Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate, set aside or correct his sentence under 28 U.S.C. 2255. The court held that counsel's conflict did not adversely affect the adequacy of his representation of petitioner at trial; the district court did not clearly err in finding that counsel's strategy was reasonable in the circumstances, the evidence of petitioner's guilt was overwhelming, and alternative strategies petitioner proposed were not objectively reasonable; and petitioner failed to show that the conflict diminished counsel's credibility in the jury's eyes. The court also held that the district court did not clearly err by finding that counsel did not know that the funds at issue were stolen and that there was insufficient evidence to support a reasonable inference that petitioner knew, or should have known, that the funds at issue were illegitimate. Finally, the district court did not clearly err by finding that emails were insufficient to raise an inference that counsel was entangled with the conspiracy. View "Kiley v. United States" on Justia Law

Plaintiff appealed the district court's dismissal of her 42 U.S.C. 1983 action alleging that the City deprived her of her constitutional rights. Plaintiff's amended complaint alleged that she was arrested, her car was towed, and she was held at the police station until it was discovered that she had paid certain fines.The Eighth Circuit held that the district court erred because, whether or not the clerk had absolute or qualified immunity, that immunity did not foreclose an action against the City if the complaint adequately alleged an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee. Although the record has not been developed with respect to the clerk's duties and responsibilities, the source of the clerk's pay, or the degree that state or local officials exercised over the clerk, the court held that the complaint at least stated a plausible claim of wrongdoing. Therefore, the court remanded for further proceedings. View "Evans v. City of Helena-West Helena" on Justia Law

Plaintiffs filed a putative class action against the City, alleging several constitutional violations under 42 U.S.C. 1983 stemming from the City's alleged detention of plaintiffs for their inability to pay traffic fines. The City subsequently sought interlocutory review of the district court's denial of the City's motion to dismiss based on sovereign immunity. The Eighth Circuit dismissed the appeal for lack of jurisdiction because the City disclaimed any sovereign immunity for itself and sought only to invoke the sovereign immunity of a nonparty. View "Fant v. City of Ferguson" on Justia Law

Plaintiffs filed a class action against the State of Missouri and others, alleging that the state failed to meet its constitutional obligation to provide indigent defendants with meaningful representation. The Eighth Circuit reversed the district court's denial of the State and the governor's motion to dismiss based on sovereign immunity and legislative immunity.The court held that the Missouri Supreme Court would apply long-established principles to cases involving prospective equitable relief and hold that the state was immune; neither the statute nor the Missouri Constitution's general-enforcement provision make the governor an Ex parte Young defendant; to the extent plaintiffs claim that the governor's general enforcement authority and appointment authority were non-legislative acts that lead to a constitutional violation, the governor was subject to sovereign immunity for those acts because they did not satisfy Ex parte Young; and even if the governor's appropriation-reduction authority was not shielded by sovereign immunity through Ex parte Young, legislative immunity, a separate defense, foreclosed suit against the governor. View "Church v. Missouri" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against defendants after William Collin Spradling was shot and killed during an investigation. Plaintiff's action was filed outside the Arkansas statute of limitations. The court affirmed the district court's judgment and held that the limitations period was not equitable tolled because the undisputed facts placed plaintiff on objective notice of the need to investigate the shooting. In this case, a witness had informed plaintiff outlining inconsistencies she believed existed in the file and plaintiff did not file suit until after the limitations period had expired. View "Spradling v. Hastings" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims of false arrest, excessive force, and denial of medical care. The court affirmed the district court's judgment and held that plaintiff failed to meet his burden of showing the necessity to disqualify the entire City of Lincoln Attorney's Office and thus the district court did not abuse its discretion by denying the motion to disqualify. The court also held that the district court did not err by granting qualified immunity to the officers and rejected plaintiff's claims of evidentiary errors. In this case, the false arrest claim failed because the officers had probable cause to arrest plaintiff for obstruction of justice; there were no genuine disputes of material fact regarding the excessive force claim; and the district court correctly dismissed plaintiff's claim against one of the officers from suit for denial of medical care. View "Awnings v. Fullerton" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the school district in an action under Section 504 of the Rehabilitation Act. The court held that, where parents refuse special education services for their child under the Individuals with Disabilities Education Act (IDEA) and bring suit under another act, they must first exhaust their administrative remedies under the IDEA if the relief they seek in the suit is also available under the IDEA. Therefore, because plaintiffs failed to exhaust their administrative remedies under the IDEA in this case, the school district was entitled to summary judgment. View "E. D. v. Palmyra R-I School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for defendants in an action alleging racial discrimination in violation of 42 U.S.C. 1981 and 1983, Title VI of the Civil Rights Act of 1964, and the Equal Protection Clause of the Fourteenth Amendment. The court held that, even assuming that plaintiff successfully stated a prima facie case of discrimination, she could not survive summary judgment because she failed to rebut the nondiscriminatory reasons defendants offered for their conduct. In this case, defendants offered legitimate, non-discriminatory reasons for the differing airport lease terms at issue where the airport needed flexibility in its redevelopment efforts, and was concerned over the physical state of plaintiff's building and whether a hobby shop was an FAA-approved aeronautical use. View "Lucke v. Solsvig" on Justia Law

The Eighth Circuit affirmed the district court's grant of qualified immunity to defendant, a jailer, in an action alleging excessive force under 42 U.S.C. 1983 and assault and battery under Iowa law. The court held that the district court did not err in determining that the jailer was entitled to qualified immunity on the excessive force claim during the booking procedure where the amount of force the jailer used was objectively reasonable in light of the need to maintain order and institutional security, and the jailer's reasonable belief that plaintiff posed a security threat. Likewise, the court held that the district court did not err in granting summary judgment on the state law claim where the amount of force was objectively reasonable. View "Parrish v. Dingman" on Justia Law

Plaintiff filed suit against his former employer for race and age discrimination under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act (ADEA), the Arkansas Civil Rights Act, and for promissory estoppel. The Eighth Circuit affirmed the district court's grant of the company's motion to strike portions of plaintiff's statement of material disputed facts and grant of summary judgment.The court held that the district court did not abuse its discretion in striking paragraphs of plaintiff's statement of material fact as unsupported by the record or irrelevant and immaterial; the district court properly granted the employer summary judgment on claims arising more than 180 days before plaintiff filed his EEOC charges; the district court properly granted the employer summary judgment on the failure to rehire claim because plaintiff took no action, never applied for reemployment, and believed he could not perform the duties of the position; the Arkansas Civil Rights Act claims were time-barred; and there was no factual basis for the promissory estoppel claim. View "Kirklin v. Joshen Paper & Packaging of Arkansas Co." on Justia Law