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

Plaintiff filed suit under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., against his employer after he retired. The court concluded that plaintiff's age-based hostile work environment claim failed because the supervisor's age-related comments were not so severe as to affect a term, condition, or privilege of his employment; without more than plaintiff's speculation, a reasonable juror could not find the supervisor's actions - although contemptible - amounted to harassment based on sex; plaintiff has not shown sufficient facts to infer a hostile work environment and he cannot prove constructive discharge; and plaintiff has not suffered an adverse employment action and cannot establish a claim for either disparate treatment or retaliation. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer. View "Rickard v. Swedish Match North America" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that his probation officer violated his First Amendment rights by requiring him to satisfy the terms of a court probation order directing him to complete a privately run substance abuse treatment program (ARCH). Plaintiff alleged that the program prohibited him from practicing his faith as a Jehovah's Witness. The court affirmed the district court's conclusion that quasi judicial absolute immunity applied to the officer because he was carrying out a court order. View "Rose v. Flairty" on Justia Law

Plaintiff, a custodian for the school district, filed suit under 42 U.S.C. 1983 and state law against the district after plaintiff's wife spoke at a public school board meeting. Plaintiff's wife was speaking as a member of the public, suggesting that the school board should consider sharing a superintendent and eliminating a principal. The court affirmed the district court's finding that the evidence did not establish any genuine dispute of material fact or sufficient evidence to show that plaintiff's association with his wife was a substantial or motivating factor in his alleged constructive discharge; the district's proffered reasons for plaintiff's reassignment was pretext; or the requisite personal motive necessary for a tortious interference with a contract. View "Skalsky v. Indep. Sch. Dist. No. 743" on Justia Law

Plaintiff, the trustee of Cody Laganiere's estate, filed suit against ADC and others under 42 U.S.C. 1983 after Cody was found dead in his cell from a methadone overdose. Plaintiff alleged that defendants deliberately disregarded Laganiere's medical needs in violation of the Eighth Amendment. The court affirmed the district court's grant of summary judgment to defendants, concluding that there was no evidence that defendants knew Laganiere suffered serious side effects from methadone but deliberately disregarded the issue; the supervisor did not fail to train the detention deputy; and because plaintiff failed to show that any officer deliberately disregarded plaintiff's medical needs, ADC and the county are not liable. View "Laganiere v. The County of Olmsted" on Justia Law

Plaintiff, a Caucasian male, filed suit after being terminated from the AHTD, alleging race and gender discrimination and violations of various statutory and constitutional rights. Because plaintiff has not provided analysis or development of his briefs, he has waived some of his claims. The court concluded that the district court did not abuse its discretion in denying plaintiff leave to amend because amendment would be futile; plaintiff failed to present direct evidence of discrimination where, at most, plaintiff's evidence showed discord with his female subordinates, not that any discriminatory animus motivated his termination by the decisionmakers; and, under the McDonnell Douglas burden-shifting framework, plaintiff's claims of race and gender discrimination fail where, even if plaintiff made a prima facie showing, AHTD offered a legitimate, non-discriminatory justification for his termination - his violation of the sexual harassment policy. Accordingly, the court affirmed the judgment of the district court. View "Moody v. Vozel" on Justia Law

Plaintiffs, three ex-fire chiefs, appealed the adverse grant of summary judgment on their procedural due process claims challenging their terminations. The court concluded that plaintiffs, at-will employees pursuant to Missouri law, were terminable at the will of their employer and they had not property interest in their continued employment under the Fourth Amendment; there was no stigma sufficient to deprive plaintiffs of a liberty interest; and plaintiffs' individual capacity claims allege no constitutional deprivation. Accordingly, the court affirmed the judgment of the district court. View "Crews v. Monarch Fire Protection Dist." on Justia Law

Plaintiff, a Minnesota inmate, sought leave to proceed in forma pauperis (IFP) in a suit under 42 U.S.C. 1983. The district court denied IFP status and dismissed the complaint because plaintiff had three strikes within the meaning of 28 U.S.C. 1915(g). The third case the district court relied on was dismissed under 28 U.S.C. 1915A(b)(2) after it was determined that the only named defendant was entitled to prosecutorial immunity. The court held that dismissals based on immunity are not among the types of dismissals listed as strikes in section 1915(g) and, therefore, the dismissal of this action is not a strike under section 1915(g). Accordingly, the court vacated and remanded for further proceedings.View "Castillo-Alvarez v. Krukow" on Justia Law

Plaintiff filed suit against Associated Underwriters after she was terminated, alleging claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court dismissed both claims. The court concluded that plaintiff presented sufficient evidence to allow a reasonable jury to conclude that there was a direct correlation between employee age and the termination decision - that it was the but-for cause of plaintiff's termination. Therefore, the court reversed the district court's dismissal of the ADEA claim. The court concluded, however, that the district court properly dismissed the ADA claim where there is no evidence that Associated Underwriters terminated her employment on the basis of disability. Therefore, the court affirmed as to this claim.View "Tramp v. Associated Underwriters, Inc." on Justia Law

In 1989, Wheatley plaintiffs filed suit against the District alleging on-going violations of the Voting Rights Act, 42 U.S.C. 1971 et seq., and the Fourteenth Amendment. In 1990, the district court confirmed a settlement between the parties. In 2012, the District filed a motion to modify or terminate the settlement decree, seeking an order permitting the District to relocate the middle school grades from the Wheatley campus to the Palestine campus. The district court granted the motion and the Wheatley plaintiffs appealed. The court concluded that the district court properly applied the standards for modifying a consent decree when changed circumstances have caused it to be unjust under Rufo v. Inmates of the Suffolk County Jail. In this case, the district court did not abuse its discretion in approving the modification, which was directly related to the evidence of changed circumstances the District presented. Further, it is apparent from the face of the consent decree that many of its eleven contractual commitments were premised on continued use of two school campuses and, therefore, these provisions were effectively terminated. Other provisions in the decree do not require functioning schools in both communities. The district court did not intend that its order terminate the entire consent decree, and the court so construed its order. Accordingly, the court affirmed the district court's order.View "Smith, et al. v. Palestine-Wheatley Sch. Dist, et al." on Justia Law

Plaintiff, a pathologist, filed suit against Avera, alleging that Avera violated federal and state laws for terminating a Services Agreement. Plaintiff filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; the Family Medical Leave Act (FMLA), 29 U.S.C. 2617 et seq.; and the South Dakota Human Relations Act (SDHRA), S.D. Codified Laws 20-13-1 et seq. The court affirmed the district court's grant of summary judgment dismissing all of plaintiff's claims because plaintiff was an independent contractor of St. Luke's Hospital under his Services Agreement and not an employee.View "Alexander v. Avera St. Luke's Hospital" on Justia Law