Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against police officers under 42 U.S.C. 1983 for violating her constitutional rights. The district court denied the officers qualified immunity and the officers filed an interlocutory appeal. The court concluded that the district court correctly determined that no reasonable police officer could actually believe that plaintiff's warrantless arrest was lawful, given the information supplied to the officers and the circumstances surrounding the arrest. The officers arrived at plaintiff's door when she was nursing her infant and lead her out of her home in handcuffs based on an invalid, recalled arrest warrant for failure to appear to contest a simple traffic violation. After she was given a strip search and body cavity search, plaintiff was detained in jail overnight, the first time she had been separated from her infant. Because the court affirmed the district court's denial of qualified immunity on the grounds of the warrantless arrest, the court did not address whether the humiliating indignities suffered by plaintiff as a result of the officers' conduct constituted an independent rationale for a section 1983 claim on unreasonable seizure. Accordingly, the court affirmed the judgment of the district court. View "Bechman v. Magill, et al." on Justia Law

Plaintiff, after being acquitted of state law charges related to the possession of firearms, filed suit against the City and eight police officers, under 42 U.S.C. 1983. On appeal, plaintiff challenged the district court's grant of summary judgment for the officers on his Fourth Amendment claim against them in their individual capacities. The court concluded that the officers did not exceed the scope of plaintiff's consent for them to be in the basement of his home where the officers had to walk through the basement to access another room; the warrant was supported by probable cause where the officers noticed two sawed off shotguns; the record did not reflect the deliberate falsehood or reckless disregard for the truth that violated the Fourth Amendment; and the officers had probable cause to arrest him on the state gun charges. Accordingly, the court affirmed the district court's judgment. View "Fagnan v. City of Lino Lakes, et al." on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, alleging that recent amendments to Minnesota's No-Fault Automobile Insurance Act, Minn. Stat. 65B.41-71, violated the First Amendment. Plaintiffs sought a preliminary injunction seeking to enjoin defendants from enforcing the new provisions. The court concluded that the "inherently misleading" standard was broad enough in application to encompass 411-Pain's references to the $40,000 in potential insurance benefits. As such, the court affirmed the district court's denial of plaintiffs' request for a preliminary injunction barring enforcement of subdivision 6(d)(5). The court concluded that plaintiffs were not likely to succeed on the merits in the ultimate litigation because the ads at issue were "inherently misleading" where 411-Pain's use of actors posing as persons of authority to sell its business extended a misleading aura of authorized approval to the services in question and where the disclaimer "PAID ACTOR" did not disclaim endorsement by the actors. Accordingly, the court affirmed the district court's denial of plaintiffs' request for a preliminary injunction barring enforcement of subdivision 6(d)(6). Finally, the court concluded that the requirements at issue in subsections 6(d)(1), 6(d)(2), and 6(d)(3) were constitutional and the court rejected plaintiffs' claims to the contrary. Therefore, the court affirmed the district court's denial of plaintiffs' request for a preliminary injunction. View "1-800-411-Pain Referral, et al. v. Leroy Otto, D.C., et al." on Justia Law

Plaintiff filed suit claiming malicious prosecution and violations of his civil rights. After plaintiff's attorney failed to comply with discovery deadlines, the district court dismissed plaintiff's suit with prejudice for failure to prosecute and failures to comply with a court order and the Federal Rules of Civil Procedure. The court concluded that, in these circumstances, it was an abuse of discretion to impose the "ultimate sanction" of dismissal with prejudice without first considering the viability of lesser sanctions. Accordingly, the court vacated and remanded. View "Bergstrom v. Sgt. Michelle Frascone, et al." on Justia Law

Plaintiff filed suit against Timothy Geithner, in his capacity as the Secretary of the Treasury, for retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The court concluded that no senior-international-agent position was available to which plaintiff could be promoted based on his work in the "M" case and plaintiff failed to demonstrate that the IRS's failure to promote him to a senior international agent for his work on the "M" case constituted a materially adverse employment action; failed to demonstrate unlawful retaliation because no reasonable juror could determine that the IRS undertook material adverse employment actions; and failed to demonstrate constructive discharge. Accordingly, the court affirmed the judgment of the district court. View "AuBuchon v. Geitner" on Justia Law

Plaintiff filed suit against the city building inspector under 42 U.S.C. 1983, alleging violations of his First Amendment rights. The district court granted summary judgment to defendant and the city, dismissing plaintiff's suit with prejudice. The court affirmed, concluding that, while the inspector was acting inappropriately, he did not violate plaintiff's First Amendment rights where the potential chilling effect of the inspector's instruction to a city employee to call the police when plaintiff wanted to file a grievance against the inspector was mitigated by the fact that the other city employees present did not echo the inspector's attitude. View "Scheffler v. Molin, et al." on Justia Law

Plaintiff, a Missouri inmate, appealed the district court's dismissal of an action alleging that defendants violated section 504 of the Rehabilitation Act of 1973 (RA), 29 U.S.C. 701, and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq, by the way they handle his medical needs. The court affirmed the dismissal of the individual-capacity claims against Defendants Lange and Logan, prison officials, because they could not be sued in their individual capacities under the ADA or the RA; affirmed the dismissal of the claims against the medical doctors and CMS because those claims were based on medical treatment decisions which could not form the basis of a claim under the RA or ADA; reversed the dismissal of claims for injunctive relief against Lange, Logan, the State of Missouri and MDOC that were not based on medical treatment decisions; remanded damages claims against the State of Missouri and the MDOC under the ADA, and against the MDOC under the RA, because some of defendants' alleged behavior could violate the Eighth and Fourteenth Amendments; affirmed the dismissal of the unnamed medical doctors and CMS, and the individual capacity claims against Lange and Logan; reversed the dismissal of injunctive relief claims against the state defendants that were not based on medical treatment decisions; reversed the dismissal of damages claims against the State of Missouri and the MDOC; and remanded for further proceedings. The court denied plaintiff's appellate motions. View "Dinkins v. Correctional Medical Services" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and Minnesota state law, alleging that officers violated her Constitutional rights when they arrested her. The court concluded that the officer's decision to arrest plaintiff for violating Minnesota's open-container law was reasonable, even if the flask found under her seat was empty. The officer was reasonable in viewing the time of day, plaintiff being non-cooperative, and plaintiff repeatedly asking to urinate as additional factors sufficient for probable cause to arrest for constructive possession. The officer's conduct did not show plain incompetence or a knowing violation of the law. Therefore, the officer was entitled to qualified immunity and the court affirmed the judgment of the district court. View "Branch v. Gorman, et al." on Justia Law

Plaintiff, an involuntarily committed patient at the Iowa Civil Commitment Unit for Sexual Offenders (CCUSO), filed suit under 42 U.S.C. 1983 alleging that defendant, a nurse practitioner at CCUSO, provided him constitutionally deficient medical care. The district court denied defendant's motion for summary judgment on the basis of qualified immunity. The court concluded that the district court erred in analyzing plaintiff's claim under the professional judgment standard. Instead, where a patient's Fourteenth Amendment claims were for constitutionally deficient medical care, the court applied the deliberate indifference standard from the Eighth Amendment. Because the district court applied the wrong constitutional standard in denying qualified immunity, the court remanded to the district court to apply the deliberate indifference standard in the first instance. View "Scott v. Benson, et al." on Justia Law

Plaintiffs, African American officers who worked in a state penitentiary, filed suit under 41 U.S.C. 1981 and 1983 against supervisors for race based harassment and retaliation. On appeal, the officers challenged the district court's dismissal of their claims against Lieutenants Stoner, Haney, and Runge and against Sergeants Miles and Furby. The court concluded that the evidence revealed acts, comments, and inaction by Sergeant Miles sufficient to make out prima facie harassment claims against him, which must be reinstated and remanded; there was insufficient evidence of harassment by the other supervisors and therefore the claims against Lieutenant Stoner, Runge, and Haney, and Sergeant Furby were affirmed; the retaliation claims by supervisors were affirmed; and Sergeant Miles has not shown that he was entitled to qualified immunity on the officers' harassment claims, nor have Lieutenants Stoner and Haney shown they were entitled to qualified immunity on the retaliation claims of Officer Ellis. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Ellis, et al. v. Houston, et al." on Justia Law