Justia U.S. 8th Circuit Court of Appeals Opinion SummariesArticles Posted in Constitutional Law
Pribyl v. County of Wright
Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA). The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory. View "Pribyl v. County of Wright" on Justia Law
In Re: Grand Jury Subpoena Dated August 14, 2019
An August 14, 2019 subpoena duces tecum ordered the IDPS to appear before the court's grand jury and provide documents relating to the investigation of an ISP officer for misconduct or use of excessive force. IDPS complied with five of the listed document categories but filed a motion to quash categories 3 and 4, which seek any and all records relating to the investigation of Officer John Doe for misconduct and any and all records relating to complaints made against Officer John Doe. The Eighth Circuit affirmed the district court's order denying IDPS's motion to quash and rejected IDPS's assertion that quashing the subpoena is needed to protect the Fifth Amendment rights of IDPS employees who participated in internal investigations; the procedural protections established by Kastigar v. U.S., 406 U.S. 401 (1972), and Garrity v. New Jersey, 385 U.S. 493 (1967), provide sufficient protection from the improper use of compelled statements; the Fifth Amendment allows the government to prosecute using evidence from legitimate independent sources; and the district court did not abuse its Federal Rule of Criminal Procedure 17(c)(2) discretion in deciding that IDPS failed to meet its substantial burden to show that compliance with the challenged portions of the grand jury subpoena would be "unreasonable or oppressive" when balanced against the interests of the government in enforcing the subpoena. View "In Re: Grand Jury Subpoena Dated August 14, 2019" on Justia Law
Shelton v. Stevens
Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force and seeking damages for injuries sustained during plaintiff's arrest. The district court denied the officer's motions for summary judgment. The Eighth Circuit agreed with the district court that, on balance, the challenged use of force was unreasonable, but that the question is not beyond debate, and the right at issue was thus not clearly established. In this case, officers were attempting to arrest plaintiff for his role in a brutal beating, plaintiff fled from officers at high speed for several miles while armed with a handgun and ammunition, and a foot race ensued after the car chase where five officers pinned plaintiff. While the officers pinned plaintiff, plaintiff refused to surrender his hands and the officers reasonably believed that plaintiff's position posed a threat to officer safety, because at least one of his hands was unrestrained in an area of his body where weapons could be concealed. Therefore, the court held that it was objectively reasonable for officers to apply some amount of supplemental force in order to gain control of plaintiff's hands and to restrain him. However, the court held that the officer's use of force was unreasonable under the Fourth Amendment. The court stated that a stomp on the ankle with sufficient force to break it was excessive when the legitimate objective was to facilitate restraint of plaintiff's hands while he was pinned to the ground by several officers. The court stated that a number of the relevant factors supported the use of force, so reasonableness was a matter of degree, and qualified immunity protects officers from the specter of lawsuits and damages liability for mistaken judgments in gray areas. Accordingly, the court reversed the denial of qualified immunity. View "Shelton v. Stevens" on Justia Law
Horton v. Midwest Geriatric Management
Plaintiff filed suit under Title VII against Midwest after it allegedly withdrew his job offer after learning that he was gay. The Eighth Circuit reversed the district court's dismissal based on Williamson v. A.G. Edwards & Sons, Inc., 876 F.2d 69, 70 (8th Cir. 1989), and remanded for further proceedings in light of the Supreme Court's decision in Bostock v. Clayton Cty., 590 U.S. ___, Nos. 17-1618, 17-1623, 18-107, slip op. at 4 (June 15, 2020), which held that it "defies" Title VII for "an employer to discriminate against employees for being homosexual or transgender," because to do so, it "must intentionally discriminate against individual men and women in part because of sex." View "Horton v. Midwest Geriatric Management" on Justia Law
Kingsley v. Lawrence County
The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's 42 U.S.C. 1983 claims against the county, the sheriff, and two deputy sheriffs. The court held that Deputy Ford was entitled to qualified immunity on the Fourth Amendment false arrest claim where he had probable cause to make the warrantless arrest of plaintiff. In this case, prior to arresting plaintiff, Deputy Ford was told by his dispatcher that plaintiff had tried to stab the victim; the victim gave both oral and written statements about the incident; and other evidence corroborated the victim's statements. The court also held that the sheriff and the second deputy are entitled to qualified immunity on the Fourth Amendment false arrest claim; the officers are entitled to qualified immunity on plaintiff's Fourteenth Amendment substantive due process claim for failure to investigate; plaintiff's section 1983 civil conspiracy claim failed as a matter of law because plaintiff failed to establish that he was deprived of a constitutional right or privilege; and in the absence of a constitutional violation, plaintiff's Monell claim also failed. View "Kingsley v. Lawrence County" on Justia Law
Rinehart v. Weitzell
The Eighth Circuit reversed the district court's sua sponte dismissal of plaintiff's in forma pauperis complaint as failing to state a claim under the Americans with Disabilities Act (ADA). Plaintiff is currently serving a prison sentence and has a diagnosis of diverticulitis, a chronic colon condition that causes diarrhea and constipation. The court held that plaintiff has stated a Title II claim by sufficiently alleging that he is a qualified individual with a disability under the ADA and that he was denied the benefit of the prison's privilege system by reason of his disability. The court also held that plaintiff has stated a claim under Title VI and that defendants retaliated against him for his filing of ADA grievances by taking the adverse action of rescinding his medical classification without providing a medical reevaluation or rationale. Finally, because plaintiff's complaint sufficiently states a claim upon which relief may be granted, the court necessarily reversed the district court's assignment of a strike under the Prison Litigation Reform Act. View "Rinehart v. Weitzell" on Justia Law
Yearns v. Koss Construction Co.
The Eighth Circuit affirmed the district court's grant of summary judgment to Koss in an action brought by plaintiff, a former employee, alleging that Koss terminated her employment in retaliation for her complaints about pay discrimination based on sex in violation of the Equal Pay Act (EPA). The court held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to pretext. In this case, plaintiff failed to present sufficient evidence as to the question of whether there was no basis in fact for Koss's proffered reason for her termination: there was lack of work at the project. The court also held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact on the question of whether a retaliatory reason more likely motivated the manager's decision to terminate her. View "Yearns v. Koss Construction Co." on Justia Law
Button v. Dakota, Minnesota & Eastern Railroad Corp.
Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent. The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination. View "Button v. Dakota, Minnesota & Eastern Railroad Corp." on Justia Law
Stockley v. Joyce
The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants under 42 U.S.C. 1983 and state law, stemming from plaintiff's acquittal of a first degree murder charge. Plaintiff was a St. Louis Metropolitan Police Department (SLMPD) officer at the time he shot and killed a fleeing suspect. The court held that the district court did not err in dismissing plaintiff's claims against the city prosecutor based on absolute immunity; the prosecutor's decision that there was sufficient evidence to end the investigation, even after only one day, and charge plaintiff with first degree murder clearly falls within the prosecutorial function of initiating judicial proceedings; and, even if the prosecutor's termination of the investigation and initial decision declining to prosecute plaintiff could be construed as indicating that she had an improper motive, allegations of unethical conduct and improper motive in the performance of prosecutorial functions did not defeat the protection of absolute immunity. The court also held that plaintiff failed to state a substantive due process claim against the prosecutor based on her public statements where the conduct did not rise to the level of conscience-shocking. Finally, plaintiff failed to state a defamation claim against the prosecutor. The court also held that the district court did not err in dismissing the section 1983 and malicious prosecution claims against a sergeant in the police department's Internal Affairs Division in his individual capacity. Furthermore, the district court properly dismissed the Monell claim against the city where the prosecutor's decision to terminate the investigation and charge plaintiff was an individual charging decision based upon a particular set of facts supported by arguable probable cause. View "Stockley v. Joyce" on Justia Law
Williams v. United Parcel Service, Inc.
The Eighth Circuit affirmed the district court's grant of summary judgment to UPS in an action brought by plaintiff for retaliation and discrimination under 42 U.S.C. 1981. The court held that plaintiff's retaliation claim failed because he cannot link protected conduct with his demotion. In this case, plaintiff concedes that his supervisor and his supervisor's supervisor did not know about the statements plaintiff made on two different occasions. The court also held that plaintiff's race discrimination claim failed at the third step of the McDonnell Douglas framework because UPS provided a legitimate, non-discriminatory basis for the action: plaintiff was failing to perform his duties. Furthermore, plaintiff failed to raise a genuine issue of material fact as to whether UPS's explanation for his demotion was pretext for discrimination. View "Williams v. United Parcel Service, Inc." on Justia Law