Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's ruling that the City was not immune from a 42 U.S.C. 1983 suit in a putative class action alleging that the City's policy or custom of automatically issuing arrest warrants was unconstitutional. In this case, the City automatically issues an arrest warrant whenever someone ticketed for violating its traffic and vehicle laws fails to pay a fine or appear in court. The court held that municipalities, unlike States, did not enjoy a constitutionally protected immunity from suit under the Eleventh Amendment; the court rejected the City's contention that it enacted or maintained the contested practices as an arm of the State; and the court rejected the City's contention that it was also immune from suit since all of the individuals the complaint identified as participating in the contested practices were personally immune from suit. The court has long held that a municipality may be held liable for its unconstitutional policy or custom even when no official has been found personally liable for his conduct under the policy or custom. View "Webb v. City of Maplewood" on Justia Law

Plaintiff filed suit alleging that he was improperly rejected for the position of Criminal Investigator with the USPS in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and that he should have been given preference for the position due to his status as a veteran. The district court granted the Postmaster General’s motion to dismiss the action under Federal Rule of Civil Procedure 12(b)(6). The Eighth Circuit held that the district court erred in dismissing the ADEA claim because plaintiff alleged a prima facie case of discrimination where he demonstrated that he had the educational and professional experience required for the position. Accordingly, the court reversed as to the ADEA claim and remanded for further proceedings. The court affirmed in all other respects. View "McPherson v. Brennan" on Justia Law

Defendant was committed to the custody of the Missouri Department of Mental Health for treatment after he was found not guilty by reason of insanity under Missouri state law when he fired shots in the direction of two officers. Plaintiff filed a 42 U.S.C. 1983 action against defendants, alleging that he had been deprived of his substantive due process right to liberty during his in-patient commitment as well as during his period of conditional release. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants based on qualified immunity, holding that the evidence viewed in the light most favorable to plaintiff did not show that defendants' actions "shocked the conscience." In this case, plaintiff gave no reason to believe any medical opinion was offered in bad faith and the evidence did not suggest that any of defendants' representations to the circuit court were inspired by malice or otherwise untruthful. Furthermore, the ultimate decision to grant release lay with the circuit court and it repeatedly declined to grant release. View "Andrews v. Schafer" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an age discrimination claim. The court held that the district court did not abuse its discretion in deciding not to admit a Department of Corrections internal investigation report because plaintiff was allowed to elicit the content of the report during her questioning of the Warden and providing the report to the jury would have added little beyond the information already in evidence. Therefore, plaintiff failed to establish reversible error in how the district court handled this evidentiary issue. View "Parker v. Arkansas Department of Correction" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss an action filed by plaintiff, challenging the termination of his employment from the University. The court held that plaintiff's speech stemmed from his professional responsibilities and was made in furtherance of those responsibilities, and was therefore not protected under the First Amendment; the pre- and post-termination procedures did not violate plaintiff's Fourteenth Amendment due process rights; plaintiff failed to establish a substantive due process claim because he failed to show that the University President's decision to terminate him was both conscience shocking and in violation of one or more fundamental rights; the district court properly dismissed the individual capacity claims against the University President based on qualified immunity; and the district court properly dismissed the claims against defendants in their official capacity. View "Groenewold v. Kelley" on Justia Law

Plaintiff filed a class action against Harne defendants under 42 U.S.C. 1983, alleging that the State's failure to share annual payments under a Settlement Agreement, where Minnesota released and forever discharged tobacco companies from claims that they violated state consumer protection statutes in exchange for substantial period payments, constituted a taking in violation of the Fifth Amendment. The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss, holding that res judicata barred the claim. In this case, plaintiff's takings claim in federal court was identical to the federal takings claims asserted in Harne v. State, No. A14-1985, 2015 WL 4523895; Harne involved the same parties; under Minnesota law, the dismissal of the claims in Harne as time-barred was a final judgment on the merits; and plaintiff and Harne actually litigated their federal claims in Harne. View "Foster v. Minnesota" on Justia Law

After being arrested, Whitney was taken to the St. Louis University Hospital for treatment of an irregular heartbeat. He attempted to escape and said that he wanted the police to take his life so that he would not be sent back to prison. He was determined to be suicidal. After being treated by psychiatry and showing improvement, he was released and transported to the St. Louis City Justice Center. Two days later, Whitney was moved to a medical unit, suffering from detoxification from heroin use, congestive heart failure, hypertension, and diabetes. Sharp was assigned to monitor Whitney in his cell via closed-circuit television. Sharp last saw Whitney pacing by the shower area at 9:05 a.m. Within the next 14 minutes, she discovered that he had hanged himself, using his ripped hospital gown. The district court dismissed 42 U.S.C. 1983 claims by Whitney’s estate. The Eighth Circuit affirmed. The complaint failed to allege that Sharp knew that Whitney presented a suicide risk. There was no claim that any identifiable jail official had knowledge or suspected that Whitney was suicidal or was harming himself; the complaint fails to allege any constitutional violation arising out of a municipal policy that would expose the city to Monell liability. View "Whitney v. City of St. Louis" on Justia Law

Plaintiff, who was paralyzed from the waist down and used a wheelchair, filed suit against RL Liquor for violating Title III of the Americans with Disabilities Act (ADA), after he encountered barriers at the store. The Eighth Circuit affirmed the district court's dismissal of the action as moot, holding that plaintiff failed to meet his burden to prove a readily achievable barrier removal method. Following the Tenth, Second, and Eleventh Circuits, the court held that the district court properly required plaintiff to initially present evidence tending to show that the suggested method of barrier removal was readily achievable under the circumstances. In this case, plaintiff failed to offer a plausible proposal for barrier removal. View "Wright v. RL Liquor" on Justia Law

Plaintiff filed suit against her former employer for hostile work environment sexual harassment and retaliatory termination in violation of Title VII of the Civil Rights Act of 1964, and the Iowa Civil Rights Act (ICRA). Plaintiff was terminated after she burned a customer with her cigarette when he was sexually harassing her. The Eighth Circuit affirmed the district court's dismissal of the ICRA claim as time-barred and held that the pendency of an EEOC review did not toll a state civil rights claim. The court rejected the Title VII claims on summary judgment where the customer's action did not constitute conduct so severe or pervasive to affect a term, condition, or privilege of plaintiff's employment. Furthermore, plaintiff failed to show that the employer new of the customer's harassing conduct but failed to take remedial action. The court also held that the retaliatory discrimination claim was time-barred. Finally, the court affirmed the district court's exclusion of evidence regarding previous sexual assaults and expert testimony. View "Hales v. Casey's Marketing Co." on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims of excessive force and municipal liability, as well as state tort claims. The Eighth Circuit affirmed the district court's denial of the officers' motion for summary judgment based on qualified immunity where plaintiff established that the officers violated his Fourth Amendment right to be free from excessive force. In this case, the officers delivered repeated strikes, punches, and blows to plaintiff while plaintiff pleaded with them to stop hitting him because he was not resisting arrest or doing anything wrong. Therefore, a reasonable officer standing in defendants' shoes would have understood that the amount of force used to subdue plaintiff was excessive, as was their action in purposefully dropping plaintiff face-first onto the sidewalk after he had been subdued and handcuffed. The court also held that it lacked jurisdiction over the officers' appeal of the denial of summary judgment on the state law claims because the court's resolution of the qualified immunity appeal did not necessarily resolve plaintiff's state law claims against the officers. View "Burnikel v. Fong" on Justia Law