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

Articles Posted in Constitutional Law

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Plaintiff filed a 42 U.S.C. 1983 action for damages, alleging that the city, the police department, and an officer violated plaintiff's constitutuional rights when he was detained and tased as part of an arrest. The Eighth Circuit affirmed the district court's grant of summary judgment to the city, because plaintiff failed to provide the evidence to support his claims of municipal liability. In this case, plaintiff has not presented any evidence to suggest that the city has created, adopted, or supported any policy or custom that would demonstrate municipal liability. The court affirmed the grant of summary judgment to the officer on the First Amendment claim, where, as here, speech and nonspeech elements combine in the same course of conduct, a sufficiently important government interest in regulating the nonspeech element can justify incidental limitations on First Amendment freedoms. In regard to the excessive force claims against the officer, the court held that the first and third tasings were objectively reasonable, but there was a genuine issue of material fact as to whether the second tasing amounted to excessive force. Accordingly, the court reversed in part and remanded for further proceedings. View "Jackson v. Stair" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against Arkansas prison officials, alleging deprivations of his constitutional rights while incarcerated. Plaintiff's claims stemmed from his almost seven month detention in administrative segregation. The Eighth Circuit affirmed on the alternative ground that the complaint failed to adequately allege a violation of plaintiff's clearly established constitutional rights and therefore defendants were entitled to qualified immunity. The court explained that, although defendants did not raise qualified immunity in their motion to dismiss, the posture of the case has materially changed, and the court saw no bar to addressing qualified immunity. In regard to plaintiff's claim of deliberate indifference to his serious medical needs, the court held that defendants did not violate his clearly established rights. In this case, the nine occasions when plaintiff did not receive his daily treatment during his time in administrative segregation were insufficient to create an Eighth Amendment claim. In regard to plaintiff's claims related to his conditions of confinement, the court held that plaintiff failed to cite circuit precedent holding that an inadequate justification for administrative segregation or shortcomings in review of a prisoner's placement violates the Due Process Clause; defendants' conduct did not violate clearly established law; and it was not beyond debate that defendants curtailed plaintiff's liberty interest by segregating a prisoner with plaintiff's particular medical condition for 203 days under the conditions alleged. View "Hamner v. Burls" on Justia Law

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Plaintiffs, a class of civilly committed residents, appealed the dismissal of their claims against state officials, alleging that the state's commitment provisions are facially unconstitutional, and that the treatment program as applied to the residents violates their substantive due process rights. The Eighth Circuit affirmed, holding that plaintiffs did not assert a typical substantive due process claim but, rather, they contend that defendant officials must change the way that they conduct annual reviews of civilly-committed persons, design procedures for releasing low-risk residents into less restrictive housing, and carry out a statutory duty to authorize petitions for release of low-risk residents. The court held that an entitlement to these actions is not deeply rooted in the Nation's history and tradition or implicit in the concept of ordered liberty. In this case, plaintiffs had procedures available to them that were sufficient to vindicate their liberty interest in gaining release from detention once the reasons that justified the commitment dissipate. The court explained that the fact that the Act provides additional opportunities to facilitate release, and that state officials allegedly have failed to implement them properly, does not run afoul of substantive due process. In the alternative, the court held that the shortcomings cited by the district court in Missouri mirror those that Karsjens v. Piper, 845 F.3d 394 (8th Cir. 2017), held were not conscience-shocking in Minnesota. Accordingly, the district court correctly reasoned that the as-applied substantive due process claims should be dismissed. Finally, there was no reversible error in the district court's conclusion that plaintiffs abandoned their state law claims. View "Van Orden v. Stringer" on Justia Law

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The Eighth Circuit affirmed the district court's denial of plaintiff's petition for habeas corpus relief. The court held that plaintiff's counsel's representation did not fall below an objective standard of reasonableness, and even if it did, plaintiff has not demonstrated that he was prejudiced. The court also held that, even assuming that plaintiff fairly presented his claim to the state court, his claim failed where considering an aggravating factor in violation of a state statute alone does not amount to a constitutional violation meriting federal habeas relief. Finally, the court held that the tools were available to plaintiff to make his arguments -- that his youth at the time of the offense and the serious mental illnesses categorically exempt him from the death penalty -- before the state court, he failed to show cause, and his procedural default was not excused. View "Anderson v. Kelley" on Justia Law

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Plaintiff filed suit against two officers, Hawkins and Swinton, for civil conspiracy and one of the officers, Hawkins, for excessive force and performing an unreasonable search. The Eighth Circuit reversed the district court's grant of summary judgment on the civil conspiracy and excessive force claims, holding that plaintiff failed to allege sufficient facts to support her claims. In this case, plaintiff failed to allege the existence of an agreement between the officers for the conspiracy claim. Furthermore, it was not clearly established at the time that the amount of force used by Hawkins was excessive considering the injuries sustained by plaintiff were minor. However, the court affirmed the district court's denial of summary judgment to Hawkins on the unreasonable search claim, because issues of material fact remain as to whether Hawkins' search was reasonable. The court stated that a reasonable jury could conclude that the search was unreasonable in both scope and manner. Finally, the district court did not err in denying Hawkins qualified immunity on plaintiff's unreasonable search claim. The court remanded for further proceedings. View "Robinson v. Hawkins" on Justia Law

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Plaintiffs filed suit against the University under Title IX of the Education Amendments of 1972 and various state laws, alleging that the University failed to protect them against stalking and sexual harassment by a fellow student. The Eighth Circuit affirmed the district court's grant of summary judgment to the University, holding that, because Plaintiff Kirkpatrick could not satisfy the actual knowledge element, her Title IX claim failed as a matter of law and the district court properly granted summary judgment in favor of the University on that claim; the district court properly granted summary judgment to the University on Pearson's Title IX claim because there was no genuine dispute of material fact as to whether the University was deliberately indifferent to any stalking or harassment that she experienced; and the district court properly dismissed plaintiffs' state law premises liability and general negligence claims, because plaintiffs could not establish that the school owed them a duty of care under Missouri law. View "Pearson v. Logan University" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983, alleging that Officers Bryant and Oldham used excessive force in violation of the Fourth Amendment when they arrested her and her minor son. The Eighth Circuit reversed the district court's denial of summary judgment based on qualified immunity. The court held that the officers' actions did not violate plaintiff and her son's clearly established rights, because there was no controlling authority at the time establishing a right to be free from any of the three tasings applied to plaintiff. The situation in this case involved aggressive behavior and a chaotic combative scene. Therefore, the court held that plaintiff failed to identify a robust and consensus of cases that placed the excessive force question beyond debate at the time of the violation. The court also held that Oldham did not violate a clearly established right by handcuffing the son's wrists behind his back. View "Rudley v. Bryant" on Justia Law

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After plaintiff, an attorney, discovered that SBAND was using his compulsory dues to oppose a state ballot measure he supported, plaintiff filed suit against SBAND and various state officials in their official capacities, alleging First Amendment claims. The district court granted summary judgment for defendants and the Eighth Circuit affirmed. A year later, the Supreme Court issued its decision in Janus v. American Federation of State, County, and Municipal Employees, 138 S. Ct. 2448 (2018). On remand from the Supreme Court, the Eighth Circuit again affirmed the district court's judgment and held that Janus did not alter its prior decision explaining why the district court did not err in granting summary judgment dismissing plaintiff's claim that SBAND's procedures violate his right to "affirmatively consent" before subsidizing non-germane expenditures. The court held that plaintiff forfeited his claim that mandatory state bar association membership violates the First Amendment by compelling him to pay dues and to associate with an organization that engages in political or ideological activities; SBAND's revised fee statement and procedures clearly do not force members to pay non-chargeable dues over their objection; nothing in the summary judgment record suggests that SBAND's revised fee statement is so confusing that it fails to give SBAND members adequate notice of their constitutional right to take the Keller deduction. View "Fleck v. Wetch" on Justia Law

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Where a plaintiff seeks damages based on alleged illegal actions of a municipal official, there is no authority to award damages against the municipality when the jury concludes that the official committed no wrong. Plaintiff filed suit against the city and the mayor under 42 U.S.C. 1983, alleging that defendants discriminated against him based on race in violation of 42 U.S.C. 1981. The jury returned a verdict in favor of the mayor but against the city. The Eighth Circuit reversed and held that, because there was no race discrimination violation of section 1981, the city could not be held liable for damages under section 1983. In this case, plaintiff did not challenge the jury's finding that the mayor did not discriminate against him based on race and there was insufficient evidence that any other city official, or combination of the mayor or other municipal officers or employees, discriminated against plaintiff based on race. View "Ridgell v. City of Pine Bluff" on Justia Law

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The Eighth Circuit affirmed the district court's denial of defendant's motion to correct his sentence under 28 U.S.C. 2255 based on Johnson v. United States, 135 S. Ct. 2551 (2015). The court held that Johnson did not justify relief in this case, because defendant's prior conviction for first degree assault qualified as a violent felony under the force clause. Therefore, defendant was not sentenced based on the residual clause and failed to satisfy the requirements for proceeding with a successive motion under section 2255(h)(2). View "Unverzagt v. United States" on Justia Law