Justia Civil Rights Opinion Summaries

Plaintiff filed suit seeking a preliminary injunction against enforcement of Minn. Stat. 325E.27(a), which restricts the use of robocalls. The court affirmed the district court's denial of the motion, holding that plaintiff was unlikely to succeed on his First Amendment claim. The court held that Van Bergen v. Minnesota, 59 F.3d 1541 (8th Cir. 1995), was controlling in this case. Van Bergen concluded that the first three exceptions in subsection (b) were not content-based restrictions, but were valid time, place, and manner restrictions. The court also held that the content-based exception for tax-exempt charitable organizations, which was added to the statute in 2009, was severable from the rest of the statute. View "Gresham v. Swanson" on Justia Law

Large crowds gathered in Ferguson, Missouri after Michael Brown, Jr. was killed by a police officer. Six sets of plaintiffs filed suit alleging multiple claims related to the police response to the largely peaceful demonstrations. The district court granted summary judgment to defendants, concluding that the individual defendants were entitled to qualified immunity on plaintiffs' 42 U.S.C. 1983 claims for unlawful arrest and excessive force. The Eighth Circuit affirmed in part, reversed in part, and remanded on claims alleged by Plaintiffs Nathan Burns; Damon Coleman and Theophilus Green; Antawn Harris; Kerry White, Sandy Bowers, and Kai Bowers; Tracey White and William Davis; and DeWayne Mathews. View "White v. Jackson" on Justia Law

The Eighth Circuit affirmed the dismissal of plaintiff's complaint alleging a Title IX student-on-student harassment claim against Culver-Stockton College after she was allegedly sexually assaulted by a Culver-Stockton student on campus. The court held that, assuming arguendo that plaintiff's status as a non-student did not preclude her from asserting a Title IX harassment claim, the complaint failed to state a plausible claim to survive dismissal under Fed. R. Civ. P. 12(b)(6). In this case, plaintiff failed to plausibly allege that the college acted with deliberate indifference, the college had actual knowledge of discrimination, and that either the alleged misconduct or the college's response to plaintiff's allegations had the required systemic effect such that she was denied equal access to educational opportunities provided by the college. View "K.T. v. Culver-Stockton College" on Justia Law

After the City revoked his rental licenses, plaintiff filed suit alleging that the City violated 42 U.S.C. 1983 by subjecting plaintiff to the deprivation of his rights, privileges, or immunities under the Fourth and Fourteenth Amendments to the United States Constitution. The Eighth Circuit affirmed the district court's grant of the City's motion for summary judgment on the Fourth and Fourteenth Amendment claims. The court held that plaintiff had not demonstrated, as a matter of law, that the City violated his substantive-due-process rights under the Fourteenth Amendment. The court also held that the City's conduct was not arbitrary, oppressive, and shocking to the conscience, and there was no genuine dispute of material fact regarding whether the City violated plaintiff's Fourth Amendment rights. In this case, plaintiff did not have a reasonable expectation of privacy in the common spaces entered by the City's police officers, and any argument that the police officers may have physically intruded on constitutionally protected areas by trespassing in his buildings to search for incriminating evidence was waived. View "Azam v. City of Columbia Heights" on Justia Law

North Dakota may enforce the suspend-and-reimburse provisions of N.D.C.C. 65-05-05(2). The Eighth Circuit held that the reimbursement provision readily passed rational basis scrutiny and was not subject to equal protection or substantive due process challenges. Furthermore, the cost and difficulty of recovering benefits paid during the suspension period were a rational basis for the suspension provision. The court also held that the suspension provision did not violate North Dakota's constitutional obligation to provide full faith and credit to Colorado's death benefits provision. Accordingly, the court affirmed the district court's judgment on the pleadings for WSI. View "DeCrow v. North Dakota Workforce Safety & Insurance Fund" on Justia Law

The State appealed the district court's grant of a preliminary injunction preventing the enforcement of an Arkansas statute requiring medication-abortion providers to contract with a physician who has hospital admitting privileges. The Eighth Circuit vacated the preliminary injunction, holding that the district court failed to make factual findings estimating the number of women burdened by the statute. On remand, the district court should conduct fact finding concerning the number of women unduly burdened by the contract-physician requirement and determine whether that number constitutes a "large fraction." View "Planned Parenthood of Arkansas & Eastern Oklahoma v. Jegley" on Justia Law

Plaintiff, Kenny Gurley's mother, filed suit alleging numerous federal and state law causes of action after Gurley was involved in a physical altercation with two officers and died. On appeal, the officers and the Board sought interlocutory review of the district court's grant in part and denial in part of summary judgment on the basis of state and federal immunity. The Eighth Circuit held that the officers were not entitled to qualified immunity on the 42 U.S.C. 1983 claims where the officers violated Gurley's constitutional right to be free from excessive force and the officers' actions were objectively unreasonable at the time. Furthermore, the officers were not entitled to official immunity on the state law claims where a jury could find that the officers acted with bad faith and malice. With respect to the Board, the court held that it was not entitled to qualified immunity on plaintiff's section 1983 claim. However, the Board was protected by sovereign immunity on the wrongful death claim. Accordingly, the court affirmed in part and reversed in part. View "Lancaster v. Board of Police Commissioners" on Justia Law

Plaintiff filed suit on behalf of her son, alleging that VICC's race-based, school-transfer policy violated the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff lacked standing because the mention of magnet schools and the generalized grievance about VICC's transfer policy for them was insufficient to allege an injury in fact. In this case, VICC had no administrative or supervisory authority over charter schools, which are independent public schools, governed by the state. Even if VICC's policy applied to charter schools, VICC still would not cause the son's injury because VICC does not make or adopt rules or regulations for charter schools. Because the son's injury was not fairly traceable to VICC, he lacked standing. View "E.L. v. Voluntary Interdistrict Choice Corporation" on Justia Law

Plaintiff, a commercial photographer, filed suit against the Village for injunctive and declaratory relief after the Village passed a municipal ordinance prohibiting all commercial activity in its neighborhood park without a permit. The Eighth Circuit affirmed the district court's denial of her Free Speech rights claims, holding that the ordinance met constitutional scrutiny as applied to plaintiff because it was content neutral, was narrowly tailored to serve the Village's significant government interests, left ample alternatives for her to communicate her message, and did not provide the Village with unbridled discretion. View "Josephine Havlak Photographer, Inc. v. Village of Twin Oaks" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against a former police officer, alleging that the officer violated plaintiff's constitutional rights by deliberately or recklessly giving partially inaccurate testimony in a probable cause hearing. After two prior remands, the district court found that the officer was entitled to qualified immunity. The Eighth Circuit held that, although a reasonable officer would know that it was unlawful to use deliberate or reckless falsehoods in a probable cause hearing, the officer here was entitled to qualified immunity. In this case, ample facts supported the issuance of the arrest warrant for plaintiff without the officer's inaccuracies. Accordingly, the court affirmed summary judgment and dismissal in favor of the officer. View "Odom v. Kaizer" on Justia Law