Justia Constitutional Law Opinion Summaries

Plaintiff, a person required to register as a "predatory offender" in Minnesota, brought this action against two state officials, pursuant to 42 U.S.C. 1983, asserting that the enforcement of Minnesota's predatory offender registration statute, Minn. Stat. 243.166, violated his constitutional rights to due process. Plaintiff litigated the same procedural due process claims that he raised on this appeal in his direct appeal from the 2009 conviction for a registration offense. Therefore, plaintiff was precluded from litigating those points in this federal action. Plaintiff also litigated in the 2009 state-court appeal his contention that the registration statute violated substantive due process and, therefore, he was precluded from relitigating in this federal action whether the predatory registration statute had a rational basis. Accordingly, the court affirmed the judgment. View "Meyers v. Roy, et al" on Justia Law

Appellant, a creditor of the debtor corporation, appealed a decision of the Bankruptcy Appellate Panel (BAP) affirming the bankruptcy court's denial of his motion to determine claims. The bankruptcy court granted appellant's subsequent motion to reopen the case, agreeing with the state court that appellant's claims were precluded and denied his motion to determine claims. The BAP affirmed the bankruptcy court on a different ground, reasoning that the bankruptcy court lacked subject-matter jurisdiction to consider appellant's motion. Because the court must accord the state court's judgment preclusive effect under 28 U.S.C. 1738, the court affirmed the decision of the bankruptcy court. View "Cawley v. Celeste, et al" on Justia Law

Plaintiff appealed from the district court's grant of summary judgment to a law enforcement officer on plaintiff's 42 U.S.C. 1983 action alleging an excessive use of force claim. The district court determined that the officer had used a reasonable amount of force and that, even if the Taser application constituted excessive force, it was not clearly established at the time that the use of force resulting in only de minimis injuries might violate the Fourth Amendment. The court affirmed, concluding that plaintiff had not set forth sufficient evidence to show that the officer's application of a Taser caused more than de minimis injury. Accordingly, the officer was entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights. Further, the court found no error in the application of the pleading standard set forth in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal. Accordingly, the court affirmed the judgment. View "LaCross v. City of Duluth, et al" on Justia Law

Plaintiff, employed by the CRMC, filed charges of discrimination against her employer after CRMC's placement of her on administrative leave following work-related epileptic seizures and the hiring of a younger technician. Because plaintiff was not a qualified individual to perform the job duties with or without accommodation, the court did not err in granting summary judgment to CRMC based on the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., and Missouri Human Rights Act, Mo. Rev. Stat. 213.010, claims. Plaintiff's age discrimination claims failed for the same reason her disability discrimination claims failed. Accordingly, the court affirmed the judgment. View "Olsen v. Capital Region Medical Center, et al" on Justia Law

Plaintiff, Shirley Phelps-Roper, brought this action under 42 U.S.C. 1983 seeking declaratory and injunctive relief against the State of Missouri after Missouri passed funeral protest laws Mo. Rev. Stat. 578.501 and Mo. Rev. Stat. 578.502. The district court entered a preliminary injunction prohibiting the enforcement of the statutes following this court's decision in Phelps-Roper v. Nixon. The district court later declared both statutes unconstitutional under the First and Fourteenth Amendments and granted Phelps-Roper's motion for summary judgment. Nixon has since been abrogated by the court's recent en banc decision in Phelps-Roper v. City of Manchester, Mo. The court affirmed the district court's judgment to the extent the district court held that section 578.501 violated the Free Speech Clause of the First Amendment; reversed the district court's judgment to the extent it held that section 578.502 was unconstitutional under the Free Speech Clause, severed the term "processions" from section 578.502(3), and held that the remaining provisions of section 578.502 were narrowly tailored time, place, and manner restrictions; and remanded for the district court to address in the first instance Phelps-Roper's alternative challenges that section 578.502 violated the Free Exercise Clause of the First Amendment, the Due Process Clause of the Fourteenth Amendment, and Missouri statutory and constitutional law. View "Phelps-Roper v. Koster, et al" on Justia Law

The City terminated plaintiff's employment after she refused a state trooper's request to take a drug test. Plaintiff sued the City and others, claiming that she was terminated in retaliation for her decision to exercise her Fourth Amendment rights. Even assuming the termination violated plaintiff's Fourth Amendment rights, it was not clearly established at the time of the incident that such an action was unconstitutional, and therefore defendants were entitled to qualified immunity. The court also agreed with the district court that plaintiff's remaining federal claims failed to allege a constitutional violation. The court further held that the district court properly dismissed the official capacity claims and the claims against the City where plaintiff failed to allege facts indicating that the City delegated final policymaking authority to the officials. Finally, because plaintiff did not explain why her Arkansas Civil Rights Act, Ark. Code Ann. 16-123-105(a), claims warranted separate analysis, the district court did not err in dismissing the ACRA claims alongside the 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment. View "Hess v. Abels, et al" on Justia Law

Plaintiffs, patients at the Iowa Civil Commitment Unit for Sex Offenders (CCUSO), filed a complaint under 42 U.S.C. 1983 challenging the placement of video cameras in CCUSO restrooms, and moved for a preliminary injunction to stop their use. The district court denied the motion as to cameras in the dormitory style restrooms but granted a preliminary injunction ordering that cameras in the traditional style bathrooms be pointed at the ceiling or covered with a lens cap. The administrators of CCUSO appealed the district court's grant of the preliminary injunction. The court concluded that by capturing images of patients while they occupy single-user bathrooms, CCUSO violated its patients' reasonable expectation of privacy, thus conducting a search under the Fourth Amendment, irrespective of whether there was some chance that those images would not be viewed. The court agreed with the district court that plaintiffs showed the requisite probability of success on their Fourth Amendment claim; plaintiffs established a threat of irreparable harm; plaintiffs' interests in this case outweighed the injuries that the injunction would inflict on other parties; and there was a greater public interest in protecting the Fourth Amendment rights of plaintiffs and their personal privacy and dignity against unwarranted intrusion by the State. Accordingly, the court affirmed the judgment. View "Arnzen, III, et al. v. Palmer, et al." on Justia Law

Providers brought suit against the State, asserting that the Adoption Assistance and Child Welfare Act of 1980 (CWA), 42 U.S.C. 670 et seq., gave them a privately enforceable right under 42 U.S.C. 1983 to receive payments from the State sufficient to cover the cost of certain statutorily enumerated components of foster care. At issue was whether Congress, in enacting the CWA, evinced a clear intent to grant foster care providers an individually enforceable right to foster care maintenance payments sufficiently large to cover the costs of each item enumerated in section 675(4)(A). The court held that Congress did not ambiguously confer such a right and, therefore, affirmed the district court's dismissal of the Providers' complaint for failure to state a claim. View "Midwest Foster Care, etc., et al v. Kincade, et al" on Justia Law

Chrylser appealed an adverse jury verdict in favor of plaintiff on a retaliation claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. Plaintiff cross-appealed, claiming that the district court improperly granted a motion for directed verdict on a punitive-damages claim and improperly reduced the attorney's fee award. The court held that the jury instruction on plaintiff's retaliation claim was proper; evidence was sufficient to support the verdict under the MHRA "contributing factor" standard; and the evidence was sufficient to support the jury's economic-damages award. The court affirmed the district court's refusal to submit the punitive damages claim to the jury. Because plaintiff also requested attorney's fees for time spent on post-trial motions and appellate work, however, the court remanded to the district court for consideration of this request, leaving the issue to the district court's discretion. View "Al-Birekdar v. Chrysler Group, LLC" on Justia Law

Plaintiff sued United Systems for sex and disability discrimination after she was terminated. After plaintiff prevailed on both claims, United Systems appealed the district court's denial of its post trial motions for judgment as a matter of law and for remittitur of the mental anguish damages. The court concluded that a legally sufficient basis existed for a reasonable jury to determine that plaintiff had made a showing that she had been discriminated against by her employer. Since the court concluded that the district court did not err in denying United Systems' motion for judgment as a matter of law on plaintiff's sex discrimination claims, the court need not address the denial of the motion on her disability discrimination claims. Considering precedent and the record made in this case, the court could not conclude that the award of $100,000 to plaintiff was monstrous, shocking, or grossly excessive. Accordingly, the district court did not manifestly abuse its discretion in denying the motion for remittitur. View "Hudson v. United Systems of Arkansas, Inc." on Justia Law