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

Plaintiff, a former jail administrator, filed suit under 42 U.S.C. 1983 and the Peace Officer Discipline Procedures Act (PODPA), alleging claims related to his termination. The Eighth Circuit affirmed the district court's grant of summary judgment to the County and held that, regardless of whether plaintiff held a constitutionally protected interest in his employment, the process surrounding his termination satisfied the Due Process Clause. The court also held that plaintiff was not entitled to the additional protections of PODPA given his actual duties as Assistant Jail Administrator and given the fact that the County neither charged him with the duties of general law enforcement nor utilized his services for those purposes. View "Pena v. Kindler" on Justia Law

Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law

Plaintiff, an African American farmer, filed suit against the USDA and others, alleging racial discrimination, retaliation, and conspiracy regarding his loan applications, servicing requests, and the application of administrative offsets to collect on a defaulted loan. The district court dismissed the complaint with prejudice. The Eighth Circuit reversed the district court's conclusions that plaintiff's Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691 et seq., claims were barred by res judicata and collateral estoppel because the Office of the Assistant Secretary for Civil Rights could not bar subsequent federal litigation; the individual defendants have not demonstrated that plaintiff failed to state an ECOA claim against them where the complaint included sufficient allegations from which one could plausibly infer that the individual defendants qualified as creditors under the ECOA; the district court erred in dismissing plaintiff's Bivens claims against the individual defendants in their individual capacities because his constitutional claims were not barred by a comprehensive remedial scheme; and plaintiff failed to state a claim for conspiracy against the individual defendants. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Johnson v. Perdue" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity and dismissal of the City's appeal for lack of jurisdiction in an action alleging violation of plaintiff's civil rights after she was arrested for possession of methamphetamine. The court held that Officer Cotton violated no constitutional right by arresting plaintiff and was entitled to qualified immunity for the arrest; Officer Delezene was not entitled to qualified immunity because plaintiff's allegations were based on disputed material facts and thus summary judgment was not appropriate in this case; and the court lacked jurisdiction to hear the City's appeal. View "Manning v. Cotton" on Justia Law

Plaintiffs Combs and Williams, on behalf of themselves individually and others similarly situated, filed a race discrimination suit against several entities with the District. Plaintiffs alleged that defendants engaged in a pattern and practice of racial discrimination that interfered with the ability of African American men to patronize bar and restaurant establishments in the District. The district court granted summary judgment to all defendants. The Eighth Circuit held that Combs was not judicially estopped from certain claims because they had not been listed as assets in his bankruptcy petition, and thus the district court abused its discretion by applying judicial estoppel to claims involving Defendants Mosaic and Tango. On the merits, there was insufficient evidence to support a rabbit scheme at Maker's Mark and LiveBlock. Furthermore, summary judgment was properly granted to Defendant First Response because plaintiffs failed to establish that First Response employed the security guards who escorted Combs out of the LiveBlock. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Combs v. The Cordish Companies, Inc." on Justia Law

Plaintiff filed suit against Nebraska and others, alleging negligence, unlawful taking of property for public use under Nebraska law, and a deprivation of federal rights under 42 U.S.C. 1983, after his true name and picture mistakenly appeared on the Nebraska State Patrol's online sex offender registry. The Eighth Circuit held that even if plaintiff's pleading was sufficient to state a claim of negligence against defendants, his claim was barred by the two-year statute of limitations of the Nebraska State Tort Claims Act; plaintiff's claim of unlawful takings failed because he did not allege that any property was taken or damaged for public use; the district court properly dismissed under Rule 12(b)(1) the official-capacity claims and the claim against the State as they were pleaded; and the district court properly dismissed the section 1983 claims against the state employees in their individual capacities because a mistake or lack of due care by state employees in a particular circumstance did not establish invidious or irrational treatment that could violate the Equal Protection Clause. Accordingly, the court affirmed the judgment. View "Roe v. Nebraska" on Justia Law

Plaintiff filed suit alleging that the union had violated the Missouri Human Rights Act (MHRA) by failing to accommodate his disability, by discriminating against him based on his disability, and by retaliating against him for reporting his disability and seeking accommodation. The district court determined that the claims were preempted under section 301(a) of the Labor Management Relations Act (LMRA) and section 9(a) of the National Labor Relations Act (NLRA), and that the statute of limitations had expired on those federal claims. The Eighth Circuit held that, because plaintiff's state-law claims were not completely preempted by section 301(a) of the LMRA or section 9(a) of the NLRA, the district court lacked removal jurisdiction over this case. Accordingly, the court vacated and remanded. View "Markham v. Wertin" on Justia Law

Minnesota state law grants a child attending a nonpublic school the right to a free appropriate education (FAPE), as well as the right to dispute the provisions of special education services in an impartial due process hearing. In this case, R.M.M. and her parents have a right, under both state and federal law, to an impartial due process hearing to dispute the provision of a FAPE by MPS. Accordingly, the court affirmed the district court's judgment. View "Special School District No. 1 v. R.M.M." on Justia Law

The Eighth Circuit reversed the district court's adverse grant of summary judgment on plaintiff's employment claim alleging retaliatory termination. The court held that a reasonable jury could conclude that her protected action was the but-for cause of her termination. In this case, it was undisputed that plaintiff's letter complaining of unequal pay based on her sex was a protected act and that she suffered an adverse employment action. View "Donathan v. Oakley Grain, Inc." on Justia Law

Plaintiffs filed suits against Hiland Dairy, alleging race discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and Nebraska law. The Eighth Circuit held that, because plaintiffs failed to produce direct evidence of discrimination, the court must apply the McDonnell Douglas burden-shifting framework. Applying the framework, the court held that Hiland Dairy satisfied its burden by articulating and presenting evidence of a legitimate and indiscriminatory reason for firing them. In this case, Hiland Dairy cited "theft of time" and dishonest conduct as reasons for termination. The court rejected plaintiffs' claim that they were disciplined more severely than similarly-situated white employees because the reasons Hiland Dairy gave were significant and sufficient distinctions making the situations not similarly situated in all relevant respects. The court rejected plaintiffs' remaining contentions and affirmed the judgment. View "Edwards v. Hiland Roberts Dairy" on Justia Law