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

Plaintiff worked at the University of Arkansas-Pulaski Technical College (“UAPTC”). In April 2018, Plaintiff requested and received leave under the Family and Medical Leave Act (“FMLA”) to care for her mother who had cancer. After being notified that her position would be eliminated in an upcoming reorganization she applied for a different position. The hiring committee led by Defendant interviewed Plaintiff and five other candidates. After the interview, the committee hired another applicant to whom Defendant had given a more favorable interview score.   Plaintiff sued the Board of Trustees of the University of Arkansas, members of the Board of the Trustees in their official capacities, the hiring committee director in his official and individual capacities, and UAPTC. Among other claims, she alleged that the hiring committee director violated the FMLA by discriminating and retaliating against her.   The district court denied the summary-judgment motion in relevant part, rejecting the hiring director’s qualified immunity defense on the ground that “qualified immunity is not available to defendants on an FMLA claim.” The Eighth Circuit remanded the case to the district court for consideration of the motion for summary judgment on the basis of qualified immunity. The court explained that the district court’s rejection of the hiring director’s qualified-immunity defense was based on a misreading of our statement in Darby v. Bratch. The court construed the statement in Darby about qualified immunity to mean that the FMLA clearly established the violative nature of the particular conduct in that case, not that qualified immunity can never be available on an FMLA claim. View "Rebecca Sterling v. Board of Trustees" on Justia Law

Plaintiff, a woman with severe autism, and her mother, filed an employment discrimination lawsuit against Menards. Plaintiff's mother, who was also a plaintiff in the suit, arranged to have a job coach help Plaintiff obtain employment. However, despite the coach being willing to help Plaintiff through her orientation, Menards did not allow the coach to be present. After orientation, Plaintiff signed an arbitration agreement without the opportunity to show it to her job coach. Ultimately, Plaintiff was terminated and filed this case.Menards moved to compel arbitration. The district court denied Menards' request, resulting in this appeal.On appeal, the Eighth Circuit held that the fact Plaintiff's mother was appointed as Plaintiff's conservator did not necessarily mean that Plaintiff lacked the ability to enter into the contract. However, the court held that the record was not sufficiently developed to determine whether the facially valid contract was revocable under the void contract defense. Thus, the Eighth Circuit vacated the district court's order denying the motion to compel arbitration, and remanded to the district court for further proceedings. View "Mary Triplet v. Menard, Inc." on Justia Law

Plaintiff was removed from a political rally and arrested for violating a St. Louis, Missouri ordinance that prohibits disturbing the peace. After Plaintiff was acquitted of that charge in state court, he brought claims against, as pertinent to this appeal, three St. Louis Metropolitan Police Department officers. The district court granted summary judgment in favor of the officers, and Plaintiff appealed.   The Eighth Circuit affirmed holding that it was objectively reasonable for the officers to mistakenly believe, under the totality of the circumstances that Plaintiff was engaged in acts or conduct inciting violence or intended to provoke others to violence. The court explained that two of the officers had arguable probable cause to arrest and then initiate prosecution against Plaintiff meaning that it was not clearly established that doing so would violate Plaintiff’s right to be free from unlawful seizure, malicious prosecution, or First Amendment retaliation. Thus, the court affirmed the district court’s grant of qualified immunity to those officers. Further, the court wrote that the district court properly granted qualified immunity to the remaining officer because it was not clearly established that initiating prosecution against Plaintiff would violate his Fourth Amendment right to be free from malicious prosecution or his corresponding right under Missouri law. View "Rodney Brown v. Matthew T. Boettigheimer" on Justia Law

College of the Ozarks, a private Christian college in Missouri, brought this action to challenge the lawfulness of a memorandum issued by an acting assistant secretary of the United States Department of Housing and Urban Development. The College moved for a temporary restraining order and preliminary injunction. The district court ruled that the College lacked standing to establish a case or controversy and dismissed the action for lack of jurisdiction. The College appealed and the Eighth Circuit affirmed.   The court explained that the College’s alleged injury is too speculative to establish Article III standing. The College, in effect, asked the court to assume that the following series of events is imminent: a sex-discrimination complaint will be filed against the College based on claims involving sexual orientation or gender identity; following an investigation, HUD will charge the College with sex discrimination, even though HUD has never enforced the Fair Housing Act’s sex-discrimination prohibition against a college whose housing policies have been exempted from the prohibition on sex discrimination under Title IX; HUD will determine, pursuant to the Memorandum, that the College is not entitled to an exemption under the Religious Freedom Restoration Act or the Free Exercise Clause as discussed in Bostock; and the College will therefore be subject to penalties. This is the kind of “highly attenuated chain of possibilities” that “does not satisfy the requirement that threatened injury must be certainly impending.” Further, the court explained that the complaint thus fails to allege either an actual chilling of speech or a credible threat of enforcement that justifies self-censorship. View "The School of the Ozarks, Inc. v. Joseph Biden, Jr." on Justia Law

Des Moines detectives arrested Plaintiff on her porch after she refused to comply with their requests to check on her daughter’s welfare. Plaintiff sued them under 42 U.S.C. Section 1983 and Iowa tort law. The district court granted summary judgment to Plaintiff on her Section 1983 claim and denied qualified immunity to the detectives.   Defendants appealed and the Eighth Circuit affirmed. The court explained state officials are entitled to qualified immunity in Section 1983 lawsuits unless they violated a federal “statutory or constitutional right that was clearly established at the time.”  Here, because the detectives did not have arguable probable cause to arrest Plaintiff for interference with official acts, and they likewise didn’t have arguable or actual probable cause to arrest her for another offense, her Fourth Amendment right to be free from warrantless arrests under these circumstances was clearly established. And because the detectives subjected Plaintiff to a warrantless arrest that was unsupported by probable cause, they violated her clearly established rights. The detectives are not entitled to qualified immunity. View "Trenisha Webster v. Jennifer Westlake" on Justia Law

This is the third appeal to the Eighth Circuit involving litigation arising from police response to protest activity in St. Louis on September 17, 2017. In this case, as in the others, Plaintiffs allege that St. Louis police officers boxed civilians into a downtown intersection in a maneuver characterized as a “kettle.” Some persons caught in this kettle allegedly were beaten, pepper sprayed, handcuffed with zip-ties, and arrested. The Eighth Circuit has issued two decisions in cases brought by different plaintiffs against the same six police officers.   The Eighth Circuit reversed the district court’s order denying the officers’ motion to dismiss with respect to Plaintiffs’ claims alleging use of excessive force and conspiracy to deprive civil rights. The court affirmed the order with respect to the claims alleging unlawful arrest.   The court explained that the case-at-hand arises in the same procedural posture and includes the same relevant factual allegations as Baude v. Leyshock, 23 F.4th 1065 (8th Cir. 2022), and Baude precludes a grant of qualified immunity on the arrest claims in this case as well. Thus, the court concluded that the allegations, in this case, are insufficient to establish a plausible claim that the defendant officers violated any Plaintiffs clearly established right against the use of excessive force. View "Alicia Street v. Gerald Leyshock" on Justia Law

The parties to this matter—Plaintiff, on behalf of her son, and the Belton School District—disagree about the appropriate school placement for Plaintiff’s son pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. Section 1400 et seq. Plaintiff appealed the decision of the district court granting judgment on the administrative record to the District.   On appeal, Plaintiff asserts that transferring her son to Trails West would violate his right under the IDEA to be educated in the least restrictive environment (LRE). Alternatively, Plaintiff argued, if her son needs additional services, the District should provide them in her son’s current placement. Thus, the question is whether Kentucky Trail or Trails West is the LRE in which Plaintiff’s son can receive a free appropriate public education (FAPE).   The Eighth Circuit affirmed finding no clear error in the district court’s factual findings and agreed that a preponderance of the evidence supports the AHC’s conclusion that placement at Trails West respects Plaintiff’s son's rights under the IDEA. Second, although Plaintiff emphasizes the social benefit her son receives from his more integrated placement at Kentucky Trail, the evidence shows that her son receives all of his instruction in the special education classroom and eats lunch there as well, and he has contact with nondisabled peers only when passing in the hallways or at recess. Further, there was sufficient evidence to support the conclusion that placement at Trails West offers substantial benefits for Plaintiff’s son. View "J.P. v. Belton School District No. 124" on Justia Law

Current and former Minnesota state employees brought an action seeking damages for money deducted from their paychecks by unions that represented their local bargaining units. Although the Supreme Court held the deduction practice unlawful in Janus v. American Federation of State, County, & Municipal Employees, 138 S. Ct. 2448 (2018), the district court determined that the unions acted in good faith reliance on state statutes and existing judicial precedent. Accordingly, the court ruled that the unions were entitled to a defense to liability under 42 U.S.C. Section 1983, and dismissed the employees’ claims.   The employees appealed arguing that there is no good-faith defense to liability for damages under Section 1983. The Eighth Circuit affirmed the district court’s judgments. The court explained because the unions collected fair-share fees under Minn. Stat. Section 179A.06 at a time when the procedure employed had been deemed constitutional by the Supreme Court, their reliance on the statute was objectively reasonable, and they are entitled to a good-faith defense. Even if subjective intent were deemed relevant, the employees have pleaded no facts to support a plausible inference that the unions collected these fees in subjective bad faith. The good-faith defense thus bars the employees’ claims for damages. View "Eric Brown v. AFSCME" on Justia Law

Appellants are four Minnesota state employees who sued unions that represented their local bargaining units. The employees sought monetary relief based on the amount of so-called “fair-share” fees that were deducted from employee paychecks for the benefit of the unions. The district court granted summary judgment in favor of the unions.  On appeal, the employees argue that the district court erred by granting summary judgment in favor of the unions on each of the claims for retrospective relief.   The Eighth Circuit affirmed, holding that the unions’ reliance on Section 179A.06 was objectively reasonable. It is an open question whether subjective intent is relevant to the defense, but the employees did not present a submissible case that the unions collected fair-share fees in subjective bad faith in any event. Therefore, the district court correctly granted summary judgment for the unions on these claims.   The unions prevailed on motions for summary judgment. The rules of civil procedure provide those costs “should be allowed to the prevailing party,” unless the court or a federal statute or rule directs otherwise. Further, the employees point to no authority that requires a district court to reduce an award of costs because a defendant opted to forgo a motion to dismiss and to file a dispositive motion only after developing a factual record. A defendant may choose how best to defend a lawsuit, and if the case is resolved in favor of the defense on a motion for summary judgment, then the defendant is presumptively entitled to costs. View "Linda Hoekman v. Education Minnesota" on Justia Law

Plaintiff, an employee of the Department of Veterans Affairs, sued Denis McDonough, Secretary of the Department of Veterans Affairs, for disability discrimination. Plaintiff alleged three violations of the Rehabilitation Act: failure to accommodate; disability discrimination; and retaliation for requesting an accommodation. The district court granted summary judgment to Secretary McDonough.   The Eighth Circuit affirmed. The court wrote that Plaintiff’s requested accommodation was not required under the Rehabilitation Act because it would impose an undue hardship on the VAPD. The court explained that Plaintiff’s accommodations would have violated the VAPD’s collective bargaining agreement, which requires that “[s]cheduled off-tours shall be rotated fairly and equitably among affected employees, i.e., day/evening, day/night.” Plaintiff’s requested accommodations are therefore presumptively unreasonable.   Plaintiff further argued that his reassignment was not reasonable for two reasons. First, he claimed that day shifts were not the only form of requested relief; they were just one of many possible accommodations the VAPD could have made. But the record undermines his argument. Further, he also suggested that his reassignment constituted an adverse employment action, not a reasonable accommodation. The VAPD provided the only available reasonable accommodation—reassignment. The district court was therefore correct to grant summary judgment to Secretary McDonough on Plaintiff’s failure to accommodate claim.   Moreover, Plaintiff claimed the unusual nature of his hiring process proves that the real reason for his non-selection was disability discrimination. However, showing that an interview process is “unusual” is not sufficient to prove that an employer’s proffered reason is pretextual. View "Jesse LeBlanc v. Denis McDonough" on Justia Law