Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against defendants, the city and four officers, alleging, among other things, Fourth Amendment excessive force violations of 42 U.S.C. 1983; and violations of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12132; and Rehabilitation Act of 1973, 29 U.S.C. 794; and state tort law. The events at issue occurred when officers arrived at plaintiff's home after his mother called 911, reporting that he was having a psychotic episode and had attacked a member of the family. The court affirmed the denial of qualified immunity and denial of summary judgment to Officer Martinec on plaintiff's Fourth Amendment excessive force claim in securing plaintiff; reversed the denial of qualified immunity and denial of summary judgment for Officers Ricker, Jones, and Raders on plaintiff's Fourth Amendment excessive force claims as to these individual officers; reversed the denial of qualified immunity for all the officers and the denial of summary judgment as to the ADA and Rehabilitation Act claims; reversed the denial of the city's motion for summary judgment on plaintiff's ADA and Rehabilitation Act failure to train claims; and remanded for further proceedings. View "Roberts v. City of Omaha, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 alleging that the deputy sheriff used excessive force against him. The court concluded that precedent in place at the time of this incident suggested that the presence of only de minimus injuries could preclude a claim for excessive force. In this instance, the amount of force that the sheriff used did not cause more than de minimus injury. Therefore, the sheriff was entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights under the Fourth Amendment. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the sheriff. View "Bishop v. Deputy Dale Glazier, et al." on Justia Law

Plaintiffs filed suit against the Cafe and its owner and manager for willfully violating the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq. On appeal, defendants challenged the district court's denial of their motion for judgment as a matter of law, arguing that plaintiffs, as aliens without work authorization, lacked standing to sue. The court affirmed the judgment, concluding that the FLSA did not allow employers to exploit any employee's immigration status or to profit from hiring unauthorized aliens in violation of federal law. View "Lucas, et al. v. Jerusalem Cafe, LLC, et al" on Justia Law

Plaintiffs ("Parents") filed suit against Educators seeking a declaratory judgment that the Arkansas Public School Choice Act of 1989, Ark. Code Ann. 6-18-206(f)(1), violated the Equal Protection Clause and an injunction transferring their children to another school district. The court concluded that Parents' claims for declaratory and injunctive relief were moot because the Arkansas General Assembly enacted the Public School Choice Act of 2013, Ark. Code Ann. 6-18-1901 et seq., which repealed the 1989 Act in its entirety. Accordingly, the court vacated and remanded with directions to dismiss. View "Teague, et al. v. Arkansas Board of Education, et al." on Justia Law

Plaintiffs filed suit against the District alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 706 and 794a. Plaintiffs' claims involved disputes with the District over the manner in which the District implemented individualized education programs. The court concluded that plaintiffs were required to exhaust their administrative remedies under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491, before filing their ADA and Rehabilitation Act claims in the district court. Further, the futility, inadequate remedy, and contrary to law exceptions were not applicable in this case. Accordingly, the court affirmed the district court's grant summary judgment in favor of the District. View "J.B., et al. v. Avilla R-XIII School District" on Justia Law

Plaintiff filed suit against the OHA after she was terminated. At issue on appeal was whether plaintiff's appeal must be dismissed for failure to order the necessary portions of a trial transcript. Plaintiff ordered the portion of the trial transcript that contained her testimony and the remaining portions of the transcript were not transcribed and were not available. The court could not properly review the issues in the case based on the record plaintiff provided and, therefore, the court did not address the merits of plaintiff's First Amendment retaliation claim. Accordingly, the court granted the OHA's motion to dismiss plaintiff's appeal based on Federal Rule of Appellate Procedure 10(b). View "Kelly v. Omaha Housing Authority, et al." on Justia Law

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law

Plaintiff brought this action alleging that a correctional officer and a lieutenant at the jail in which plaintiff was detained violated plaintiff's constitutional rights by failing to protect him from being attacked by three fellow inmates. Both defendants appealed the district court's denial of their motion for summary judgment based on qualified immunity. The court concluded that the district court properly denied qualified immunity to the correctional officer where there was sufficient evidence on the present limited record from which a jury could infer that he acted with the requisite mental state for a constitutional violation. The court concluded, however, that there was no admissible evidence to establish that the lieutenant knew about a substantial risk to plaintiff's safety and, thus, the lieutenant was entitled to qualified immunity. Accordingly, the court affirmed in part and denied in part, remanding for further proceedings. View "Glaze v. Andrews, et al." on Justia Law

Plaintiff filed suit against defendant, the deputy sheriff that had arrested him, alleging excessive force and false arrest under the Fourth and Fourteenth Amendments and 42 U.S.C. 1983. The district court found that defendant had failed to meet his burden of proving probable cause and denied his motion for partial summary judgment on the false arrest claim. The court found no merit in defendant's claim that the district court effectively imposed a novel requirement that an officer may conduct a warrantless arrest for a misdemeanor offense only if that offense took place in the presence of the officer. The court reversed and remanded, concluding that defendant met his burden of showing arguable probable cause and he was, therefore, entitled to qualified immunity with respect to the false arrest claim. View "Chevallier v. Hand" on Justia Law