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

Plaintiff sued his former employer for alleged violations of state and federal discrimination claims after he was terminated by the former employer when he was 57-years-old. The district court granted summary judgment in favor of the former employer on plaintiff's federal claim under the Age Discrimination in Employment Act ("ADEA"), 29 U.S.C. 623 (a)(1), but the court remanded and instructed the district court to dismiss without prejudice plaintiff's claim under the Missouri Human Rights Act ("MHRA"), Mo. Ann. Stat. 213.055(1). Plaintiff petitioned for a panel or en banc rehearing to have the court's disposition of the MHRA claim reconsidered where diversity of citizenship jurisdiction existed over plaintiff's MHRA claim. At issue was whether the district court erred in granting summary judgment in favor of the former employer on plaintiff's MHRA claim. The court agreed that diversity of citizenship jurisprudence existed over plaintiff's claim which required it to revisit its prior disposition and granted the former employer's petition for a panel rehearing. The court also held that the district court erred in granting summary judgment where it would not be unreasonable for a jury to conclude that plaintiff's age played a part in producing the adverse employment actions he alleged.

Plaintiff sued the City of Little Rock under Title II of the Americans with Disabilities Act ("ADA"), 42 U.S.C. 12133, and the Rehabilitation Act of 1973 ("Rehabilitation Act"), 29 U.S.C. 794a(a)(2), when she was injured at the Little Rock Zoo where her rental scooter tipped over on an incline. At issue was whether plaintiffs may recover compensatory damages under the ADA and the Rehabilitation Act without showing a "heightened standard" of intentional discrimination. Also at issue was whether the rental fee charged by the zoo for the scooter was an impermissible surcharge under applicable ADA regulations. Further at issue was whether the district court erred in concluding that plaintiff lacked standing to challenge the zoo's liability waiver imposed after her accident. The court affirmed the judgment and held that plaintiff was not entitled to recover compensatory damages where she failed to show intentional discrimination through proof of deliberate indifference or otherwise. The court also held that the surcharge was not illegal where the zoo was not "required" to provide scooters to disabled visitors. The court further held that plaintiff lacked standing to challenge the waiver of tort liability the zoo enacted after her injury where she failed to show an adequate injury in fact.

Appellant filed suit against the United States Department of Health and Human Services ("Department") alleging, inter alia, that the Department violated her rights under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000, when the administrative officer and acting chief executive officer ("CEO") of the medical clinic operated by the Department began making sexually suggestive comments to her, called her at home while intoxicated, and appeared unannounced at her home on different occasions including one instance where she came home to find him sleeping naked in her bed. At issue was whether the district court erred in its findings. The court affirmed and held that appellant's claims for misconduct that occurred before June 18, 2005 were barred where she failed to report the incidents within 45 days of their occurrence, instead of a year later, and denied her claims for equitable tolling. The court also held that the CEO's alleged rumor-spreading was not harassment so severe or pervasive that it met the high threshold for a hostile work environment and that this single act of discriminatory conduct was insufficient to establish a hostile work environment or constructive discharge claim. The court further held that appellant failed to prove that she suffered an adverse employment action and was treated differently than similarly situated males where neither party disputed that the Department never terminated her, cut her pay or benefits, or changed her job duties or responsibilities. Therefore, appellant's retaliation claim necessarily failed where she did not demonstrate that the Department took a materially adverse action against her.

Appellee, a 21 year-old paraplegic with several serious medical conditions, sued the director of the Olmstead County Adult Detention Center ("ADC") where he was incarcerated, alleging constitutional violations under the Eighth Amendment, Monell v. Department of Social Services, and the Americans with Disabilities Act. The director appealed the district court's judgment and award of punitive damages to appellee. The court held that there was ample evidence to support the district court's findings of fact where the ADC could not accommodate appellee's known medical needs; the director knew the ADC could not accommodate appellee's known medical needs; the director misrepresented the ability of the ADC to care for appellee's needs to a judge; and the director failed to take adequate steps to provide appellee medically-necessary care or have him removed from the full-time medical care of the ADC. The court also held that the district court did not clearly err by finding that the director's deliberate indifference caused injury to appellee. The court further held that there was sufficient evidentiary basis for the district court to find that the director's behavior called for an award of punitive damages and that the district court adequately explained the appropriateness of the punitive damages.

Appellants, a child with a learning disability and his parents, sued the Special School District No. 1 ("School District") in Minneapolis, Minnesota alleging that the School District violated his rights under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, by denying him a free appropriate public education. At issue was whether the district court properly granted summary judgment in favor of the School District when it determined that the parents were not entitled to reimbursement from the School District for one year of private tuition when they transferred the child to a private education institution ("institution"). The court reversed the district court's decision and held that appellants were not precluded from reimbursement for tuition for the 2008-2009 academic year where the institution was a proper placement for the child and where the institution did not need to satisfy the least-restrictive environment requirement to be "proper" under the IDEA.