Justia Civil Rights Opinion Summaries

Under Missouri campaign finance law, chapter 130, a “campaign committee” is formed to receive contributions or make expenditures solely to support or oppose particular ballot measures, "such committee shall be formed no later than thirty days prior to the election for which the committee receives contributions or makes expenditures." Thirteen days before the November 2014 general election, a group formed MFA as a campaign committee, to accept contributions and make expenditures in support of Proposition 10. MFA sued to enjoin enforcement of the formation deadline, citing the First Amendment. The district court granted MFA a temporary restraining order. MFA received contributions and made expenditures before the election. After the election, MFA terminated as a campaign committee. The Eighth Circuit affirmed summary judgment in favor of MFA. While a formation deadline by itself might not expressly limit speech, the deadline here is more than a disclosure requirement because it prohibits (or significantly burdens) formation of a campaign committee, a requisite for legally engaging in speech, even if the individual or group is willing to comply with organizational and disclosure requirements. Even if the state’s interest in preventing circumvention of chapter 130’s disclosure regime is compelling, the formation deadline is unconstitutional because it is not narrowly tailored, given its burden on speech and its modest effect on preventing circumvention of the disclosure regime. View "Missourians for Fiscal Accountability v. Klahr" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Walmart in an action alleging employment discrimination. The court held that plaintiff failed to file a charge of discrimination with the EEOC within 180 days of the alleged Americans with Disabilities Act (ADA) violation. The court also held that plaintiff's failure to file his EEOC claim within 180 days was not the result of any misconduct by Walmart. In this case, failing to respond to a settlement demand made ten days before the statutory deadline, and accompanied by a statement that the employee would file a charge with the EEOC if the matter could not be settled, was not conduct that the employer should unmistakably have understood would cause the employee to miss the filing deadline. View "Rodriguez v. Wal-Mart Stores, Inc." on Justia Law

After plaintiffs were exonerated for the murder of Helen Wilson in 2008, they filed a 42 U.S.C. 1983 action, alleging that their arrests and imprisonment were the result of a reckless investigation and manufactured false evidence, as well as parallel conspiracy claims under 42 U.S.C. 1985. Plaintiffs were awarded approximately $28.1 million in damages. The Eighth Circuit held that it would not review or reverse its prior rulings as to whether Gage County could be held liable; the evidence was sufficient to support the jury's verdict finding Gage County liable; the facts developed at trial continued to support the district court's conclusion that the sheriff's deputies were not entitled to qualified immunity; the deputies conducted a reckless investigation and fabricated evidence; limited references to plaintiffs' innocence did not warrant a new trial in light of the curative actions and overwhelming evidence; and there was no error in the reckless investigation jury instruction. View "Dean v. Searcey" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to a prosecutor and judge in a civil rights action alleging that defendants conspired to deprive plaintiff of his constitutional rights during criminal proceedings related to a 1990 homicide. The court held that the prosecutor was entitled to absolute immunity because the only supported instances of misconduct occurred after he was appointed special prosecutor and were intimately associated with the judicial phase of the criminal process. Likewise, the judge was entitled to absolute judicial immunity as any evidence of alleged misconduct on his part related directly to his official role as a judge. View "Woodworth v. Hulshof" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiffs' 42 U.S.C. 1983 complaint as time-barred. The court held that plaintiffs' claims accrued in October 2011, when they were notified of the allegedly discriminatory decision to install the grinder systems instead of gravity systems at their residences. As such, the installation of the pumps and plaintiffs' continuing responsibility for the additional expenses they entailed, were delayed but inevitable consequences of that decision. Consequently, plaintiffs were on notice as of 2011 and their limitations period expired in October 2014. Therefore, plaintiffs' complaint was time-barred because they did not file this action until May 2016. View "Humphrey v. Eureka Gardens Public Facility Board" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiffs' Fourteenth Amendment and wrongful death claims, as well as plaintiffs' claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act (RA), 29 U.S.C. 701, et seq. Plaintiffs filed suit after Jereme Hartwig committed suicide by hanging himself with a bed sheet in his cell when he was confined at the St. Louis County Justice Center. The court held that plaintiffs failed to show that any defendant was deliberately indifferent to a substantial risk that Hartwig would commit suicide; the clinical psychologist's professional judgment, even if negligent, fell well short of deliberate indifference; the corrections officer's failure to recall the details of her monitoring at a deposition three years later did not create a genuine issue that she failed to conduct the hourly monitoring of inmates under the jail's suicide prevention policy; in regard to the Missouri wrongful death claim, the jailer performed her duties in accordance with the suicide prevention policy and did not breach a ministerial duty; and the ADA and Rehabilitation Act claims failed to state a claim. View "A.H. v. St. Louis County, Missouri" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendants' request to reconsider its previous denial of their motion for summary judgment based on qualified immunity. In this case, an inmate at the ADC filed suit against defendants, alleging deliberate indifference to his painful dental condition. Because defendants did not timely appeal the district court's denial of summary judgment, the court only had jurisdiction to review the district court's order denying reconsideration under Rule 60(b). The court held that the district court did not abuse its discretion in denying the reconsideration under Rule 60(b) where, unlike the defendants in Cullor v. Baldwin, 830 F.3d 830 (8th Cir. 2016), the defendants here have not shown that they tried to get plaintiff treatment after they were alerted to his condition. The court held that defendants were constitutionally obligated to see that the inmates in their custody who need dental care receive it and were deliberately indifferent to plaintiff's serious dental condition. View "Williams v. York" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner after he was convicted of raping an adult woman with the mental capacity of a young child and sentenced to seventy years in prison as a habitual offender. The court held that, under Arkansas law, parole-eligibility determinations by the Department of Corrections did not constitute a modification of a prison sentence. Therefore, trial counsel's deficient performance in this case did not deprive petitioner of a due process claim that Ark. Code Ann. 16-93-609(b) should not apply when the jury, court, and defendant were unaware of the Act and did not intend for the Act to apply to the judgment. Although the state court improperly instructed the jury that petitioner would be eligible for parole after serving 70% of his sentence if sentenced to a term of years, petitioner was not prejudiced under Strickland v. Washington when his trial counsel failed to correct the error. View "Stewart v. Kelley" on Justia Law

The Eighth Circuit granted rehearing en banc and vacated the panel opinion in Faidley v. United Parcel Serv. of Am., Inc., 853 F.3d 447 (8th Cir. 2017).The court affirmed the district court's grant of summary judgment for UPS in an action alleging that UPS violated the Iowa Civil Rights Act (ICRA) when it placed him on medical leave from his long time position as a package car driver and then failed to reasonably accommodate his physical disability. The court held that UPS did not violate the Americans with Disabilities Act (ADA) or ICRA by refusing plaintiff's request for an eight-hour work day because that accommodation would have made him unqualified to perform the essential job functions of a package car driver. The court also held that no reasonable jury could find that UPS's decision to instead pursue reassignment to full-time jobs which plaintiff had suggested, and for which he was immediately qualified, was disability discrimination; UPS did not violate the ADA when it refused to accommodate an expert's restrictions of working certain hours per day; and a reasonable jury could not find that UPS acted in bad faith. View "Faidley v. United Parcel Service" on Justia Law

The Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment based on qualified immunity and state statutory immunity. Plaintiff had filed suit against defendant and others, alleging claims under 42 U.S.C. 1983 for deliberate conduct that shocks the conscience and a state law claim for outrage. The court held that plaintiff failed to demonstrate sufficient facts to give rise to a triable question as to an alleged violation of a constitutional right. In this case, while law enforcement corruptly conducting an investigation with a view towards presenting knowingly false charges against an innocent person might well represent an instance of conscience-shocking behavior, plaintiff has not presented any evidence beyond surmise that would allow a reasonable finder of fact to conclude that this happened. Therefore, the district court erred in denying qualified immunity to defendant. Likewise, plaintiff's state law claim failed for the same reasons as the federal claim. The district court did not err in denying summary judgment for defendant on the ground of state statutory immunity. View "Williams v. Mannis" on Justia Law