Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment for Cargill in an action alleging that the company discriminated against a former employee in violation of the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA). The court held that plaintiff failed to present direct and indirect evidence of disability discrimination; plaintiff was not a qualified individual protected by the ADA because she failed to demonstrate that at the time of her termination she could regularly and reliably attend work, an essential function of her employment; and the ADA's protections did not extend to providing plaintiff with her desired accommodation of more time off following her 194 days of unplanned absences. View "Lipp v. Cargill Meat Solutions Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRAThe court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed. View "Hustvet v. Allina Health System" on Justia Law

The Eighth Circuit affirmed the district court's order granting Steak 'n Shake's motion for summary judgment on plaintiff's Americans with Disabilities (ADA) discrimination claim and his Missouri Workers' Compensation claim. The court held that plaintiff failed to show that he was a qualified individual within the meaning of the ADA. In this case, although he believed that he could perform the essential job functions of a fountain operator, plaintiff's permanent medical restrictions barred him from performing the duties described in the job description. Likewise, plaintiff could not perform the duties of other positions he identified as alternative jobs. View "Denson v. Steak 'n Shake, Inc." on Justia Law

Moore-Jones passed Arkansas State Trooper Quick’s marked police car. Quick checked and found her registration was expired and began a traffic stop, which was recorded on his dash-cam. Quick pulled behind Moore-Jones, activating his emergency lights, spotlight, and sirens at 8:23 p.m. She decelerated and pulled onto the shoulder, which was narrow and unlit. She returned to the road, accelerating to 35-38 MPH, her speed for the rest of the pursuit. The posted speed limit was 55 MPH. At 8:24, she continued past the last exit before the nearest city. After the exit, Quick began a Precision Immobilization Technique (PIT) maneuver, striking Moore-Jones's right-rear fender with his left-front bumper, causing her car to spin into a ditch, hitting a cement culvert. Moore-Jones and her child and were treated and released at a hospital. She was cited for expired tags and failure to yield to an emergency vehicle, both misdemeanors. She sued Quick for excessive force and assault and battery. The Eighth Circuit held that Quick is entitled to qualified immunity. The right to be free from a PIT maneuver in these circumstances was not sufficiently definite. From a reasonable officer’s perspective, Moore-Jones refused to comply with commands to pull over. At the time, Quick was justified in using some force to secure compliance. View "Moore-Jones v. Quick" on Justia Law

Henderson, a 19-year-old black man, was attending a party at a Woodbury, Minnesota Red Roof Inn. Without warning, another young black male, Ballinger, pulled a gun, robbed the other guests, including Mark, and held them hostage. A woman called 911 and then hid her phone. Though the caller was unable to speak with the operator, the operator kept the line open and listened; the operator discerned an apparent confrontation between someone with a gun and another person with a knife. The person with the gun (Ballinger) demanded that the person with the knife (Henderson) give it up. The dispatcher alerted police. During the response, which involved Henderson trying to escape the hotel room while Ballinger fired shots, Henderson was shot by three officers who fired 17 rounds while he was lying on the ground. Henderson died. The district court rejected, on summary judgment, claims by his estate under 42 U.S.C. 1983. The Eighth Circuit reversed. The resolution of the conflicting testimony between one officer's more or less contemporaneous statement to investigators and all of the officers' subsequent unified deposition testimony should be left to a jury; the district court erred in finding the defendants entitled to qualified immunity. View "Henderson v. City of Woodbury" on Justia Law

In 2001, Nelson pled guilty to the kidnapping and unlawful interstate transportation of Pamela for the purpose of sexual abuse which resulted in her death. The government dropped a charge traveling across state lines with the intent to engage in a sex act with a female under the age of 12 which resulted in death. Days later, Nelson attempted suicide by ingesting prescription medicine. The penalty phase jury returned a death penalty verdict. The court allowed Nelson to address the court. Nelson, showing no remorse, blistered the court and the victim’s family with a profanity-laden tirade. The court imposed the death sentence. The Eighth Circuit affirmed; the Supreme Court denied certiorari. The Eighth Circuit affirmed the rejection of Nelson’s 28 U.S.C. 2255 motion. The jury heard substantial mitigating evidence and there was no reasonable probability that its death sentence verdict would have been different if the evidence produced at the habeas evidentiary hearing had been introduced during the penalty phase, so the district court did not err in denying Nelson's ineffective assistance of counsel claims concerning failure to conduct an adequate mitigation investigation, failure to adequately investigate his mental health and failure to advise Nelson to decline to submit to a mental health exam by a government examiner. View "Nelson v. United States" on Justia Law

Missouri inmate Barr filed suit under 42 U.S.C. 1983 alleging that state-contracted health care providers violated the Eighth Amendment when they stopped administering his multiple sclerosis medication. Barr’s medical record indicated that he was being followed “for high suspicion of multiple sclerosis” but had discontinued taking Avonex “on his own due to undesirable side effects.” The Eighth Circuit affirmed summary judgment in favor of the Defendants. While inmates have a right to adequate medical care, they have no right to receive a particular or requested course of treatment. Defendants’ decision to halt Barr’s Avonex injections did not rise to a level akin to criminal recklessness and was probably not even negligent. Even if Barr did not refuse his injections, Defendants had good reason to end them. Three different health care providers wrote in Barr’s medical record that he had complained to them about side effects; it was well within Defendants’ independent medical judgment to stop administering Avonex. Barr does not allege that any harm occurred after the injections ended. After Barr’s injections were halted, Defendants continued to provide medical care—prescribing other medication, scheduling follow-ups, and requesting additional diagnostic tests. No rational trier of fact could find that Defendants were deliberately indifferent. View "Barr v. Pearson" on Justia Law

Plaintiff filed suit alleging that a county deputy was deliberately indifferent to Jeffry Alan Barton's serious medical needs and that the county jail administrator failed to adequately train or supervise the deputy. Plaintiff also alleged that the county did not adequately train its detention facility workers and that its policies failed to ensure that detainees received adequate medical care.The Eighth Circuit affirmed the district court's denial of qualified immunity to the deputy where a jury could find that Barton was experiencing a medical need so obvious that a layperson would recognize the need for prompt medical attention, the deputy did not perform the healthcare screening the jail policies required, and it was clearly established at the time that booking Barton into jail would constitute deliberate indifference. The court reversed the denial of qualified immunity to the administrator and held that the administrator did not know that the deputy was inadequately trained or supervised. Finally, the court dismissed the county's appeal for lack of jurisdiction. View "Barton v. Ledbetter" on Justia Law

The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee.The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Saint Luke's in an employment discrimination action. The court held that the district court did not abuse its discretion in denying defendant's motion to reconsider under Federal Rule of Civil Procedure 60(b)(1). The court explained that, although defendant's delay was brief, Saint Luke's made no claim of prejudice and defendant did not act in bad faith, such factors did not outweigh defendant's carelessness or mistake in construing the rules and the absence of any apparent meritorious defense. Furthermore, there were no exceptional circumstances in this case that warranted relief under Rule 60(b)(6). View "Giles v. St Luke's Northland-Smithville" on Justia Law