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

Plaintiff filed suit against JJSC for discrimination under the Americans with Disabilities Act (ADA), alleging that the company denied him full and equal access to one of its service and gas stations. After removal to federal court, the district court dismissed the case without prejudice for lack of subject-matter jurisdiction.The Eighth Circuit held that plaintiff lacks standing to bring an ADA claim based on the accessibility of the stations' slopes and accessible routes where he failed to allege or provide evidence showing that he intends to patronize the station in the imminent future. Furthermore, he concedes that he did not observe any potential hazards related to the slope. The court also held that the district court properly concluded that the accessible parking claim is moot where JJSC had remedied plaintiff's concerns. Finally, the court explained that when a federal court lacks subject-matter jurisdiction over a removed case, it must remand it to state court even if, as is true here, the removed claim is one arising under federal, not state, law. Therefore, the court vacated the district court's judgment dismissing plaintiff's complaint and instructed the district court to remand to state court. View "Dalton v. JJSC Properties, LLC" on Justia Law

Plaintiffs filed suit challenging Section 204D.13(2) of the Minnesota Statutes, which requires that major party candidates be listed on the ballot in reverse order of the parties' electoral showing in the last general election. Plaintiffs contend that the law irrationally disadvantages their preferred political candidates and is therefore unconstitutional. The district court granted a preliminary injunction enjoining the law's enforcement and prescribed instead a lottery-based system of ordering candidates on Minnesota ballots. Political committees intervened and moved to stay the injunction.As a preliminary matter, the Eighth Circuit held that plaintiffs have Article III standing by alleging a cognizable and redressable injury fairly traceable to the statute. On the merits of the preliminary injunction, the court held that intervenors have shown that, absent a stay, they would be irreparably injured.As to intervenors' likelihood of success, the court held that, under the Anderson/Burdick standard, the burdens imposed by section 204D.13(2) do not unconstitutionally violate the rights asserted. The court considered the character and magnitude of the asserted injury, and observed that the statute does not in any way restrict voting or ballot access; the statute neither systematically advantages incumbents nor advantages the state’s most popular party; but, rather, the statute favors candidates from parties other than the one that received the most votes (on average) in the last general election. In this case, Minnesota's justifications are rationally related to placing political parties in reverse order of popularity and, by design, the statute cannot advantage the state's predominant party. Furthermore, incumbents cannot count on using the statute's operation to its advantage and the statute promotes political diversity. Therefore, the court granted the motion to stay the injunction pending appeal. View "Pavek v. Donald J. Trump for President, Inc." on Justia Law

After plaintiff was assaulted by another inmate with a wooden board at a correctional facility, he suffered head injuries that require life-long medical treatment and has developed a seizure disorder. Plaintiff filed a 42 U.S.C. 1983 action against seven correctional facility officials, alleging that each violated his Eighth Amendment right to be free from cruel and unusual punishment by failing to protect him from a substantial risk of serious harm.The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss based on failure to state a claim, holding that plaintiff failed to plausibly allege an Eighth Amendment violation. In this case, the amended complaint failed to allege that defendant had previously been threatened by the assailant or by another inmate; that the assailant was known to be a violent, volatile inmate; that plaintiff and the assailant had previously argued or fought, been cellmates at any time, or even knew each other; or that either plaintiff or the assailant have recently been in protective custody or in a restrictive status such as administrative segregation. The court explained that plaintiff was the unfortunate victim of a surprise attack and thus his failure-to-protect claim failed. View "Vandevender v. Sass" on Justia Law

AVF is sponsoring a ballot initiative to amend the Arkansas Constitution’s redistricting provisions and began circulating a petition during the COVID–19 pandemic. The Arkansas Constitution and statutes require canvassers to attach to the petition an affidavit affirming that all the petition signatures were made in the presence of the canvasser. The plaintiffs claim they cannot comply with these requirements during the pandemic; all are particularly vulnerable to COVID–19 because of age or medical conditions. They claimed enforcement of the requirements during the pandemic would impermissibly burden their First Amendment rights to express their position on a political matter. The district court preliminarily enjoined the enforcement of the requirements.The Eighth Circuit reversed. The district court erroneously applied strict scrutiny; neither requirement violates the First Amendment. The court noted that the right to a state initiative process is not guaranteed by the U.S. Constitution, but is created by state law; states have considerable leeway to protect the integrity of the process. The Arkansas Code provides accommodations for individuals who require assistance signing an initiative petition and, even without those accommodations, there are simple ways to safely comply with the in-person signature requirement during the pandemic. The requirement imposes real burdens but not severe burdens, and serves important interests in preventing signatures from ineligible voters. View "Miller v. Thurston" on Justia Law

Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA).The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory. View "Pribyl v. County of Wright" on Justia Law

An August 14, 2019 subpoena duces tecum ordered the IDPS to appear before the court's grand jury and provide documents relating to the investigation of an ISP officer for misconduct or use of excessive force. IDPS complied with five of the listed document categories but filed a motion to quash categories 3 and 4, which seek any and all records relating to the investigation of Officer John Doe for misconduct and any and all records relating to complaints made against Officer John Doe.The Eighth Circuit affirmed the district court's order denying IDPS's motion to quash and rejected IDPS's assertion that quashing the subpoena is needed to protect the Fifth Amendment rights of IDPS employees who participated in internal investigations; the procedural protections established by Kastigar v. U.S., 406 U.S. 401 (1972), and Garrity v. New Jersey, 385 U.S. 493 (1967), provide sufficient protection from the improper use of compelled statements; the Fifth Amendment allows the government to prosecute using evidence from legitimate independent sources; and the district court did not abuse its Federal Rule of Criminal Procedure 17(c)(2) discretion in deciding that IDPS failed to meet its substantial burden to show that compliance with the challenged portions of the grand jury subpoena would be "unreasonable or oppressive" when balanced against the interests of the government in enforcing the subpoena. View "In Re: Grand Jury Subpoena Dated August 14, 2019" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force and seeking damages for injuries sustained during plaintiff's arrest. The district court denied the officer's motions for summary judgment.The Eighth Circuit agreed with the district court that, on balance, the challenged use of force was unreasonable, but that the question is not beyond debate, and the right at issue was thus not clearly established. In this case, officers were attempting to arrest plaintiff for his role in a brutal beating, plaintiff fled from officers at high speed for several miles while armed with a handgun and ammunition, and a foot race ensued after the car chase where five officers pinned plaintiff. While the officers pinned plaintiff, plaintiff refused to surrender his hands and the officers reasonably believed that plaintiff's position posed a threat to officer safety, because at least one of his hands was unrestrained in an area of his body where weapons could be concealed. Therefore, the court held that it was objectively reasonable for officers to apply some amount of supplemental force in order to gain control of plaintiff's hands and to restrain him. However, the court held that the officer's use of force was unreasonable under the Fourth Amendment. The court stated that a stomp on the ankle with sufficient force to break it was excessive when the legitimate objective was to facilitate restraint of plaintiff's hands while he was pinned to the ground by several officers.The court stated that a number of the relevant factors supported the use of force, so reasonableness was a matter of degree, and qualified immunity protects officers from the specter of lawsuits and damages liability for mistaken judgments in gray areas. Accordingly, the court reversed the denial of qualified immunity. View "Shelton v. Stevens" on Justia Law

Plaintiff filed suit under Title VII against Midwest after it allegedly withdrew his job offer after learning that he was gay. The Eighth Circuit reversed the district court's dismissal based on Williamson v. A.G. Edwards & Sons, Inc., 876 F.2d 69, 70 (8th Cir. 1989), and remanded for further proceedings in light of the Supreme Court's decision in Bostock v. Clayton Cty., 590 U.S. ___, Nos. 17-1618, 17-1623, 18-107, slip op. at 4 (June 15, 2020), which held that it "defies" Title VII for "an employer to discriminate against employees for being homosexual or transgender," because to do so, it "must intentionally discriminate against individual men and women in part because of sex." View "Horton v. Midwest Geriatric Management" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's 42 U.S.C. 1983 claims against the county, the sheriff, and two deputy sheriffs. The court held that Deputy Ford was entitled to qualified immunity on the Fourth Amendment false arrest claim where he had probable cause to make the warrantless arrest of plaintiff. In this case, prior to arresting plaintiff, Deputy Ford was told by his dispatcher that plaintiff had tried to stab the victim; the victim gave both oral and written statements about the incident; and other evidence corroborated the victim's statements.The court also held that the sheriff and the second deputy are entitled to qualified immunity on the Fourth Amendment false arrest claim; the officers are entitled to qualified immunity on plaintiff's Fourteenth Amendment substantive due process claim for failure to investigate; plaintiff's section 1983 civil conspiracy claim failed as a matter of law because plaintiff failed to establish that he was deprived of a constitutional right or privilege; and in the absence of a constitutional violation, plaintiff's Monell claim also failed. View "Kingsley v. Lawrence County" on Justia Law

The Eighth Circuit reversed the district court's sua sponte dismissal of plaintiff's in forma pauperis complaint as failing to state a claim under the Americans with Disabilities Act (ADA). Plaintiff is currently serving a prison sentence and has a diagnosis of diverticulitis, a chronic colon condition that causes diarrhea and constipation.The court held that plaintiff has stated a Title II claim by sufficiently alleging that he is a qualified individual with a disability under the ADA and that he was denied the benefit of the prison's privilege system by reason of his disability. The court also held that plaintiff has stated a claim under Title VI and that defendants retaliated against him for his filing of ADA grievances by taking the adverse action of rescinding his medical classification without providing a medical reevaluation or rationale. Finally, because plaintiff's complaint sufficiently states a claim upon which relief may be granted, the court necessarily reversed the district court's assignment of a strike under the Prison Litigation Reform Act. View "Rinehart v. Weitzell" on Justia Law