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

Plaintiff sued Judge Larry Williams for wrongful termination, in violation of plaintiff's rights under the First Amendment and the Family Medical leave Act (FMLA), 29 U.S.C. 2601, et seq. Plaintiff appealed the district court's grant of summary judgment in favor of Williams. The court held that a genuine issue of material fact existed as to whether Williams terminated plaintiff's employment because of the letter plaintiff wrote to the editor of a local paper in 2007 regarding the judge's financial committee. The court also held that the district court properly granted summary judgment in favor of Williams in his individual capacity on plaintiff's FMLA claims where plaintiff failed to argue how Williams personally received adequate notice and, given the undisputed record that Williams generally delegated the operation of the Road Department to others. Therefore, the court held that the district court erred in granting summary judgment against plaintiff on his First Amendment claims; erred in granting summary judgment against plaintiff on his official-capacity claims under the FMLA; but properly granted summary judgment against plaintiff on his individual-capacity FMLA claims against Williams.

Appellant filed suit against her former employer, alleging that it wrongfully denied (or delayed) her promotion and subsequently, wrongfully terminated her. Appellant challenged four of the district court's interlocutory orders, contended that the district court erred by awarding costs to the employer, and asserted that the district court erroneously dismissed some of her claims and erroneously granted summary judgment to the employer on her remaining claims. The court held that the district court did not abuse its discretion where it repeatedly attempted to accommodate appellant despite her attorney's repeated failures to comply with court orders and court-imposed deadlines. The court also held that appellant had not shown that the district court abused its discretion by awarding costs to the employer. The court further held that the district court did not err by dismissing appellant's duplicative claims and affirmed the district court's dismissal of her claim under the Ledbetter Act, which she attempted to add without permission from the employer or leave from the court. The court finally held that the district court did not err in granting summary judgment to the hostile work environment claim and the Family Medical Leave Act, 29 U.S.C. 2615, claims. Accordingly, the court affirmed the judgment of the district court.

The Minnesota Law Enforcement Association (MLEA) appealed the district court's grant of summary judgment to the Equal Employment Opportunity Commission (EEOC), concluding as a matter of law that the MLEA's retirement plan arbitrarily discriminated against older employees on the basis of age, in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623. The court held that this exclusively age-based reduction in benefits typified "arbitrary age discrimination" and therefore failed to meet the ADEA's safe harbor requirements. The court also held that, although the Department of Corrections was not obligated under federal law to employ certain persons over the age of 55 for reasons that could include age, it could not discriminate against all persons over age 55 solely due to their age. Therefore, the court affirmed the district court's grant of summary judgment.

Appellant appealed the denial of her application for Social Security Administration (SSA) disability benefits where the ALJ concluded that she retained the ability to perform her past relevant work and was therefore not disabled. The court held that the ALJ was not required to give controlling weight to the opinions of appellant's treating physician. The court also held that because there was substantial evidence in the record to support the ALJ's findings, the court declined to disturb the ALJ's decision on the ground that the ALJ failed to comply with the SSA Commissioner's policies in evaluating the severity of appellant's fibromyalgia and that the ALJ failed to give adequate weight to appellant's statements and the statements of her family and friends. The court further held that the ALJ's hypothetical to the vocational expert was proper and there was no evidence in this case to support a finding that bias impacted the ALJ's decision. Accordingly, the Commissioner's final decision to deny appellant's application for benefits was affirmed.

Appellant appealed the district court's order, which affirmed the decision of the Commissioner of the Social Security Administration (Commissioner), denying appellant's application for disability benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. 401 et seq. At issue was whether the ALJ committed legal error by failing to correctly apply the requisite five-step sequential evaluation process. The court held that the ALJ's failure to follow the mandated procedure was more than a mere oversight in opinion writing and that the ALJ was required to follow one of two paths at step five of the sequential process and there was no record indicating that the ALJ followed either path. Accordingly, the court reversed the district court's order affirming the Commissioner's decision and instructed the district court to remand the case to the Commissioner for further proceedings.

Appellant filed suit against the Fayetteville, Arkansas School District (District) alleging he was a victim of sexual harassment in violation of Title IX, 20 U.S.C. 1681. At issue was whether the district court erroneously instructed the jury and further erred in empaneling a twelve-member jury as oppose to a six-member jury. The court held that the district court did not abuse its discretion because the instruction provided by the district court accurately portrayed the law underlying appellant's Title IX claim where the "harasser must be motivated by [appellant's] gender or his failure to conform to stereotypical male characteristics" and because appellant was not entitled to an instruction on his theory of the case since it did not comport with the law where mere name-calling and rumors with sexual connotations were insufficient to provide relief under Title IX. The court also held that appellant's argument regarding the district court's error in empaneling a twelve-member jury had no merit where the district court had discretion to select "at least 6 and no more than 12 members" for a jury. Accordingly, the judgment was affirmed.

Appellant alleged that he was disabled as a result of Post Traumatic Stress Disorder, Parkinson's disease, Attention Deficit Disorder, and peripheral neuropathy and that these mental and physical limitations he had as a result of these conditions, combined with his advanced age and limited job skills, rendered him unable to perform any work available in the national economy. Appellant challenged the district court's affirmance of the Social Security Administration's (SSA) denial of his claim for disability benefits. The court affirmed the judgment and held that the ALJ's findings were supported by substantial evidence.

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

This case arose when Pauline Thomas brought her daughter, Jane Doe and four of her grandchildren, including John Doe and R.N.T. to the Emergency Room at the Hennepin County Medical Center and reported her concerns that Jane Doe might have been sexually abused by R.N.T. Appellants brought suit against appellees claiming that the 72-hour hold placed on John Doe, the internal examination of Jane Doe, and the examination of John Doe violated the children's rights under the Fourth Amendment and that the seizure and search of both children violated the Fourteenth Amendment rights of all appellants. At issue was whether the district court properly granted summary judgment in favor of appellees and denied appellants' motion for partial summary judgment on their claims under 42 U.S.C. 1983. The court rejected appellants' contention that appellees failed to move for summary judgment on all of appellants' claims; that the district court ignored questions of material fact; and that the district court at times used the wrong legal standards when analyzing the facts. The court also held that because it affirmed the district court's adverse grant of summary judgment against appellants, the court did not reach the denial of appellants' partial motion for summary judgment.

D.J.M., a student in the Hannibal Public School District #60 (district), sent instant messages from his home to a classmate in which he talked about getting a gun and shooting some other students at school. After D.J.M. was subsequently suspended for ten days and later for the remainder of the school year as a result of his actions, D.J.M.'s parents sued under 42 U.S.C. 1983, alleging that the district violated D.J.M.'s First Amendment rights. At issue was whether the district court properly granted summary judgment to the district on D.J.M.'s constitutional claims and remanded his state claim for administrative review. The court held that D.J.M. intentionally communicated his threats to a third party and the district court did not err in finding that they were true threats. The court also held that true threats were not protected under the First Amendment and the district was given enough information that it reasonably feared D.J.M. had access to a handgun and was thinking about shooting specific classmates at the high school. Therefore, in light of the district's obligation to ensure the safety of its students and reasonable concerns created by shooting deaths at other schools, the district court did not err in concluding that the district did not violate the First Amendment by notifying the police and subsequently suspending him after he was placed in juvenile detention. The court further held that it was reasonably foreseeable that D.J.M.'s threats would be brought to the attention of school authorities and created a risk of substantial disruption within the school environment. The court finally held that it was not an abuse of discretion to dismiss the state law claim as moot. Accordingly, the judgment of the court was affirmed.