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

Plaintiffs, Hispanic residents of Hastings, filed suit alleging a variety of state and federal law claims against various city and county employees, the State of Nebraska, Adams County, and the City of Hastings. Plaintiffs were arrested on charges of conspiracy and witness tampering for their alleged actions in the aftermath of a domestic disturbance in Hastings, and the charges were eventually dismissed.The Eighth Circuit held that the district court had jurisdiction over the 42 U.S.C. 1983 claims and the second amended complaint was properly before the court. The court declined to address the statute of limitations question because the second amended complaint did not meet federal pleading standards; the district court did not err in dismissing the claims against the Officer Defendants where the pleadings consisted almost entirely of non-specific conclusory allegations; the district court committed no error in dismissing the claims against the Doe Defendants where the second amended complaint did not sufficiently allege who they were, what they allegedly did, their positions were for the city, or any other facts that would permit them to be noticed or identified through discovery; and the district court did not clearly abuse its discretion when it denied plaintiffs' motion to amend or alter the judgment. View "Perez v. John and Jane Does 1-10" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Ford on plaintiff's claims of disability discrimination and retaliation under the Missouri Human Rights Act (MHRA). Plaintiff, born without a left forearm and hand, applied for an entry-level assembler position at Ford's assembly plant.The court held that the district court did not err by using the broad-range-of-jobs standard because this case only involved the major life activity of working or employment; the district court did not err in concluding that plaintiff had not satisfied the broad-range-of jobs standard because Ford considered him permanently restricted from a single, particular job he applied for; plaintiff waived his argument regarding direct evidence of discrimination; and therefore plaintiff's claim of discrimination under the MHRA failed, because plaintiff failed to show that Ford regarded him as having a disability. Finally, the court declined to consider the retaliation claim on appeal. View "Heuton v. Ford Motor Co." on Justia Law

Plaintiffs filed suit against a trooper, alleging that the trooper used excessive force when he shot and killed Gerry Thompson during a domestic disturbance response. The district court denied the trooper's motion for summary judgment based on qualified immunity and the trooper appealed.The Eighth Circuit dismissed the trooper's appeal, holding that the appeal turned on disputed issues of fact as to what occurred before the shooting and thus the court lacked jurisdiction. View "Thompson v. Dill" on Justia Law

After police shot and killed a suspect, the administrators of the decedent's estate filed suit against the officer who fired the fatal shots, alleging that the officer violated the decedent's constitutional rights by using unreasonable force. The Eighth Circuit affirmed the district court's judgment and held that the officer was entitled to qualified immunity because his use of force, even if just over the line of reasonableness, violated a clearly established right. In this case, the officer was suddenly confronted, at a distance of only three feet, with a suspect who was armed with a knife after ignoring multiple commands to drop it. View "Swearingen v. Judd" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2255 motion based on ineffective assistance of counsel. The court held the ineffective assistance of counsel claim regarding petitioner's plea was properly denied, because a reasonable attorney could have determined that the record, including the government's uncontested evidence and petitioner's own colloquy with the magistrate judge, established an adequate factual basis for petitioner's guilty plea to the money laundering charge. The court also held that petitioner's claim that trial counsel improperly coerced the plea was properly rejected. Finally, the issue of ineffective assistance of appellate counsel was not included in the certificate of appealability and the court declined to address it. View "Meza-Lopez v. United States" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the deputy warden, alleging that the deputy warden failed to protect him from harm by fellow inmates. The Eighth Circuit affirmed the district court's grant of the deputy warden's motion for judgment as a matter of law, and held that the evidence did not establish that the deputy warden acted with deliberate indifference. In this case, plaintiff's statements to the deputy warden were speculative and non-specific, and plaintiff's stated suspicions were insufficient to show that the deputy warden knew of a specific risk to plaintiff if he returned to general population. View "Blair v. Terry" on Justia Law

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.The Eighth Circuit affirmed the district court's denial of qualified immunity to the defendant officials. In this case, the information released about the minors interviewed in the investigation was highly personal and involved the most intimate aspects of human affairs. Furthermore, the information was inherently private and entitled to constitutional protection. Therefore, the court held that plaintiffs have stated a plausible claim for the violation of their constitutional right to confidentiality, and the right of minor victims of sexual abuse not to have their identities and the details of their abuse revealed to the public was clearly established at the time. Because plaintiffs have sufficiently pleaded intentional torts, the officials are not entitled to statutory or qualified immunity on plaintiffs' state law claims at this stage of the proceedings. View "Dillard v. Hoyt" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an action brought by an investor, alleging that Missouri fraudulently induced a loan between the investor and EngagePoint and illegally discriminated against EngagePoint. The court held that the investor failed to plead fraud with particularity.The court also held that the investor's unlawful discrimination claims failed because it has failed to identify any impaired contractual relationship under which it had rights, and 42 U.S.C. 1981 does not allow the investor to sue on EngagePoint's behalf. Similarly, the investor failed to state a discrimination claim under Title VI of the Civil Rights Act of 1964. View "FCS Advisors, LLC v. Missouri" on Justia Law

MDI, a Minnesota nonprofit organization, and one of its members filed suit under Title III of the Americans with Disabilities Act, seeking declaratory and injunctive relief. The Eighth Circuit affirmed the district court's motion to dismiss the action based on res judicata grounds, because the action was precluded by the final judgment on the merits in a prior suit by MDI and one of its members. The court explained that the dismissal of the second suit was a product of MDI's decision to assert associational standing claims as a co-plaintiff on behalf of its members in the MDI-Testa suit and then to dismiss its representational claims on the merits. The court noted that the only nonparty individuals bound by these tactics are members of MDI at the time. View "Midwest Disability Initiative v. JANS Enterprises, Inc." on Justia Law

Plaintiff, a pretrial detainee, filed suit against defendants under 42 U.S.C. 1983, alleging that defendants deprived him of dental care in violation of the Eighth Amendment. In this case, plaintiff suffered from multiple cavities and tooth pain. The district court ultimately granted summary judgment to defendants.The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in setting aside the entry of default against Defendant Collier where Collier had a meritorious defense and plaintiff was not significantly prejudiced. The court also held that plaintiff failed to meet the substantial evidentiary threshold required to show that the MEND Defendants and Collier were deliberately indifferent. In this case, defendants regularly responded to plaintiff's sick calls and followed protocol. Furthermore, any delay in permanently filling plaintiff's cavities did not show any unnecessary and wanton infliction of pain that was sufficiently harmful to evidence deliberate indifference to his serious medical needs. View "Johnson v. Leonard" on Justia Law