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

The Eighth Circuit affirmed the district court's denial of qualified immunity at summary judgment for an officer in a 42 U.S.C. 1983 action alleging excessive force. The court held that the district court did not err in finding the officer's action in tasing plaintiff constituted a violation of his Fourth Amendment right to be free from excessive force and that the right was clearly established at the time. In this case, it was clearly established that intentionally tasering, without warning, an individual who has been stopped for a nonviolent misdemeanor and who was not resisting or fleeing while his hands were visible violated the Fourth Amendment right to be free from excessive force. View "Thompson v. Singleton" on Justia Law

The NAACP filed suit against the school district for voter dilution under section 2 of the Voting Rights Act of 1965 (VRA). The Eighth Circuit affirmed the district court's finding that (1) the NAACP had proved the preconditions for a section 2 vote dilution claim, and (2) the totality of the circumstances indicated that the district's black voters had less opportunity to elect their preferred candidate than other members of the electorate. The court held that the district court found a section 2 violation after engaging in the requisite precondition analysis and conducting a thorough totality-of-the-circumstances balancing. View "NAACP v. Ferguson-Florissant School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for DFJ on his age discrimination and retaliation claims brought under the Age Discrimination in Employment Act (ADEA); (2) disability discrimination and retaliation claims brought under the Americans with Disabilities Act (ADA); and (3) state-law claim for age and disability discrimination and retaliation brought under the Arkansas Civil Rights Act of 1993 (ACRA).The court held that plaintiff failed to exhaust his administrative remedies as to his federal claims where his termination played no part in the initial EEOC charge because the right-to-sue letter preceded the date of the termination; plaintiff's ACRA claim failed because no genuine issues of material fact exist on whether plaintiff was qualified to do the essential job functions of his position and whether the termination was due to his disability. The court also held that plaintiff's hostile work environment claim failed because the alleged harassment was not severe enough to support his claim, and plaintiff's ADA claims also failed because he was unable to perform the essential functions of his job, with or without accommodation, and he failed to show but-for causation as to retaliation. View "Moses v. Dassault Falcon Jet Corp." on Justia Law

An Arkansas trial judge filed suit against the Arkansas Supreme Court and justices in their official capacities, alleging that they violated his constitutional rights by permanently barring him from presiding over death penalty cases. The district court dismissed claims against the Arkansas Supreme Court as barred by sovereign immunity and denied the justices' motion to dismiss. The Eighth Circuit granted the justices' motion for writ of mandamus and directed plaintiff to dismiss the complaint with prejudice. The court held that plaintiff's free speech claim failed because he did not allege that he engaged in a protected activity where the recusal order applied to him in his role as a public employee and where recusal from death penalty cases was not an adverse employment action; the recusal order did not affect defendant's right to practice religion and his Free Exercise Clause claim failed; plaintiff's claim under the Arkansas Religious Restoration Act also failed; plaintiff was not deprived of his due process rights where he alleged no cognizable life, liberty or property interest; plaintiff failed to plausibly allege an equal protection claim; and the district court erred in allowing plaintiff's civil conspiracy claim to proceed were he failed to allege a plausible constitutional violation to support the claim. View "In Re: Honorable John Kemp" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants in an action alleging claims under the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25. The court held that the district court properly dismissed plaintiff's claims against Defendant Kopp as untimely under the applicable statute of limitations; plaintiff failed to state a claim for direct municipal liability against Duluth because she failed to plead sufficient facts supporting an inference that the City knowingly allowed Kopp to access the database for any reason other than her official duties; and plaintiff failed to preserve any vicarious liability claim. View "Loeffler v. City of Duluth" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the United States and the Deputy U.S. Marshals in their individual and official capacities on plaintiff's claims for false arrest, false imprisonment, abuse of process, and assault and battery under the Federal Tort Claims Act (FTCA). In this case, plaintiff was mistakenly arrested when defendants were executing an arrest warrant for another individual. Applying Missouri tort law, the court held that none of plaintiff's proposed facts contradicted a material fact that the district court relied on in conducting its summary judgment analysis; the district court did not err in granting summary judgment on the false arrest and false imprisonment claim where plaintiff's arrest and 20-minute detention were justified; defendants were also entitled to summary judgment on plaintiff's claims for abuse of process; and the court's prior holding on qualified immunity was dispositive of plaintiff's assault and battery claim. View "Wright v. United States" on Justia Law

Under Missouri campaign finance law, chapter 130, a “campaign committee” is formed to receive contributions or make expenditures solely to support or oppose particular ballot measures, "such committee shall be formed no later than thirty days prior to the election for which the committee receives contributions or makes expenditures." Thirteen days before the November 2014 general election, a group formed MFA as a campaign committee, to accept contributions and make expenditures in support of Proposition 10. MFA sued to enjoin enforcement of the formation deadline, citing the First Amendment. The district court granted MFA a temporary restraining order. MFA received contributions and made expenditures before the election. After the election, MFA terminated as a campaign committee. The Eighth Circuit affirmed summary judgment in favor of MFA. While a formation deadline by itself might not expressly limit speech, the deadline here is more than a disclosure requirement because it prohibits (or significantly burdens) formation of a campaign committee, a requisite for legally engaging in speech, even if the individual or group is willing to comply with organizational and disclosure requirements. Even if the state’s interest in preventing circumvention of chapter 130’s disclosure regime is compelling, the formation deadline is unconstitutional because it is not narrowly tailored, given its burden on speech and its modest effect on preventing circumvention of the disclosure regime. View "Missourians for Fiscal Accountability v. Klahr" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Walmart in an action alleging employment discrimination. The court held that plaintiff failed to file a charge of discrimination with the EEOC within 180 days of the alleged Americans with Disabilities Act (ADA) violation. The court also held that plaintiff's failure to file his EEOC claim within 180 days was not the result of any misconduct by Walmart. In this case, failing to respond to a settlement demand made ten days before the statutory deadline, and accompanied by a statement that the employee would file a charge with the EEOC if the matter could not be settled, was not conduct that the employer should unmistakably have understood would cause the employee to miss the filing deadline. View "Rodriguez v. Wal-Mart Stores, Inc." on Justia Law

After plaintiffs were exonerated for the murder of Helen Wilson in 2008, they filed a 42 U.S.C. 1983 action, alleging that their arrests and imprisonment were the result of a reckless investigation and manufactured false evidence, as well as parallel conspiracy claims under 42 U.S.C. 1985. Plaintiffs were awarded approximately $28.1 million in damages. The Eighth Circuit held that it would not review or reverse its prior rulings as to whether Gage County could be held liable; the evidence was sufficient to support the jury's verdict finding Gage County liable; the facts developed at trial continued to support the district court's conclusion that the sheriff's deputies were not entitled to qualified immunity; the deputies conducted a reckless investigation and fabricated evidence; limited references to plaintiffs' innocence did not warrant a new trial in light of the curative actions and overwhelming evidence; and there was no error in the reckless investigation jury instruction. View "Dean v. Searcey" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to a prosecutor and judge in a civil rights action alleging that defendants conspired to deprive plaintiff of his constitutional rights during criminal proceedings related to a 1990 homicide. The court held that the prosecutor was entitled to absolute immunity because the only supported instances of misconduct occurred after he was appointed special prosecutor and were intimately associated with the judicial phase of the criminal process. Likewise, the judge was entitled to absolute judicial immunity as any evidence of alleged misconduct on his part related directly to his official role as a judge. View "Woodworth v. Hulshof" on Justia Law