Articles Posted in Constitutional Law

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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

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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

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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

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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

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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

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After Gary Wenzel was shot and killed by a police officer, Wenzel's family filed suit against the officer, alleging a claim under 42 U.S.C. 1983 for excessive force. The Eighth Circuit reversed the district court's denial of summary judgment based on the officer's claim of qualified immunity. The court held that, given the officer's knowledge of Wenzel's reputation of being aggressive and violent towards law enforcement officers, it was reasonable for the officer to believe that Wenzel posed an immediate threat of serious physical harm to him, notwithstanding the fact that the officer could see that Wenzel's hands were empty and the later-discovered fact that Wenzel was unarmed. In this case, a reasonable officer on the scene would have viewed Wenzel's indisputably aggressive approach as a precursor to a physical altercation, and the officer was required to make a split-second decision in an unpredictable and dangerous circumstance. View "Wenzel v. Storm" on Justia Law

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The Eighth Circuit affirmed the district court's denial of summary judgment to a state trooper based on qualified immunity in a 42 U.S.C. 1983 action alleging that the trooper used excessive force. The court held that the trooper's use of force was not objectively reasonable under the circumstances. In this case, plaintiff was an unarmed, nonviolent offender who was not actively resisting or fleeing, but the trooper nonetheless lifted plaintiff off the ground and slammed his head into the floor, causing him to lose two teeth. The court held that a reasonable police officer would have known at the time of the incident that throwing a nonviolent, nonthreatening misdemeanant who was not actively resisting face first to the ground was not permissible use of force. View "Rokusek v. Jansen" on Justia Law

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The Prison Litigation Reform Act's (PLRA) gatekeeper function against frivolous suits does not require a prison inmate to make a showing of a physical injury caused by an unconstitutional act. Rather, in the Eighth Amendment context, in order to recover compensatory damages, the PLRA requires a showing of harm caused by some unconstitutional conduct that amounted to deliberate indifference and an accompanying showing of physical injury. In this prisoner medical needs case, plaintiff appealed the district court's judgment awarding him only nominal and no punitive damages. The district court held that defendants violated plaintiff's Eighth Amendment rights by their deliberate indifference to his serious medical needs while he was in their custody, but that the PLRA precluded plaintiff's recovery of compensatory damages because he failed to meet 42 U.S.C. 1997e(e)'s physical injury threshold. The Eighth Circuit held that plaintiff's severe pain resulted from an actual physical injury when an officer's takedown move broke his shoulder, and thus plaintiff met the PLRA's physical injury requirement under section 1997e(e). Therefore, the court reversed and remanded with instructions for the district court to calculate compensatory damages that result from the pain differential, if any, that plaintiff experienced from having to take non-prescription pain relievers instead of the ten prescribed hydrocodone tablets. Finally, the district court did not abuse its discretion by denying punitive damages. View "McAdoo v. Martin" on Justia Law

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The Eighth Circuit reversed the district court's grant of summary judgment to officers in a 42 U.S.C. 1983 action alleging unlawful arrest and excessive force. The court held that, accepting plaintiff's version of the events as true, the officers' use of force was objectively unreasonable. In this case, the officers suspected plaintiff of making a false statement, plaintiff was neither fleeing nor actively resisting arrest, plaintiff posed no threat to the security of the officers or the public, and the officers made the arrest by grabbing plaintiff by the throat and using a baton with sufficient force to break his arm. In regard to the unlawful arrest claim, the court also held that it was objectively unreasonable to believe that there was probable cause to arrest plaintiff where plaintiff's statement that his sister intentionally drove her car over his foot was not a false report justifying his arrest. The court remanded for further proceedings. View "Michael v. Trevena" on Justia Law

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The Eighth Circuit reversed the district court's denial of a petition for habeas relief based on petitioner's claim that he is intellectually disabled. In this case, the district court did not have the benefit of the Supreme Court's decision in Moore v. Texas, 137 S. Ct. 1039 (2017), when it conducted its evidentiary hearing and issued its order. Accordingly, the court remanded for the district court to consider petitioner's claim in light of Moore. View "Jackson v. Kelley" on Justia Law