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

Appellant filed a lawsuit, after she was terminated from her position as a clerk-typist at Iowa State University (University), claiming that those responsible for the termination violated her rights under federal statutes, the Due Process and Equal Protection Clauses of the Fourteenth Amendment, and Iowa law. The district court dismissed her complaint in its entirety and denied a motion to alter or amend the judgment. Appellant appealed the dismissal of her due process claim, the denial of her post-judgment motion, and the dismissal of the state-law claims. The court affirmed the dismissal of appellant's "freestanding" due process claim for failure to state a claim on which relief could be granted. The court also held that the district court did not abuse its discretion by denying appellant's post-judgment motion. The court held, however, that the state law claim against the president of the University and appellant's supervisor, in their individual capacities, must be remanded for further proceedings because the court had no basis to say how the district court would have exercised its discretion under 28 U.S.C. 1367 if the district court believed that it had authority to do so. Accordingly, the judgment of the district court was affirmed in part and denied in part.

After the city did not hire appellant for a position with the Minneapolis Police Department, appellant, who was born in Afghanistan, filed suit alleging that the city discriminated against him based on his race, color, and national origin in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. At issue was whether the district court properly granted summary judgment in favor of the city. The court held that the city had articulated a legitimate, nondiscriminatory reason for its decision not to hire appellant because it had serious concerns about his temperament. The court also held that appellant failed to meet his burden of providing sufficient evidence to create a genuine dispute of material fact that the city's proffered reason was mere pretext for discrimination. Accordingly, the judgment of the district court was affirmed.

Appellant appealed the district court's adverse grant of summary judgment in her employment discrimination action against UPS, brought pursuant to 42 U.S.C. 1981 and Title VII of the Civil Rights Act, 42 U.S.C. 2000e. Defendant initiated two actions: the first challenging the promotion decisions in 2004 and 2005 and the second claiming that appellant's manager retaliated against her in 2007 and gave her a failing score on the initial assessment for the promotion. The court held that appellant failed to carry her burden of showing a prima facie case of race or sex discrimination based on UPS's promotions of Virginia Fry, a white female, and Christopher Lee, a white male, and therefore, the district court properly granted summary judgment on appellant's claims with respect to the 2004 promotion decisions. The court also held that the district court properly granted summary judgment on claims arising from UPS's 2005 promotion decisions where the continuing violation doctrine was not applicable to failure-to-promote claims which arose from discrete employment actions and where appellant failed to allege a claim concerning the promotion of the two white male employees in 2005 and that she was similarly situated to them. The court further held that the district court properly determined that appellant failed to make a prima facie showing of retaliation and even if appellant had presented a prima facie case, UPS proffered legitimate, non-discriminatory reasons for why she received a failing score on her initial assessment, which she failed to rebut. The court finally held that appellant failed to offer any argument as to why the district court's striking of the statement for noncompliance with the local rule was error and therefore, there was no abuse of discretion.

Plaintiff sued defendant alleging that defendant retaliated against him for seeking accommodation for a disabled subordinate contrary to the Iowa Civil Rights Act, Iowa Code 216.6 & 216.11. At issue was whether a jury should decide whether an intermediate supervisor's retaliatory animus was a proximate cause of the plant manager's decision to fire plaintiff. The court held that plaintiff failed to create a genuine dispute for trial as to whether retaliatory animus was the proximate cause of his termination and therefore, the district court did not err in granting defendant's motion for summary judgment on the issue.

Appellants, on behalf of their disabled daughter, appealed the district court's finding that the Fort Osage R-1 School District ("school district") offered the daughter a free appropriate public education ("FAPE") within the meaning of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, et seq., for the 2006-2007 school year. Appellants sought reimbursement for their costs of placing their daughter at a private facility during the school year. The court held that the district court did not err in concluding that the school district offered the daughter a FAPE and that the Individualized Education Plan put forward by the school district did not suffer from any procedural error. Accordingly, the court affirmed the judgment of the district court.

Appellant appealed from the district court's grant of summary judgment in favor of his former employer on his claims of race discrimination, hostile work environment, and termination as a result of retaliation in violation of Title VII of the Civil Rights Act of 1964, 41 U.S.C. 2000e-2000e-17, and the Minnesota Human Rights Act, Minn. Stat. 363A.15 ("MHRA"). The court held that the district court correctly determined that the former employer was entitled to summary judgment on the harassment/hostile work environment claim where appellant failed to establish the threshold of actionable harm necessary to constitute a hostile work environment. The court also held that the district court correctly granted summary judgment on appellant's claims that he was fired on the basis of his race, and treated less favorably than similarly-situated white employees on the job where appellant presented no direct evidence that his termination or alleged lack of training or job change opportunities were racially motivated. The court held, however, that the district court erred in granting summary judgment on appellant's retaliation claims where he had produced sufficient evidence of retaliation.

Plaintiffs sued defendant, their former employer, for age discrimination in violation of the Age Discrimination in Employment Act ("ADEA"), 29 U.S.C. 623(a), and the Minnesota Human Rights Act ("MHRA"), Chapter 363A. At issue was whether the district court properly granted summary judgment for defendant. The court affirmed summary judgment and held that defendant articulated legitimate non-discriminatory grounds for plaintiffs' terminations and plaintiffs failed to show that the reasons were pretexts for age discrimination because defendant maintained a consistent explanation for the termination-shifting client needs and an anticipated reduction in workload and profitability.

Plaintiff received disability insurance benefits under the Social Security Act 42 U.S.C. 301 et seq., between September 1994 and March 2004. After an investigation, the Social Security Administration ("SSA") notified plaintiff that she was ineligible for disability benefits because her employment income had exceeded SSA limits and determined that she was required to repay more than $60,000 in over paid benefits. At issue was whether the district court properly entered judgment for the SSA and denied plaintiff's waiver of over payment recovery and affirmed the ALJ's conclusion that it lacked authority to consider plaintiff's new argument contesting the amount of the overpayment itself. The court held that plaintiff failed to meet the administrative exhaustion requirement because she did not timely challenge her overpayment. Accordingly, since no final decision was made, the district court lacked jurisdiction under 42 U.S.C. 405(g) to consider plaintiff's challenge to the overpayment. The court also held that plaintiff was not entitled to a waiver of overpayment recovery because substantial evidence showed that she was not without fault in causing the overpayment and that the ALJ properly found that plaintiff knew or should have known that her work information was material because of her agreement to report such work in her benefit applications. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued defendants, including the police officer that shot him, alleging violations of 42 U.S.C. 1983 and various state law theories. At issue was whether the district court erred by denying the officer's motion for summary judgment on plaintiff's section 1983 claim, concluding that the facts established a violation of the Fourth Amendment and that the law was clearly established at the time of the shooting. The court concluded that it was not clearly established as of the time of the shooting that an officer in Missouri could effect a seizure under the Fourth Amendment without subjectively intending to do so. Therefore, the district court erred in denying the officer's motion for summary judgment on plaintiff's Fourth Amendment claim without considering the officer's subjective intent. Accordingly, the court vacated the section 1983 claim and remanded for further proceedings regarding the officer's subjective intent.

Plaintiff sued defendant under the Minnesota Human Rights Act ("MHRA"), Chapter 363A, alleging that defendant terminated her and took other adverse employment actions against her because she made complaints of discrimination. At issue was whether the district court properly granted summary judgment in favor of defendant on plaintiff's retaliation claims. The court affirmed summary judgment and held that plaintiff failed to create a triable issue of fact regarding whether defendant retaliated against her for reporting alleged discrimination where defendant articulated a non-discriminatory ground for plaintiff's termination, violation of a work rule, in which plaintiff failed to show pretext for retaliation.