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

The Eighth Circuit affirmed the district court's denial of summary judgment based on qualified immunity to a police officer and summary judgment based on official immunity to the City. The court held that the officer lacked arguable probable cause to arrest plaintiff where the totality of the circumstances suggested that the officer had reason to know that plaintiff could not deliver the type of pain he felt (a kick) and he had no information suggesting that she was even in a position to do so. Furthermore, the arguable probable cause undergirding the warrantless arrest here was missing a fundamental element: observation—either by the officer or a witness who relayed that information to him—of a criminal act. The court also held that unlawfulness of the officer's conduct was clearly established at the time. Finally, the court held that a factfinder could determine the officer had reason to believe that he arrested plaintiff without probable cause, and the City, therefore, was not entitled to official immunity. View "Johnson v. City of Minneapolis" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to correction center officials in a 42 U.S.C. 1983 action brought by a former inmate alleging that the officials failed to protect him from sexual and physical harassment, threats, and assault. The court held that sufficient factual allegations from the verified complaint remained pending to support the district court's finding of material factual disputes. Therefore, the court dismissed the appeal for lack of jurisdiction. View "Berry v. Doss" on Justia Law

Plaintiff, who is paralyzed from the waist down and uses a wheelchair for mobility, filed suit against Holiday, alleging that the company discriminated against him in violation of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA) by failing to have an accessible parking lot at one of its stores. The district court granted Holiday's motion for summary judgment.The Eighth Circuit vacated the district court's judgment with instructions to remand plaintiff's access-aisle and vertical-signage claims to state court. In regard to these two claims, plaintiff suffered no injury and thus could not establish Article III standing. The court also remanded for the district court to consider whether to exercise supplemental jurisdiction over the remaining garbage-can claim. In this case, plaintiff established an injury in fact by offering specific evidence that the allegedly dangerous circumstances caused him not to enter the store. The district court erred in treating a photograph that plaintiff submitted along with his declaration as definitive proof that he had plenty of room to maneuver around the garbage can. View "Hillesheim v. Holiday Stationstores, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the County and others in a 42 U.S.C. 1983 action alleging that plaintiff was sexually assaulted by former corrections officer Louis Campana. The court held that the claims against the County were properly dismissed where plaintiff failed to show that the County itself caused the constitutional violation at issue; nothing in the record established that any failure to train Campana caused him to assault plaintiff or that the County was deliberately indifferent to plaintiff's rights; two supervisors' negligence was not sufficient to establish section 1983 liability; a reasonable officer in Sheriff Samuelson's position would not have known that he needed to more closely supervise Campana, and the Sheriff was entitled to qualified immunity; and a reasonable officer in Defendant Gregg's position would not have concluded on this record that Campana posed an obvious risk to commit sexual assault. View "Marsh v. Phelps County" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the school district in an action filed by plaintiffs of a student, alleging violation of the student's rights under the Rehabilitation Act when the school district failed to make reasonable accommodations for her. The court held that the parents' complaint sought relief available under the Individuals with Disabilities Education Act (IDEA) -- relief for the denial of a free and appropriate public education-- and thus they must exhaust their administrative remedies unless an exception to the exhaustion requirement applied. In this case, none of the three exceptions to the exhaustion requirement applied. Therefore, the district court properly granted summary judgment for failure to exhaust administrative remedies under the IDEA. View "Nelson v. Charles City Community School District" on Justia Law

Plaintiff filed suit against corrections officials at Crossroads Correctional Center for violation of his Eighth Amendment rights under 42 U.S.C. 1983. The Eighth Circuit affirmed the jury's finding that the officials were deliberately indifferent to plaintiff's serious medical need by failing to take reasonable steps to abate the risk of harm that secondhand smoke posed to him. In this case, there was sufficient evidence to show that the officials violated plaintiff's Eighth Amendment rights by being deliberately indifferent to the fact that plaintiff's asthma was exacerbated by offenders smoking indoors. However, there was insufficient evidence to justify an award of punitive damages where plaintiff failed to show that the officials were motivated by evil motive or intent or showed callous indifference to plaintiff's rights. Therefore, the court vacated the award of punitive damages and remanded for further proceedings. View "Washington v. Denney" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's 42 U.S.C. 1983 action against the City and a municipal judge, seeking costs and attorney's fees after plaintiff successfully defended himself in municipal court against a charge that he violated an ordinance for disorderly conduct. The court affirmed the district court's holding that no municipal liability under section 1983 was present in this case because the municipal court's ruling did not constitute a final municipal policy decision. The court also held that the judge was not a policymaker, and thus relief under section 1983 was foreclosed. View "King v. The City of Crestwood" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Wells Fargo in an action alleging that the bank violated the Age Discrimination in Employment Act (ADEA) in terminating plaintiff's employment. The court held that the district court identified exactly the two policies that plaintiff challenged. The court also held that plaintiff failed to establish a prima facie case of disparate impact discrimination under the ADEA where plaintiff was disqualified for the job he held due to a prior conviction for fraud and he failed to present statistical evidence of any kind that the two challenged policies created a disparate impact among Wells Fargo employees older than 40. View "Eggers v. Wells Fargo Bank, N.A." on Justia Law

After child abuse investigators removed seven minor children from plaintiffs' home, plaintiffs brought a 42 U.S.C. 1983 action against DHS and others. On appeal, a civilian investigator for the Crimes Against Children Division appealed the district court's denial of her motion to dismiss based on qualified immunity. The Eighth Circuit affirmed and held that the facts plausibly alleged that the investigator could be liable if the children were removed from their parents' home without reasonable suspicion of child abuse. Furthermore, it was clearly established at the time the investigator acted that reasonable suspicion was required to remove the children from their home and their parents' custody. View "Stanley v. Finnegan" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for St. Luke's in an action brought by a former employee, alleging discrimination in violation of the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA). The court held that plaintiff failed to show that St. Luke's reason for his termination was pretext for unlawful discrimination. In this case, St. Luke's terminated plaintiff for his disclosure of confidential information in violation of hospital policies. The court also held that plaintiff failed to exhaust his administrative remedies on that claim, and he could not pursue it in federal court. View "Lindeman v. Saint Luke's Hospital of Kansas City" on Justia Law