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

The Eighth Circuit affirmed the district court's grant of summary judgment to Koss in an action brought by plaintiff, a former employee, alleging that Koss terminated her employment in retaliation for her complaints about pay discrimination based on sex in violation of the Equal Pay Act (EPA).The court held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to pretext. In this case, plaintiff failed to present sufficient evidence as to the question of whether there was no basis in fact for Koss's proffered reason for her termination: there was lack of work at the project. The court also held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact on the question of whether a retaliatory reason more likely motivated the manager's decision to terminate her. View "Yearns v. Koss Construction Co." on Justia Law

Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent.The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination. View "Button v. Dakota, Minnesota & Eastern Railroad Corp." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants under 42 U.S.C. 1983 and state law, stemming from plaintiff's acquittal of a first degree murder charge. Plaintiff was a St. Louis Metropolitan Police Department (SLMPD) officer at the time he shot and killed a fleeing suspect.The court held that the district court did not err in dismissing plaintiff's claims against the city prosecutor based on absolute immunity; the prosecutor's decision that there was sufficient evidence to end the investigation, even after only one day, and charge plaintiff with first degree murder clearly falls within the prosecutorial function of initiating judicial proceedings; and, even if the prosecutor's termination of the investigation and initial decision declining to prosecute plaintiff could be construed as indicating that she had an improper motive, allegations of unethical conduct and improper motive in the performance of prosecutorial functions did not defeat the protection of absolute immunity. The court also held that plaintiff failed to state a substantive due process claim against the prosecutor based on her public statements where the conduct did not rise to the level of conscience-shocking. Finally, plaintiff failed to state a defamation claim against the prosecutor.The court also held that the district court did not err in dismissing the section 1983 and malicious prosecution claims against a sergeant in the police department's Internal Affairs Division in his individual capacity. Furthermore, the district court properly dismissed the Monell claim against the city where the prosecutor's decision to terminate the investigation and charge plaintiff was an individual charging decision based upon a particular set of facts supported by arguable probable cause. View "Stockley v. Joyce" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to UPS in an action brought by plaintiff for retaliation and discrimination under 42 U.S.C. 1981. The court held that plaintiff's retaliation claim failed because he cannot link protected conduct with his demotion. In this case, plaintiff concedes that his supervisor and his supervisor's supervisor did not know about the statements plaintiff made on two different occasions. The court also held that plaintiff's race discrimination claim failed at the third step of the McDonnell Douglas framework because UPS provided a legitimate, non-discriminatory basis for the action: plaintiff was failing to perform his duties. Furthermore, plaintiff failed to raise a genuine issue of material fact as to whether UPS's explanation for his demotion was pretext for discrimination. View "Williams v. United Parcel Service, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of a petition for habeas relief challenging petitioner's three Iowa methamphetamine-related convictions. The court held that petitioner failed to meet his burden of showing that the Iowa court's application of the Jackson sufficiency of the evidence standard was both incorrect and unreasonable; petitioner's challenges to the state court's factual findings also fail; and petitioner procedurally defaulted on his argument regarding his conviction for lithium with intent to manufacture methamphetamine. The court rejected petitioner's claims of ineffective assistance of counsel and Brady claim. Finally, the court held that petitioner's sentence did not violate the Fifth Amendment because Iowa courts have held the enhancements were to apply in tandem, and petitioner's Eighth Amendment argument was procedurally defaulted. View "Stephen v. Smith" on Justia Law

The Sheriff's Office appealed the district court's denial of qualified immunity on First Amendment wrongful-discharge claims brought by former Deputy Sheriffs Timothy Bruce and Robert Curtis. Bruce and Curtis's complaints alleged that Cole, the newly elected sheriff, discharged them for political reasons in violation of their First Amendment rights.The Eighth Circuit reversed the district court's denial of qualified immunity, holding that political loyalty is an appropriate requirement for the job of deputy sheriff under Missouri law because of the closeness and cooperation required between sheriffs and their deputies in fulfilling overlapping duties. In this case, Cole did not violate Bruce and Curtis's constitutional rights. Consequently, the county is also entitled to summary judgment on the claims against it. The court remanded for further proceedings. View "Curtis v. Christian County" on Justia Law

The Eighth Circuit reversed the district court's denial of qualified immunity and statutory immunity to a police trooper in an action alleging excessive force under 42 U.S.C. 1983 and assault and battery under state law. The court held that it was reasonable for the trooper to believe that plaintiff was attempting to evade arrest by flight where the trooper knew that multiple officers had attempted to stop a white male riding a black motorcycle with no license plate for speeding and that the suspect had evaded arrest multiple times by fleeing at a high rate of speed. Furthermore, the court concluded that there can be little doubt but that a reasonable officer could conclude that fleeing from four other officers at speeds exceeding 100 miles per hour in evening traffic demonstrates an extreme indifference to the value of human life. Likewise, because the trooper believed plaintiff had fled from no fewer than four other officers, traveling at speeds exceeding 100 miles per hour in evening traffic, he could reasonably conclude that defendant posed an immediate threat to the safety of the officers and others. The court also held that it was not clearly established at the time that it constituted excessive force in violation of the Fourth Amendment to use a taser, without warning, against a suspect perceived as attempting to flee from officers. Therefore, the trooper was entitled to qualified immunity on the section 1983 excessive force claim.The court also held that the trooper was entitled to statutory immunity under Arkansas law, because plaintiff failed to produce sufficient evidence to create a triable issue of fact regarding malice. View "Boudoin v. Harsson" on Justia Law

The Eighth Circuit affirmed the district court's grant of a preliminary injunction, holding that the district court did not err in finding that plaintiffs were likely to succeed on the merits of their claim that Arkansas's recent amendments to the requirements for new political parties to appear on the next general-elections ballot on a whole-ballot basis were unconstitutional.The court also held that, assuming a compelling interest exists, and taking the general boundaries established by precedent, a regime containing (1) a substantial signature requirement, (2) a limited rolling window for obtaining signatures, and (3) a deadline 425 days removed from the general election is not narrowly tailored to a generalized interest in regulating the integrity of elections. Although plaintiffs did not make an overwhelming showing as to the actual burdensomeness of the current regime on their own particular ability or inability to comply, the court held that their showing was sufficient and found no clearly erroneous determinations by the district court. Finally, the district court did not abuse its discretion in fashioning the injunctive relief. View "The Libertarian Party of Arkansas v. Thurston" on Justia Law

The Eighth Circuit granted defendants' petition for rehearing en banc of the panel's qualified immunity ruling. In this case, plaintiffs filed a 42 U.S.C. 1983 action against the City, the County, and officials, alleging violations of their constitutional right to privacy and of Arkansas tort law in connection with defendants' decisions to release information identifying them as victims of childhood sexual abuse. Plaintiffs are sisters and stars of the popular reality show 19 Kids and Counting. Plaintiffs were interviewed along with others as part of a police investigation into sexual misconduct by plaintiffs' brother. Reviewing de novo, the court reversed the denial of qualified immunity and held that the asserted due process right to informational privacy was not clearly established at the time. The court reinstated the remainder of the court's opinion. View "Dillard v. Hoyt" on Justia Law

Plaintiff, a Satanist, filed suit challenging a Missouri law requiring her to certify that she has had a chance to review certain information before having an abortion. Plaintiff alleged that Missouri's informed-consent law violates the Establishment and Free Exercise Clauses of the First Amendment.The Eighth Circuit affirmed the district court's dismissal of plaintiff's First Amendment claims. As a preliminary matter, the court did not permit plaintiff to plead a new undue burden claim at this stage in the proceedings because Missouri lacked fair notice of the claim based on the complaint itself. On the merits, the court held that the statute's requirement that every woman seeking an abortion in Missouri must first receive a state-authored informed-consent book does not violate the Establishment Clause because alignment to a religious belief alone is not enough to show a violation. The court also held that the requirement that plaintiff certify that she had a chance to view an ultrasound at least 24 hours prior to the procedure and that she received the informed consent booklet does not violate her free-exercise rights. In this case, plaintiff makes no argument that the informed-consent law is anything other than neutral and generally applicable. View "Doe v. Parson" on Justia Law