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

Articles Posted in Civil Rights
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Defendant appealed a judgment of the district court committing him to the custody of the Attorney General for medical care and treatment under 18 U.S.C. Section 4246. The court found that Defendant presently suffered from a mental disease or defect as a result of which his release from custody posed a substantial risk of bodily injury to another person or serious damage to the property of another.   The Eighth Circuit affirmed, concluding that the findings underlying the commitment were not clearly erroneous. The court explained that the district court’s finding that Defendant posed a substantial risk to persons or property was adequately supported in the record. The court relied on the unanimous recommendation of the experts. The experts observed that the most reliable predictor of future violence is past violence, and they detailed Defendant’s history of random and unpredictable violent actions. The court further found that the parties have not made a sufficient showing to justify sealing the briefs in this appeal. View "United States v. Dewayne Gray" on Justia Law

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Plaintiff filed a 42 U.S.C. Section 1983 lawsuit stemming from her son’s death while under the supervision of employees at an Arkansas jail. She alleged that Defendants were deliberately indifferent to her son’s serious medical needs. The district court denied Defendants’ motion for summary judgment based on qualified immunity.   The Eighth Circuit reversed. The court explained that it disagreed with the district court’s opinion that a layperson would recognize seizure-like activity as a serious medical need that one of the Defendant’s deliberately ignored. The court reasoned that a reasonable jury could not conclude from this description of events that Defendant was aware of a serious medical need. Second, a reasonable officer would not necessarily infer that seizure-like activity in these circumstances required him to take additional action. The decedent was behaving normally at booking, though very thirsty and reportedly under the influence of methamphetamine. It isn't unreasonable to believe that whatever medical episode he experienced during transport (if he actually experienced one) had fully resolved itself by the time Defendant encountered him.   Further, the court explained that in these circumstances, Defendants can't be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments. And even though the decedent was obviously sick, recognizing that someone is sick is not the same as knowing that he is receiving inadequate care from a trained medical professional. View "Donna Reece v. S. Williams" on Justia Law

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Appellant brought a variety of state and federal claims against the City of Waynesville (the City), the Waynesville Police Department (WPD), WPD Chief, WPD Officers, and Pulaski County Prosecutor (collectively, Appellees). The district court dismissed most of Appellant’s claims pursuant to Federal Rule of Civil Procedure 12(b)(6), and later granted the Appellees’ motion for summary judgment on Appellant’s remaining claims. Appellant appealed the grant of summary judgment. Appellant conceded that his unreasonable seizure and conspiracy-to-cause-false-arrest claims do not involve the officer. Additionally, Appellant clarified that his appeal of the unreasonable search claim is limited to “the district court’s determination about the computer and home searches.”   The Eighth Circuit affirmed. The court held that, at minimum, it was objectively reasonable for the police Chief and Officer to believe that Appellant had committed or was committing a violation of Mo. Rev. Stat. Section 455.085.2, Mo. Rev. Stat. Section 565.090.1 or Mo. Rev. Stat. Section 565.225.2-3. Accordingly, arguable probable cause exists, meaning that it was not clearly established that arresting Appellant on these facts would violate his right to be free from unlawful seizure. Thus, the court affirmed the district court’s grant of summary judgment on Appellant’s unreasonable-seizure claim because Appellees are entitled to qualified immunity.   Further, the court concluded that reasonable suspicion supported the search of Appellant’s house. Moreover, because there is only one minor inaccuracy in the otherwise thorough search warrant affidavit for Appellant’s computer, and the issuing judge found that there was enough evidence to support a finding of probable cause, that judgment is entitled to deference on appeal. View "Dennis Ryno v. City of Waynesville" on Justia Law

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Plaintiff alleged that Police officers in the St. Peters Police Department created a text messaging group to update each other about local Black Lives Matter (BLM) protests. Although the text group was intended for official purposes, specifically for officers to share up-to-date information about local BLM protests, they also shared “unrelated” content. Plaintiff sent the group a video from an animated sitcom called “Paradise PD.” It showed a black police officer who accidentally shot himself with a media headline stating, “another innocent black man shot by a cop.” According to Plaintiff, the video was satire and a parody of the BLM protests. The next morning, the Police Chief berated Plaintiff, ordered him to resign, and told him that if he refused, Plaintiff would open an investigation and recommend to City Administrator that Plaintiff be fired. Plaintiff resigned and filed a lawsuit under Section 1983, alleging that he was retaliated against for exercising his First Amendment right to free speech. Defendants moved to dismiss, and the district court granted their motion.   The Eighth Circuit reversed and remanded. The court reasoned that based on the allegations in the complaint, the group text was used to send both work-related and unrelated messages, and Plaintiff’s video was such an unrelated message. The court explained that while Plaintiff has met the threshold showing required to advance his First Amendment claim, the court expressed no opinion on the merits of that claim. View "Brian Bresnahan v. City of St. Peters" on Justia Law

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Plaintiffs brought a U.S.C. Section 1983 action against the City of Florissant, Missouri. They allege the City is liable under Monell v. Department of Social Services, 436 U.S. 658 (1978), because Florissant police officers, acting pursuant to an unlawful custom or policy, violated First and Fourteenth Amendment rights at five protests in June and July 2020 when they declared an unlawful assembly and ordered the dispersal of protestors who had not committed the Missouri crimes of unlawful assembly or refusal to disperse. Plaintiffs appealed the district court’s Memorandum and Order dismissing their complaint for failure to state a claim on the ground that a municipality’s police power “to declare that an assembly is unlawful and to order individuals to disperse is not tethered to Missouri’s statutes codifying the criminal offenses of unlawful assembly and failure to disperse.”   The Eighth Circuit affirmed. The court explained that Plaintiffs’ First Amended Complaint for Declaratory and Injunctive Relief (“FAC”) improperly limited Florissant’s broad civil authority to manage protests in the public interest to situations violating the criminal offenses of unlawful assembly and failure to disperse. The court reasoned that the alleged customs of declaring unlawful assemblies and ordering protesters to disperse in “the absence of an agreement of one person acting in concert with six or more other persons to imminently violate a criminal law with force or violence” do not state a claim of constitutional injury under Monell. Thus, the FAC failed to plausibly allege a constitutional violation by any city employee and therefore failed to state a claim of Monell liability. View "Khalea Edwards v. City of Florissant" on Justia Law

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Plaintiff argued with a police officer during a protest in downtown St. Louis. Defendant- Lieutenant saw the confrontation and, fearing for the other officer’s safety, pepper-sprayed him. Plaintiff alleged that the force used was both excessive and retaliatory the district court granted qualified immunity. Plaintiff brought excessive force and First Amendment retaliation claims against the Lieutenant and a municipal liability claim against the City of St. Louis.   The district court dismissed Plaintiff’s federal claims at summary judgment and declined to exercise supplemental jurisdiction over what remained. The Eighth Circuit affirmed. The court explained that Plaintiff’s arguments are just general complaints about the Lieutenant’s “true motivations, intentions, and testimonial fabrications.” None of these arguments make any difference because “evil intentions will not make a Fourth Amendment violation out of an objectively reasonable use of force.” Further, even viewing the facts in a light most favorable to Plaintiff, causation is missing. As Plaintiff acknowledged, the Lieutenant “was not even in the area” when he criticized the Bicycle Response Team. Nor did Plaintiff “have any interaction with him” during the mere seconds between the beginning of the incident and the use of pepper spray. Accordingly, the court’s conclusion that the Lieutenant did not violate Plaintiff’s First or Fourth Amendment rights also forecloses his constitutional claims against the City of St. Louis. View "Derek Laney v. City of St. Louis, Missouri" on Justia Law

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Plaintiff and Defendant both work for the State of Iowa. Plaintiff is a urologist at the University of Iowa Hospitals and Clinics; Defendant is a professor at the University of Iowa College of Law. After Defendant criticized Plaintiff’s expert testimony in a case unrelated to this one, Plaintiff sued Defendant under 42 U.S.C. Section 1983, alleging that Defendant retaliated against him for engaging in constitutionally protected speech. The district court dismissed Plaintiff’s claim on multiple grounds, including that Plaintiff failed to allege plausibly that Linder’s conduct was under color of state law.  Plaintiff argues that his complaint contains ample facts that together plausibly allege that Defendant acted under color of state law. These include that Defendant (1) identified himself as a state employee when he criticized Plaintiff in the newspaper articles, (2) relied on “the prestige of his official position with [UI] to gain credibility with his audience,” and (3) “used the instrumentalities and resources of the State of Iowa to facilitate his retaliatory conduct.”   The Eighth Circuit affirmed. The court agreed with the district court that Plaintiff failed to plead adequately that Defendant’s retaliatory actions were under color of state law. Contrary to Plaintiff’s insistence, our case law is clear that a state employee, merely by publicly identifying himself as such, does not act under color of state law. Further, even assuming that a public university professor acts in his official capacity or within the scope of his employment when he comments on public affairs, it would not necessarily follow that he acts under color of state law. View "James Brown v. Marc Linder" on Justia Law

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Plaintiff, an attorney, sued the Minnesota Office of Lawyers Professional Responsibility, the Minnesota Lawyers Professional Responsibility Board, associated government officials, and lawyers and other private defendants alleging, among other claims, they violated his constitutional rights by pursuing an ethics complaint against him. The district court granted the state defendants' motion to dismiss under Younger v. Harris and found that Plaintiff waived his abuse-of-process claim against the private defendants. The court also held that Plaintiff lacked standing to seek sanctions based on the private defendants' alleged violations of the Minnesota Rules of Professional Conduct.Finding that the district court did not abuse its discretion in any of its determinations, the Eighth Circuit affirmed. View "Herbert Igbanugo v. Minnesota OLPR" on Justia Law

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Defendant stopped Plaintiff for speeding. Plaintiff sued Defendant under 42 U.S.C. Section 1983, alleging, among other things, that Defendant pulled him over without probable cause. The district court denied Defendant’s summary judgment and qualified immunity on Plaintiff’s unlawful stop claim. On appeal, Defendant argued that he is entitled to qualified immunity.   The Eighth Circuit dismissed Defendant’s appeal, holding that it lacks jurisdiction to review the court’s factual assumptions. The court explained that Defendant’s claim that Plaintiff’s speed is immaterial for qualified immunity purposes assumes that Defendant used radar, clocked Plaintiff’s van, and clocked Plaintiff over the speed limit. But the district court did not assume these facts, which are material to whether Defendant reasonably believed Plaintiff broke the law Defendant’s jurisdictional arguments are “based on facts not assumed by the district court.” The court explained that because the factual record, as assumed by the district court, is unsettled and disputed, it lacks jurisdiction to go further. View "Sheck Mulbah v. Cody Jansen" on Justia Law

Posted in: Civil Rights
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Plaintiff sued her former employer, Marsden Building Maintenance, L.L.C., alleging wage discrimination, sex discrimination, and retaliation in violation of the Iowa Civil Rights Act (ICRA). Plaintiff appealed the district court’s grant of summary judgment in favor of Marsden. Plaintiff argued that the district court erred in granting summary judgment on her wage discrimination claim. Plaintiff also argued that the district court erred in granting summary judgment to Marsden on her sex discrimination claim.   The Eighth Circuit affirmed. The court held that on the record, Marsden has met its burden to prove the pay differential between Plaintiff and her male counterparts was based on a factor other than sex. Further, the court wrote that Plaintiff offered no evidence to support her sex discrimination allegation. Plaintiff took issue with how Marsden’s operations manager conducted himself in the role of operations manager. But none of the evidence she presented supports a reasonable inference that his decision to fire her is “more likely than not” explained by an intent to discriminate against her on the basis of her sex. View "Maria Mayorga v. Marsden Building Maintenance" on Justia Law