Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's dismissal of TJN's 42 U.S.C. 1983 action against defendants, in an action arising from the Craighead County District Judges Boling and Fowler's implementation of an Amnesty Program forgiving all fees that probationers owed to TJN for probation services. The court held that Judges Boling and Fowler were entitled to absolute judicial immunity against all of TJN's claims, because Arkansas judges have authority to suspend the imposition of fines in criminal cases and may modify terms and conditions of supervision. Furthermore, TJN's request for declaratory relief was retrospective and thus it was not entitled to such relief under section 1983. The court also rejected the municipal liability claims and held that the judges are state government officials whose actions are not attributable to the county or city defendants. View "Justice Network Inc. v. Craighead County" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1981 against K.C. Live for assault, battery, false imprisonment, negligence, and malicious prosecution. The district court granted K.C. Live's motion to dismiss after finding the claim was barred by res judicata in light of the state court's prior dismissal with prejudice.The Eighth Circuit affirmed, holding that the suit was barred by res judicata because plaintiff asserted the same cause of action against the same party in federal court that he did in the state court, which had jurisdiction and entered a final judgment. View "Brown v. Kansas City Live, LLC" on Justia Law

Plaintiff filed suit against her employees, alleging that they unlawfully terminated her in retaliation for exercising her rights under the Family and Medical Leave Act (FMLA) and the Missouri Human Rights Act (MHRA). Plaintiff's husband filed suit for loss of consortium.The Eighth Circuit held that the district court did not err in granting defendants summary judgment on the FMLA claim, because plaintiff's use of FMLA leave some half-year prior to her termination was insufficient to show her termination was an act of discrimination. The court also held that the district court did not err in granting summary judgment in favor of defendants on the MHRA claim, because plaintiff could not have had a reasonable good faith belief that the conduct she opposed had constituted disability discrimination in violation of the MHRA. For purposes of the MHRA, accusing an employee of racism does not constitute racial discrimination. Furthermore, evidence of general temporary work restrictions, without more, was insufficient to constitute a disability. Finally, the loss of consortium claim was properly dismissed. View "Lovelace v. Washington University School of Medicine" on Justia Law

Plaintiff, a minor, filed suit against the SWAT team officers, the detectives, and the Board under 42 U.S.C. 1983, after she suffered Post-Traumatic Stress Disorder (PTSD) from the blast of a flash-bang grenade. In this case, even though the SWAT team knew the suspect was already in custody, they broke open the screen door of the suspect's residence and threw a flash-bang grenade into the living room of the home before a young woman could open the door with the keys she was holding in her hand. The only people inside where three women and a two year old girl. The girl suffered PTSD from the officers' use of the flash-bang grenade.The Eighth Circuit held that the SWAT team officers were not entitled to qualified immunity because any reasonable officer would have known the use a flash-bang grenade under these circumstances constituted excessive force. It was clearly established at the time that use of a flash-bang grenade was unreasonable where officers have no basis to believe they will face a threat of violence and they unreasonably fail to ascertain whether there are any innocent bystanders in the area where the grenade is deployed. Therefore, the district court did not err by denying summary judgment based on qualified immunity. The court also held that detectives are entitled to summary judgment because there was probable cause to support the search warrant, even considering the omitted information, and because their decision to use a SWAT team, regardless of whether it was reasonable, did not violate clearly established law. Accordingly, the court reversed the district court's grant of summary judgment as to the detectives. Finally, the court held that it lacked appellate jurisdiction to review the district court's denial of summary judgment to the Board, and the court dismissed the appeal as to the Board. View "Z. J. v. Kansas City Board of Police Commissioners" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Union Pacific in an action brought by plaintiff against the employer, alleging disparate treatment and failure to accommodate under the Americans with Disabilities Act (ADA). Plaintiff suffered from chronic back pain and wanted to take time off as necessary and to receive 24 hours of rest per shift (between shifts).The court held that plaintiff could not establish a prima facie case of discrimination, because job attendance is an essential function of a Union Pacific Locomotive Engineer and plaintiff could not perform this essential function with or without reasonable accommodation. View "Higgins v. Union Pacific Railroad Co." on Justia Law

Plaintiffs, Hispanic residents of Hastings, filed suit alleging a variety of state and federal law claims against various city and county employees, the State of Nebraska, Adams County, and the City of Hastings. Plaintiffs were arrested on charges of conspiracy and witness tampering for their alleged actions in the aftermath of a domestic disturbance in Hastings, and the charges were eventually dismissed.The Eighth Circuit held that the district court had jurisdiction over the 42 U.S.C. 1983 claims and the second amended complaint was properly before the court. The court declined to address the statute of limitations question because the second amended complaint did not meet federal pleading standards; the district court did not err in dismissing the claims against the Officer Defendants where the pleadings consisted almost entirely of non-specific conclusory allegations; the district court committed no error in dismissing the claims against the Doe Defendants where the second amended complaint did not sufficiently allege who they were, what they allegedly did, their positions were for the city, or any other facts that would permit them to be noticed or identified through discovery; and the district court did not clearly abuse its discretion when it denied plaintiffs' motion to amend or alter the judgment. View "Perez v. John and Jane Does 1-10" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Ford on plaintiff's claims of disability discrimination and retaliation under the Missouri Human Rights Act (MHRA). Plaintiff, born without a left forearm and hand, applied for an entry-level assembler position at Ford's assembly plant.The court held that the district court did not err by using the broad-range-of-jobs standard because this case only involved the major life activity of working or employment; the district court did not err in concluding that plaintiff had not satisfied the broad-range-of jobs standard because Ford considered him permanently restricted from a single, particular job he applied for; plaintiff waived his argument regarding direct evidence of discrimination; and therefore plaintiff's claim of discrimination under the MHRA failed, because plaintiff failed to show that Ford regarded him as having a disability. Finally, the court declined to consider the retaliation claim on appeal. View "Heuton v. Ford Motor Co." on Justia Law

Plaintiffs filed suit against a trooper, alleging that the trooper used excessive force when he shot and killed Gerry Thompson during a domestic disturbance response. The district court denied the trooper's motion for summary judgment based on qualified immunity and the trooper appealed.The Eighth Circuit dismissed the trooper's appeal, holding that the appeal turned on disputed issues of fact as to what occurred before the shooting and thus the court lacked jurisdiction. View "Thompson v. Dill" on Justia Law

After police shot and killed a suspect, the administrators of the decedent's estate filed suit against the officer who fired the fatal shots, alleging that the officer violated the decedent's constitutional rights by using unreasonable force. The Eighth Circuit affirmed the district court's judgment and held that the officer was entitled to qualified immunity because his use of force, even if just over the line of reasonableness, violated a clearly established right. In this case, the officer was suddenly confronted, at a distance of only three feet, with a suspect who was armed with a knife after ignoring multiple commands to drop it. View "Swearingen v. Judd" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2255 motion based on ineffective assistance of counsel. The court held the ineffective assistance of counsel claim regarding petitioner's plea was properly denied, because a reasonable attorney could have determined that the record, including the government's uncontested evidence and petitioner's own colloquy with the magistrate judge, established an adequate factual basis for petitioner's guilty plea to the money laundering charge. The court also held that petitioner's claim that trial counsel improperly coerced the plea was properly rejected. Finally, the issue of ineffective assistance of appellate counsel was not included in the certificate of appealability and the court declined to address it. View "Meza-Lopez v. United States" on Justia Law