Justia Constitutional Law Opinion Summaries

Plaintiffs, including Samantha Hill and Missouri Lieutenant Governor Peter Kinder, acting in his personal capacity, brought this action to challenge various provisions of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 124 Stat. 119. The district court dismissed the suit for lack of standing. Because neither Hill nor Kinder pleaded sufficient facts to establish an injury-in-fact, both plaintiffs lacked standing to sue, and there was no Article III case or controversy. Accordingly, the court affirmed the judgment. View "Kinder, et al v. Geithner, et al" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law

Plaintiff filed suit claiming that UPS discriminated against him based on his gender, sexual orientation, and disability when it failed to hire him as a part-time package handler. The court affirmed the district court's grant of summary judgment in favor of UPS, holding that plaintiff could not prove that UPS discriminated against him because of a protected status of which it was unaware and even if a jury could find that there was discrimination, UPS provided a legitimate non-discriminatory reason for not hiring plaintiff.

Plaintiff brought suit against his employer, the City of O'Fallon, alleging, among other things, that the city retaliated against him for exercising his right to free speech guaranteed by the United States and Missouri Constitutions. Plaintiff's free speech claim alleged that the city retaliated against him for the comments made in his report to the Board of Alderman by failing to promote plaintiff, by failing to follow internal procedures while investigating him, and by taking negative personnel actions against him. Defendant's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634, and Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213.055, claims alleged that the city failed to promote plaintiff because of his age. The district court granted summary judgment in favor of the city. The court held that the district court did not err in granting summary judgment in favor of the city on plaintiff's free speech claims; plaintiff failed to meet his burden under the MHRA and summary judgment was properly granted on this claim; summary judgment was properly granted on the ADEA claim; and his Missouri Workers' Compensation Act, Mo. Rev. Stat. 287.780 claim. Accordingly, the court affirmed the judgment.

Plaintiff, an inmate of the Missouri Department of Corrections, filed suit under 42 U.S.C. 1983, alleging that his transfer, detention, and involuntary medication violated his due process rights. The court concluded that plaintiff need only be found gravely disabled before he could be involuntarily medicated; plaintiff's involuntary medication for a clinical necessity did not violate Missouri Department of Corrections Policy IS12-6.1; and plaintiff's procedural rights were not violated where Policy IS12-6.1 closely followed Washington's policy approved in Washington v. Harper and where, before his forced treatment, plaintiff was given notice of his due process hearing, was present at it, was permitted to cross-examine witnesses, and a neutral decisionmaker made the decision. Accordingly, the court affirmed the judgment.

Plaintiff sued her employer alleging disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Iowa Civil Rights Act (ICRA), Iowa Code 216 et seq. Because plaintiff was unable to perform the essential functions of her position, with or without reasonable accommodation, she failed to make a prima facie showing of discrimination under the ADA. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued Missouri prison officials under 42 U.S.C. 1983 for refusing to feed him for several days while he was restrained. A jury returned a verdict for the prison officials, which plaintiff appealed. The court held that the district court erred in not submitting a nominal damages instruction to the jury where the lack of nominal damages instruction had a probable effect on the verdict. Accordingly, the district court abused its discretion and the judgment was reversed and remanded.

Plaintiff sued his employer, Trinity, alleging that Trinity discriminated against him on the basis of his son's disabilities, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. He also alleged a violation of his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court affirmed the district court's grant of summary judgment, holding that the district court did not err in applying the honest belief rule; plaintiff failed to show that his termination was based on pretext or a discriminatory motive; and plaintiff failed to present sufficient evidence of an FMLA violation. Trinity proffered a legitimate nondiscriminatory reason for the termination - it believed that plaintiff violated company policy by encouraging a work slowdown - and plaintiff presented insufficient evidence to show that the explanation was pretextual.

Patients, civilly committed to the Minnesota Sex Offender Program (MSOP), brought suit under 42 U.S.C. 1983 against DHS officials and DOC officials, alleging that various MSOP policies and practices relating to Patients' conditions of confinement were unconstitutional. The district court granted summary judgment to DHS officials and DOC officials on all of Patients' claims and Patients appealed, raising ten assertions of error. The court rejected Patients' claims and affirmed the summary judgment.

Plaintiff sued St. Louis County and three of its police officers - Lane Hollandsworth, Stephen Deen, Sr., and Jack Webb - under 42 U.S.C. 1983, alleging that they violated his constitutional rights by causing his wrongful conviction for rape and delaying his exoneration. After dismissing the County from the case, the district court granted summary judgment to the individual defendants, dismissing all claims with prejudice. The court affirmed, holding that, even assuming Hollandsworth caused some degree of suggestiveness in the photo lineup, it did not violate plaintiff's constitutional rights; there was no material issue of fact whether Hollandsworth knew that the December 4, 1982, incident was exculpatory evidence and tried to suppress the evidence; and therefore, the district court did not err in granting summary judgment to Hollandsworth. The court also held that Deen did not violate defendant's due process rights by conducting an impermissibly suggestive live lineup. Further, the court held that the district court did not err in granting summary judgment to Webb where there was no evidence in the record that Webb signed a false affidavit. Finally, the district court did not err in denying the motion for leave on the basis of futility and the district court did not abuse its discretion in denying plaintiff's motion to alter or amend its judgment.