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

After being employed by the City of St. Louis as a corrections officer for over two decades, the plaintiff was transferred to a clerk typist position in the City’s towing division following an injury. In her new role, she uncovered and reported numerous instances of apparent misconduct and fraud involving the unlawful sale or transfer of vehicles by employees at the tow lot. She conveyed her concerns to various city officials, including her supervisors, the mayor’s office, and the comptroller’s office, and ultimately disclosed the information to the media. Following these disclosures, she experienced workplace retaliation and was ultimately terminated by the Director of the Department of Streets the day after a news story, which included information she had provided, was broadcast.The United States District Court for the Eastern District of Missouri dismissed the First Amendment claim against the City but allowed the First Amendment retaliation claim against the Director, in his individual capacity, to proceed to trial. The jury found in favor of the plaintiff, concluding that her protected speech was a motivating factor in her termination, and awarded compensatory and punitive damages. The district court denied the Director’s post-trial motions for judgment as a matter of law and for a new trial.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the Director failed to preserve his qualified immunity defense for appeal and found that there was sufficient evidence for the jury to find that the plaintiff’s protected speech motivated her termination. The court further determined that the district court did not abuse its discretion in admitting contested evidence or in denying a new trial, and that there was enough evidence for punitive damages. The Eighth Circuit affirmed the district court’s judgment. View "Woods v. City of St. Louis, Missouri" on Justia Law

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain.The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law

During unrest following the death of George Floyd in May 2020, a large crowd gathered outside the Minneapolis Police Department’s Fifth Precinct after a citywide curfew had been imposed due to ongoing violence and destruction. Raven Bartz joined the crowd, which she characterized as peaceful, though widespread chaos and threats to public safety were documented that night. As police attempted to clear the area, officers deployed various crowd-control measures. Bartz was struck in the head by a projectile fired from a less-lethal launcher by Officer Conan Hickey while fleeing after a blast ball was thrown. She sustained a laceration requiring staples but was released from the hospital without a concussion diagnosis.Bartz filed suit in the United States District Court for the District of Minnesota against Officer Hickey and the City of Minneapolis, alleging excessive force in violation of the Fourth Amendment, a Monell claim alleging unconstitutional policies or customs, and a state law battery claim. The district court granted summary judgment to the defendants on the federal claims, finding that even assuming a seizure occurred, Officer Hickey’s actions were reasonable in light of the chaotic and dangerous circumstances. The court found that qualified immunity applied and dismissed the Monell claim for lack of an underlying constitutional violation. It declined to exercise supplemental jurisdiction over the state law claim.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of circumstances—including the violence, curfew violations, and threats faced by officers—Officer Hickey’s use of force was objectively reasonable and did not violate the Fourth Amendment. Without a constitutional violation, the Monell claim failed. The appellate court also found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state law claim. Accordingly, the judgment was affirmed. View "Bartz v. City of Minneapolis" on Justia Law

During the summer of 2021, protests occurred at a pipeline construction site in northern Minnesota. On the evening in question, protesters, including Joshua Hollamon, attempted to disrupt operations by locking themselves to a vehicle at the entrance and then trying to breach the security fences surrounding the site. The construction site was protected by two fences topped with barbed wire and marked with “No Trespassing” signs, separated by a berm. As protesters, including Hollamon, climbed the outer fence despite warnings from officers, Sergeant Dustin Miller fired pepperballs at them. Hollamon alleges he was struck multiple times, including on the head. Despite the use of force, Hollamon and the group continued their attempts to breach the inner fence, and he was eventually arrested and charged with trespassing and obstructing the legal process.The United States District Court for the District of Minnesota granted summary judgment in favor of Sergeant Miller and the County of Wright on Hollamon’s 42 U.S.C. § 1983 claim, concluding that there was no constitutional violation, or, alternatively, that Sergeant Miller was entitled to qualified immunity. The court also declined to exercise supplemental jurisdiction over state law claims. Hollamon appealed, arguing the use of pepperballs constituted excessive force under the Fourth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. Assuming without deciding that a seizure occurred, the appellate court held that Sergeant Miller’s use of force was objectively reasonable under the totality of the circumstances, given the protesters’ active trespass, refusal to comply with officer commands, and intent to disrupt the site. The court rejected the argument that the use of pepperballs rose to the level of deadly force and distinguished this case from others involving compliant individuals. The Eighth Circuit affirmed the district court’s judgment. View "Hollamon v. County of Wright" on Justia Law

During the COVID-19 pandemic, a county employer required its employees to either be fully vaccinated or undergo weekly COVID-19 testing. Employees could test at county facilities during work hours or use at-home test kits and count that time as work. Two employees objected to these requirements on religious grounds. One employee, Borgheiinck, asserted that mandatory vaccines and testing conflicted with her Christian beliefs about bodily autonomy. She was initially given unpaid leave as an accommodation, but the county later revoked this, citing undue hardship, and ultimately terminated her after not responding to her proposals for alternative work arrangements. The other employee, Colson, also objected on religious grounds. She was granted an exemption from nasal swab testing and allowed to use saliva tests, which she found intrusive and non-private, but she was not terminated.The United States District Court for the District of Minnesota dismissed all claims, including those under Title VII. The plaintiffs sought leave to file a motion for reconsideration based on new legal precedent, but the court denied this request. The plaintiffs appealed the dismissal of their Title VII claims and the denial of reconsideration.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. It held that Borgheiinck’s complaint did not sufficiently connect her religious beliefs to an objection to the testing policy, as required to state a plausible claim under Title VII. For Colson, the court held that she had not plausibly alleged that she suffered any adverse employment action, such as termination or unpaid testing time, since the county’s policy allowed testing during compensated time. The Eighth Circuit affirmed the district court’s dismissal of the Title VII claims and its denial of leave to seek reconsideration. View "Colson v. Hennepin County" on Justia Law

After protests in Des Moines, Iowa, escalated into rioting and looting at a mall in late May 2020, law enforcement was deployed to restore order and clear the area. A special police team, including Deputy Jason Tart, was authorized to use less-lethal munitions such as impact rounds. Monica Perkins, who had attended a vigil elsewhere, arrived near the mall area with her daughter. After an argument between Perkins and another driver on a nearby road, Deputy Tart fired an impact round that struck Perkins in her hand, injuring her. Perkins sued the City, various police officials, and Deputy Tart, alleging constitutional violations including excessive force and failure to intervene.The United States District Court for the Southern District of Iowa granted summary judgment to all defendants on every claim. The district court found that Perkins was not “seized” within the meaning of the Fourth Amendment, and even if she had been, Deputy Tart was entitled to qualified immunity. The court also held that Deputy Tart’s conduct did not amount to a substantive due process violation and that, because there was no underlying constitutional violation, the failure-to-intervene claim against other officers could not stand.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit agreed with the district court, holding that Deputy Tart’s actions did not objectively manifest an intent to restrain Perkins and thus did not constitute a seizure under the Fourth Amendment. The court further found no evidence that Deputy Tart’s conduct was conscience-shocking under the Fourteenth Amendment and concluded he was entitled to qualified immunity. As a result, the failure-to-intervene claim against the other officers also failed. The Eighth Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Perkins v. City of Des Moines" on Justia Law

Police officers in Des Moines executed an arrest warrant for Tyrone Cameron, who was wanted for First-Degree Murder and had a history of violent crime. Officers surrounded a house where Cameron was hiding, and one officer brought a trained canine, Bero. When Cameron was spotted attempting to flee by jumping from the roof, Officer Meunsaveng released Bero without giving Cameron a warning. Bero caught Cameron, who did not resist further or reach for weapons as officers handcuffed him. After Cameron was secured, Officer Meunsaveng removed Bero. Cameron later sued the City of Des Moines, Officer Meunsaveng, and other officers, alleging excessive force under 42 U.S.C. § 1983 and related tort claims under Iowa law.The United States District Court for the Southern District of Iowa granted summary judgment to all defendants. It found that Officer Meunsaveng did not use excessive force and had not violated any clearly established rights. As a result, claims against other officers for failing to intervene, as well as claims against the police chief and the City for failure to train, were denied. The district court also dismissed Cameron’s common law tort claims, reasoning that the absence of excessive force under federal law meant those claims could not succeed.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Cameron raised a genuine dispute of material fact as to whether Officer Meunsaveng violated a clearly established right by failing to warn before releasing Bero. The court reversed summary judgment on this claim. On all other claims—including the use of Bero to hold Cameron and the method of removing Bero—the court affirmed summary judgment for the defendants. The court remanded the Iowa common law tort claims to the district court for further consideration. View "Cameron v. City of Des Moines" on Justia Law

The plaintiff, an inmate in an Arkansas correctional facility, was placed in isolation for approximately six weeks during the summer, in a cell lacking air conditioning. He claimed that, as a dialysis patient subject to fluid restrictions, exposure to excessive heat caused him significant discomfort and posed a risk to his health. Throughout his confinement, he submitted several grievances to prison officials, asserting that his medical condition required air-conditioned housing. Although medical staff and other personnel were consulted, no documented medical restriction indicated that air conditioning was medically necessary for him, and prison officials relied on a physician’s opinion that his situation did not constitute an emergency.After discovery, the plaintiff brought a civil rights action under 42 U.S.C. § 1983 against three prison officials, alleging cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The United States District Court for the Western District of Arkansas granted summary judgment in favor of the defendants, finding them entitled to qualified immunity. The plaintiff’s motion for reconsideration was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court assumed, for purposes of analysis, that the plaintiff’s medical condition presented an objectively serious risk. However, the court concluded that the record lacked evidence of deliberate indifference by the defendants: they consulted medical professionals, responded to grievances, implemented measures to mitigate heat, and treated the plaintiff’s medical complaints. Because the defendants did not violate a clearly established constitutional right, they were entitled to qualified immunity. The Eighth Circuit affirmed the district court’s judgment, holding that the prison officials were not deliberately indifferent to the plaintiff’s serious medical needs and did not subject him to cruel and unusual punishment. View "Hamilton v. Earl" on Justia Law

Donald Stephens was employed as an operator for United States Environmental Services, LLC, a position that required him to maintain a valid commercial driver's license (CDL). During a Saturday shift, Stephens refused to perform tasks typically assigned to technicians and raised several safety concerns, including inadequate equipment and staff. He also disclosed a heart condition to his supervisor. As a result, he was required to undergo a medical examination, which led to a 45-day medical hold on his CDL. Although he was medically cleared to perform non-driving work, USES denied his request for reassignment and recommended he seek short-term disability. After the hold was lifted and he was cleared to drive, Stephens resigned, claiming discomfort with his treatment by USES. Stephens filed suit in the United States District Court for the Eastern District of Arkansas, alleging disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act, as well as violations of the Fair Labor Standards Act (FLSA). The district court dismissed the FLSA claim and granted summary judgment to USES on the remaining claims. The court held that Stephens did not have a disability as defined by the ADA because his heart condition did not substantially limit a major life activity, and that USES did not regard him as disabled. The court also found that Stephens had not engaged in protected activity necessary to support a retaliation claim. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court affirmed the district court’s judgment, holding that Stephens did not demonstrate a substantial limitation of a major life activity and did not establish that he engaged in protected activity under the ADA. The Eighth Circuit also declined to consider an argument Stephens raised for the first time on appeal. View "Stephens v. U.S. Environmental Services LLC" on Justia Law

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law