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

In 2007-2012, Stewart was supervisor of a branch office for Rise, a welfare-services non-profit entity that obtained funding from a Minnesota welfare program, "Pathways." Stewart supervised counselors who directly assisted clients. Stewart's performance was measured in part by the relative workforce participation rate for her office's clients compared to clients of other Pathways organizations. During Stewart's tenure, other offices closed, a state government shut-down occurred, and workloads from different offices were consolidated, without a commensurate increase in staffing. When Stewart began working at Rise, the workforce participation rate was at a generally acceptable level. By the time she was terminated, her office’s performance had deteriorated. Stewart's predecessor and successor were, like Stewart, American-born African-American women. Stewart claimed that male, Somali-born subordinates created a hostile work environment through sexist, racist, and nationalist comments and through physical violence and intimidation, and that her supervisors ignored her complaints, denied her the authority to terminate the offending employees, allowed the hostile environment to persist, and eventually terminated her employment as an act of discrimination and retaliation. The district court granted summary judgment for Rise. The Eighth Circuit reversed and remand as to the hostile work environment claim but otherwise affirmed. View "Stewart v. Rise, Inc." on Justia Law

Eva Robinson and her son Matthew were walking their dog. Dover Deputy Payton observed "suspicious people walking." He stopped them. The dog ran away; Matthew chased it. After Matthew returned with the dog, Payton placed them inside his patrol car. Pope County Deputy Stevens and Arkansas State Trooper Condley arrived. Stevens asked Matthew to exit the patrol car. Matthew did not exit. Stevens tased Matthew. According to the Robinsons, Matthew, who is very large, was tased while struggling to get out. Condley asserts Matthew refused to exit after multiple requests. The parties disagree about whether warning was given. Condley removed Eva from the vehicle, and handcuffed her. Payton pulled Matthew from the car and stunned him, then took Matthew to the ground and stunned him again. Photos show at least 15 taser marks. Searching Matthew, the officers found cigarette lighters and an air chuck. Eva thought the officers were shooting a handgun. She urinated on herself and screamed. Wanting to cover Matthew, she broke free a. Condley grabbed her and slammed her onto the hood of the patrol car. Eva was charged with disorderly conduct, refusal to submit to arrest, and criminal mischief. Matthew was charged with refusal to submit to arrest. The Robinsons sued under 42 U.S.C. 1983. The district court denied Condley's motion for qualified immunity on the claim that Condley failed to intervene during the other officers' use of excessive force. The Eighth Circuit reversed. Condley's duty to intervene in these circumstances was not clearly established, View "Robinson v.Condley" on Justia Law

Because of an unpaid drug debt, Velez attacked the victim in a prolonged beating with a metal pole causing numerous broken bones and other serious injuries. Velez pleaded guilty to two counts of "willful injury causing serious injury" under Iowa law. The plea agreement provided that the state would recommend consecutive sentences for the counts, both based upon the July 5, 2010, incident. The state court sentenced Velez to consecutive 10-year sentences. On appeal, Velez asserted there was an inadequate factual basis for his plea, that counsel was ineffective, and that the sentence violated the Double Jeopardy Clause of the U.S. Constitution. The Iowa Court of Appeals reversed, finding that the plea colloquy only established a factual basis for the proposition that Velez had caused multiple serious injuries, not that there were at least two discrete incidents. The Iowa Supreme Court reversed, finding that the record as a whole contained a sufficient factual basis to support a finding of two separate assaults. The federal district court denied habeas relief, finding that the state court's adjudication of the federal issue was not an unreasonable application of the Supreme Court's double jeopardy jurisprudence and that Velez's convictions were not based upon an unreasonable determination of the facts. The Eighth circuit affirmed. View "Velez v. Clarinda Corr. Facility" on Justia Law

Franklin claimed that Young, an assistant caseworker at the facility where Franklin was incarcerated, violated the Eighth Amendment by failing to protect him from sexual assault by another inmate by being deliberately indifferent to a substantial risk that he would be sexually assaulted by inmate Mosley. The district court denied Young’s motion for summary judgment on the ground of qualified immunity, holding that factual disputes prevented the court from determining whether Young violated Franklin’s rights. The Eighth Circuit dismissed an interlocutory appeal. A district court's summary judgment order denying qualified immunity may not be appealed “insofar as [it] determines whether or not the pretrial record sets forth a genuine issue of fact for trial.” Essentially, Young argued that the district court erred in finding a genuine dispute of material fact over whether he violated Franklin’s Eighth Amendment rights. By challenging the district court's finding on sufficiency of the evidence, Young was asking the court to engage in “the time-consuming task of reviewing a factual controversy about intent.” View "Franklin v. Young" on Justia Law

Heartland provides laboratory services to long-term healthcare facilities. Watson, an African-American woman, was a route phlebotomist, traveling to several facilities, drawing blood from patients, and returning to the lab to process the samples. As a new employee, Watson was subject to a 90-day probationary period. Watson's route included Plaza Manor, where she was assigned to draw blood from Ramsey. While Watson was attempting to draw Ramsey's blood, he touched Watson’s inside thigh and moved his hand upward. Watson told Ramsey to stop and brushed his hand away. When Ramsey touched her "crotch area," Watson knelt down to draw Ramsey's blood. Ramsey put his hand on her side. After she stopped attempting to draw blood, Ramsey "grabbed the back of [Watson's] neck to try to kiss [her]." Watson left and reported the incident to Heartland, which ensured that she never provided services for Ramsey again, but denied her request for a route change. Watson continued to visit Plaza Manor. Ramsey verbally assaulted Watson, making racial and sexually derogatory remarks. After the seventh incident, Watson missed three days of work. Under Heartland's policy, an employee is considered to have voluntarily abandoned her job after two consecutive days of absence without properly notifying Heartland. Heartland left multiple voicemail messages. The Eighth Circuit affirmed summary judgment rejecting her claims of hostile work environment, constructive discharge, and retaliation under the Missouri Human Rights Act. View "Watson v. Heartland Health Labs, Inc." on Justia Law

Ransom was driving home to Kansas City. His van began backfiring. He pulled over. Someone called 911 and reported that shots had been fired from or near a white van, though the caller did not report seeing flashes. Officers Phillips and Conaway arrived and pulled behind Ransom’s van, which had on its hazard lights. The van backfired; its driver’s-side door opened. Phillips yelled, “Get back in.” Ransom apparently did not hear and stepped out. The officers fired eight shots. Ransom did not notice that they had fired at him. The officers reported “shots fired.” Ransom stated “My van is backfiring.” Phillips stated, ““No, it’s not. Our window’s shot out” and ordered Ransom to walk toward the squad car. Ransom complied. The Officers requested back-up, thinking another person might be shooting from a ditch. Ransom was taken to police headquarters. When his interview ended, he accepted a ride. Officers pulled behind the van, began to exit, and heard a loud backfire that they thought was a gunshot. The officers believed that they were being “ambushed.” When Ransom did not follow a command to get back in his car, Phillips believed that Ransom was attempting suicide by cop and feared for his safety and for bystanders. The officers thought they heard more shots and fired at Ransom. An investigation determined Ransom’s van was backfiring; there was no suspect nearby. Ransom was again questioned. In his suit under 42 U.S.C. 1983, the court concluded that there were disputed issues and denied the officers’ motion for qualified immunity. The Eighth Circuit directed judgment in favor of the defendants, finding the officers’ conduct reasonable. View "Ransom v. Grisafe" on Justia Law

Officer Williams allegedly searched and seized Banks without probable cause, took $1,100 from him without including it in department records, and filed false reports, leading to a criminal prosecution against Banks for unlawful use of a weapon, a charge on which he was acquitted. Plaintiffs sued, in state court, under 42 U.S.C. 1983. An amended complaint against Williams, in his individual and official capacities, alleged that Williams’s actions were part of a pattern of unconstitutional conduct about which the St. Louis Police Board was deliberately indifferent. Williams and the Board were served. Williams and an attorney for the Board were notified of the potential default and a scheduled hearing. Only plaintiffs appeared. A$900,000 default judgment entered against Williams "in his personal and official capacities, jointly and severally." Plaintiffs unsuccessfully sought to enforce the judgment against city officials in state court. The federal district court declined to enter a declaratory judgment, finding that it lacked jurisdiction. The Eighth Circuit reversed. Refusal to honor the default judgment against Williams in his official capacity, not the state court denial of mandamus, was the source of the injury from which plaintiffs seek relief. Plaintiffs did not ask a federal court to overturn an injurious state-court judgment. Younger abstention is also inappropriate. View "Banks v. Slay" on Justia Law

Snyder was on parole after serving sentences for possession of a controlled substance and automobile theft. The Missouri Board of Probation and Parole determined that Snyder had absconded and issued a warrant for his arrest. Julian, an employee of the Board’s Fugitive Apprehension Unit, received a telephone call informing him that Snyder was at an apartment in Cape Girardeau. Julian drove to the address and positioned his car in a well-lighted parking lot in front of the apartment. Julian saw Snyder, got out of his car, and informed Snyder that he was a parole officer with a warrant for Snyder’s arrest. Snyder placed his hands on the back of Julian’s car. Julian approached, stood to Snyder’s left, and placed his left hand on Snyder’s left shoulder. Snyder then turned to his right and began to run. After Snyder took two steps, Julian fired one shot, killing him. In a suit by Snyder’s estate, the jury rejected claims under 42 U.S.C. 1983, but awarded $1 million for wrongful death. The Eighth Circuit affirmed, finding that there was sufficient evidence to defeat Julian’s motion for judgment as a matter of law, and that the damages award did not require a new trial. View "Estate of Snyder v. Julian" on Justia Law

Danial received a 120-day "shock" sentence for possessing marijuana. At the Missouri Western Correction Center, Danial was placed in the prison's "hospital" ward, where he beat on the walls. Following a request from mental health personnel, Danial was moved to a padded cell. He remained in a manic state, under the highest level of observation, requiring in-person checks for an affirmative response four times an hour. One night, staff merely viewed Danial through a monitor. Around 11:26 p.m., Danial fell and hit his head against a wall, slid down, and remained sitting until he fell backward again, hitting his head on the door jamb. Danial stated that he injured his head and needed medical attention. Staff did not open the cell door. They obtained no responses from Danial during the rest of the shift. Around 9:00 a.m., staff tried to wake him, even splashing water on Danial's face through a door opening. Danial responded by moving his eyes "slightly" and groaning. Danial had been in the same position, unresponsive for hours, but staff still did not open the door. When staff finally entered Danial's cell, his temperature was below 90 degrees, his pulse was between 30 and 34 beats per minute, and his eyes were fixed and dilated. He died in a hospital three days later, as a result of subdural hematoma caused by the falls in his cell. His parents sued under 42 U.S.C. 1983. The district court denied defendants’ motion for summary judgment on deliberate indifference claims, asserting qualified immunity. The Eighth Circuit reasoned that a jury could find two defendants liable for deliberate indifference, but that the conduct of a third officer constituted, at most, negligence. View "Letterman v. Farnsworth" on Justia Law

Wagner worked for Gallup for 12 years before his 2011 termination at age 50. Wagner co-authored two books for Gallup. The first became a New York Times bestseller. Gallup still sells both books. Wagner received positive verbal feedback from individuals in management. Gallup presented him with many awards during his employment. In 2011, Bogart became Wagner's supervisor. Bogart was 35, but had worked for Gallup longer than Wagner. Wagner stated that he and Bogart only interacted twice while Bogart was his supervisor. Bogart called Wagner and discussed the ongoing transitional situation of Wagner’s position and Bogart's difficulty finding a place for Wagner on a team given the perception that Wagner was too "self-referential." During a second call, Bogart terminated Wagner, informing Wagner that his position had been eliminated. Wagner sued, alleging age discrimination under the Minnesota Human Rights Act and invasion of privacy based on appropriation of his name or likeness. Wagner submitted declarations from two former Gallup employees who had worked with Wagner. Both stated that Gallup had initiated a "youthful movement" and targeted older employees for termination. The district court granted judgment in favor of Gallup. The Eighth Circuit affirmed. Wagner was unable to establish a question of fact as to Gallup's motives for his termination and did not establish intentionality with respect to his privacy clam. View "Wagner v. Gallup, Inc." on Justia Law