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

Plaintiff filed suit against correctional officers and medical staff under 42 U.S.C. 1983, after he spent three and a half hours on a restraint board. The district court dismissed all claims except an Eighth Amendment excessive force claim against Lieutenant Jeff Gutzmer, who authorized use of the restraint board. The Eighth Circuit held that the district court erred as a matter of law when it denied qualified immunity to Gutzmer. The court held that Gutzmer was entitled to qualified immunity if the totality of the circumstances justified use of the restraint board even if Gutzmer erred in believing plaintiff was self-injurious when placed on the board. In this case, plaintiff violated rules for obtaining medical assistance, falsely claimed a medical emergency, and seriously disrupted ACU operations; discipline was warranted after nurses reported that plaintiff had contrived a medical emergency and could safely be placed on the restraint board; and employing the restraint in accordance with the safety precautions required by prison policy was needed to preserve internal order and discipline and to maintain institutional security. View "Jackson v. Gutzmer" on Justia Law

After plaintiff was arrested and charged with hindering, obstructing, resisting, or otherwise interfering with Kansas City police officers in violation of Kansas City Ordinance 50-44(a), he filed suit against the arresting officers and police officials for various claims. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that summary judgment on the malicious prosecution claim was proper where the officers had probable cause to arrest plaintiff; plaintiff's fabrication of evidence claim failed where any misleading impression the incident report may leave as to the order of events demonstrated at most negligence; and because plaintiff's 42 U.S.C. 1983 claim of fabrication of evidence was properly dismissed, the civil conspiracy claim based on the alleged fabrication also failed. View "Riddle v. Riepe" on Justia Law

Plaintiff filed suit against three state officials to challenge provisions of Missouri law that authorize roving stops of certain vehicles for inspection without suspicion. The Eighth Circuit held that plaintiff had standing to sue the superintendent, and his claims against her for injunctive and declaratory relief were not barred by the Eleventh Amendment; claims against the governor and the attorney general were properly dismissed, because there was no case or controversy between plaintiff and those officials; Mo. Rev. Stat. 304.230.1, .2, and .7 can be applied constitutionally to participants in the commercial trucking industry under New York v. Burger, 482 U.S. 691 (1987), and the provisions were not unconstitutional on their face; but it was error for the district court to dismiss plaintiff's as-applied claims against the superintendent for declaratory and injunctive relief based on the meaning of "person" under 42 U.S.C. 1983. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Calzone v. Hawley" on Justia Law

After her son was shot approximately 10 times and killed by the police, plaintiff filed suit against defendants, alleging excessive force and wrongful death under state law. The Eighth Circuit reversed the dismissal of the excessive force claims against the officers, holding that plaintiff demonstrated that there were at least two genuine disputes of material fact: (1) whether the officers saw plaintiff's son throw his gun and therefore knew he was unarmed, and (2) whether he was turning around to the officers with his hands raised to surrender. The court held, however, that there was insufficient evidence for a rational jury to conclude the officers acted with malice or in bad faith. Therefore, the court affirmed the grant of summary judgment and dismissal as to the wrongful death claims. The court reversed in all other respects and remanded. View "Wealot v. Brooks" on Justia Law

Plaintiff filed suit seeking a preliminary injunction against enforcement of Minn. Stat. 325E.27(a), which restricts the use of robocalls. The court affirmed the district court's denial of the motion, holding that plaintiff was unlikely to succeed on his First Amendment claim. The court held that Van Bergen v. Minnesota, 59 F.3d 1541 (8th Cir. 1995), was controlling in this case. Van Bergen concluded that the first three exceptions in subsection (b) were not content-based restrictions, but were valid time, place, and manner restrictions. The court also held that the content-based exception for tax-exempt charitable organizations, which was added to the statute in 2009, was severable from the rest of the statute. View "Gresham v. Swanson" on Justia Law

Large crowds gathered in Ferguson, Missouri after Michael Brown, Jr. was killed by a police officer. Six sets of plaintiffs filed suit alleging multiple claims related to the police response to the largely peaceful demonstrations. The district court granted summary judgment to defendants, concluding that the individual defendants were entitled to qualified immunity on plaintiffs' 42 U.S.C. 1983 claims for unlawful arrest and excessive force. The Eighth Circuit affirmed in part, reversed in part, and remanded on claims alleged by Plaintiffs Nathan Burns; Damon Coleman and Theophilus Green; Antawn Harris; Kerry White, Sandy Bowers, and Kai Bowers; Tracey White and William Davis; and DeWayne Mathews. View "White v. Jackson" on Justia Law

The Eighth Circuit affirmed the district court's denial of summary judgment to Bi-State in a False Claims Act (FCA), action brought by a private actor. Bi-State is an interstate compact entity that owns and operates public transportation services. After determining that the Barket factors point in two different directions, the court turned to the "Eleventh Amendment's twin reasons for being" as its "prime guide" in determining whether Bi-State was more like an arm of the state or a local government entity. In this case, the twin reasons for being, respect for the dignity of the states as sovereigns and the prevention of federal-court judgments that must be paid out of a State's treasury, weigh in favor of finding that Bi-State was more like a local government entity. Therefore, Bi-State does not enjoy the special constitutional protection of the States themselves and was not entitled to Eleventh Amendment sovereign immunity. View "United States ex rel Fields v. Bi-State Development Agency" on Justia Law

The Eighth Circuit affirmed the dismissal of plaintiff's complaint alleging a Title IX student-on-student harassment claim against Culver-Stockton College after she was allegedly sexually assaulted by a Culver-Stockton student on campus. The court held that, assuming arguendo that plaintiff's status as a non-student did not preclude her from asserting a Title IX harassment claim, the complaint failed to state a plausible claim to survive dismissal under Fed. R. Civ. P. 12(b)(6). In this case, plaintiff failed to plausibly allege that the college acted with deliberate indifference, the college had actual knowledge of discrimination, and that either the alleged misconduct or the college's response to plaintiff's allegations had the required systemic effect such that she was denied equal access to educational opportunities provided by the college. View "K.T. v. Culver-Stockton College" on Justia Law

After the City revoked his rental licenses, plaintiff filed suit alleging that the City violated 42 U.S.C. 1983 by subjecting plaintiff to the deprivation of his rights, privileges, or immunities under the Fourth and Fourteenth Amendments to the United States Constitution. The Eighth Circuit affirmed the district court's grant of the City's motion for summary judgment on the Fourth and Fourteenth Amendment claims. The court held that plaintiff had not demonstrated, as a matter of law, that the City violated his substantive-due-process rights under the Fourteenth Amendment. The court also held that the City's conduct was not arbitrary, oppressive, and shocking to the conscience, and there was no genuine dispute of material fact regarding whether the City violated plaintiff's Fourth Amendment rights. In this case, plaintiff did not have a reasonable expectation of privacy in the common spaces entered by the City's police officers, and any argument that the police officers may have physically intruded on constitutionally protected areas by trespassing in his buildings to search for incriminating evidence was waived. View "Azam v. City of Columbia Heights" on Justia Law

North Dakota may enforce the suspend-and-reimburse provisions of N.D.C.C. 65-05-05(2). The Eighth Circuit held that the reimbursement provision readily passed rational basis scrutiny and was not subject to equal protection or substantive due process challenges. Furthermore, the cost and difficulty of recovering benefits paid during the suspension period were a rational basis for the suspension provision. The court also held that the suspension provision did not violate North Dakota's constitutional obligation to provide full faith and credit to Colorado's death benefits provision. Accordingly, the court affirmed the district court's judgment on the pleadings for WSI. View "DeCrow v. North Dakota Workforce Safety & Insurance Fund" on Justia Law