Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Plaintiffs, pretrial detainees at a detention center, filed suit under 42 U.S.C. 1983 against prison guards and the Sheriff, alleging a variety of constitutional violations. The court concluded that the district court correctly denied summary judgment on the basis of qualified immunity where the record supported a claim of excessive force in violation of the Eighth Amendment. The record also supported a claim for failure to protect plaintiffs from harm in violation of the Due Process Clause and the district court correctly denied the guards qualified immunity on this claim. Given the fact that the Sheriff was not at the detention center, he could not have used excessive force against plaintiffs, nor could he have an opportunity to intervene to prevent the guards from employing excessive force. Accordingly, the court reversed the district court's denial of summary judgment based on qualified immunity with respect to the Sheriff. The court affirmed in all other respects. View "Edwards, Jr., et al. v. Byrd, et al." on Justia Law

Citizens of the City filed suit against the quarry defendants in Missouri state court, asserting various state-law tort claims. The quarry defendants removed to federal district court and the district court issued an injunction prohibiting the citizens from pursuing their claims. The citizens appealed the district court's denial of their motion to remand to state court and its issuance of the injunction. The court concluded that the quarry defendants have not met their burden of establishing the district court's jurisdiction over the citizens' claims. Therefore, removal was improper and the district court erred in denying the motion to remand. Accordingly, the court reversed the denial of the motion to remand; vacated the order enjoining the citizens from pursuing their claims in any forum; and remanded with directions to remand the case to Missouri state court. View "Baker, et al. v. Martin Marietta Materials, et al." on Justia Law

St. Jude sued its competitor, Medtronic, for tortiously interfering with its business relationship with an employee. After the parties arbitrated their claims, St. Jude then sued the employee's wife (defendant) for related claims. On appeal, St. Jude challenged the district court's grant of summary judgment in favor of defendant. Defendant had left her at-will employment with St. Judge to work for Medtronic and her husband's sales at St. Jude dropped significantly. As a preliminary matter, the court concluded that Florida law applied because Florida was the forum that rendered the arbitration judgment. Applying Florida's requirements for res judicata, the court reversed the district court's dismissal of Counts 1, 3, 5, and 6 arising from defendant's acts as a St. Jude employee because they were not barred by res judicata; the court affirmed the district court's dismissal of Counts 2 and 4; and the court remanded for further proceedings. View "St. Jude Medical S.C., Inc. v. Cormier" on Justia Law