Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment to the county and to two sheriffs in an action brought by plaintiff under 42 U.S.C. 1983, alleging the use of excessive force. In this case, plaintiff was stopped by law enforcement after he stole items from a local Walmart. Plaintiff was kicked by one of the officers without provocation and that officer resigned and was terminated the next day. That officer subsequently pleaded guilty to criminal charges.The court held that plaintiff failed to prove the existence of an unconstitutional custom or policy; failed to show causation assuming there was such a custom or policy; and thus could not establish municipal liability. Therefore, the district court properly granted summary judgment for the sheriffs in their official capacities. The court rejected plaintiff's failure to train claim and held that one of the sheriffs was entitled to qualified immunity. Finally, the district court did not abuse its discretion in calculating attorneys' fees and costs. View "Brewington v. Keener" on Justia Law

Plaintiffs challenged the inscription of the national motto, "In God We Trust," on United States coins and currency. The Eighth Circuit affirmed the district court's grant of the Government's motion to dismiss based on failure to state a claim. The court joined its sister circuits and held that placing "In God We Trust" on U.S. coins and currency does not violate the Establishment Clause. In light of the Supreme Court's recent precedent in Town of Greece v. Galloway, 134 S. Ct. 1811 (2014), the court held that the long tradition of placing "In God We Trust" on U.S. money comports with the original understanding of the Establishment Clause. The court also held that plaintiffs failed to state a claim under the Free Speech Clause because the Government's inscription did not compel plaintiffs to express any message. Furthermore, plaintiffs' First Amendment rights under the Free Exercise Clause and statutory rights under Religious Freedom Restoration Act were not violated. Finally, plaintiffs' equal protection claim failed because the statutes requiring the inscription did not create any express or implied classifications and was rationally related to the Government's legitimate goal of honoring religion's role in American life and in the protection of American fundamental rights. View "New Doe Child #1 v. United States" on Justia Law

Plaintiff and his minor son filed a 42 U.S.C. 1983 action against two officers for unreasonable search and seizure, as well as use of excessive force. The district court denied the officers' motion for summary judgment. The Eighth Circuit reversed as to the unreasonable search and seizure claim, holding that the officers were justified in making the stop because they had reasonable suspicion that a child molester could be driving or hiding in the truck; the pat-down did not violate plaintiff's Fourth Amendment rights; and the officers' search of the truck was reasonably related to the scope of the circumstances which justified the stop. The court affirmed as to the excessive use of force claim, holding that the officers' continuous drawing and pointing of weapons was unreasonable and constituted excessive force, and plaintiff and his son's right to be free from excessive force was clearly established at the time. View "Wilson v. Lamp" on Justia Law

The Eighth Circuit reversed the district court's dismissal of plaintiff's second amended complaint challenging the constitutionality of Missouri's method of execution as applied to him. The court held that plaintiff's allegations were sufficient to show a plausible allegation that the State's method of execution would cause him severe pain where the complaint and his expert's attached affidavit included factual allegations that a seizure will occur when the State injects pentobarbital and that such a seizure causes severe pain. Furthermore, plaintiff has alleged that execution by lethal gas was an alternative method of execution that was feasible, readily implemented, and would in fact significantly reduce a substantial risk of severe pain for plaintiff in his particular circumstances. Finally, the complaint was not barred by the statute of limitations. The panel remanded for further proceedings. View "Johnson v. Precythe" on Justia Law

The Eighth Circuit affirmed the district court's denial of summary judgment based on qualified immunity to a police officer and summary judgment based on official immunity to the City. The court held that the officer lacked arguable probable cause to arrest plaintiff where the totality of the circumstances suggested that the officer had reason to know that plaintiff could not deliver the type of pain he felt (a kick) and he had no information suggesting that she was even in a position to do so. Furthermore, the arguable probable cause undergirding the warrantless arrest here was missing a fundamental element: observation—either by the officer or a witness who relayed that information to him—of a criminal act. The court also held that unlawfulness of the officer's conduct was clearly established at the time. Finally, the court held that a factfinder could determine the officer had reason to believe that he arrested plaintiff without probable cause, and the City, therefore, was not entitled to official immunity. View "Johnson v. City of Minneapolis" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to correction center officials in a 42 U.S.C. 1983 action brought by a former inmate alleging that the officials failed to protect him from sexual and physical harassment, threats, and assault. The court held that sufficient factual allegations from the verified complaint remained pending to support the district court's finding of material factual disputes. Therefore, the court dismissed the appeal for lack of jurisdiction. View "Berry v. Doss" on Justia Law

Plaintiff, who is paralyzed from the waist down and uses a wheelchair for mobility, filed suit against Holiday, alleging that the company discriminated against him in violation of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA) by failing to have an accessible parking lot at one of its stores. The district court granted Holiday's motion for summary judgment.The Eighth Circuit vacated the district court's judgment with instructions to remand plaintiff's access-aisle and vertical-signage claims to state court. In regard to these two claims, plaintiff suffered no injury and thus could not establish Article III standing. The court also remanded for the district court to consider whether to exercise supplemental jurisdiction over the remaining garbage-can claim. In this case, plaintiff established an injury in fact by offering specific evidence that the allegedly dangerous circumstances caused him not to enter the store. The district court erred in treating a photograph that plaintiff submitted along with his declaration as definitive proof that he had plenty of room to maneuver around the garbage can. View "Hillesheim v. Holiday Stationstores, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the County and others in a 42 U.S.C. 1983 action alleging that plaintiff was sexually assaulted by former corrections officer Louis Campana. The court held that the claims against the County were properly dismissed where plaintiff failed to show that the County itself caused the constitutional violation at issue; nothing in the record established that any failure to train Campana caused him to assault plaintiff or that the County was deliberately indifferent to plaintiff's rights; two supervisors' negligence was not sufficient to establish section 1983 liability; a reasonable officer in Sheriff Samuelson's position would not have known that he needed to more closely supervise Campana, and the Sheriff was entitled to qualified immunity; and a reasonable officer in Defendant Gregg's position would not have concluded on this record that Campana posed an obvious risk to commit sexual assault. View "Marsh v. Phelps County" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the school district in an action filed by plaintiffs of a student, alleging violation of the student's rights under the Rehabilitation Act when the school district failed to make reasonable accommodations for her. The court held that the parents' complaint sought relief available under the Individuals with Disabilities Education Act (IDEA) -- relief for the denial of a free and appropriate public education-- and thus they must exhaust their administrative remedies unless an exception to the exhaustion requirement applied. In this case, none of the three exceptions to the exhaustion requirement applied. Therefore, the district court properly granted summary judgment for failure to exhaust administrative remedies under the IDEA. View "Nelson v. Charles City Community School District" on Justia Law

Plaintiff filed suit against corrections officials at Crossroads Correctional Center for violation of his Eighth Amendment rights under 42 U.S.C. 1983. The Eighth Circuit affirmed the jury's finding that the officials were deliberately indifferent to plaintiff's serious medical need by failing to take reasonable steps to abate the risk of harm that secondhand smoke posed to him. In this case, there was sufficient evidence to show that the officials violated plaintiff's Eighth Amendment rights by being deliberately indifferent to the fact that plaintiff's asthma was exacerbated by offenders smoking indoors. However, there was insufficient evidence to justify an award of punitive damages where plaintiff failed to show that the officials were motivated by evil motive or intent or showed callous indifference to plaintiff's rights. Therefore, the court vacated the award of punitive damages and remanded for further proceedings. View "Washington v. Denney" on Justia Law