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

Planned Parenthood brought suit against various state officials in Nebraska challenging new requirements to the State's informed consent procedures for abortions. At issue was the district court's denial of NuLife's motions to intervene. The court affirmed the district court's denial of NuLife's motions to intervene as untimely and did not reach the alternative bases relied upon by the district court to deny the motions.

This case arose when defendant denied plaintiff's application for Medicaid benefits on the grounds that she had transferred property in 2005-2006 valued at $340,000. The district court subsequently dismissed plaintiff's 42 U.S.C. 1983 claim against defendants based on the abstention doctrine set forth in Younger v. Harris. Plaintiff appealed, contending that the district court should not have abstained from hearing her claim. Because, under Alleghany Corp. v. McCartney, abstention was appropriate in administrative proceedings like plaintiff's, the court held that the district court did not err in abstaining.

A police sergeant arrested plaintiff without a warrant for running a contest which allegedly violated Minnesota gambling laws. The sergeant later obtained a search warrant and seized several items from the house where plaintiff was running the contest. A reporter broadcasted a news story about the contest and plaintiff's arrest on a local CBS television station. Plaintiff subsequently sued the sergeant and the city of Minneapolis under 42 U.S.C. 1983 for civil rights violations for the arrest and search, and the reporter and CBS for defamation. Both sides moved for summary judgment and the district court granted the motion for defendants. The court held that because plaintiff failed to demonstrate that any of the sergeant's actions violated a constitutional right, he could not deprive the sergeant of qualified immunity, and thus summary judgment was appropriate. Summary judgment was also proper as to the city because municipalities could not be held liable under Section 1983 where plaintiff had not argued on appeal that any municipal policy or custom led to a deprivation of his constitutional rights. The court also held that plaintiff was a limited purpose public figure and it was not reckless disregard for the truth to conclude that plaintiff could face future incarceration related to the contests. The court further held that the district court did not abuse its substantial discretion in denying plaintiff's motion for spoliation sanctions. Accordingly, the judgment of the district court was affirmed.

Plaintiff appealed the district court's adverse grant of summary judgment on his 42 U.S.C. 1983 claim against several prison officials. Plaintiff, a pretrial detainee, was assaulted by three other inmates while he awaited trial. The court held that the evidence presented was insufficient to show that the prison officials knew or disregarded a known risk where plaintiff offered no evidence that the prison officials had any knowledge of any specified danger posed to plaintiff by another inmate in the protective custody pod. The court also held that plaintiff failed to offer evidence that prison officials provided constitutionally inadequate medical treatment. Accordingly, the judgment was affirmed.

Plaintiff filed suit pursuant to 42 U.S.C. 1983, alleging, inter alia, that his approximately 14-year detention in administrative segregation (Ad. Seg.) violated his procedural due-process rights under the Fourteenth Amendment because the periodic reviews of his detention were not meaningful. The district court subsequently found that four of the five defendants had in fact denied plaintiff due process by conducting meaningless Ad. Seg. review hearings and consequently, awarded him $4,846 in nominal damages - $1 for every day that plaintiff lived in Ag. Seg. - but denied plaintiff prayer for punitive damages. Both parties appealed. The court held that the district court did not clearly err in its factual findings as to the meaningfulness of plaintiff's Ad. Seg. reviews and affirmed that portion of the district court's decision. The court also held that plaintiff was entitled to no more than $1 for each procedurally defective Classification Committee hearing. Thus, based on this "per-constitutional-violation" analysis, the court reversed the district court's nominal damages award and remanded for recalculation. The court further held that it could not conclude that the district court abused its discretion on the record and affirmed the district court's denial of compensatory damages. The court finally held that the district court did not err in refusing to award plaintiff punitive damages.

Several Nebraska farmers filed suit under 42 U.S.C. 1983, alleging their due process rights were violated when Nebraska officials ordered the farmers to cease drawing water from the Niobrara Watershed without providing a predeprivation hearing. The court agreed with the district court that the farmers have not suffered a deprivation of their property rights where the property right held by the farmers was expressly conditioned on the Nebraska Department of Natural Resources' (DNR) determination of watershed capacity. Therefore, the farmers had no legitimate claim to the water when the DNR determined that there was a scarcity and the issuance of Closing Notices was necessary to satisfy the needs of senior appropriators. The court also held that the district court was permitted to dismiss without prejudice the pendent state-law ultra vires claim in light of its grant of summary judgment on the section 1983 claim.

Plaintiff brought a 42 U.S.C. 1983 action against the city and the police chief (defendants) alleging that they (1) deprived him of his property, namely a handgun and its ammunition, without due process of law, in violation of the Fifth and Fourteenth Amendment; and (2) through the same conduct, violated his right to keep and bear arms under the Second Amendment. The court held that the district court erred in granting defendants's motion for summary judgment on plaintiff's due process claim. The court held, however, that the district court did not err in concluding that plaintiff's Second Amendment claim failed as a matter of law.

Plaintiff brought this action to enjoin the enforcement of the Nebraska Funeral Picketing Law (NFPL), arguing that it violated her First Amendment right to free speech. Plaintiff appealed a district court order denying her motion for a preliminary injunction. The court concluded that the district court correctly applied intermediate scrutiny. The court agreed that the district court was required to follow the court's precedent, which concluded that the government was unlikely to prove a significant interest in protecting funeral attendees. Therefore, the court held that because it was bound by the previous panel decision involving a similar statute, the same procedural posture on appeal, and the identical plaintiff, the court reversed the order denying a preliminary injunction and remanded.

Plaintiff, an Arkansas inmate, brought a 42 U.S.C. 1983 action against several defendants, including the jail administrator of Ouachita County Detention Center. After granting summary judgment to all defendants except the administrator, the district court addressed plaintiff's claim against the administrator on the merits and concluded that the administrator's use of force was necessary to ensure his own safety, the safety of others, and to regain control of the facility. Therefore, the district court dismissed plaintiff's claim with prejudice and plaintiff subsequently appealed. The court held that plaintiff failed to show by a preponderance of the evidence that he was a victim of an unconstitutional excessive use of force; the district court correctly determined that the administrator's twice shoving of plaintiff toward the wall was reasonable in light of the emergent and unsafe circumstances; and a thorough reading of the district court's decision assured the court that the district court did not enforce a minimum level of injury as a legal threshold barring plaintiff's claim. Accordingly, the court affirmed the judgment of the district court.

Appellants, the Libertarian party and three candidates, challenged the constitutionality of North Dakota Century Code 16.1-11-36, contending that the statute as applied to them violated the First and Fourteenth Amendment and the Equal Protection Clause because it prevented appellants' names from appearing on the 2010 general election ballot despite their winning the party's primary. The court held that the burden imposed by the statute was not undue or excessive and the state had a compelling interest in having a minimum vote requirement before a candidate could appear on the general election ballot. Therefore, the court held that N.D.C.C. 16.1-11-36 was not unconstitutional on First or Fourteenth Amendment grounds. Furthermore, because the law applied equally to all candidates and did not result in unequal treatment, the court held that the statute did not violate the Equal Protection Clause. Accordingly, the court affirmed the district court.