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

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging a claim for unreasonable search in violation of the Fourth and Fourteenth Amendments. The district court granted the officer qualified and official immunity.Reviewing de novo, the Eighth Circuit held that it lacked jurisdiction to review the appeal based on the incomplete record. Accordingly, the court dismissed the appeal and remanded to the district court for further proceedings. View "M.A.B. v. Mason" on Justia Law

In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released.The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed. View "McKay v. City of St. Louis" on Justia Law

Plaintiff filed suit against several prison officials in their individual capacities under 42 U.S.C. 1983, challenging a disciplinary adjudication, conditions of confinement, adequacy of medical treatment, and alleged retaliatory acts. The district court denied motions to dismiss and for summary judgment.The Eighth Circuit held that officials were entitled to a ruling on their defense of qualified immunity as to the Eighth Amendment claims in Count II. Because the order granting the motion for reconsideration effectively denied the officials' motion to dismiss without ruling on qualified immunity, the court remanded the case for further proceedings to address the question of qualified immunity on Count II. As to the remaining claims, the court held that the district court did not abuse its discretion by determining that the officials failed to properly plead or carry their burden of proof as to any defenses of privileges and immunities. Accordingly, the court rejected the challenge to the order denying summary judgment on the remaining counts. View "Spann v. Lombardi" on Justia Law

A student and her parents filed suit against the Minnesota Department of Education, alleging that the school district's failure to classify the student as disabled denied her the right to a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The ALJ concluded that the school district's treatment of the student violated the IDEA and related state special-education laws. The district court then denied the school district's motion for judgment on the administrative record and granted, in part, the student's motion for judgment on the record, modifying the award of compensatory education.The Eighth Circuit held that the district court did not abuse its discretion in denying the school district's request for supplementation of the record; the school district's evaluation of the student was insufficiently informed and legally deficient; the student is eligible for special education and a state-funded FAPE like every other child with a disability; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; and the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services. However, the court reinstated the ALJ's award of compensatory education costs. View "Independent School District No. 283 v. E.M.D.H." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to plaintiff's former employer, Con-E-Co, on plaintiff's sex discrimination claim, her sexual harassment claim, and her retaliation claims under Title VII of the Civil Rights Act of 1964, and the Nebraska Fair Employment Practice Act.The court held that plaintiff failed to establish a prima facie case of sex discrimination because she did not demonstrate that she met Con-E-Co's legitimate job expectations or that Con-E-Co treated her differently than similarly situated male employees; the district court did not err in granting summary judgment to Con-E-Co regarding her sexual harassment claim based on vulgar behavior directed at her by her coworkers, because plaintiff failed to demonstrate that she subjectively perceived the alleged harassment as abusive; and plaintiff failed to establish a prima facie case for retaliation in response to either her race discrimination or sex discrimination complaints. View "Gibson v. Concrete Equipment Co., Inc." on Justia Law

After Map Kong was fatally shot by police in Burnsville, Minnesota, plaintiff filed suit against the city and the officers under 42 U.S.C. 1983 and state law. The district court denied defendants' motion for summary judgment based on qualified immunity and official immunity.The Eighth Circuit reversed, holding that the district court erred in denying the officers qualified immunity. The court held that, even if the facts showed that the officers had violated Kong's Fourth Amendment right, the law at the time of the shooting did not clearly establish the right. In this case, Kong ran toward bystanders with a knife against the officers' repeated orders to drop the weapon; there was at least one pedestrian visible on the body-camera footage; and a steady flow of vehicles through the parking lot meant that citizens might quickly approach or step out of their vehicles. Therefore, the court held that a reasonable officer would have believed the law permitted shooting Kong under these circumstances. The court also held that, even if the officers acted negligently, they did not intentionally disregard the police department's policy on crisis intervention for persons. Therefore, the officers are entitled to official immunity and the district court erred in denying summary judgment on the state-law negligence claim. Furthermore, the city is entitled to vicarious official immunity. View "Sok Kong v. City of Burnsville" on Justia Law

After an officer shot and killed Roy Lee Richards, Jr., his estate filed suit under 42 U.S.C. 1983 for excessive force in violation of the Fourth Amendment. The Eighth Circuit affirmed the district court's denial of the officer's motion for summary judgment based on qualified immunity, holding that it has authority to decide the purely legal issue of whether the facts as alleged by plaintiff and found or assumed by the district court constitute a violation of clearly established law.On the merits, the court held that the officer's use of deadly force was not objectively reasonable where the officer did not have probable cause to believe Richards was not pointing the weapon at someone and wielding it in an otherwise menacing fashion. Rather, Richards had retreated. Furthermore, the officer's failure to warn before shooting Richards exacerbated the circumstances. The court also held that it was clearly established at the time that the officer's use of deadly force was objectively unreasonable in light of the circumstances of this case. View "Cole v. Hutchins" on Justia Law

Plaintiff filed suit against her former employer, Allina, for race and national origin discrimination as well as intentional infliction of emotional distress. The Eighth Circuit affirmed the district court's grant of summary judgment as to the discrimination claims, holding that the record demonstrates that Allina considered plaintiff's race only to ensure that any corrective action was not based on racial discrimination; without direct evidence of discrimination, the court relied on the burden shifting McDonnell Douglas analysis; and, assuming plaintiff established a prima facie case, plaintiff failed to demonstrate that Allina's stated reason for terminating her was pretext.The court explained that nothing in Allina's Violence-Free Workplace policy or other policies prohibit Allina from treating some offenses as more severe than others and selecting a corrective action that it believes is proportional to the level of severity for the violation. In this case, Allina's response to plaintiff's grievance and the deposition of an Allina human resources director make clear that Allina believed that pushing a coworker was more severe than throwing a lab coat at a co-worker and that plaintiff's behavior justified a more severe punishment. View "Findlator v. Allina Health Clinics" on Justia Law

After the district court granted petitioner partial habeas relief, both petitioner and the state appealed. The Eighth Circuit agreed with the district court that petitioner's guilt-and-penalty ineffective-assistance claims were procedurally defaulted. However, the court held that no procedural default was triggered in the initial Arkansas Rule of Criminal Procedure 37 proceedings. In this case, habeas relief cannot be granted on petitioner's guilt-and-penalty ineffective-assistance claims because he cannot establish cause for the default and actual prejudice as a result of the alleged violation of federal law, or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice.The court also held that the district court did not err in denying petitioner a hearing for his jury-pool ineffective-assistance claim where petitioner received a constitutionally adequate jury and he was not prejudiced. Finally, the court held that petitioner's McCoy-type claim is procedurally defaulted and the court rejected his request for a hearing. Accordingly, the court affirmed in part and reversed in part. View "Thomas v. Payne" on Justia Law

Plaintiff, his three children, and Stop Child Protection Services from Legally Kidnapping filed suit against the county, DCSS, nine county officials, and three officials. Plaintiffs' constitutional, federal, and state law claims stemmed from a Child in Need of Protection of Services (CHIPS) proceeding by DCSS.The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss, holding that plaintiffs lacked standing to challenge the facial constitutionality of three Minnesota child welfare statutes; plaintiff was not entitled to monetary damages under 42 U.S.C. 1983, because he failed to establish a due process violation, an equal protection claim, and municipal liability and conspiracy; and the children are also not entitled to damages under section 1983. The court also held that, even if the complaint was sufficiently pled and established a constitutional violation, defendants would be entitled to qualified immunity. Furthermore, the court held that no conduct by the individual defendants, as alleged in the amended complaint, rose to the level of maliciousness required to deny official immunity under Minnesota law. Finally, plaintiffs are not entitled to declaratory relief. View "Mitchell v. Dakota County Social Services" on Justia Law