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

Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the City of Ferguson, alleging violations of his First, Fourth, and Fourteenth Amendment rights. Plaintiff's claims stemmed from nine citations he received from the officer at a park. The district court found that the officer was not entitled to qualified immunity and thus denied defendants' joint motion for summary judgment.After determining that it had jurisdiction, the Eighth Circuit vacated the district court's order denying defendants' joint motion for summary judgment and remanded so that the district court may further consider the officer's asserted entitlement to qualified immunity. In this case, when discussing plaintiff's Fourth Amendment seizure claim, the district court commenced its analysis by citing case law that outlined the general legal standards for probable cause and reasonable suspicion, but it largely failed to apply this case law, or more analogous cases, to plaintiff's version of the facts. Furthermore, the district court failed to conduct the materiality inquiry by framing legal questions as factual ones; the court was unable to discern whether the district court applied the clearly established prong at all, much less conducted a "thorough determination;" the district court defined the relevant law at too high a level of generality to conduct a proper clearly established analysis; and the district court's excessive force analysis fails to identify a specific right or factually analogous cases. Finally, the court dismissed the City's appeal for lack of jurisdiction. View "Watson v. Boyd" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action alleging claims of wrongful arrest and wrongful detention. After responding to a 911 call reporting an assault and robbery, officers arrived at an apartment complex and conducted a brief investigation, arresting plaintiff and two others for second degree robbery. During the continuing investigation after plaintiff's arrest, the police department obtained surveillance video that demonstrated that plaintiff was not in the victim's apartment at the time of the assault and robbery. Prosecutors later dropped the charges against plaintiff. The district court denied defendants' motion for summary judgment based on qualified immunity.The Eighth Circuit reversed, concluding that the record supports the conclusion that the officers had arguable probable cause to arrest plaintiff for the assault based on the victim's identification of plaintiff as one of his attackers. In this case, the record evidence does not create a factual dispute, and thus the officers are entitled to qualified immunity on the unlawful arrest claim. In regard to plaintiff's claim that defendants wrongful detained him, the court noted that this decision was not made by the named defendants but, rather, by the city prosecuting attorney. Therefore, the court concluded that plaintiff lacked standing to pursue his claim against the named defendants. View "Ngong Garang v. City of Ames" on Justia Law

The Eighth Circuit affirmed the district court's judgment in an action brought by plaintiffs, on behalf of their son, Tanner, who was arrested when he was 15 years old on charges that were later dismissed. Plaintiffs alleged violations of 42 U.S.C. 1983 and Iowa state law stemming from the officers' arrest of Tanner after he was accused of sexual assault. The court concluded that the officers had probable cause to arrest Tanner and were therefore entitled to summary judgment on the Fourth Amendment claim. The court explained that, when the officers arrested Tanner, they had probable cause to believe that he had committed the crime of third-degree sexual abuse under Iowa law.The court also affirmed the district court's grant of summary judgment on the Fourteenth Amendment claims, concluding that nothing in the officers' statements or actions indicates that they acted recklessly as they investigated the allegations against Tanner. Finally, because the officers had probable cause for the arrest, the court concluded that plaintiffs' state law claims for false arrest and malicious prosecution fail and defendants were entitled to summary judgment on the claims. View "Walz v. Randall" on Justia Law

After Jerome Goode led police on a twenty-five-mile car chase, the chase ended in his death and the deaths of passengers Lavoy Steed and Leon Haywood. Steed's next friend filed a 42 U.S.C. 1983 action against Missouri State Troopers Fowler and Ashby, alleging that the traffic stop that precipitated the chase and an attempt to halt Goode's vehicle with spike strips were unconstitutional seizures in violation of the Fourth Amendment.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the troopers, concluding that Trooper Fowler had probable cause to stop the vehicle where dashcam footage shows the vehicle going close to ninety miles per hour. Even assuming that the trooper misinterpreted the speed reading, he would still be entitled to qualified immunity because he had at least arguable probable cause to believe the vehicle was speeding. The court also concluded that the record clearly establishes that the troopers did not apply physical force by trying to use the spike strips, and thus there was no seizure. View "Steed v. Missouri State Highway Patrol" on Justia Law

The Eighth Circuit affirmed the district court's denial of the officers' motion for summary judgment in a 42 U.S.C. 1983 action brought by plaintiff, who had been arrested at a protest, alleging violations of his First and Fourth Amendment rights and conspiracy to violate his rights, and under Missouri state law. Plaintiff and his wife were documentary filmmakers who were covering protests in downtown St. Louis, Missouri, following Officer Jason Stockley's acquittal of charges arising from the death of Anthony Lamar Smith.The court concluded that, viewing the evidence in the light most favorable to plaintiff, a reasonable jury could conclude that Officer Biggins used excessive force during plaintiff's arrest, that he acted with an "actual intent to cause injury" to plaintiff, and that his use of excessive force was done in retaliation for plaintiff's First Amendment activity. Therefore, the district court did not err in denying summary judgment based on qualified immunity to Officer Biggins on plaintiff's First and Fourth Amendment claims, nor did the district court err in denying summary judgment based on official immunity to Officer Biggins on plaintiff's state law assault and battery claim. The court declined to consider the officers' argument concerning application of the intracorporate conspiracy doctrine because it was raised for the first time on appeal. View "Burbridge v. Biggins" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Walmart in an action brought by plaintiff, alleging age discrimination under the Iowa Civil Rights Act (ICRA). The court assumed that plaintiff met his prima facie burden under the McDonnell Douglas standard, but concluded that Walmart offered a legitimate, non-discriminatory reason for terminating his employment, the violation of the Hazardous Materials Endorsement policy while on a Third Written (a policy meaning he could be fired if disciplined again). The court also concluded that plaintiff's evidence was insufficient to allow a reasonable juror to find that Walmart's proffered reason for firing him was pretextual. View "Gardner v. Wal-Mart Stores, Inc." on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer unlawfully arrested him and used excessive force during the arrest. Plaintiff's claims stemmed from an incident where the officer issued tickets to him for illegal parking and resisting arrest. Plaintiff pleaded guilty to illegal parking by signing the ticket at the police station, and the City later dismissed the charge of resisting arrest.The Eighth Circuit affirmed the denial of summary judgment on plaintiff's unlawful arrest claim where there is a genuine dispute of material fact about whether the officer entered plaintiff's home without a warrant to effect the arrest. In regard to plaintiff's separate Fourth Amendment claim premised on the alleged use of excessive force, the court concluded that the officer is entitled to qualified immunity because an officer could reasonably believe that plaintiff was resisting arrest. The court explained that, under the circumstances, it was not clearly established at the time that officers were forbidden to use force, including a taser, to arrest a suspect who resisted, ignored instructions, and walked away from the officer. The court noted that any damages that plaintiff suffered because of his arrest are subsumed within his unlawful arrest claim. Therefore, even without a freestanding claim for use of excessive force, plaintiff may recover any damages that he suffered from the officer's use of a taser if plaintiff succeeds on his claim alleging unlawful arrest based on an unjustified entry into the home. View "Gerling v. Waite" on Justia Law

Plaintiffs, parents of LD, filed suit against the school district and others after their daughter LD, a 13-year-old, 7th grade student, was sexually abused by her teacher, Brian Robeson.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the school district and the principal. The court concluded that plaintiffs failed to present any evidence that the principal had actual notice of the abuse, and the principal and the school district were entitled to summary judgment on plaintiffs' Title IX and 42 U.S.C. 1983 claims. The court also concluded that the district court did not err by granting summary judgment in favor of the school district and principal on plaintiffs' Nebraska Political Subdivisions Tort Claims Act where plaintiffs' claim arose out of Robeson's sexual assault of LD, an intentional tort to which the Act's intentional tort exception applies. The court further concluded that the district court did not err in granting summary judgment in favor of the principal on plaintiffs' aiding and abetting intentional infliction of emotional distress claim where nothing in the record, even when viewed in the light most favorable to plaintiffs, indicates that the principal encouraged or assisted Robeson in inflicting emotional distress on LD.The court joined its sister circuits in finding that there is no right to a jury trial on the issue of damages following entry of default judgment. The court affirmed the district court's order denying plaintiffs' request for a jury trial on the issue of damages against Robeson. Finally, the court affirmed the $1,249,540.41 amount of damages awarded against Robeson. View "KD v. Douglas County School District No. 001" on Justia Law

Plaintiff, a tenured professor, filed suit against the University, a faculty union, and the Board of Trustees, alleging First and Fourteenth Amendment violations. Plaintiff claimed that the designation of IFO as plaintiff's exclusive representative violates the First Amendment by wrongly compelling her to speak through and associate with an entity with which she disagrees. Plaintiff also claimed that granting preferences to IFO members to serve on meet-and-confer committees discriminates against her and others who declined to associate with the union.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. Because plaintiff properly concedes that the district court correctly rejected her compelled-speech claim (Count I) under Minnesota State Board of Community Colleges v. Knight, 465 U.S. 271 (1984), the court affirmed the district court's grant of summary judgment on her Count 1 claims. Furthermore, the district court correctly rejected plaintiff's invitation to read Count II as an unconstitutional-conditions claim for three reasons: first, the complaint's text does not support this reading; second, there are inconsistencies in plaintiff's filings; and plaintiff's claim that IFO's meet-and-confer rights under Minnesota law discriminate against her associational preferences is similar to Knight. Finally, the court concluded that the district court did not abuse its discretion in denying plaintiff's request for leave to amend her complaint, which she made in her Rule 59(e) motion to vacate the judgment. View "Uradnik v. Inter Faculty Organization" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the Commission in an action brought by plaintiff, alleging that the Commission discriminated against her in violation of Title VII. Plaintiff argues that her suspension, probation, and termination were discrimination based on race and national origin. The Commission stated that plaintiff's termination was due to failure to comply with requests to provide company passwords to agency programs and documents. The court concluded that plaintiff did not show evidence of pretext or that she could satisfy the McDonnell Douglas burden-shifting framework before the district court or in her opening brief, and thus she cannot prove a circumstantial case of discrimination. View "Towery v. Mississippi County Arkansas Economic Opportunity Commission, Inc." on Justia Law