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

The Eighth Circuit affirmed the district court's denial of the landlords' motion for a preliminary injunction in an action challenging the Minneapolis City Council's enactment of Ordinance No. 244.2030 under the Fifth Amendment's Takings Clause and the Fourteenth Amendment's Due Process Clause (and similar provisions of the Minnesota Constitution). The Ordinance requires landlords to evaluate applicants for rental housing by either (1) "inclusive screening criteria" or (2) "individualized assessment."The court concluded that the landlords have neither demonstrated a physical-invasion taking nor a Penn Central taking. The court stated that, due to the individualized assessment option, the Ordinance is a restriction on the landlords' ability to use their property, not a physical-invasion taking. Furthermore, the district court properly ruled that the landlords offered nothing but conclusory assertions of economic impact and interference with investment-backed expectations. Finally, the Ordinance withstands rational basis review where it does not infringe a fundamental right and where the government had a legitimate purpose in ameliorating problems that often prevent people from finding housing. View "301, 712, 2103 and 3151 LLC v. City of Minneapolis" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer in an action brought by Marquis Jones's estate, alleging claims under state and federal law after a police officer shot and killed Jones while he was running away from a traffic stop. In this case, the court agreed with the district court that there are two genuine disputes of material fact for the jury: first, whether the officer saw Jones drop the gun when he ordered him to; and second, whether the officer was unreasonable in believing Jones was taking a firing position rather than surrendering. The court stated that, if, construing the evidence most favorably to the estate, the officer knew Jones was unarmed, then shooting him violated a clearly established constitutional right. View "Williams v. City of Burlington" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a petition for writ of habeas corpus under 28 U.S.C. 2241 challenging petitioner's conviction for distributing heroin resulting in death of another person. The court concluded that the district court lacked jurisdiction over petitioner's section 2241 petition because he failed to establish that section 2255 was inadequate or ineffective. In this case, petitioner's impediment to relief was existing caselaw, not the remedy provided by section 2255. Furthermore, because the saving clause enacted by Congress only provides relief when section 2255's remedy itself is inadequate or ineffective, the district court lacked jurisdiction over petitioner's section 2241 petition. Without jurisdiction over the section 2241 petition, the district court could not entertain the petition and therefore did not abuse its discretion in denying petitioner an evidentiary hearing. View "Crayton v. United States" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of First Care in an action brought by plaintiffs, alleging that First Care unlawfully terminated them from their positions at an assisted-living facility. First Care claimed that plaintiffs were terminated because, as mandatory reporters, they had failed to immediately report observed abuse.The court concluded that plaintiffs failed to allege a claim of retaliation under Neb. Rev. Stat. 48-1114(1)(c) where they have failed to identify any demand by First Care to engage in an unlawful action. The court also concluded that plaintiffs' race discrimination claims under 42 U.S.C. 1981, Title VII, and Neb. Rev. Stat. 48-1104(1) failed because plaintiffs ultimately failed to identify a similarly situated comparator. Finally, the court concluded that plaintiffs failed to raise a genuine issue for trial regarding the district court's exclusion of investigator notes and reports on hearsay grounds. View "Walker v. First Care Management Group, LLC" on Justia Law

Tyler owned a Minneapolis condominium. She stopped paying her property taxes and accumulated a tax debt of $15,000. To satisfy the debt, Hennepin County foreclosed on Tyler’s property and sold it for $40,000. The county retained the net proceeds from the sale. Tyler sued the county, alleging that its retention of the surplus equity—the value of the condominium in excess of her $15,000 tax debt—constituted an unconstitutional taking, an unconstitutionally excessive fine, a violation of substantive due process, and unjust enrichment under state law.The Eighth Circuit affirmed the dismissal of her complaint. Minnesota’s statutory tax-forfeiture plan allocates the entire surplus to various entities with no distribution of net proceeds to the former landowner; the statute abrogates any common-law rule that gave a former landowner a property right to surplus equity. Nothing in the Constitution prevents the government from retaining the surplus where the record shows adequate steps were taken to notify the owners of the charges due and the foreclosure proceedings. View "Tyler v. Minnesota" on Justia Law

Robinson filed a 42 U.S.C. 1983 lawsuit six years and one day after police officers arrested and allegedly beat him. The day before he sued was Veterans Day, so federal courthouses were closed. The defendants argued that his claims were untimely. The district court asked whether some of the claims were really timely filed because the limitations period, which ordinarily would have ended on a “legal holiday,” actually “continue[d] to run until the end of the next day.” Fed. R. Civ. P. 6(a)(1)(C). Despite the hint, Robinson never made that argument himself, so the court dismissed the claims.The Eighth Circuit reversed in part. Robinson’s privacy, excessive force, and false-arrest claims were timely. Robinson’s failure to argue the federal-holiday rule was forfeiture, not waiver, as it involved inaction rather than acquiescence. Once the district court raised the federal-holiday rule, Robinson’s counsel thought there was little point in pressing the issue. Forfeiture is excusable in limited, well-defined circumstances, including when “the proper resolution is beyond any doubt,” for “purely legal issue[s]” that do not require “additional evidence or argument.” Here, how the federal-holiday rule works is clear, none of the relevant dates are in dispute, and everyone agrees that a six-year statute of limitations applies; this “purely legal issue” that is “beyond doubt.” Robinson’s malicious-prosecution claim, however, does not state” a constitutional claim and was properly dismissed. View "Robinson v. Norling" on Justia Law

The plaintiff alleged that during the September 17, 2017 protests of the acquittal of a St. Louis police officer on murder charges, police officers violated his civil rights when they boxed or "kettled" him in with other protestors and then pepper-sprayed him, arrested him, and restrained him with zip ties. In the plaintiff’s suit under 42 U.S.C. 1983, the district court denied the officers' motion for summary judgment based on qualified immunity.The Eighth Circuit affirmed. The plaintiff alleged sufficient facts to indicate his seizure was unreasonable. With respect to the excessive force claims, based on the record and plaintiff's allegations, the court could not conclude as a matter of law that the force used against the plaintiff was objectively reasonable. The plaintiff's claim of excessive force against the supervising police officers was sufficient at this stage of the case to defeat the officers' claims of qualified immunity. "There are simply too many unknowns and factual disputes" to determine as a matter of law that the subordinate police officers reasonably relied on their superiors' orders to arrest the crowd at the downtown intersection. View "Baude v. Leyshock" on Justia Law

Plaintiffs, the Arc of Iowa and Iowa parents whose children have serious disabilities that place them at heightened risk of severe injury or death from COVID-19, filed suit to enjoin enforcement of Iowa's law prohibiting mask requirements in schools. The district court concluded that the law violated the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, granting a preliminary injunction completely enjoining the law.After determining that it has jurisdiction, the Eighth Circuit held that plaintiffs are entitled to a preliminary injunction because mask requirements are reasonable accommodations required by federal disability law to protect the rights of plaintiffs' children. However, the court concluded that the injunction imposed by the district court sweeps more broadly than necessary to remedy plaintiffs' injuries. Accordingly, the court vacated in part and remanded to allow the district court to enter a tailored injunction prohibiting defendants from preventing or delaying reasonable accommodations and ensures that plaintiffs' schools may provide such reasonable accommodations. View "The Arc of Iowa v. Reynolds" on Justia Law

Plaintiff, an inmate, filed suit against his healthcare provider and its medical staff for constitutional violations under 42 U.S.C. 1983 and state law medical malpractice. Plaintiff's claims stemmed from allegations that defendants failed to diagnose him with a "likely" bacterial infection and to treat symptoms related to it. Plaintiff also alleged that defendants refused to provide him with functioning hearing aids, and refused to assess and provide reconstructive surgery for his broken ankles. The district court granted summary judgment in favor of the health care provider and its medical staff.The Eighth Circuit concluded that plaintiff's deliberate indifference claims regarding non-diagnosis of the bacterial infection failed where defendants did not ignore his complaints, examined him regularly, gave him medications, and enrolled him in chronic care clinics. The court also concluded that a jury could credit plaintiff's deliberate indifference claims against defendants regarding his hearing aids, but his claims against CCS failed because he provides no evidence of any CCS policy, custom, or action by those representing official policy that inflicted a section 1983 injury. Therefore, the court reversed and remanded the district court's grant of summary judgment as to plaintiff's deliberate indifference claim regarding his hearing aids. Because there is now a federal question, the court reinstated the medical malpractice claim on remand. The court affirmed the remainder of the district court's judgment, and concluded that plaintiff's retaliation claims fail because he does not establish retaliatory motive. The court denied plaintiff's pro se motion to reassign this case to another judge on remand. View "De Rossitte v. Correct Care Solutions, LLC" on Justia Law

Plaintiffs Irvin and Bates filed 42 U.S.C. 1983 actions against police officers, the police chief, and the city, alleging violations of their Fourth Amendment rights and claims under Iowa law when Officers Richardson and Jupin stopped Irvin and Bates while responding to a 911 call.The Eighth Circuit consolidated the appeals and affirmed the district court's grant of summary judgment dismissing Irvin's claims, as well as Bates's parallel state and federal claims. However, the court reversed the district court's grant of summary judgment dismissing Bates's federal and state law claims of false arrest after the initial encounter. The court concluded that the district court did not err by concluding that Officer Richardson had reasonable suspicion to stop and detain Irvin and Bates to determine whether they were involved in an unlawful firearm display during a public disturbance minutes earlier at a location they were walking away from. Because the officers had, at a minimum, arguable reasonable suspicion, they are entitled to qualified immunity on the investigative stop claims. The court affirmed the district court's grant of qualified immunity dismissing the Fourth Amendment claims where, under the circumstances, the force used by the officers did not turn the lawful Terry stop into an arrest. The court's conclusion that plaintiffs were not arrested defeats the false arrest claims.However, the court concluded that under Iowa law the district court erred in granting defendants summary judgment on Bates's claim regarding his subsequent arrest for interference with official acts. Likewise, summary judgment was not appropriate as to Bates's section 1983 false arrest claim where the relevant facts are too confused and contested to conclude, as a matter of law, that Officer Richardson is entitled to qualified immunity. Finally, the court declined to resolve these Monell issues as a matter of law on this summary judgment record and therefore included these issues in reversing the grant of summary judgment dismissing Bates's separate false arrest claims. View "Irvin v. Richardson" on Justia Law