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

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

The Estate of Willy Fritz filed suit against a police officer and the City of West Union, alleging a claim of recklessness, among other things, after the officer's police cruiser crashed into Fritz's truck which led to Fritz's death. The district court granted defendants' motion for summary judgment.The Eighth Circuit affirmed, concluding that the evidence does not establish recklessness under Iowa law where it failed to show that the officer had conscious knowledge of a dangerous situation as his police cruiser crossed a four-way intersection. In this case, the police cruiser approached the intersection, traffic had stopped, the road was straight, and the "lane ahead" was clear. Therefore, the district court did not err in granting summary judgment. View "Estate of Fritz v. Henningar" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging retaliation, defamation, and intentional infliction of emotional distress claims against plaintiff's former employer, Workforce Development and the state of Iowa, as well as against certain former supervisors and coworkers. Plaintiff's claims stemmed from her termination as an ALJ based on allegations that she fraudulently filed insurance enrollment forms and had deliberately falsified her daughter's marital status. Plaintiff alleged that her termination was based on retaliation for her testimony before the Oversight Committee and that the insurance fraud investigation constituted a mere pretext.In regard to the whistleblower retaliation claim, the court concluded that plaintiff failed to present evidence from which a reasonable jury could find that she was suspended or terminated in reprisal for her testimony. In regard to the defamation claim, the court concluded that Defendant Wahlert was entitled to summary judgment with respect to her allegedly defamatory testimony to the Oversight Committee where her testimony and related actions were within the scope of her employment. The court also concluded that plaintiff failed to establish any constitutional violation as to the First Amendment retaliation claim; defendants' conduct was not sufficiently egregious to satisfy the outrageousness prong of the Iowa tort of intentional infliction of emotional distress; and the district court did not err in granting summary judgment on plaintiff's retaliation claim based on the Iowa Constitution's free speech clause. View "Ackerman v. Iowa" on Justia Law

Officers responded to a shooting in an apartment building's parking lot. Three victims were transported to the hospital. Officers observed a security camera in the window of apartment 1, pointed toward the parking lot. After interviewing two witnesses, Detective Dunn viewed video footage from a business across the street, which corroborated their account. He learned that Haney, an occupant of unit 1, was involved in a dispute with the sister of two shooting victims. Dunn obtain a warrant to search Unit 1; other officers executed the warrant. An officer moved clothes in the bedroom closet and saw a sawed-off shotgun. He also seized a baggie of white powder, a laptop, and cell phones from the bedroom. Other officers seized cameras, a computer monitor, a Kindle, shotgun shells, pieces of a scale with traces of drug residue, photographs, and documents bearing the names of Haney and Saddler.Saddler later unsuccessfully moved to suppress all evidence seized during the search and an incriminating statement she later made concerning the shotgun. The Eighth Circuit affirmed her subsequent conviction as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The affidavit described facts that connected Haney to the shooting and created a fair probability that evidence that would aid in a particular apprehension or conviction would be found. Dunn’s reliance on the issuance of the warrant was objectively reasonable. In addition, the seizure of the shotgun satisfied the “plain view” exception. View "United States v. Saddler" on Justia Law

Plaintiffs, formerly employed as deputy sheriffs, filed a 42 U.S.C. 1983 action alleging that defendants violated their First Amendment rights based on Defendant Cole's retaliatory employment actions taken after plaintiffs supported his political opponent. The district court granted defendants' motion for summary judgment and dismissed the complaints.The Eighth Circuit affirmed, concluding that the district court did not err in interpreting Curtis v. Christian County, 963 F.3d 777 (8th Cir. 2020), by concluding that even if plaintiff is a first responder and other provisions of Missouri law protect against discharge for engaging in political activity, because he was a Missouri deputy sheriff, plaintiff was legally terminated and Cole did not violate plaintiff's constitutional rights. The court explained that whether Cole violated plaintiffs' state statutory political activity rights is an inquiry separate from whether he violated their First Amendment rights. The court's conclusion that Cole committed no unconstitutional act necessarily resolves the municipal liability issue involving Christian County and the Christian County Commissioners, sued in their official capacities. Because Cole is entitled to qualified immunity under Curtis, the court did not address plaintiffs' second argument about affirmative defenses. View "Burns v. Cole" on Justia Law

CSI, which won a contract to perform road work on state highways across three Minnesota counties, filed a 42 U.S.C. 1983 action against Mahnomen County and its Engineer, Jonathan Large, after Large stopped two of CSI's trucks for exceeding the posted weight limit on the road on which they were traveling.The Eighth Circuit affirmed the district court's grant of summary judgment on the constitutional claims, concluding that, under the unique circumstances of this case, it was not clearly established that Large, a county engineer tasked with oversight of all county roads, could not prevent trucks that he had reason to believe were operating above the posted weight limit from passing over and damaging the roadway or could not call law enforcement to investigate compliance with the new, reduced weight restrictions. The court also concluded that it was not clearly established at the time that defendants could not change the weight restrictions in response to CSI's stated intentions to use the road despite the fact it had not been designated as a haul road or that the engineer could not seek law enforcement's assistance in investigating the trucks' weights. Furthermore, because CSI's complaint failed to allege any policy or custom of the county related to the engineer's conduct, claims against the county failed. Finally, the court concluded that the district court properly granted summary judgment in favor of defendants on CSI's state law claim for tortious interference with contract, and the engineer did not exercise the dominion and control over plaintiff's trucks required to support a trespass to chattel claim. View "Central Specialties, Inc. v. Large" on Justia Law

The Eighth Circuit concluded that the district court did not err in determining plaintiffs' 42 U.S.C. 1983 claims for false imprisonment and unlawful search and seizure are time barred under Arkansas's three-year personal injury statute of limitations. In this case, the alleged Fourth Amendment violations -- false imprisonment and seizure of property based on fabricated evidence -- occurred before legal process began and are time-barred, despite plaintiffs' claim that the unlawful seizures continued even after the criminal charges were nolle prossed. The court rejected plaintiffs' contention that the district court improperly applied summary judgment standards in granting defendants' Federal Rule of Civil Procedure 12(b)(6) motions to dismiss and in denying plaintiffs' motion to vacate or set aside the dismissal. Rather, the court concluded that the district court did not abuse its discretion in declining to vacate or set aside its initial dismissal order because plaintiffs failed to state plausible section 1983 malicious prosecution claims under controlling Eighth Circuit precedent. View "Martin v. Julian" on Justia Law