rights Act and the Iowa Civil Rights Act for retaliation, discrimination, and hostile work environment.The court held that summary judgment on the retaliation claim was proper under the McDonnell Douglas burden-shifting framework. Even assuming plaintiff established a prima facie showing of retaliation, substantial evidence in the record supported the employer's proffered reason for its termination of plaintiff: she repeatedly micromanaged and interfered with other employees. Therefore, plaintiff failed to show that the employer's reason for her termination was pretextual. The court also held that plaintiff failed to establish a prima facie case of hostile work environment based on sex, because her actions demonstrated that she did not personally experience offensive or unwelcome harassment. Furthermore, plaintiff's claim for hostile work environment based on a protected activity failed, because she failed to show that she experienced harassment so severe or pervasive as to constitute a materially adverse action. Finally, plaintiff waived her discrimination claims. View "Mahler v. First Dakota Title Limited Partnership" on Justia Law

Six Native American plaintiffs filed suit challenging portions of North Dakota's election statutes, requiring a voter to present a specific form of identification at the polls before receiving a ballot. The district court enjoined the Secretary from enforcing certain statutory requirements statewide.The Eighth Circuit held that at least one of the plaintiffs had standing to raise a facial challenge to the statute. On the merits, the court held that plaintiffs' facial challenge to the residential street address requirement likely fails, and that the statewide injunction as to that provision cannot be justified as a form of as-applied relief; the statute's requirement to present an enumerated form of identification does not impose a burden on voters that justifies a statewide injunction to accept additional forms of identification; and the record is insufficient to justify enjoining the Secretary from enforcing the supplemental documents provision statewide. Accordingly, the court vacated the preliminary injunction and remanded for further proceedings. View "Brakebill v. Jaeger" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Norac in an action brought by plaintiff, a Norac employee, alleging claims of employment discrimination following her termination. The court held that plaintiff failed to meet her burden of presenting evidence that created a fact question as to whether Norac's proffered reason for her termination was pretextual, and thus summary judgment was appropriate. The court also held that the district court did not abuse its discretion by denying plaintiff's motion to strike an email and its admission did not prejudice plaintiff. View "Lacey v. Norac, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Nationwide in an action brought by plaintiff, an employee of Nationwide, alleging discrimination against her on the basis of her sex and her age. The court held that plaintiff failed to show Nationwide's legitimate non-discriminatory reasons for not selecting her for vacant positions and promotions were pretexts for age or gender bias. In this case, Nationwide's treatment of a younger male employee similarly to plaintiff was the clearest example of a record reflecting a displeased manager rather than discrimination based on age or gender. View "Heisler v. Nationwide Mutual Insurance Co." on Justia Law

Plaintiff filed suit alleging that defendants were responsible for his delayed release from jail following the dismissal of criminal charges against him. The Eighth Circuit reversed the district court's denial of qualified immunity to the St. Louis Circuit Attorney, holding that she did not violate plaintiff's constitutional rights because the law did not clearly establish that the attorney, or prosecutors in her office, must go beyond the filing of a nolle prosequi to ensure the release of those against whom no charges are pending. Even assuming that the attorney had such a duty, plaintiff has not actually alleged that the attorney did not satisfy that responsibility.The court also held that plaintiff's false-imprisonment claim against the attorney should be dismissed where the complaint did not plausibly show that the attorney was personally involved in plaintiff's delayed release. Accordingly, the court remanded for further proceedings. View "Lewis v. Gardner" on Justia Law

The Eighth Circuit affirmed the district court's denial of plaintiff's request for declaratory and injunctive relief, seeking a ruling that the Missouri State Highway Patrol is forbidden to stop and inspect his 54,000-pound dump truck, used in furtherance of his private commercial venture, without probable cause. The court held that plaintiff is a member of the closely regulated commercial trucking industry, and that the patrol's random stops and inspections of his truck would comport with the Fourth and Fourteenth Amendments. Furthermore, Missouri's regulatory scheme advances a substantial government interest as applied to plaintiff, and warrantless inspections are necessary to further the regulatory scheme. View "Calzone v. Olson" on Justia Law