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

Plaintiff, falsely accused of rape and jailed for seventeen days, filed suit under 42 U.S.C. 1983 against the County and police officers. Plaintiff alleged that the officers failed to account for certain evidence defendant claimed was exculpatory, both in investigating the claim and in drafting an affidavit used to obtain an arrest warrant. The court concluded that the officers' decision to focus on other investigative leads rather than pursue tenuous, circumstantial, and potentially biased testimony from bar patrons neither shocks the conscience nor indicates recklessness; the officers' reaction to the investigator's suspicion of the photos of the victim demonstrated the even-handedness of their investigation where they soon called in a forensic nurse and then confronted the victim; and plaintiff's remaining allegations of reckless failures on the part of the officers was without merit. Further, plaintiff failed to show any omissions in the affidavit that demonstrated that the officers were reckless. Without a constitutional violation by the officers, there can be no liability for the county. Accordingly, the court affirmed the judgment of the district court, which found no genuine dispute of material fact as to whether the officers committed any constitutional violations. View "Hawkins v. Gage County, et al." on Justia Law

Plaintiff filed suit against her former employer, CSG, under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., alleging claims of gender discrimination and retaliation. The court concluded that, assuming without deciding, that plaintiff established a prima facie case of gender discrimination, CSG offered a legitimate, non-discriminatory justification for terminating her employment where CSG identified substantial performance-related problems; plaintiff failed to prove there was pretext for the gender discrimination; and, therefore, the court affirmed the district court's grant of summary judgment on plaintiff's discrimination claim. Likewise, plaintiff failed to demonstrate that CSG's legitimate, nondiscriminatory reason for terminating her employment was pretextual. Accordingly, the district court properly granted summary judgment on plaintiff's retaliation claim as well. View "Fiero v. CSG Systems, Inc." on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, alleging that deputies used excessive force that resulted in Jimmy Farris' death. The court concluded that the district court did not clearly abuse its discretion in weighing the interests of justice with due regard to the importance of live testimony and concluding that the circumstances here - the deputy's deployment to Afghanistan precluded him from appearing at trial without extraordinary effort, cost, and other hardship - tipped the balance in favor of admitting the deputy's deposition testimony. Even if the district court abused its discretion in admitting the deputy's deposition testimony, the error would be harmless where plaintiffs were not prejudiced. Accordingly, the court affirmed the district court's denial of plaintiffs' motion for a new trial. View "McDowell, et al. v. Blankenship, et al." on Justia Law

Plaintiff filed suit against defendant, alleging claims related to her candidacy as a legal writing instructor at the Iowa College of Law. On appeal, plaintiff challenged the district court's denial of her motion for a new trial. The court held that where a court declares a mistrial and discharges the jury which then disperses from the confines of the courtroom, the jury can no longer render, reconsider, amend, or clarify a verdict on the mistrial counts. In this case, the court concluded that the magistrate judge erred in recalling the jury to question and re-poll them as to the mistried, or not, counts. Accordingly, the court reversed and remanded. View "Wagner v. Jones, et al." on Justia Law

Plaintiffs filed suit against police officers under 42 U.S.C. 1983, alleging false arrest and retaliation. The court concluded that plaintiffs failed to preserve the issue of whether the district court erred when it vacated the partial grant of summary judgment on the issue of liability in the false arrest claim; whether plaintiff made a Rule 50(a) motion is moot because they failed to preserve the issue by making a post-judgment Rule 50(b) motion; and the district court did not abuse its consideration discretion in denying plaintiffs' motion for a new trial. Accordingly, the court affirmed the judgment of the district court. View "Hoffmeyer, et al. v. Porter, et al." on Justia Law

MHFS filed suit against the County, the Commission, and others for interfering with its business operations at the Baxter County Airport. The court concluded that the district court did not err in dismissing MHFS's claims for breach of contract where MHFS did not allege any breach of contract distinct from the breach of the duty to act in good faith; Arkansas law does not recognize a "continuing tort" theory; even if the court were to assume such acts were intentional, MHFS failed to state a claim for intentional interference with its business relationship; the district court correctly dismissed MHFS's civil rights claims for denial of procedural due process where MHFS was not deprived of any property or liberty interest; the district court did not abuse its discretion by declining to exercise supplemental jurisdiction over state law claims; and the district court did not abuse its discretion in denying the motion to amend following its dismissal of the action. Accordingly, the court affirmed the judgment of the district court. View "Mountain Home Flight Service v. Baxter County, et al." on Justia Law

Plaintiff filed suit against the officer who restrained him while executing a search warrant. Even assuming without deciding that the officer recklessly disregarded the misleading effect that omitting the facts at issue would have on the judge's probable cause determination, the officer was still entitled to qualified immunity. The court agreed with the district court that the evidence submitted to the judge would have been sufficient to support a probable cause finding even if the officer's oral affidavit had included the omitted facts. Accordingly, the court affirmed the district court's grant of summary judgment to the officer. View "Block v. Dupic" on Justia Law

Plaintiff, trustee for the heirs and next of kin of Erik Kirk Kolski, filed suit against the City and police officers, alleging that defendants violated Kolski's constitutional rights when the officers used deadly force against Kolski during a response to a domestic disturbance with a weapon. The court affirmed the district court's grant of summary judgment on the basis of qualified immunity to Officers Glirbas and Cudd where the use of deadly force was constitutionally permissible because Kolski made threats and possessed a firearm. The court also affirmed the district court's grant of summary judgment to Officers Glirbas and Cudd on the state-law claims on the basis of official immunity where plaintiff identified no evidence showing that the officers intentionally committed an act that they had reason to believe was prohibited and, instead, the evidence demonstrated that they acted reasonably in response to a significant threat of death or physical injury. View "Smith v. City of Brooklyn Park, et al." on Justia Law

Plaintiff filed suit against the State for violating section 102(a) of the Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a), and against Judge Gaertner, under 42 U.S.C. 1983, for retaliating against her for exercising her First Amendment right to free speech. The court concluded that plaintiff was not an eligible employee covered by the FMLA because she was a member of the personal staff of the judge, who held a public elective office; although plaintiff's blog posts and other speech discussed her own case in detail, the district court correctly concluded that plaintiff's speech related to a matter of public concern; plaintiff's actions were sufficient evidence of disruption; plaintiff did not cite clearly established law putting the judge on notice that Pickering balancing in a situation such as this would fall in plaintiff's favor, nor did the court identify any such case law; and the district court correctly determined that the judge was entitled to qualified immunity on plaintiff's section 1983 claim where the judge did not have notice that his termination of an insubordinate employee who compromised the propriety and efficiency of his courtroom could violate her right to free speech. Accordingly, the court affirmed the judgment of the district court. View "Hemminghaus v. State of Missouri, et al." on Justia Law

The EEOC filed suit against Audrain, alleging that Audrain violated federal civil rights statutes by refusing to consider David Lunceford to a vacant operating room nurse position on the basis of his sex. The district court concluded that Lunceford did not suffer an adverse employment decision because he never completed a Request for Transfer form so Audrain never made a decision to deny him the position. In light of the evidence, the court concluded that Lunceford did not make every reasonable attempt to convey his interest in the position and the district court did not err in concluding that the EEOC did not establish a claim of employment discrimination. Accordingly, the court affirmed the judgment of the district court. View "EEOC v. Audrain Health Care, Inc." on Justia Law