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

Plaintiff filed a 42 U.S.C. 1983 action against police officers, in their individual capacities, alleging that the officers used excessive force and exhibited deliberate indifference to medical needs in an incident that led to the death of her son. The Eighth Circuit reversed the district court's denial of summary judgment based on qualified immunity to the officers and held that the officers' use of force did not violate clearly established law nor did their actions on the scene exhibit deliberate indifference to medical needs. In this case, there was insufficient evidence that a need for medical treatment was so obvious that law enforcement exhibited deliberate indifference by taking the son to jail. Furthermore, the officers were not deliberately indifferent when they called paramedics to assist him. View "Hanson v. Best" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of JBS in an action under the Americans with Disabilities Act (ADA), the Iowa Civil Rights Act (ICRA), and the Iowa Wage Payment Collection Law (IWPCL). Plaintiff alleged a failure to accommodate claim and a termination claim, as well as a claim that JBS intentionally failed to pay plaintiff a portion of his earned wages.The court held that, even if plaintiff was disabled, he was not qualified to perform the essential functions of his job, and his claims failed on that basis. The court explained that lifting was an essential function of the maintenance mechanic position that could not be reasonably accommodated, and plaintiff failed to show that accommodations JBS offered were unreasonable. The court held that plaintiff was not a qualified individual under the ADA and thus his termination claim also failed. Finally, because mere allegations were insufficient to rebut a properly supported motion for summary judgment, the district court properly granted summary judgment as to the IWPCL claim. In this case, JBS's payroll records reflected that plaintiff was correctly paid and any errors were quickly remedied. View "Gardea v. JBS USA, LLC" on Justia Law

After her fifteen year old son was shot and killed by a police officer, plaintiff filed suit against the officer, the police chief, and the city, alleging claims under 42 U.S.C. 1983 and state law. The district court granted summary judgment for the police chief and the city. A jury found that the officer violated the boy's Fourth Amendment right to be free from excessive force and returned a verdict in favor of plaintiff.The Eighth Circuit affirmed, holding that plaintiff failed to establish a municipal custom based on failure to prevent police misconduct; plaintiff failed to show that the city acted with deliberate indifference to the rights of persons with whom its officers came into contact; the district court did not err by requiring plaintiff to establish a pattern of constitutional violations to prove her claim; plaintiff's evidence of officer-involved shootings did not establish deliberate indifference to a pattern of excessive force; and the district court likewise did not err in granting summary judgment on plaintiff's failure to train or supervise claim. The court also held that plaintiff's evidence was insufficient to hold the police chief individually liable; there was no genuine issue of material fact that a plainly obvious consequence of the hiring decision would be the officer's unjustified use of deadly force; and the evidence failed to show the chief had notice that the officer's training and supervision were inadequate and likely to result in the use of excessive force. View "Perkins v. Hastings" on Justia Law

After the sheriff's department decided not to reinstate plaintiff, she filed suit against the county alleging retaliation and sex, pregnancy, and disability discrimination, in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), and the Nebraska Fair Employment Practice Act (NFEPA). The Eighth Circuit affirmed the district court's dismissal of her claims and held that her Title VII claim failed because she did not plead any facts showing that another candidate was similarly situated or went through a reinstatement process. Because her state claim mirrored her Title VII claim, it likewise failed. View "Jones v. Douglas County Sheriff's Department" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the City in an employment discrimination suit under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA). The court held that plaintiff was not entitled to return to the Senior Accountant position because he did not return to work prior to the expiration of his Family Medical Leave Act (FMLA) leave; there was no medical reason why plaintiff needed to be reinstated to his former position; and thus he failed to show that returning to his original position was a reasonable accommodation.The court also held that plaintiff's request that he be allowed to work from home was not a reasonable accommodation in light of his testimony that he could work at City Hall but that it "would have been easier" to work from home; plaintiff failed to make a facial showing that he could perform the essential functions of the job remotely; plaintiff failed to show that the City eliminated his position because of his disability or that the City terminated him because of his disability; there was no genuine issue of material fact that the City engaged in anything but a good-faith interactive dialogue; and his retaliation claim failed. View "Brunckhorst v. City of Oak Park Heights" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of petitioner's motion under 28 U.S.C. 2255 based on the one year statute of limitations period. The court held that it was reasonably debatable whether the holding in Johnson v. United States, 135 S. Ct. 2551 (2015), regarding the Armed Career Criminal Act extends to the former mandatory guidelines and thus petitioner could not benefit from a renewed limitations period under section 2255(f)(3). In this case, the right petitioner asserted: a right under the Due Process Clause to be sentenced without reference to the residual clause of USSG 4B1.2(a)(2) under the mandatory guidelines, was not dictated by Johnson. View "Mora-Higuera v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to correct his sentence under 28 U.S.C. 2255 because it was time-barred. The court held that the motion was untimely because Johnson v. United States, 135 S. Ct. 2551 (2015), did not newly recognize the right petitioner asserted: a right under the Due Process Clause to be sentenced without reference to the residual clause of USSG 4B1.2(a)(2) under the mandatory guidelines. View "Peden v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate, set aside or correct his sentence under 28 U.S.C. 2255. The court held that counsel's conflict did not adversely affect the adequacy of his representation of petitioner at trial; the district court did not clearly err in finding that counsel's strategy was reasonable in the circumstances, the evidence of petitioner's guilt was overwhelming, and alternative strategies petitioner proposed were not objectively reasonable; and petitioner failed to show that the conflict diminished counsel's credibility in the jury's eyes. The court also held that the district court did not clearly err by finding that counsel did not know that the funds at issue were stolen and that there was insufficient evidence to support a reasonable inference that petitioner knew, or should have known, that the funds at issue were illegitimate. Finally, the district court did not clearly err by finding that emails were insufficient to raise an inference that counsel was entangled with the conspiracy. View "Kiley v. United States" on Justia Law

Plaintiff appealed the district court's dismissal of her 42 U.S.C. 1983 action alleging that the City deprived her of her constitutional rights. Plaintiff's amended complaint alleged that she was arrested, her car was towed, and she was held at the police station until it was discovered that she had paid certain fines.The Eighth Circuit held that the district court erred because, whether or not the clerk had absolute or qualified immunity, that immunity did not foreclose an action against the City if the complaint adequately alleged an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee. Although the record has not been developed with respect to the clerk's duties and responsibilities, the source of the clerk's pay, or the degree that state or local officials exercised over the clerk, the court held that the complaint at least stated a plausible claim of wrongdoing. Therefore, the court remanded for further proceedings. View "Evans v. City of Helena-West Helena" on Justia Law

Plaintiffs filed a putative class action against the City, alleging several constitutional violations under 42 U.S.C. 1983 stemming from the City's alleged detention of plaintiffs for their inability to pay traffic fines. The City subsequently sought interlocutory review of the district court's denial of the City's motion to dismiss based on sovereign immunity. The Eighth Circuit dismissed the appeal for lack of jurisdiction because the City disclaimed any sovereign immunity for itself and sought only to invoke the sovereign immunity of a nonparty. View "Fant v. City of Ferguson" on Justia Law