Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. 8th Circuit Court of Appeals

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Plaintiff filed suit under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq., alleging that the County discriminated her based on her sex and her age when they terminated her employment. Plaintiff also claimed that the County retaliated against her after she took leave under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. On appeal, plaintiff challenged the district court's grant of summary judgment on her MHRA discrimination claims. The court concluded that the County offered a non-discriminatory, legitimate justification for its conduct - plaintiff was terminated based on her repeated record-keeping errors - and plaintiff failed to show that the County's reasons for firing her was pretextual. Therefore, the court affirmed the district court's grant of summary judgment on plaintiff's sex discrimination claim. Further, plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to her sex-plus age discrimination claim where her two male co-workers of comparable age did not engage in sufficiently similar misconduct or have a similar disciplinary history. Accordingly, the court affirmed the judgment of the district court. View "Doucette v. Morrison County, Minnesota" on Justia Law

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The EEOC and Adam Breaux, a terminated employee of PFI, appealed the district court's adverse grant of summary judgment in favor of PFI. Breaux asserted that PFI discriminated against him based on his right shoulder injury and the district court erred in granting summary judgment on this claim. The court concluded that the year-long period that PFI accommodated Breaux's injury negated causation; and the casual, somewhat ambiguous conversation that took place in August 2009, does not establish a causal connection between Breaux's termination and his disability. Even if a prima facie case was established, because PFI has advanced a legitimate nondiscriminatory reason for terminating Breaux - poor performance - the burden shifted back to the EEOC and Breaux to show that PFI's proffered reason is pretext for intentional discrimination. In this case, the EEOC and Breaux failed to show pretext. Therefore, the district court correctly granted summary judgment on the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), discrimination claim. Further, the district court properly granted summary judgment on the ADA failure-to-accommodate claim where Breaux failed to prove that he requested an accommodation. Because the district court properly dismissed the discrimination and retaliation claims, the court affirmed its dismissal of the successor liability claim. Accordingly, the court affirmed the judgment of the district court. View "EEOC v. Product Fabricators, Inc., et al." on Justia Law

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Plaintiff filed suit against defendant, individually and in his official capacity as a circuit judge, alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq, as well as statutory violations. Plaintiff contended that defendant unlawfully discriminated against him on the basis of a disability, his back injury, by terminating him and by failing to accommodate his disability, and retaliated against him for requesting an accommodation. The court concluded that no genuine issue of material fact exists for trial regarding whether defendant discriminated against plaintiff on the basis of his disability; the record demonstrated that defendant accommodated all of plaintiff's known limitations during the period of his employment at issue; and defendant did not violate the ADA and the Rehabilitation Act by retaliating against him for requesting accommodation for his disability where plaintiff failed to establish a genuine issue for trial regarding a causal connection; and plaintiff failed to make a submissible case of interference with his FMLA rights. Accordingly, the court affirmed the judgment of the district court. View "Withers v. Johnson, et al." on Justia Law

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Plaintiff appealed the district court's grant of summary judgment in favor of Prairie Ethanol on his claim of disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12201 et seq. Assuming, without deciding, that plaintiff established a prima facie case of disability discrimination, Prairie Ethanol has offered a legitimate, non-discriminatory justification for terminating his employment - plaintiff's overly aggressive style of operating the plant, which resulted in the plant machinery swinging on three occasions and nearly losing the plant on one of those three occasions. Prairie Ethanol's performance-related concern constituted a legitimate, non-discriminatory justification for discharging plaintiff. Accordingly, the court affirmed the district court's judgment. View "Cody v. Prairie Ethanol, LLC" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against a law enforcement officer for violating her Fourth Amendments rights and for battery and false imprisonment under Minnesota law. The district court denied defendant's motion for summary judgment based on qualified and official immunity. The court concluded that the officer's arrest of plaintiff and frisking her did not violate plaintiff's clearly established Fourth Amendment rights. The officer reasonably believed that plaintiff was at least moderately intoxicated, and the law at the time of plaintiff's arrest was not so clear that a reasonable officer would have known that he lacked probable cause to arrest a moderately intoxicated individual in lieu of leaving her alone on a public roadway at night. Further, the officer was entitled to official immunity on plaintiff's state-law battery and false imprisonment claims where a reasonable officer would not have known that arresting and frisking plaintiff would have violated her constitutional rights and the officer provided uncontroverted testimony that it was standard practice to transport intoxicated individuals to detox facilities. Accordingly, the court reversed and remanded. View "Meehan v. Thompson" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against the two officers who stripped searched him, alleging that the officers violated his rights under the Fourth Amendment. The court affirmed the district court's grant of summary judgment to the officers based on qualified immunity where the strip search did not violate clearly established law at the time where a reasonable officer had a solid basis to believe that strip searching an arrestee was constitutional if there was reasonable suspicion that the detainee possessed contraband. In this case, plaintiff had recently admitted to smoking a bowl of marijuana so there was probable cause to believe that he had committed a controlled substance offense. View "Jacobson v. McCormick, et al." on Justia Law

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The district court found that defendant's refusal to complete a Post-Conviction Risk Assessment (PCRA) violated a condition of his supervised release and sentenced him to seven days imprisonment with no term of supervised release to follow. Defendant appealed a week after he was released, contending that the Government violated his Fifth Amendment rights by forcing him to choose between incriminating himself and violating the conditions of his supervised release. The court dismissed the appeal as moot where the possibility that defendant could face an enhanced sentence for a future crime because of his supervised release violation does not establish a concrete and continuing injury because the court must assume that defendant will conduct his future activities in accordance with the law, and the "capable of repetition" exception does not apply. View "United States v. Stanko" on Justia Law

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Plaintiffs, parents of minor children who reside in the District, filed suit challenging a resolution to exempt the District from the Public School Choice Act of 2013, Ark. Code Ann. 6-18-1901 et seq. Plaintiffs alleged that the District violated their constitutional rights when it resolved, for the 2013-2014 school year, to opt-out of the Act. The district court denied a preliminary injunction and plaintiffs appealed. The court held that the appeal was moot where the time period in which the requested relief would have been effective has expired and the controversy was not capable of repetition, yet evading review. View "Adkisson, et al. v. Blytheville Sch. Dist. #5" on Justia Law

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Plaintiff filed suit against prison officials after he was attacked three times by fellow inmates over the course of about a year and a half. Plaintiff claimed that the officials violated his Eighth Amendment right against the infliction of cruel and unusual punishment when they failed to protect him from those attacks. The court concluded that officials offered plaintiff protective custody, which he declined; when officials placed him in protective custody anyway, plaintiff asked to be returned to the general population; and plaintiff repeatedly denied the existence of any potential problems. Plaintiff failed to even show negligence, much less deliberate indifference on the part of the officials. Therefore, plaintiff has not demonstrated that prison officials responded unreasonably and, therefore, that the officials violated his Eighth Amendment rights. Accordingly, the court affirmed the judgment of the district court. View "Walls v. Tadman, et al." on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against the City, challenging the state's vehicle forfeiture proceeding under Minnesota Stat. 169A.63, Subdiv. 8(b). After looking at the three Mathews v. Eldridge factors, the court concluded that the City's current process - allowing those affected by vehicle forfeiture to request a judicial determination if they believe the forfeiture was erroneous - was sufficient to satisfy due process. In regards to plaintiff's Fourth Amendment claim, his vehicle was lawfully subject to forfeiture, and given his conviction for a fourth DWI, he was not entitled to get it back. Therefore, even if there hypothetically could have been a prolonged seizure had plaintiff requested a judicial determination within thirty days, he cannot show that he suffered any harm from the City's retention of his vehicle because the City was then the rightful owner. Accordingly, the court affirmed the district court's grant of summary judgment to the City. View "Booker v. The City of Saint Paul" on Justia Law