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

Defendants, Des Moines Police Department officers, lacking probable cause, took relatives of a stabbing victim to the station and held them for over three hours during which time the victim died. The district court denied qualified immunity, ruling for the family on their claims of illegal seizure and false arrest.   The Eighth Circuit affirmed the district court’s denial of qualified immunity. The court held both the duration and the nature of the seizure at issue exceeded the bounds of the Constitution.   The court reasoned that officers are entitled to qualified immunity unless (1) the evidence, viewed in the light most favorable to the plaintiffs, establishes a violation of a constitutional or statutory right, and (2) the right was clearly established at the time of the violation, such that a reasonable official would have known that his actions were unlawful.  Here, the officers seized the family against their will and without probable cause. There was no “reasonable ground” for the officers’ action.   The court concluded that there was no minimally-intrusive Terry stop and the detention was the most intrusive means of questioning survivors after a violent crime. Further, officers of the Des Moines Police Department were on notice that they could not detain someone for questioning against their will, even in a homicide investigation, absent probable cause.  The same evidence establishes the officers’ violation of sec. 1983 and the Fourth Amendment establishes a violation of the Iowa Constitution. View "Crysteal Davis v. Trevor Spear" on Justia Law

Plaintiff claims his former employer, the Transit Authority of the City of Omaha (“Metro”), discriminated against him based on his disability and retaliated against him for engaging in protected activity. Metro appeals the district court’s denial of its motion for judgment as a matter of law.Defendant argues that Plaintiff did not disclose the witness as an expert and it only learned the witness was a LIMHP at her trial deposition. The court reasoned that under Rule 26, non-retained experts are subject to less stringent disclosure requirements than retained experts. Further, the contents of the witness’ testimony were disclosed at the beginning of the case. Plaintiff provided what he thought was accurate information at the time of initial disclosures. Thus, the district court did not abuse its discretion in admitting the witness’s testimony because she testified as a treating practitioner only.The court affirmed the district court’s denial of its motion for judgment as a matter of law or a new trial on both the ADA and ADEA claims. Taken together, the evidence supports a reasonable inference that Plaintiff’s disability was a motivating factor in Metro terminating him. Finally, under the plain language of the ADA, the district court did not err in awarding attorney’s fees. View "John Gruttemeyer v. Transit Authority" on Justia Law

Plaintiff arrived at Becker County Jail in Minnesota with a number of physical ailments, two weeks later he was taken to the hospital and subsequently diagnosed with acute myeloid leukemia. Plaintiff filed an action against Becker County Jail (“BCJ”) and its personnel, claiming deliberate indifference to his medical needs, failure to provide adequate training to corrections officers, and negligence. The district court held that Defendants were entitled to qualified immunity. Plaintiff filed an amended complaint under 42 U.S.C. Sec. 1983, alleging Defendants violated his rights under the Eighth and Fourteenth Amendments and claims under Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978).On appeal, the court reasoned that qualified immunity “shields government officials from liability when their conduct does not violate clearly established constitutional rights of which a reasonable person would have known.” The court found no violation of the Eighth or the Fourteenth Amendments because the undisputed facts do not provide sufficient proof that the defendants acted with deliberate indifference to Plaintiff’s medical needs nor do they show intentional denial or delay in access to medical care. The court reasoned that Plaintiff gave mixed signals as to the severity of his pain. Because medical professionals failed to grasp the seriousness of his condition, prison staff without medical training could not have been expected to do so. Further, because the individual Defendants are entitled to official immunity, Becker County is entitled to the same immunity. View "Kyle Rusness v. Becker County, Minnesota" on Justia Law

Plaintiff alleges that while he was detained at a detention center, officers subjected him to severe racial harassment, including the use of racial epithets, multiple times per day. He filed several internal grievances, but each was rejected. Plaintiff alleges the grievances were rejected because of his race. Plaintiff challenges the district court’s grant of summary judgment to Defendants. He also argues that the court should have construed his pleadings to include claims for retaliation and violations of the Minnesota Human Rights Act.Plaintiff argues that his summary judgment evidence and other evidence available in the record was sufficient to establish a genuine dispute of material fact. Plaintiff identifies three “buckets” of relevant evidence: (1) his counter-affidavits; (2) the internal grievance forms filed with the adult detention center; and (3) other non-summary judgment evidence available in the record.The court found that the evidence does not raise a genuine dispute that either officer was personally involved in racial harassment or discrimination at the detention center. Plaintiff's statement fails to identify any direct or circumstantial evidence that would demonstrate the denial was racially motivated. Further, Plaintiff failed to obtain sworn testimony or documentary evidence asserting specific facts to help prove his claim. The court held that Plaintiff’s summary judgment evidence is insufficient to establish a genuine dispute of material fact that Defendants were personally involved in racial discrimination or harassment. Thus, Plaintiff cannot demonstrate that either officer’s conduct violated his Fourteenth Amendment rights, and both are entitled to qualified immunity View "Wilbert Glover v. Matt Bostrom" on Justia Law

Under Michigan abortion law, a minor may bypass the parental-consent requirement by obtaining a court order granting the right to self-consent (for mature minors) or judicial consent (for “best interests” minors). When the plaintiff sought to apply for judicial bypass, the defendant hadn’t heard of the process and told the plaintiff to come back later. Plaintiff sued the defendant in her individual and official capacities under 42 U.S.C. § 1983, alleging that defendant’s refusal to allow her to apply for a judicial bypass without parental notification violated her Fourteenth Amendment rights. The district court denied the motion when the defendant moved for summary judgment, invoking quasi-judicial and qualified immunity.Before the Eighth Circuit, the defendant claimed she acted at the direction of the Associate Circuit Judge (“Judge”). The Judge testified that he did not recall telling the defendant not to accept the application without parental consent. The circuit court concluded there was a genuine issue of material fact regarding the Judge’s practice of giving pre-filing directions. Further, the is a clearly established right to apply for a judicial bypass. Thus the circuit court declined to address the defendant’s other arguments regarding qualified immunity. View "Jane Doe v. Michelle Chapman" on Justia Law

Minnesota Governor Walz (“Walz”) signed an executive order mandating a statewide residential eviction moratorium. Heights Apartments, LLC (“Heights”), a property owner of residential units, challenged the executive orders, raising First Amendment, Fifth Amendment, and Fourteenth Amendment claims under Section 1983.The court found that the plaintiffs met the two-prong test to determine whether a state has impermissibly interfered with a contract. However, the court held that Heights has failed to allege a cognizable Petition Clause claim because the only potential remedy is damages; Heights has not pleaded damages that are somehow unique to its Petition Clause claim.Heights alleged it was deprived of its expected return on investment in the form of rental income. These alleged damages are sufficient to plausibly give rise to a Fifth Amendment takings claim. Finally, Heights has alleged violations of various rights that trigger protections under other constitution amendments; however, it has failed to plausibly plead a substantive due process violation. Thus, Heights has plausibly argued constitutional claims under the Contract Clause and Takings Clause. The court reversed the dismissal of those two claims and remanded for further proceedings. View "Heights Apartments, LLC v. Tim Walz" on Justia Law

The Eighth Circuit reversed the district court's adverse grant of summary judgment in favor of Metro Transit in an action brought by plaintiff, who is blind and deaf, alleging claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Minnesota Human Rights Act (MHRA). In this case, plaintiff's claims stemmed from 150 complaints he made regarding bus operators' failure to stop at T-Signs and announce the bus route. The court concluded that the record contains evidence sufficient to raise a genuine issue of material fact as to whether Metro Transit provided meaningful access to disabled bus riders. The court stated that, at trial, the DOT regulations cited by plaintiff are admissible as evidence that the jury may consider and weigh when determining whether he has met his burden of demonstrating that he was denied meaningful access to Metro Transit's services. View "Segal v. Metropolitan Council" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment in favor of Bi-State in an action brought by plaintiff under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court concluded that the district court did not abuse its discretion in determining that plaintiff's claims regarding federal transportation regulations were barred by judicial estoppel where his position on summary judgment is inconsistent with the position he took on Bi-State's motion for a judgment on the pleadings; he persuaded the district court that he was not pursuing a private right of action under the federal regulations; and allowing him to take an inconsistent position would give him an unfair advantage in the litigation.The court rejected plaintiff's argument that the district court erred when it determined his claims were barred by the previous settlement agreement and, alternatively, granted summary judgment to Bi-State on the merits. The court concluded that, even assuming the agreement does not bar plaintiff's claims, those claims would still fail because he cannot demonstrate that Bi-State denied him meaningful access to its services. In this case, plaintiff has not shown he was denied an opportunity to access the same services as non-disabled riders. Finally, the court concluded that it lacked jurisdiction to review the denial of plaintiff's motion to amend the complaint. View "Gustafson v. Bi-State Development Agency" on Justia Law

After a jury found plaintiff not guilty of a drug trafficking offense, he filed a civil rights action against two police officers alleging they conspired to include false statements in an affidavit of probable cause executed shortly after his arrest.The Eighth Circuit affirmed the district court's grant of the motion to dismiss based on qualified immunity where the affidavit provided arguable probable cause for plaintiff's arrest even without the allegedly false statements at issue. The court concluded that the uncontested portions of the affidavit show officers knew at the time that plaintiff repeatedly had been with the targets of their investigation close in time to cocaine sales. Viewed in totality through the lens of common sense, the court stated that the affidavit with the alleged falsehoods removed still supports probable cause. The court affirmed the dismissal of all plaintiff's claims as they are derivative of the probable cause argument. View "Allen v. Monico" on Justia Law

Plaintiff filed suit against Morton County and North Dakota state officials under 42 U.S.C. 1983, alleging that a violation of his First, Fourth, and Fourteenth Amendment rights related to an incident where law enforcement officials shot plaintiff with lead-filled bean bags while he was protesting.The Eighth Circuit concluded that, although plaintiff's First Amendment retaliation claims are not Heck barred, they are subject to dismissal under Federal Rule of Civil Procedure 12(b)(6) on the merits. In this case, the nonconclusory allegations in the complaint do not give rise to a plausible inference that the officers who allegedly shot and arrested plaintiff acted out of retaliatory animus. However, the court concluded that the district court erred in dismissing the excessive force claims against the officers who shot plaintiff under the Fourth Amendment, as the complaint asserted use of more than de minimus force when plaintiff did not threaten anyone, flee, or resist arrest and the law was clearly established. The court stated that, if the allegations in his complaint are true, then Morton County law enforcement engaged in a persistent pattern of excessive force against peaceful protestors that was tacitly authorized by Sheriff Kirchmeier and that led to plaintiff's injury. Furthermore, Sergeant Kennelly is liable for the violation of plaintiff's Fourth Amendment rights because he failed to intervene. Finally, plaintiff's equal protection claims were properly dismissed where he failed to allege facts showing that otherwise similarly situated non-Native Americans were treated more favorably than he was. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Mitchell v. Kirchmeier" on Justia Law