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

James Setchfield, a 68-year-old man, filed a lawsuit against St. Charles County Police Department officers Nicholas Seiverling and Scott Ronald, alleging they used excessive force during an incident in a parking lot. The incident began when Setchfield arrived to pick up his son, who had been arrested for driving under the influence. A confrontation ensued between Setchfield and Corporal Ronald, during which Setchfield was allegedly beaten by the officers while still seated in his car. Setchfield claimed he did not threaten or resist the officers, but was nonetheless pulled from his car, beaten, and arrested, resulting in various injuries and subsequent PTSD.The United States District Court for the Eastern District of Missouri dismissed claims against St. Charles County and one officer, John Williams, but denied summary judgment for Corporal Ronald and Officer Seiverling on Setchfield’s excessive force and unlawful arrest claims. The court found that material factual disputes remained, precluding summary judgment based on qualified immunity for the officers.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of summary judgment, holding that the officers were not entitled to qualified immunity. The court found that, viewing the facts in the light most favorable to Setchfield, the officers used unreasonable force against a non-threatening, non-resisting individual. Additionally, the court determined that the officers lacked probable cause or arguable probable cause to arrest Setchfield for interfering with police duties or resisting arrest. The court concluded that the officers’ actions violated clearly established constitutional rights, thus denying them qualified immunity. View "Setchfield v. Ronald" on Justia Law

Eddie Humes was arrested on October 19, 2017, and booked into the White County Detention Center. The next day, he was bitten by a spider, causing his hand and arm to swell significantly. Over three days, Humes repeatedly asked Lieutenant Misty Jones and Deputy Stephanie Gray for medical help, showing them his worsening condition. Despite their assurances, they took no action. By October 25, Humes's hand and arm had swollen to the size of a small watermelon and were oozing pus. He filed a grievance and was taken to the emergency room, where he was diagnosed with a staph infection and treated. The next day, he developed a high fever and was diagnosed with an abscess, requiring emergency surgery.Humes filed a civil-rights lawsuit against several defendants, including Jones and Gray, alleging deliberate indifference to his serious medical needs. The United States District Court for the Eastern District of Arkansas granted summary judgment to all defendants except Jones and Gray in their individual capacities, denying them qualified immunity. Jones and Gray appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity de novo. The court considered whether Jones and Gray violated a constitutional right and whether that right was clearly established. The court found that the district court correctly determined that a reasonable jury could find Jones and Gray were deliberately indifferent to Humes's serious medical needs, as they ignored his worsening condition. The court also held that the right to medical care for serious conditions was clearly established, referencing precedents like Hartsfield v. Colburn and Dadd v. Anoka County. Consequently, the Eighth Circuit affirmed the district court’s denial of qualified immunity and remanded the case for trial. View "Humes v. Jones" on Justia Law

Luke LeFever was involved in a series of criminal activities following a roadside encounter with Deputy Castellanos of the Dawson County Sheriff’s Department. LeFever lunged at the deputy, was tased twice, and fled the scene. He attempted to steal multiple vehicles, broke into a home, assaulted a resident, and led officers on a high-speed chase, driving recklessly and endangering public safety. The chase ended when officers fired 60 to 70 rounds at LeFever’s vehicle, resulting in serious injuries.The United States District Court for the District of Nebraska denied LeFever’s requests for appointed counsel and granted summary judgment in favor of the defendants. The court found that Deputy Castellanos had probable cause for the initial arrest and that the use of force, including the tasings and the shot fired at the utility vehicle’s wheel, was reasonable. The court also found that the report of “shots fired” by Deputy Castellanos did not rise to the level of a constitutional violation. Additionally, the court ruled that the actions of the other officers during the chase and subsequent shooting were reasonable under the circumstances and that qualified immunity applied.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the use of force by Deputy Castellanos and the other officers was reasonable and that qualified immunity protected the officers from liability. The court also found no abuse of discretion in the district court’s denial of LeFever’s requests for appointed counsel, noting that the facts and legal issues were clear and uncomplicated, and that the district court had provided adequate assistance to LeFever in managing his case. View "LeFever v. Castellanos" on Justia Law

Joshua Francisco, an inmate at Farmington Correctional Center (FCC), suffered from mental illness and was placed on suicide watch multiple times during his incarceration. Despite receiving treatment and being evaluated by mental health professionals, Francisco was found hanging in his cell on October 22, 2014, after his cellmate reported he was suicidal. Francisco had denied being suicidal to correctional officers and mental health staff earlier that day.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the correctional officers and the warden, finding no deliberate indifference to Francisco's medical needs. The court determined that the officers' actions did not rise to the level of criminal recklessness required to establish a violation of the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the correctional officers and the warden were entitled to qualified immunity. The court found that the officers had conducted reasonable investigations and searches based on the information available to them and that Francisco's repeated denials of suicidal intent, along with the absence of a noose, did not indicate a strong likelihood of self-harm. The court also concluded that the warden was not personally involved in any unconstitutional custom or practice and that the claim of an unconstitutional policy requiring inmates to explicitly state they were suicidal was not supported by the evidence. View "Francisco v. Villmer" on Justia Law

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Kenneth Hunt arrived at the Lee County Courthouse to testify in a criminal case. Directed outside due to courtroom scheduling, Hunt re-entered and sat on a staircase. Officer Dale Acosta confronted Hunt, leading to a heated exchange. Despite Hunt's explanation of his courthouse business, Acosta arrested him for obstruction, claiming Hunt disrupted the county tax office.The United States District Court for the Eastern District of Arkansas dismissed most of Hunt's claims but allowed his Fourth Amendment claim against Acosta, a failure to train or supervise claim against Mayor Jimmy Williams and Chief of Police Martin Wilson, and a Monell claim against the City of Marianna. The court denied qualified and quasi-judicial immunity for Acosta and qualified immunity for Williams and Wilson. Acosta, Williams, and Wilson appealed the denial of immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of quasi-judicial immunity for Acosta's initial stop of Hunt, as Acosta acted under a judge's directive. However, the court affirmed the denial of quasi-judicial and qualified immunity for Acosta's arrest of Hunt, finding no probable cause for obstruction. The court also reversed the denial of qualified immunity for Williams and Wilson, ruling that Hunt failed to show a pattern of unconstitutional acts by Acosta that would have put them on notice. The case was remanded for further proceedings consistent with these findings. View "Hunt v. Acosta" on Justia Law

Officer Daniel Irish, while pursuing a suspect, was bitten by a police K9 named Thor, handled by Deputy Keith McNamara. Irish sued McNamara under 42 U.S.C. § 1983, claiming a violation of his Fourth Amendment rights due to excessive force and unreasonable seizure. The incident occurred during a high-speed chase that ended in a cemetery, where McNamara deployed Thor without a leash. Irish, unaware of the K9's presence, was bitten by Thor, who was commanded to "get him" by McNamara.The United States District Court for the District of Minnesota denied McNamara's motion to dismiss based on qualified immunity. The court reasoned that it was clearly established that a seizure occurred under the Fourth Amendment, despite acknowledging the incident as a "highly unfortunate accident."The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether it was clearly established that the K9's bite constituted a seizure under the Fourth Amendment. The court noted that for a seizure to occur, an officer must intentionally apply physical force or show authority to restrain an individual's freedom of movement. The court found that the law was not clearly established regarding whether an officer's subjective intent was necessary for a seizure. The court concluded that McNamara did not subjectively intend to seize Irish, as evidenced by his commands to Thor to disengage and his immediate actions to restrain the K9.The Eighth Circuit held that it was not clearly established that an officer could seize a fellow officer with a K9 without subjectively intending to do so. Therefore, McNamara was entitled to qualified immunity. The court reversed the district court's decision and remanded with instructions to dismiss Irish's complaint. View "Irish v. McNamara" on Justia Law

S.A.A. filed a lawsuit under 42 U.S.C. § 1983 against Officer Samantha Geisler, alleging Fourth Amendment violations during her arrest. The initial complaint, filed on September 20, 2021, claimed false arrest and excessive force but did not specify the capacity in which Geisler was sued. S.A.A. admitted she had not alleged official capacity claims. She amended her complaint twice before the deadline in May 2022 and sought to amend it a third time after the deadline, which the magistrate judge allowed with a warning. Geisler moved for summary judgment, arguing that S.A.A. failed to plead personal capacity claims as required by the Eighth Circuit’s clear statement rule. S.A.A. then moved to amend her complaint a fourth time, which the magistrate judge denied.The United States District Court for the District of Minnesota granted Geisler’s motion for summary judgment, overruled S.A.A.’s objection to the magistrate judge’s denial of her motion to amend, and denied her fourth motion to amend. The court found that S.A.A. failed to plead personal capacity claims against Geisler, adhering to the Eighth Circuit’s clear statement rule, which interprets complaints silent on the capacity in which the defendant is sued as including only official capacity claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that S.A.A. did not explicitly plead individual capacity claims and that the district court did not abuse its discretion in denying her fourth motion to amend the complaint. The court emphasized that S.A.A. failed to demonstrate diligence in meeting the scheduling order’s requirements, which is the primary measure of good cause under Federal Rule of Civil Procedure 16. View "S.A.A. v. Geisler" on Justia Law

Three gun rights organizations and their members challenged Minnesota’s permit-to-carry statute, which requires applicants to be at least 21 years old, arguing it violates the Second and Fourteenth Amendments. The district court granted summary judgment to the plaintiffs, finding that the Second Amendment’s plain text covered their conduct and that the government failed to show that restricting 18 to 20-year-olds’ right to bear handguns in public was consistent with the nation’s historical tradition of firearm regulation. Minnesota appealed the decision.The United States District Court for the District of Minnesota ruled in favor of the plaintiffs, declaring the age restriction facially unconstitutional for otherwise qualified 18 to 20-year-olds and enjoining its enforcement. The district court applied the two-part test from New York State Rifle & Pistol Association, Inc. v. Bruen, focusing on the Second Amendment’s text and historical tradition. The court found that the plain text covered the plaintiffs’ conduct and that the government did not meet its burden to demonstrate a historical tradition of similar firearm regulations.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that ordinary, law-abiding 18 to 20-year-olds are part of “the people” protected by the Second Amendment. The court found that Minnesota failed to provide sufficient historical analogues to justify the age restriction, noting that the state’s proffered evidence did not meet the burden of demonstrating a historical tradition of similar firearm regulations. Consequently, the court ruled that the age restriction in Minnesota’s permit-to-carry statute is unconstitutional. View "Worth v. Jacobson" on Justia Law