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

Articles Posted in Constitutional Law
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Plaintiff, a former employee of the Pine Bluff Arsenal, filed suit against the Army under Title VII of the Civil Rights Act of 1964, alleging that she was subject to a hostile work environment based on sex and that the Army retaliated against her after she reported sexual harassment. The district court entered summary judgment in favor of the Army.The Eighth Circuit concluded that the district court did not err in granting summary judgment in favor of the Army on plaintiff's hostile work environment claim where she failed to establish that the harassment she experienced was sufficiently severe or pervasive to alter the conditions of her employment and create an abusive working environment. However, the court concluded that the district court erred in granting summary judgment in favor of the Army on plaintiff's retaliation claim where she presented enough admissible evidence to raise a genuine doubt as the legitimacy of the Army's stated motive for her termination. Accordingly, the court remanded this claim for further proceedings. View "Hairston v. Wormuth" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the City in an action brought by plaintiffs, challenging its enforcement of the City's zoning regulations against them. Plaintiffs' claims stemmed from the City's enforcement of commercial zoning regulations.Even assuming zoning-enforcement decisions are susceptible to class-of-one challenges, the court concluded that plaintiffs have not shown that the City lacked a rational basis for its differential treatment of plaintiffs and other property owners. In this case, plaintiffs have not shown that they are identical or directly comparable to the comparator property owners in every material respect. The court also concluded that plaintiffs did not present sufficient evidence of affirmative misconduct to withstand summary judgment on their equitable-estoppel claim. View "Bruning v. City of Omaha" on Justia Law

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The Eighth Circuit affirmed the district court's denial of a petition for writ of habeas corpus where petitioner alleged that his trial counsel was ineffective for not providing closing argument during the penalty phase of his capital-murder trial. Petitioner, though advised otherwise, insisted that his trial counsel forgo closing argument.The panel concluded that petitioner's informed, voluntary decision prevented his attorney's reluctant compliance with petitioner's wishes from subsequently becoming ineffective assistance of counsel. The court explained that the nature of the decision to forego oral argument, whether fundamental or one of trial strategy, does not alter this result. Therefore, petitioner's ineffective assistance-of-counsel claim is procedurally defaulted and barred. View "Taylor v. Steele" on Justia Law

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Plaintiff, a tenured professor, filed suit against MSCU, the University, and five University employees, under 42 U.S.C. 1981 and 1983, claiming various discrimination and retaliation counts. Plaintiff's complaint stemmed from a series of decisions made between 2013 and 2016 about faculty class schedules, resource allocation, and participation in certain programs. Plaintiff, a Black man born in Nigeria, claimed the individual defendants made these adverse decisions against him because of his race and national origin. Plaintiff also claimed the individual defendants retaliated against him for an earlier lawsuit against the University, and for reporting a University employee's alleged discriminatory conduct.The Eighth Circuit affirmed the district court's dismissal of plaintiff's freestanding section 1981 claims, concluding that he was barred from asserting section 1981 retaliation claims against state actors. The court also affirmed the district court's dismissal of plaintiff's section 1983 claims, concluding that plaintiff failed to provide direct evidence of retaliation and thus failed to establish causation. View "Onyiah v. St. Cloud State University" on Justia Law

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Following the death of Justin Stufflebean after he allegedly was denied necessary medication while incarcerated, his parents filed suit alleging that the County and others were liable for wrongful death under Missouri law. The district court denied the County's motion to dismiss, concluding that the County had waived sovereign immunity by purchasing liability insurance that covered the wrongful-death claim.The Eighth Circuit affirmed the district court's denials of the County's motion to dismiss, as well as a related motion for reconsideration, concluding that Mo. Rev. Stat. 537.610(1)'s plain text, bolstered by the statute's purpose and Missouri caselaw, shows that the County's acquisition of liability insurance in this case constitutes a waiver of its sovereign immunity. In this case, the County entered into an inmate-health-services contract with ACH; the contract contained an agreement to pay ACH approximately $300,000 per year; and, in exchange, ACH agreed to provide various services. View "Davis v. Buchanan County, Missouri" on Justia Law

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The Eighth Circuit affirmed the district court's holding that University employees violated InterVarsity's First Amendment rights and denial of qualified immunity. In this case, the University deregistered InterVarsity as a Registered Student Organization based on the University's determination that InterVarsity had violated the University's Policy on Human Rights by requiring its leaders to subscribe to certain religious beliefs.The court agreed with the district court that the University's policy was reasonable and viewpoint neutral, but not as applied to InterVarsity. The court explained that the University's choice to selectively apply the policy against InterVarsity suggests a preference for certain viewpoints over InterVarsity's. Furthermore, these rights were clearly established at the time of the violation. View "Intervarsity Christian Fellowship/USA v. University of Iowa" on Justia Law

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On remand from the Supreme Court in light of Caniglia v. Strom, 593 U.S. ---, 141 S. Ct. 1596 (2021), the Eighth Circuit affirmed the district court's grant of summary judgment for the officers and the City in this action under 42 U.S.C. 1983 and Minnesota state law.The court concluded that it was well established at the time that the community-caretaking exception was a standalone doctrine that could justify the officers' warrantless entry into a home. In the circumstances here, the court concluded that the officers' warrantless entry did not violate plaintiff's Fourth Amendment rights under the then-extant community-caretaking jurisprudence. Therefore, the officers were entitled to qualified immunity with respect to the Fourth Amendment warrantless-entry claim.In regard to plaintiff's claim that the officers violated her Fourth Amendment right to be free from unreasonable seizures when they seized her for a mental-health evaluation, the court affirmed summary judgment and concluded that probable cause of dangerousness is the standard that must be met for a warrantless mental-health seizure to be reasonable under the Fourth Amendment. Furthermore, assuming the officers lacked probable cause here, they may still be entitled to qualified immunity given the ambiguity in the court's case law about the requisite standard. Finally, the officers are entitled to qualified immunity because their actions did not violate clearly established law under the lower reasonable-belief standard some of the court's precedents suggested was the requisite standard.In regard to plaintiff's claim of retaliatory arrest, the court affirmed summary judgment because no reasonable jury could conclude that retaliatory animus was a but-for cause of plaintiff's arrest. In regard to plaintiff's claim that the City's policy concerning seizures for emergency mental-health evaluation was facially unconstitutional, the district court affirmed summary judgment because the policy requires probable cause that the person is a threat to self or others. The court rejected plaintiff's inadequate-training claim and concluded that the officers were entitled either to statutory or official immunity on the state law claims. View "Graham v. Barnette" on Justia Law

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Plaintiff filed suit against Union Pacific in Missouri state court, alleging age discrimination, constructive discharge, and hostile work environment claims under the Missouri Human Rights Act (MHRA). Plaintiff also filed suit against Missouri resident Foster B. McDaniel, claiming that McDaniel aided and abetted Union Pacific in its discriminatory acts. After Union Pacific removed to federal court, the district court granted McDaniel's motion to dismiss and denied plaintiff's motion to remand. The district court later granted Union Pacific's motion for summary judgment on plaintiff's hostile work environment claim.The Eighth Circuit affirmed, concluding that the district court did not err in dismissing McDaniel on the basis of fraudulent joinder because plaintiff's complaint failed to make a colorable claim that McDaniel directly oversaw or was actively involved in discrimination. The court also concluded that the district court did nor err in determining plaintiff did not administratively exhaust his constructive discharge claim. Finally, the court concluded that the district court did not err in granting Union Pacific summary judgment on plaintiff's hostile work environment claim because plaintiff failed to establish age-related harassment sufficiently severe or pervasive to establish the existence of a hostile work environment. View "Henson v. Union Pacific Railroad Co." on Justia Law

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Plaintiff filed suit challenging the constitutionality of a traffic ordinance in St. Louis. Plaintiff's claims arose from her attendance at an event called the Women's March in 2017 where she was arrested for failing to move to the sidewalk. An officer arrested her for violating section 17.16.275 of the Revised Code of St. Louis, which prohibits obstructing traffic. After the charges were dismissed, plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of the ordinance under the First and Fourteenth Amendments.The Eighth Circuit reversed the district court's grant of plaintiff's motion for partial summary judgment. The court concluded that the St. Louis ordinance does not forbid all expressive activities on streets and sidewalks. Instead, it merely forbids a person to position herself in a way that obstructs the reasonable flow of traffic. Therefore, plaintiff has not established that the ordinance unduly restricts free speech in light of the City's legitimate interest in regulating traffic. The court also concluded that the ordinance is not void for vagueness and thus is not unconstitutional on its face. The court further concluded that the ordinance is not unconstitutional as applied to plaintiff where the record does not support a conclusion that police invidiously discriminated against plaintiff based on her speech by selectively enforcing the traffic ordinance. The court remanded with directions to enter judgment for the City. View "Langford v. City of St. Louis" on Justia Law

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Plaintiff filed suit challenging the constitutionality of Arkansas' limits on which candidates can appear on its general-election ballot, Ark. Code 7-7-101. After the district court entered judgment upholding the challenged provisions, plaintiff appealed. While the appeal was pending, the 2020 general election came and went.The Eighth Circuit dismissed plaintiff's appeal as moot, concluding that the "capable-of-repetition-yet-evading-judicial-review" exception to mootness did not apply. The court explained that plaintiff's interest in this case was predicated on his status as an Independent candidate; without such a candidacy, the challenged provisions do not apply to him. However, plaintiff's 2020 Independent candidacy has ended and he has not indicated whether he intends to run as an Independent again. Therefore, this case is no longer "live." Furthermore, plaintiff has failed to show that he is reasonably likely to be subject to the challenged statutory provisions again. View "Whitfield v. Thurston" on Justia Law