Articles Posted in Civil Rights

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The Eighth Circuit affirmed the district court's grant of summary judgment to the United States and the Deputy U.S. Marshals in their individual and official capacities on plaintiff's claims for false arrest, false imprisonment, abuse of process, and assault and battery under the Federal Tort Claims Act (FTCA). In this case, plaintiff was mistakenly arrested when defendants were executing an arrest warrant for another individual. Applying Missouri tort law, the court held that none of plaintiff's proposed facts contradicted a material fact that the district court relied on in conducting its summary judgment analysis; the district court did not err in granting summary judgment on the false arrest and false imprisonment claim where plaintiff's arrest and 20-minute detention were justified; defendants were also entitled to summary judgment on plaintiff's claims for abuse of process; and the court's prior holding on qualified immunity was dispositive of plaintiff's assault and battery claim. View "Wright v. United States" on Justia Law

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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

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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

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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

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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

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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

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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

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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

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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

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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