Justia Constitutional Law Opinion Summaries

Plaintiff, as trustee for the next of kin of her deceased son, filed suit against five police officers and the city, alleging violations of the son's (1) Fourth Amendment right to be secure against unreasonable seizure, under 42 U.S.C. 1983, and (2) the Minnesota wrongful death statute, Minn. Stat. 573.02. The court concluded that Officer Devick was entitled to qualified immunity for his actions during his initial encounter with the son where a reasonable officer faced with the same circumstances would not have known that the decision to kick and hit the son in an attempt to detain him clearly violated the Fourth Amendment. The court also concluded that the officers were entitled to qualified immunity for their actions during the second encounter with the son where plaintiff failed to establish that the punches, kicks, knee strikes, and tasers they used on the son were unconstitutional. Even if the conduct was unconstitutional, it was not clearly established at the time. The court agreed with the district court's finding that plaintiff failed to demonstrate sufficient evidence showing that the officers intentionally apprehended the son in a way that they believed was prohibited by law. Accordingly, the court affirmed the district court's grant of official immunity and dismissal of the wrongful death claim against the individual officers. The court also affirmed the district court's dismissal of the vicarious liability claim against the city. View "Smith v. City of Minneapolis, et al." on Justia Law

After plaintiff was arrested for violation of Mo. Rev. Stat. 578.095, which prohibits flag desecration, he filed suit under 42 U.S.C. 1983 against Cape Girardeau, the arresting police officer, and the prosecuting attorney. Both the arresting officer and attorney stated that they were unaware of the Supreme Court's decisions in Texas v. Johnson and United States v. Eichman, which struck down statutes criminalizing flag desecration as unconstitutional. Plaintiff's charges were dismissed against him and he was released from jail. On appeal, the officer challenged the district court's denial of his motion for summary judgment on the basis of qualified immunity and award of attorney's fees. The State, which intervened, appealed the district court's order declaring its flag desecration statute facially unconstitutional and the award of attorney's fees. The court concluded that the officer was not entitled to qualified immunity where a reasonably competent officer in his position would have known that plaintiff's expressive conduct was constitutionally protected and would have concluded no arrest warrant should issue for the expressive conduct engaged in by plaintiff. The court concluded that Mo. Rev. Stat. 578.095 was overbroad and criminalizes a substantial amount of expressive activity. Further, the statute was not susceptible to an appropriate narrowing construction and, therefore, the district court did not err in holding the statute to be facially unconstitutional. The district court did not abuse its discretion in holding the officer and the state jointly and severally liable for attorney's fees and costs; the district court did not abuse its discretion in awarding attorneys' fees based on the rate for the St. Louis legal market, instead of Cape Girardeau; and the district court did not err in granting summary judgment for Cape Girardeau. Accordingly, the court affirmed the judgment of the district court. View "Snider, III v. Peters" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, claiming that his Eighth Amendment rights were violated after Sgt. Earl Eaton pepper-sprayed him when he refused to return to his cell after showering, and Cpl. Renita White turned off the water, preventing him from rinsing off the pepper spray for ten to fifteen minutes. The court affirmed the district court's grant of summary judgment dismissing the Eighth Amendment excessive force claim where plaintiff was warned that he would be pepper-sprayed if he did not comply with the order to "catch the cuffs," plaintiff threw an object or spit on Eaton three times, and Eaton deployed a small amount of pepper spray after each act of defiance. Further, there was no specific evidence of malicious motive to harm, or evidence that the force used was excessive. The court concluded that Eaton was entitled to qualified immunity on the delayed decontamination claim where plaintiff failed to demonstrate that Eaton acted with deliberate indifference to a serious medical need. The court also affirmed the district court's dismissal of White's claim for failure to exhaust administrative remedies. View "Burns v. Eaton, et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the Red Cross on her claims, inter alia, of race discrimination and retaliation. The court concluded that plaintiff failed to establish a prima facie case of race discrimination based on the Red Cross' decision not to promote her and based on the failure to train her; the decision to suspend and terminate plaintiff was not a result of race discrimination but, rather, because plaintiff failed to meet her employer's legitimate expectations; even if plaintiff was able to show that she had met her employer's legitimate expectations, she failed to show that similarly situated employees committed the same conduct but were treated differently. The court concluded that the district court did not err in granting Red Cross summary judgment on the retaliation claim where plaintiff failed to establish a prima facie case of retaliation because plaintiff failed to raise a genuine issue of material fact to show a causal link between her protected activity and the adverse employment actions taken against her. Finally, the court concluded that the district court did not err in granting the Red Cross summary judgment on plaintiff's outrage claim. View "Robinson v. American Red Cross" on Justia Law

Plaintiff, a victim of sexual assault while in pretrial detention in jail, filed suit under 42 U.S.C. 1983 and pendent state law, alleging claims against those he considered responsible for the assault. At issue in this interlocutory appeal are plaintiff's Fourteenth Amendment failure to train claims against the sheriff and the jail administrator. The court denied plaintiff's motion to dismiss the appeal for lack of jurisdiction because the court had jurisdiction over the case under the collateral order doctrine. On the merits, the court concluded that plaintiff's failure to train and supervise claims must be judged by Farmer v. Brennan's subjective deliberate indifference standard where plaintiff must prove that the prison officials personally knew of the constitutional risk posed by their inadequate training or supervision and proximately caused him injury by failing to take sufficient remedial action. The court concluded that the district court's findings of fact adequately supported the district court's legal conclusion that the administrator was not presently entitled to qualified immunity on plaintiff's claim that the administrator failed to train a jailer regarding the jail's policy to lock the cell doors overnight. The court found nothing but speculation, conjecture, or fantasy to rebut the sheriff's testimony that he did not know of the substantial risk posed by the administrator's failure to train the jailer. Accordingly, the court affirmed the denial of qualified immunity to the administrator, reversed the denial of qualified immunity to the sheriff, and remanded for further proceedings. View "Walton v. Dawson, et al." on Justia Law

Plaintiff, a former inmate, filed suit under 42 U.S.C. 1983 against the State and the Iowa Board of Parole, alleging violations of his constitutional rights based on defendants' failure to conduct in-person parole interviews. The court agreed with the district court that plaintiff failed to exhaust administrative remedies under the Prison Litigation Reform Act of 1995, 42 U.S.C. 1997e(a), and dismissal of his complaint was proper. Accordingly, the court affirmed the judgment of the district court. View "Martin v. State of Iowa, et al." on Justia Law

Plaintiff filed suit against the city, alleging claims under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 701; and the Arkansas Civil Rights Act (ACRA), Ark. Code 16-123-107. Both parties appealed the judgment of the district court. The court concluded that a reasonable juror could find that plaintiff could perform the essential functions of the job for which he interviewed and that plaintiff presented sufficient evidence to support an inference of a retaliatory motive on the part of the city. Accordingly, the court affirmed the district court's denial of the city's motion for judgment as a matter of law on the FMLA retaliation claim. The court affirmed the district court's grant of the city's motion for judgment as a matter of law on plaintiff's ACRA disability-discrimination claim where plaintiff introduced no evidence to demonstrate that the city knew about his conditions when he sought to be rehired; affirmed the district court's vacatur of the jury's award for emotional-distress where the ACRA claim submitted to the jury did not provide a basis for the jury's award of emotional-distress damages; and reversed the denial of liquidated damages because the city cited no evidence in support of the district court's finding that it acted in good faith in refusing to rehire plaintiff and the court could find none. View "Jackson v. City of Hot Springs" on Justia Law

South Dakota Native American inmates filed suit against defendants claiming that a tobacco ban substantially burdened the exercise of their religious beliefs in violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc-1(a). The court concluded that the record amply showed that the inmates have satisfied their burden. That some Native Americans practicing the Lakota religion would consider red willow bark a sufficient alternative to tobacco did not undermine the decision of the district court. Even assuming that defendants' ban on tobacco furthered compelling government interests in security and order, the ban was not the least restrictive means of achieving that interest. The court concluded that the scope of the district court's remedial orders extended no further than necessary to remedy the violation of inmates' rights under RLUIPA. Accordingly, the court affirmed the district court's grant of injunctive relief in all respects. View "Native American Council, etc., et al. v. Weber, et al." on Justia Law

Plaintiffs, pretrial detainees at a detention center, filed suit under 42 U.S.C. 1983 against prison guards and the Sheriff, alleging a variety of constitutional violations. The court concluded that the district court correctly denied summary judgment on the basis of qualified immunity where the record supported a claim of excessive force in violation of the Eighth Amendment. The record also supported a claim for failure to protect plaintiffs from harm in violation of the Due Process Clause and the district court correctly denied the guards qualified immunity on this claim. Given the fact that the Sheriff was not at the detention center, he could not have used excessive force against plaintiffs, nor could he have an opportunity to intervene to prevent the guards from employing excessive force. Accordingly, the court reversed the district court's denial of summary judgment based on qualified immunity with respect to the Sheriff. The court affirmed in all other respects. View "Edwards, Jr., et al. v. Byrd, et al." on Justia Law

Plaintiff, a prison inmate, filed suit asserting various claims, including 42 U.S.C. 1983 claims alleging violations of the First and Fourteenth Amendments, that prison officials wrongfully censored and confiscated his mail. The court concluded that when an official properly and timely files a motion for dismissal or for summary judgment asserting qualified immunity, the official was entitled to a ruling on the issue of qualified immunity. As such, the district court must issue a reviewable ruling before requiring the officials to progress further in litigation at the district court. Therefore, the court reversed the district court's order converting the officials' motion to dismiss into a motion for summary judgment; vacated the district court's partial denial of the officials' motion for summary judgment; and remanded with instructions for the district court to decide, consistent with this opinion, whether the officials were entitled to qualified immunity on the pleadings under Rule 12(b)(6). View "Payne v. Britten, et al." on Justia Law