Justia Civil Rights Opinion Summaries

The case involves Charles and Lisa Kass, parents of Brody Kass, who sued the Western Dubuque Community School District (the District) alleging that the District violated the Individuals with Disabilities Education Act (IDEA) and other statutes when it developed Brody’s individualized education program (IEP) for the 2020–21 school year. Brody has epilepsy, autism, attention deficit/hyperactivity disorder, severe vision impairment, and intellectual disabilities. Despite Brody having enough credits to graduate, his IEP Team determined he had unmet transitional needs and should remain in school. The District proposed that Brody would not enroll in general education courses in the traditional classroom setting. Instead, Brody would spend a half-day focusing on developing his reading and math skills through individualized and practical training. The Kasses objected to the proposed IEP and filed a complaint with the Iowa Department of Education.The administrative law judge (ALJ) ruled in favor of the District on all claims, concluding the District did not violate Brody’s right to a free appropriate public education (FAPE) in the 2018–19 or 2019–20 school years. The ALJ also determined neither the draft IEP nor its development violated any procedural or substantive provisions of the IDEA. The Kasses brought this action in federal district court, alleging violations of the IDEA, the Americans with Disabilities Act (ADA), and the Rehabilitation Act. The district court affirmed the ALJ’s decision on the IDEA claims and dismissed the other claims as subsumed under the IDEA claims.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The court held that compensatory education may be available beyond a student’s twenty-first birthday. The court also concluded that the District complied with the IDEA’s procedural requirements in drafting the May 2020 IEP. The court found that the May 2020 IEP’s specific and measurable goals were reasonably calculated to enable Brody to progress in light of his circumstances, and thus met the IDEA’s requirements. View "Kass v. Western Dubuque Community School District" on Justia Law

The case revolves around an incident involving Corey Fisherman, an inmate at Minnesota’s maximum-security prison, and David Launderville, a prison guard. Fisherman was being transferred to a more restrictive area after a shank was found in his cell. During the transfer process, Fisherman initially refused to undergo a strip search, leading to the intervention of the A-Team, a group of guards trained to handle noncompliant inmates, which included Launderville. After the search, Fisherman objected to kneeling and placing his hands through a small opening in his cell door. Once he complied, he was handcuffed. Fisherman alleges that Launderville kneed him six times, three times each in the face and body, while another guard kneeled on his legs. Launderville, however, claims he struck Fisherman twice in the leg because he was resisting.The case was initially heard in the United States District Court for the District of Minnesota. The magistrate judge identified a potential jury issue: whether Launderville struck a restrained inmate six times in the face and body or a partially unrestrained one just twice in the leg. The district court adopted the report and recommendation, leading to an appeal to the United States Court of Appeals for the Eighth Circuit.The Court of Appeals affirmed the district court's decision, denying Launderville's claim of qualified immunity. The court found that a reasonable jury could conclude that the repeated blows to Fisherman's head and body were "malicious and sadistic." The court also determined that the law was clearly established that repeatedly striking a fully restrained inmate violates the Eighth Amendment. Therefore, the court concluded that every reasonable official in Launderville's position would have understood that kneeing a restrained inmate several times in the face and body violated that right. View "Fisherman v. Launderville" on Justia Law

In the case, Sease Beard, a transgender inmate, alleges mistreatment and retaliation by prison officials. Beard, who identifies as a transgender woman, has been provided hormone-replacement therapy by the Missouri Department of Corrections since 2019. The issue in the case centers on whether the prison officials are shielded by qualified immunity.Beard was involved in multiple incidents with guards. In one particular incident, when a guard expressed disapproval of Beard's attire, Beard refused to change. Subsequently, several guards physically restrained Beard, used pepper spray, removed Beard's clothes, and carried Beard through the prison's hallways in view of other inmates. Following this incident, Beard filed a lawsuit against nearly everyone involved, claiming violations of state law and the First, Fourth, Eighth, and Fourteenth Amendments to the United States Constitution.The lower court, the United States District Court for the Western District of Missouri, denied the officials' motion to dismiss the case, asserting their claim to qualified immunity.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision in part and reversed in part. The court found that certain prison officials were not entitled to qualified immunity for some of Beard's claims, including a Fourth Amendment claim regarding a strip search and First Amendment retaliation claims related to denial of a promotion, restriction of shower access, and confiscation of personal property. However, the court found that other officials were entitled to qualified immunity for claims related to the denial of mental health treatment and the supervisors' inaction. The case was sent back to the district court for further proceedings. View "Beard v. Falkenrath" on Justia Law

Four ninth-grade football players at Park Hill High School in Kansas City, Missouri, were suspended or expelled after one of them created an online petition titled "Start Slavery Again" and the others posted comments favoring the petition. They filed a lawsuit against the Park Hill School District and various school officials, claiming that their rights to equal protection and due process were violated.In their suit, the students argued that they were deprived of substantive and procedural due process in the disciplinary procedures. They also claimed that they were deprived of equal protection because another student, who they alleged was a willing participant in creating the petition, was not punished. The U.S. District Court for the Western District of Missouri granted summary judgment for the school district, dismissing all of the students' claims.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The appellate court found that the students received adequate notice and meaningful opportunity to present their case in the school disciplinary proceedings, satisfying the requirements of due process. The court further held that the disciplinary actions taken by the school district were not so egregious as to violate the students' substantive due process rights. Lastly, the court rejected the students' equal protection claim on the basis that the student who was not punished was not similarly situated to the plaintiffs given their greater involvement in creating and supporting the petition. View "Plaintiff A v. Park Hill School District" on Justia Law

The case involves the death of Andrew Dawson Bell, who committed suicide while detained at the Washington County Detention Center (WCDC) in Fayetteville, Arkansas. Bell's mother, Judy Lynn Smith-Dandridge, filed a lawsuit against several Fayetteville Police Department officers, WCDC employees, nurses, and Washington County itself, alleging that they were deliberately indifferent to Bell's serious medical needs, in violation of 42 U.S.C. § 1983 and the Arkansas Civil Rights Act, Arkansas Code Ann. § 16-123-105. The district court granted summary judgment in favor of all defendants, and Smith-Dandridge appealed to the United States Court of Appeals for the Eighth Circuit.Bell had a history of mental illness and substance abuse. On the day he died, Bell had called the police several times, reporting hallucinations of people trying to break into his apartment. Officers responded but found no evidence of a break-in. They arrested Bell for terroristic threats, disorderly conduct, and carrying a weapon. When Bell was processed into WCDC, he informed the intake officers of his mental health history, including a history of suicidal ideation. Despite this, he was placed in the general population.The main issue on appeal was whether the police officers and WCDC personnel had knowledge of Bell's substantial risk of suicide and deliberately disregarded it. Smith-Dandridge argued that the officers’ interactions with Bell and their review of his arrest history established they had the requisite knowledge to establish deliberate indifference. However, the court found that while Bell's behavior put the officers on notice of signs of mental illness, it did not make it obvious to them that Bell had a substantial risk of suicide. Similarly, the court found that the WCDC personnel's inaction to prevent Bell's suicide did not constitute criminal recklessness.The court also dismissed Smith-Dandridge's claim that Washington County was deliberately indifferent in its failure to train jail staff. The court found that Smith-Dandridge failed to show that the alleged deficient training caused WCDC personnel to be deliberately indifferent to Bell's substantial risk of suicide. As such, the court affirmed the district court's grant of summary judgment in favor of all defendants. View "Smith-Dandridge v. Geanolous" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a district court's grant of summary judgment, based on qualified immunity, in favor of government attorneys Michael Spindler-Krage and Thomas Canan. The plaintiff, Michael Davitt, had brought a 42 U.S.C. § 1983 action against Spindler-Krage and Canan, alleging they violated his Fourth and Fourteenth Amendment rights when they advised police that Davitt could be removed from his hotel room without eviction proceedings.During the COVID-19 pandemic, Olmsted County, Minnesota, arranged temporary, non-communal housing for elderly and vulnerable homeless individuals. Davitt, who was 69 years old and homeless, was moved into a Super 8 hotel room. When the county stopped paying for his room, Davitt refused to leave, citing a Minnesota governor's executive order temporarily prohibiting evictions. Spindler-Krage and Canan, after reviewing the relevant state law, the executive order, and the Agreement for Hotel Guests, advised the police that Davitt was a hotel guest, not a tenant protected by the executive order.In granting Spindler-Krage and Canan summary judgment based on qualified immunity, the district court found that no case law, statute, or other legal authority clearly established that Davitt was a tenant with a constitutionally protected right to his hotel room. The court also found that the advice provided to the police was objectively reasonable. The Court of Appeals agreed, ruling that Spindler-Krage and Canan did not violate Davitt’s clearly established rights and were thus entitled to qualified immunity. View "Davitt v. Krage" on Justia Law

This case involves Aaron Norgren and his father, Joseph Norgren, who worked for the Minnesota Department of Human Services (DHS). Both men filed Title VII discrimination and retaliation claims against DHS, as well as First Amendment retaliation and compelled speech claims against the DHS Commissioner, Jodi Harpstead. These claims stemmed from the denial of the Norgrens' religious exemption requests to workplace trainings on racism and gender identity. The lower court dismissed their complaints for failure to state a claim.Aaron Norgren argued he was denied a promotion due to his protected activities. The court found that Aaron plausibly established his case and reversed the dismissal of his Title VII discrimination and retaliation claims. However, his First Amendment retaliation claim was dismissed due to insufficient evidence of Commissioner Harpstead's personal involvement in the alleged discriminatory practices.Joseph Norgren's Title VII discrimination claim was dismissed as he did not plausibly allege that he was constructively discharged or that Commissioner Harpstead was personally involved. His First Amendment retaliation claim was also dismissed due to insufficient evidence.Both Norgrens' compelled speech claims were dismissed. The court ruled that while the trainings advanced expressive messages that the Norgrens objected to, there was no evidence they were forced to affirmatively agree with any of the statements in the trainings or were threatened with penalties if they expressed their own viewpoints.Therefore, the court reversed the dismissal of Aaron's Title VII discrimination and retaliation claims and affirmed the dismissal of the remaining claims. View "Norgren v. Minnesota Department of Human Services" on Justia Law

In this case, a minor student known as A.J.T., who suffers from epilepsy, sued her school district, Osseo Area Schools, alleging disability discrimination for not providing her evening instruction sessions. A.J.T.'s epilepsy is severe in the mornings, preventing her from attending school until noon. The child's parents requested evening instruction so that she could have a school day closer in length to her peers. However, the school district denied these requests.A.J.T., through her parents, filed a lawsuit alleging violations of Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The district court granted Osseo Area Schools' motion for summary judgment, finding that the school district could not be held liable as it did not act with bad faith or gross misjudgment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court stated that while A.J.T. might have established a genuine dispute about whether the district was negligent or even deliberately indifferent, she failed to prove that school officials acted with "either bad faith or gross misjudgment." The court found that the school district did not ignore A.J.T.'s needs or delay its efforts to address them. It further held that in cases involving educational services for disabled children, mere noncompliance with applicable federal statutes or failure to provide a reasonable accommodation is not enough to trigger liability. The plaintiff must prove that the school officials acted with bad faith or gross misjudgment. In this case, A.J.T. failed to identify conduct that cleared that high bar, and as such, the court held that summary judgment was proper. View "A.J.T. v. Osseo Area Schools, Independent School District No. 279" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered the appeal of Osseo Area Schools (the District) against the ruling of the district court, which held that the District had denied A.J.T., a student with a disability, a Free Appropriate Public Education (FAPE) as mandated by the Individuals with Disabilities Education Act (IDEA). A.J.T. suffers from a rare form of epilepsy, causing seizures that prevent her from attending school before noon. Consequently, her parents had requested the District to provide evening instruction, which was refused.The district court found that the District's refusal to provide A.J.T. with evening instruction resulted in her making de minimis progress overall and even regressing in some areas, such as toileting. The court also determined that A.J.T. would have made more progress had she received evening instruction. On these grounds, the court concluded that the District had failed to provide A.J.T. with a FAPE.On appeal, the Eighth Circuit affirmed the district court's judgment. The court rejected the District's argument that the IDEA's scope was limited to regular school hours, noting nothing in the IDEA suggested such a limitation. Furthermore, the court agreed with the district court's assessment of A.J.T.'s limited progress and regression in toileting. After considering the evidence, the court concluded that the District's refusal to provide evening instruction, based solely on administrative concerns, resulted in A.J.T.'s minimal progress and denied her a FAPE. View "Osseo Area Schools, Independent School District No. 279 v. A.J.T." on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law