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

Officer Blayne Newton of the Kansas City, Missouri Police Department shot and killed Donnie Sanders during a traffic stop. Sanders’s children, Latetia Nunley and Zahleyiah Fielder, filed a lawsuit against Officer Newton under 42 U.S.C. § 1983, alleging a violation of Sanders’s Fourth Amendment right to be free from excessive force. Officer Newton sought summary judgment based on qualified immunity, which the district court denied, citing genuine issues of material fact. Officer Newton appealed the denial of qualified immunity.The United States District Court for the Western District of Missouri denied Officer Newton’s motion for summary judgment, finding that there were disputed facts essential to the analysis of the totality of the circumstances, including the nature of the threats made by Sanders and his level of compliance with commands. The court highlighted discrepancies between Officer Newton’s testimony and the forensic evidence from the autopsy, which suggested that Sanders was shot in a manner inconsistent with Newton’s account of Sanders pointing something at him.The United States Court of Appeals for the Eighth Circuit reviewed the case. Officer Newton argued that the district court erred in denying him qualified immunity and that the excessive-force claim was barred under the Eleventh Amendment. The appellate court dismissed the appeal for lack of jurisdiction, stating that it could not resolve genuine disputes of material fact in favor of the party seeking summary judgment. The court emphasized that the factual record was unsettled and disputed, preventing it from determining whether Newton’s actions were objectively reasonable or whether they violated clearly established law. The court concluded that the district court’s finding of a material factual dispute precluded it from granting qualified immunity at this stage. View "Nunley v. Newton" on Justia Law

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law

Angela Richardson, an inmate in Arkansas, filed a lawsuit against Krystle Reed Duncan, a former prison security officer, under 42 U.S.C. § 1983, alleging sexual harassment and assault in violation of the Eighth Amendment. Richardson claimed that between November 2018 and January 2019, she and Duncan engaged in a consensual sexual relationship, which included kissing and digital penetration. Richardson did not report the relationship to prison officials until late 2020, after learning that Duncan had been involved with other inmates, which caused her emotional distress.The United States District Court for the Eastern District of Arkansas reviewed the case. Duncan did not respond to the complaint, leading to a default entry. A magistrate judge held a hearing and recommended vacating the default and dismissing the complaint for failure to state a claim. The magistrate judge found that Richardson's allegations described consensual sexual activity and did not support a claim of coercion or non-consensual conduct. The district court adopted this recommendation and dismissed the complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Richardson failed to state a claim under the Eighth Amendment. The court applied its precedent from Freitas v. Ault, which held that consensual sexual interactions, even if inappropriate, do not constitute "pain" under the Eighth Amendment. The court found that Richardson's complaint and testimony did not allege any coercion, force, or threats by Duncan, and thus did not meet the objective component of an Eighth Amendment violation. The judgment of the district court was affirmed. View "Richardson v. Duncan" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law

In 2020, the Springfield R-12 School District mandated "equity training" for its employees. Two employees, Brooke Henderson and Jennifer Lumley, attended the training and later sued the school district and several officials under 42 U.S.C. § 1983. They claimed that the training compelled them to speak on matters of public concern and engaged in viewpoint discrimination, violating their First and Fourteenth Amendment rights. The training included interactive sessions and online modules that required participants to discuss prompts and select "correct" answers to questions about equity and diversity.The United States District Court for the Western District of Missouri granted summary judgment in favor of the school district, ruling that the plaintiffs lacked standing because they did not suffer an injury in fact. The court also deemed the lawsuit frivolous and awarded attorney’s fees to the school district. The plaintiffs appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal, agreeing that the plaintiffs did not establish an injury in fact. The court found that the plaintiffs' fear of punishment for their speech during the training was speculative and not objectively reasonable. The court also concluded that the plaintiffs' completion of online modules did not constitute a First Amendment injury. However, the Eighth Circuit reversed the award of attorney’s fees, determining that the plaintiffs' claims were not frivolous given the nuanced and unsettled nature of the constitutional issues involved. View "Henderson v. Springfield R-12 School District" on Justia Law

Russell Hotchkiss, a resident of Linn County, Iowa, began sending emails to the Cedar Rapids Community School District officials in September 2021, criticizing their COVID-19 masking and vaccination policies. His communications included threats of criminal charges against board members, particularly targeting Jennifer Borcherding, a board member. Hotchkiss attended board meetings in November and December 2021, where he voiced his opposition aggressively. Following these incidents, the District issued a no-trespass notice to Hotchkiss on January 10, 2022, barring him from District premises due to his disruptive and threatening behavior.Hotchkiss filed a lawsuit on May 17, 2023, claiming First Amendment retaliation under 42 U.S.C. § 1983 and a violation of the Iowa Open Meetings Act. He sought a preliminary injunction to prevent the enforcement of the no-trespass order. The United States District Court for the Northern District of Iowa denied his motion, concluding that Hotchkiss failed to demonstrate irreparable harm. The court noted that Hotchkiss had not attempted to return to District premises, had moved his child to another school district, and had not communicated with the District since the notice was issued.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision. The appellate court affirmed the denial of the preliminary injunction, agreeing that Hotchkiss did not show a likelihood of irreparable harm. The court emphasized that speculative harm does not justify a preliminary injunction and noted Hotchkiss's delay in seeking relief and lack of recent attempts to exercise his First Amendment rights. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction based on the failure to demonstrate irreparable harm. View "Hotchkiss v. Cedar Rapids Community School District" on Justia Law

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law

Christopher Lockhart, a licensed Arkansas bail bondsman and private investigator, was stopped by Siloam Springs police officer Zachary Ware around 3:30 AM on March 11, 2019, for alleged traffic violations. Lockhart was arrested and charged with DWI, careless driving, and driving left of center. After refusing a plea deal, Lockhart was tried for DWI but was found not guilty. Subsequently, Lockhart filed a § 1983 action against multiple defendants, including claims of unreasonable stop, unlawful arrest, and malicious prosecution.The United States District Court for the Western District of Arkansas granted summary judgment to the defendants on most claims but allowed Lockhart’s illegal stop and false arrest claims against Officer Ware and the malicious prosecution claim against Siloam Springs to proceed. The court found genuine disputes of material fact regarding whether Officer Ware had probable cause to stop Lockhart, as the dashcam video did not conclusively support Ware’s testimony. The court also denied summary judgment on the malicious prosecution claim, finding a material fact dispute about whether the prosecutor had probable cause to try Lockhart for DWI.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that Officer Ware had probable cause to stop Lockhart for careless driving, as Lockhart’s tires touched the centerline, which under Arkansas law constitutes a traffic violation. The court reversed the district court’s decision regarding the initial stop and remanded the case for further proceedings on the remaining issues. The court also affirmed the district court’s denial of summary judgment on the malicious prosecution claim, agreeing that Arkansas statutory immunity does not apply to intentional torts like malicious prosecution. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

In 2000, Karl Roberts was convicted and sentenced to death in Arkansas state court for the rape and murder of his twelve-year-old niece. Roberts waived his right to challenge his conviction on direct appeal, in state postconviction proceedings, and in federal habeas corpus proceedings. Both the Arkansas state trial court and the Arkansas Supreme Court found the waiver to be knowing and voluntary. On the day of his scheduled execution in 2004, Roberts moved for a stay of execution, which was granted, and subsequently filed a petition for writ of habeas corpus, initiating two decades of litigation.The United States District Court for the Eastern District of Arkansas denied Roberts’s nineteen habeas corpus claims but granted a certificate of appealability (CoA) on three claims: whether Roberts was intellectually disabled, competent to be tried, and competent to waive his direct appeal. The Eighth Circuit expanded the CoA to include two ineffective assistance of counsel claims: failure to investigate and challenge Roberts’s competency to be tried and failure to investigate and present evidence of Roberts’s mental health as mitigating evidence at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s denial of Roberts’s habeas petition. The court held that the Arkansas courts’ findings that Roberts was not intellectually disabled, was competent to stand trial, and was competent to waive his direct appeal were reasonable and supported by the record. The court also found that Roberts’s trial counsel was not ineffective, as the counsel’s performance did not fall below an objective standard of reasonableness, and there was no prejudice to Roberts. The court concluded that Roberts failed to show that the outcome of his trial would have been different but for the alleged errors by his counsel. View "Roberts v. Payne" on Justia Law

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law