Justia Constitutional Law Opinion Summaries

Southern Wine filed suit challenging the Divisions' denial of its application for a license to sell liquor wholesale in Missouri. The Division denied the application because Southern Wine did not satisfy a residency requirement under Missouri law. The court concluded that Southern Wine had not shown that the residency requirement was unconstitutional on the ground that it was motivated by mere economic protectionism; the Division has established a sufficient basis for its residency requirement, which was meaningfully tied to the aim of the Twenty-first Amendment to allow States to maintain an effective and uniform system for controlling liquor by regulating its transportation, importation, and use; and the requirement had a rational basis and did not deprive Southern Wine of equal protection of the laws under the Fourteenth Amendment. Accordingly, the court affirmed the judgment of the district court upholding the statute. View "Southern Wine & Spirits, et al. v. Division of Alcohol & Tobacco, et al." on Justia Law

After 15-year-old B.K. was barred from showing livestock at 4-H exhibitions, B.K.'s father filed suit under 42 U.S.C. 1983 against the unincorporated 4-H Association and two 4-H officials. The district court granted preliminary injunctive relief from the claimed denial of B.K.'s constitutional right to procedural due process. The court inferred that 4-H membership and participation was a "right or status" open to all South Dakota children interested in a career in agriculture, subject to reasonable, non-discriminatory terms; the record clearly demonstrated that the ban deprived B.K. of the opportunity to participate in a public program that was important to her education and career development and from which she obtained significant personal income; and, therefore, the district court did not abuse its discretion in concluding that B.K. had a fair chance of proving that defendants published a defamatory ruling that deprived her of a right or status conferred by state law and that she was entitled to the constitutional protection of the Due Process Clause. Further, B.K. was not afforded minimal procedural due process protection; there was a sufficient showing of the threat of irreparable injury; and the balance of the equities and the public interest supported the issuance of the injunction. Accordingly, the court affirmed the judgment of the district court. View "Kroupa v. Nielsen, et al." on Justia Law

After plaintiff served 24 years in prison for murder, a Missouri court found that plaintiff's trial had been fundamentally unfair and ordered his release. Plaintiff then filed suit against the St. Louis Board of Police Commissioners and others, alleging, inter alia, that defendants recklessly or intentionally manipulated evidence and conducted suggestive identification procedures. The court concluded that the district court did not err in granting summary judgment on plaintiff's claims that defendants manipulated the investigation or evidence against him or deprived him of a fair trial; plaintiff had not adduced evidence to show that the identification procedure in this case was impermissibly suggestive and the circumstances of the photo identification procedure did not create a very substantial likelihood of irreparable misidentification; the court found no evidence to support a reasonable inference that any of the defendants conspired to frame plaintiff or otherwise deprive him of his constitutional rights; and plaintiff's Monell claims against the Board failed where none of the individual defendants were liable on plaintiff's 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "Burton v. St. Louis Board of Police, et al." on Justia Law

Plaintiff filed suit against the County and others after her son Johnny died from multiple drug intoxication while in the county jail. At issue on appeal was the district court's denial of qualified immunity on summary judgment for the law enforcement officials. The court concluded that Officer Furr did not have subjective knowledge that Johnny required medical attention and that Officer Furr was not deliberately indifferent to Johnny's medical needs. Accordingly, Officer Furr was entitled to qualified immunity. In regards to Officer King, the court concluded that a reasonable officer would have known that a constitutional violation occurred by deliberately disregarding Johnny's serious medical needs in the circumstances Officer King confronted. Accordingly, the district court properly denied Officer King qualified immunity because this constitutional right was clearly established. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Thompson v. King, et al." on Justia Law

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

Plaintiff, a self-described "professing Evangelical Christian," distributed Bibles at the Twin Cities Pride Festival for many years in an exhibitor's booth but in 2009, Twin Cities Pride denied plaintiff's application for a booth. On appeal, plaintiff challenged the district court's denial of his motion for a preliminary injunction against enforcement of a local regulation that restricted literature distribution in a public park during the Festival. The court concluded that plaintiff has shown a likelihood of success on his claim that the literature distribution regulation was not narrowly tailored to serve a significant governmental interest; plaintiff satisfied the irreparable harm requirement; the balance of the equities favored granting the injunction; and the injunction was in the public interest. Accordingly, the court reversed the district court's denial of plaintiff's motion for a preliminary injunction and remanded for further proceedings. View "Johnson v. Minneapolis Park and Rec. Bd." on Justia Law

Plaintiff and his wife appealed the denial of his application for Medicaid benefits, arguing that the Department wrongfully denied the application because it had improperly counted against the wife's eligibility an annuity owned by the wife. The district court ruled in favor of plaintiffs and the Department appealed. The court concluded that, because the wife had no right, authority, or power to liquidate the annuity, the annuity benefits were not a resource, but rather was income indicated by the federal statute defining "unearned income." Therefore, the Department applied a more restrictive methodology under state law by classifying the annuity benefits as a resource that counted against plaintiff's eligibility for Medicaid benefits. The court rejected the Department's counter-arguments and the remaining arguments, and affirmed the judgment of the district court. View "Geston, et al. v. Anderson" on Justia Law

Plaintiff filed suit under 1983 alleging that police officers violated his constitutional rights by arresting him in his home without first obtaining a warrant to do so. The court concluded that plaintiff demonstrated sufficient facts to show a violation of his Fourth Amendment right to be free from unreasonable searches and seizures; a reasonable officer would have known that at the time plaintiff tried to close the door, he stood within his home and thus could not be pulled therefrom and placed under arrest in the absence of exigent circumstances; and, therefore, the court affirmed the district court's order denying qualified immunity as to Defendant Shearer. The court dismissed for lack of jurisdiction plaintiff's cross appeal challenging the grant of qualified immunity as to Defendants Spiker and Bone where the district court has not issued a final decision and the collateral order doctrine did not apply when a party complains that the district court should not have granted summary judgment based on qualified immunity. View "Mitchell v. Shearrer" on Justia Law

Plaintiff filed suit against Trinity alleging wrongful termination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq.; the North Dakota whistleblower statute, N.D. Cent. Code 34-01-20(1); and N.D. Cent. Code 34-01-04 (the intimidation statute). On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Trinity and the denial of her motion for a default judgment. The court found no abuse of discretion in the district court's denial of plaintiff's motion for summary judgment or default judgment, which asked the court to grant a dispositive discovery sanction against Trinity for its willful pattern of action in failing to comply with the scheduling order. Plaintiff failed to advance any evidence indicating that Trinity did in fact replace plaintiff with someone substantially younger, that she was treated differently than any other similarly situated male employee, that plaintiff engaged in a protected activity under the whistleblower statute, and that there was a private right of action under the intimidation statute. Accordingly, the court affirmed the judgment of the district court. View "Holmes v. Trinity Health" on Justia Law

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law