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

Rinchem Company, Inc. fired Jeffrey Sherman after Sherman alleged lied in the course of Rinchem's investigation of complaints about his behavior. Sherman disputed Richem's allegation and contended that Rinchem's accusation defamed him and compelled him to reveal to prospective employers that he had been fired for lying. The district court granted summary judgment to Rinchem on Sherman's defamation claim. Sherman appealed, arguing that the district court (1) should have granted his motion for summary judgment as a sanction for spoliation of evidence, or, in the alternative, an adverse-inference instruction; and (2) erred in granting summary judgment on his defamation claim. The Eighth Circuit Court of Appeals affirmed, holding (1) federal law applies to the imposition of sanctions for the spoliation of evidence, and the district court did not abuse its discretion by denying a sanction for the spoliation of evidence, as Sherman conceded that Richem did not act in bad faith; and (2) the district court did not err in granting summary judgment on Sherman's spoliation of evidence claim, as Rinchem was entitled to qualified privilege that defeated the claim. View "Sherman v. Rinchem Co., Inc." on Justia Law

Plaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity. View "Williams v. Herron" on Justia Law

Toni Duncan sued her former employer, Dakota County, Nebraska, under 42 U.S.C. 1983 for hostile-work-environment sexual harassment and constructive discharge in violation of the Equal Protection Clause of the Fourteenth Amendment. Duncan also sued Sheriff James Wagner and her supervisor, Chief Deputy Rodney Herron, in their individual capacities. The district court (1) granted summary judgment to Wagner; and (2) denied the motions for summary judgment by the County and Herron on the basis of qualified immunity. The Eighth Circuit Court of Appeals reversed in part, holding that Herron was entitled to qualified immunity on Duncan's claim, as Herron did not violate Duncan's right to equal protection. Remanded. View "Duncan v. Herron" on Justia Law

Plaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment. View "Crutcher-Sanchez v. Wagner" on Justia Law

Mischelle Richter appealed (1) the district court's order dismissing her retaliation claims under Title VII and the Missouri Human Rights Act for failure to exhaust administrative remedies, and (2) the dismissal of her wrongful discharge claim under Missouri law for failure to state a claim upon which relief may be granted. The Eighth Circuit Court of Appeals (1) affirmed the district court's dismissal of the retaliation claims, holding that Richter did not properly exhaust her retaliation claims; but (2) reversed and remanded on the state-law wrongful discharge claim, holding that Richter alleged sufficient facts to state a wrongful discharge claim under Missouri law. View "Richter v. Advance Auto Parts, Inc." on Justia Law

In this diversity action involving Minnesota's Whistleblower Act, Appellant Ann Hilt alleged that her employer, St. Jude Medical S.C., Inc., decided to terminate her based, in part, on her reports concerning St. Jude's illegal conduct and her participation in a government investigation. The district court granted summary judgment in favor of St. Jude. The Eighth Circuit Court of Appeals affirmed the judgment of the district court, holding that Hilt failed to present sufficient evidence to demonstrate that St. Jude's proffered reasons for including her in the St. Jude's ten percent reduction in force was a pretext for a retaliatory motive. View "Hilt v. St. Jude Med. S.C., Inc." on Justia Law

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees. View "Marez v. Saint-Gobain Containers, Inc." on Justia Law

Shirley Frisby died from an apparent heart attack while working on an assembly line at Milbank Manufacturing Company in Arkansas. A claim for workers' compensation death benefits was filed just before the two-year statute of limitations expired. The Arkansas Workers' Compensation Commission denied the claim. Curtis Frisby, as administrator of his wife's estate, then commenced this wrongful death diversity action against Milbank. The district court dismissed the action as time barred. Curtis appealed, arguing that the filing of a workers' compensation claim tolls the statute of limitations for a tort claim against the employer for the same injury, and alternatively, that the Arkansas "savings statute" applies and provided him one year after the workers' compensation claim denial to file this action for the same injury. The Eighth Circuit Court of Appeals affirmed, holding (1) because Curtis was able to file a timely wrongful death tort action before or concurrent with the claim for workers' compensation benefits, the district court correctly rejected his tolling argument; and (2) the savings statute did not apply because the dismissal of the workers' compensation claim did not have the same effect as a nonsuit. View "Frisby v. Milbank Mfg. Co." on Justia Law

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims. View "Bone v. G4S Youth Servs., LLC" on Justia Law

Appellant brought this action under 42 U.S.C. 1983 against the Kansas City Board of Police Commissioners and its members, the chief of police, and certain police officers, alleging constitutional violations under the Fourth and Fourteenth Amendments of the Constitution. The district court dismissed the action for failure to exhaust administrative remedies, reasoning Title VII of the Civil Rights Act of 1964 provided the exclusive remedy for Appellant's claims and Appellant could not circumvent the Act's procedural requirements by solely pleading constitutional violations under section 1983. The Eighth Circuit Court of Appeals reversed, holding that to the extent that Appellant's complaint asserted the violation of rights secured by the Constitution and committed by persons acting under color of state law, the district court erred in dismissing her section 1983 action for failure to comply with Title VII's procedural requirements. View "Henley v. Brown" on Justia Law