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

Articles Posted in Civil Rights
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After plaintiff was terminated, she filed suit against the President of Henderson State University for employment discrimination. The Eighth Circuit affirmed the district court's grant of summary judgment for defendant, holding that plaintiff was an at-will employee at the time of her termination. In this case, passing a proposed budget including plaintiff's name, title, and salary, did not create an employment contract. Therefore, plaintiff had no property right in continued employment. In regard to plaintiff's claim that she has a protected liberty interest in her reputation, which entitled her to a name-clearing hearing, the court held that plaintiff presented no evidence of defendant directly accusing her of stealing or mismanagement. Furthermore, any claims that plaintiff was stigmatized by innuendo or defendant's commenting on any part of the audit report failed. Therefore, plaintiff failed to establish that she was deprived of a protected liberty interest in her reputation. View "Correia v. Jones" on Justia Law

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Plaintiffs filed suit challenging an Arkansas anti-loitering law that bans begging in a manner that is harassing, causes alarm, or impedes traffic. The Eighth Circuit affirmed the district court's grant of a statewide preliminary injunction preventing Arkansas from enforcing the ban while plaintiffs pursue their claim that the law violates the First Amendment. The court held that plaintiffs had standing to seek a preliminary injunction where plaintiff's chilled speech amounted to a constitutional injury, the injury was fairly traceable to the potential enforcement of the anti-loitering law, and the injury would be redressable by an injunction. The court held that plaintiffs were likely to prevail on their First Amendment claim, because Arkansas failed to establish that the law was narrowly tailored to achieve a compelling interest. Furthermore, plaintiffs have established that the law likely violates the First Amendment, and thus they have satisfied the remaining three Dataphase factors. Finally, the court held that the district court did not abuse its discretion in applying the preliminary injunction statewide rather than limiting its application to plaintiffs. View "Rodgers v. Bryant" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against Defendants McCarber and LaLuzerne, alleging that defendants violated his constitutional rights by carrying out an arrest without probable cause and in retaliation for speech, falsifying a police report, using excessive force against him, and conspiring to violate his rights. The district court denied defendants qualified immunity. The Eighth Circuit held that defendants were entitled to qualified immunity on the false arrest, retaliatory arrest, and due process claims, because defendants at least had arguable probable cause to arrest plaintiff. In this case, the night club was closed, the lead security guard told plaintiff that he was no longer allowed in the club and needed to leave, and plaintiff admitted that he did not leave promptly after receiving defendants' instructions to exit. Even if plaintiff initially had a right to wait in the lobby, the court held that a reasonable officer could have believed that the guard or defendants themselves revoked that right by asking plaintiff to leave. Furthermore, the court held that plaintiff was not deprived of liberty after his trial. Finally, the court held that defendants were entitled to qualified immunity on the excessive force claims involving pushing and applying pepper spray, but were not entitled to qualified immunity to use tasers where it was clearly established that it was unreasonable under the Fourth Amendment to apply a taser to a nonviolent, suspected misdemeanant who was not fleeing or resisting arrest, and who posed little to no threat to anyone's safety. View "Johnson v. McCarver" on Justia Law

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Plaintiff filed suit alleging that Missouri's lobbying requirements violate his freedom of speech and right to petition the government, and that the law is facially invalid because ordinary citizens do not have fair notice of whom it covers. The Eighth Circuit vacated the district court's order denying plaintiff a preliminary injunction. The court held that Missouri's application of the law to plaintiff violates the First Amendment, because his political activities did not involve the transfer of money or anything of value, either to him or anyone else, and Missouri's interest in transparency did not reflect the seriousness of the actual burden on his First Amendment rights. The court also held that, even though the law does not define or otherwise explain what "designated" means, it is not vague. Instead, the court applied the word's common and ordinary meaning, in context, and held that, just because the law is broad does not mean that it is ambiguous, much less constitutionally vague. Accordingly, the court remanded for further consideration of plaintiff's request for a permanent injunction. View "Calzone v. Summers" on Justia Law

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Plaintiff filed suit against Dollar General after the company denied her request for a leave of absence due to a medical condition, alleging claims under the Americans with Disabilities Act (ADA), the Family Medical Leave Act (FMLA), and state law. The court reversed the district court's dismissal of plaintiff's ADA claim and held that a reasonable jury could conclude that Dollar General was aware of her disability; that she requested an accommodation; and that Dollar General, had it engaged in the interactive process, could have reasonably accommodated her. However, plaintiff's remaining claims failed because she could not show defendants' actions amounted to retaliation and she failed to follow the steps Dollar General had established for requesting FMLA leave. View "Garrison v. Dolgencorp, LLC" on Justia Law

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Iowa inmates filed a 42 U.S.C. 1983 action against the IDOC and IDOC officials, alleging that IDOC's administration of its Sex Offender Treatment Program violates their constitutional rights to equal protection, due process, and necessary medical care. The Eighth Circuit held that the district court erred in concluding that the federal claims must be dismissed without prejudice under 42 U.S.C. 1997e(a), because plaintiffs failed to exhaust their available post-conviction remedies under Belk v. State, 905 N.W.2d 185, 191 (Iowa 2017). In this case, defendants cite no case holding that post-conviction judicial remedies were "administrative remedies" that must be exhausted under section 1997e(a), and the court has not found an opinion that even addresses the question. The panel also held that plaintiffs' claim that defendants' unconstitutional conduct deprived plaintiffs of their statutory right to accrue earned-time credit and of receiving a reduction of sentence was barred by Heck v. Humphrey, 512 U.S. 477 (1994). Accordingly, the panel reversed and remanded for further proceedings. View "Minter v. Bartruff" on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action for damages, alleging that the city, the police department, and an officer violated plaintiff's constitutuional rights when he was detained and tased as part of an arrest. The Eighth Circuit affirmed the district court's grant of summary judgment to the city, because plaintiff failed to provide the evidence to support his claims of municipal liability. In this case, plaintiff has not presented any evidence to suggest that the city has created, adopted, or supported any policy or custom that would demonstrate municipal liability. The court affirmed the grant of summary judgment to the officer on the First Amendment claim, where, as here, speech and nonspeech elements combine in the same course of conduct, a sufficiently important government interest in regulating the nonspeech element can justify incidental limitations on First Amendment freedoms. In regard to the excessive force claims against the officer, the court held that the first and third tasings were objectively reasonable, but there was a genuine issue of material fact as to whether the second tasing amounted to excessive force. Accordingly, the court reversed in part and remanded for further proceedings. View "Jackson v. Stair" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against Arkansas prison officials, alleging deprivations of his constitutional rights while incarcerated. Plaintiff's claims stemmed from his almost seven month detention in administrative segregation. The Eighth Circuit affirmed on the alternative ground that the complaint failed to adequately allege a violation of plaintiff's clearly established constitutional rights and therefore defendants were entitled to qualified immunity. The court explained that, although defendants did not raise qualified immunity in their motion to dismiss, the posture of the case has materially changed, and the court saw no bar to addressing qualified immunity. In regard to plaintiff's claim of deliberate indifference to his serious medical needs, the court held that defendants did not violate his clearly established rights. In this case, the nine occasions when plaintiff did not receive his daily treatment during his time in administrative segregation were insufficient to create an Eighth Amendment claim. In regard to plaintiff's claims related to his conditions of confinement, the court held that plaintiff failed to cite circuit precedent holding that an inadequate justification for administrative segregation or shortcomings in review of a prisoner's placement violates the Due Process Clause; defendants' conduct did not violate clearly established law; and it was not beyond debate that defendants curtailed plaintiff's liberty interest by segregating a prisoner with plaintiff's particular medical condition for 203 days under the conditions alleged. View "Hamner v. Burls" on Justia Law

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Plaintiffs, a class of civilly committed residents, appealed the dismissal of their claims against state officials, alleging that the state's commitment provisions are facially unconstitutional, and that the treatment program as applied to the residents violates their substantive due process rights. The Eighth Circuit affirmed, holding that plaintiffs did not assert a typical substantive due process claim but, rather, they contend that defendant officials must change the way that they conduct annual reviews of civilly-committed persons, design procedures for releasing low-risk residents into less restrictive housing, and carry out a statutory duty to authorize petitions for release of low-risk residents. The court held that an entitlement to these actions is not deeply rooted in the Nation's history and tradition or implicit in the concept of ordered liberty. In this case, plaintiffs had procedures available to them that were sufficient to vindicate their liberty interest in gaining release from detention once the reasons that justified the commitment dissipate. The court explained that the fact that the Act provides additional opportunities to facilitate release, and that state officials allegedly have failed to implement them properly, does not run afoul of substantive due process. In the alternative, the court held that the shortcomings cited by the district court in Missouri mirror those that Karsjens v. Piper, 845 F.3d 394 (8th Cir. 2017), held were not conscience-shocking in Minnesota. Accordingly, the district court correctly reasoned that the as-applied substantive due process claims should be dismissed. Finally, there was no reversible error in the district court's conclusion that plaintiffs abandoned their state law claims. View "Van Orden v. Stringer" on Justia Law

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The Eighth Circuit affirmed the district court's denial of plaintiff's petition for habeas corpus relief. The court held that plaintiff's counsel's representation did not fall below an objective standard of reasonableness, and even if it did, plaintiff has not demonstrated that he was prejudiced. The court also held that, even assuming that plaintiff fairly presented his claim to the state court, his claim failed where considering an aggravating factor in violation of a state statute alone does not amount to a constitutional violation meriting federal habeas relief. Finally, the court held that the tools were available to plaintiff to make his arguments -- that his youth at the time of the offense and the serious mental illnesses categorically exempt him from the death penalty -- before the state court, he failed to show cause, and his procedural default was not excused. View "Anderson v. Kelley" on Justia Law