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

Plaintiff was terminated from his employment with the City of Victoria, Minnesota. Plaintiff bought an action against his former employer, alleging violations of the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), the Due Process Clause of the Fourteenth Amendment, and state law. The district court granted summary judgment in favor of the City. The Eighth District affirmed, holding (1) summary judgment on Plaintiff's ADA claim was proper; (2) Plaintiff's termination did not violate the ADEA, as Plaintiff was not qualified for the position because of his disability; and (3) Plaintiff was not deprived of property without due process of law by being discharged without a formal hearing. View "Otto v. City of Victoria " on Justia Law

Dr. Lee Davis, an African-American cardiologist, obtained medical-staff privileges at Jefferson Regional Medical Center (JRMC). Later, JRMC's Board of Directors voted to revoke Davis's medical-staff privileges for poor quality of patient care, improper medical documentation, and unprofessional behavior. Davis filed the instant suit in federal district court, alleging, inter alia, race discrimination and retaliation, in violation of 42 U.S.C. 1981 and the Arkansas Civil Rights Act (ACRA), and conspiracy to interfere with his civil rights, in violation of 42 U.S.C. 1985(3). The district court granted summary judgment to Defendants, JRMC, its CEO, and several physicians (Defendants), and dismissed all of Davis's claims. The Eighth Circuit Court of Appeals affirmed, holding (1) because Davis failed to provide any evidence giving rise to an inference that Defendants racially discriminated against him, the district court did not err in granting summary judgment on Davis's race discrimination claims; (2) Davis failed to establish a prima facie case of retaliation under section 1981 and ACRA; and (3) the district court did not err in dismissing Davis's civil rights conspiracy claim pursuant to section 1985(3), as Davis failed to show any racial animus on the part of Defendants.

Appellees entered into performance and stock agreements with their employer, appellant ONEOK, Inc. The agreements required Appellees to continue their employment for three years (performance period) in order to receive the full number of shares, but allowed pro rata payments if Appellees' employment terminated under certain conditions. After Appellees left ONEOK's employment before the earliest performance period ended, ONEOK denied Appellees' claims for pro rata payments under the agreements. Appellees sued ONEOK for breach of contract. The district court found for Appellees and awarded Appellees money damages equal to each of their pro rata shares under the agreements, and denied their request for attorney fees. The Eighth Circuit Court of Appeals reversed the denial of attorney fees, holding that the district court erred in determining Appellees were not entitled to attorney fees under the Nebraska Wage Payment and Collection Act (NWPCA). Remanded for a determination of the amount of the attorney fees award under the NWPCA.

United States Steel Corporation (U.S. Steel) operated an iron ore plant in Minnesota. After the economic downturn, U.S. Steel idled operations at the plant and laid off 313 workers represented by the United Workers of America Local 2660 (the Union). The Union filed a complaint for damages, alleging that U.S. Steel had violated the Worker Adjustment and Retraining Notification Act (the WARN Act) by failing to provide the required notice under the Act prior to the layoff. The district court granted summary judgment to U.S. Steel. The Eighth District Court of Appeals affirmed, holding (1) in light of the circumstances, U.S. Steel satisfied its burden of proving that the conditions giving rise to the WARN Act's unforeseeable business circumstances exception had been met; and (2) the notice given to the Union was sufficient under the WARN Act and was given as soon as practicable in this case.

Plaintiff sued her former employer after the company made public statements about her involvement in an incident in which a pernicious racial slur appeared on a return receipt that she handed to a customer. Plaintiff subsequently appealed the district court's dismissal of her claim for false light invasion of privacy and grant of summary judgment in favor of the employer on her defamation claim. The court concluded that plaintiff was a private figure and a reasonable jury could conclude that the employer's statements were false, that they harmed her reputation, and that this harm was distinguishable from any harm flowing from the generic news stories. Therefore, the district court erred by granting summary judgment to the employer on plaintiff's defamation claim. The court agreed, however, with the district court that Missouri would not recognize plaintiff's false light claim.

Plaintiff, an advanced practical nurse at the University, sued the Board of Curators, alleging a violation of the Equal Pay Act, 29 U.S.C. 206(d), claiming that she was paid less than a male who performed substantially equal work under similar work conditions. The district court, over plaintiff's objection, gave the business-judgment instruction and the jury returned a verdict for the Curators. Plaintiff appealed. The court concluded that the business-judgment instruction limited the jury from ruling for plaintiff solely for irrelevant reasons that were not in the proceeding three instructions. Taken as a whole, the instructions correctly stated the law, requiring a verdict for the plaintiff under some circumstances or for the defendant under others. Accordingly, there was no error and the court affirmed the judgment.

Plaintiff appealed the district court's grant of the City's motion for summary judgment on his Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Minnesota Human Rights Act (MHRA), Minn. Stat 636A, claims. The court held that plaintiff was unable to show that the City's justification for not hiring him was not pretext. Consequently, the court affirmed the dismissal of plaintiff's ADA claim because plaintiff had not put forth either direct or indirect evidence that the City regarded him as disabled person due to his knee injury. The court also held that the facts did not show how plaintiff was materially limited in the major life activity of working or regarded as such and therefore, the district court correctly dismissed his MHRA claim.

Defendants appealed from the district court's denial of summary judgment on the basis of qualified immunity. Plaintiff, an Intake and Placement Director in the Arkansas Department of Human Services, Division of Youth Services (DYS), claimed gender discrimination after being fired for untruthfulness in connection with the release of a youth resident from residential custody. The court reversed, finding that defendants where entitled to qualified immunity because plaintiff had not established a constitutional violation where plaintiff failed to offer evidence that could convince a reasonable jury that defendant Angel's and DYS's stated reason for firing her was pretext for intentional discrimination.

Plaintiff sued his former employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Nebraska Fair Employment Practices Act (NFEPA), Neb. Rev Stat. Ann. 48-1101 et seq. The district court granted defendant's motion for summary judgment on all claims and plaintiff appealed with respect to his ADA and NFEPA claims. The court concluded that plaintiff had not met his burden of demonstrating pretext at the summary judgment stage of his wrongful termination claim where there was no evidence showing that the difference in consequences for plaintiff and a co-worker was a result of anything except their different conduct and different roles in the company. The court also concluded that plaintiff failed as a matter of law to demonstrate the elements necessary to establish a hostile work environment claim. Accordingly, the court affirmed the judgment.

Plaintiff appealed the district court's order granting summary judgment to defendants on various claims arising from plaintiff's unsuccessful application for appointment as director of the City's Department of Human Rights and Equal Economic Opportunity, as well as denial of his motion to compel various depositions. The court affirmed the district court's grant of summary judgment to defendants on plaintiff's due process claims because he had no protected property interest in the position; because plaintiff had not presented evidence that he was treated differently from similarly situated candidates or that he was the victim of intentional or purposeful discrimination, plaintiff's equal protection claim failed as a matter of law; the court affirmed the district court's grant of summary judgment to defendants on plaintiff's conspiracy claim because plaintiff's assertion did not demonstrate a class-based invidiously discriminatory animus; and the court affirmed the district court's remaining rulings.