Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against his former employer, CSL, alleging violations of the Missouri Human Rights Act (MHRA), Mo. Rev. 213.055, 213.070. The district court granted CSL's motion for summary judgment. In regard to the sex discrimination claim, the court concluded that plaintiff failed to show a genuine issue of material fact regarding the credibility of his written warnings, and plaintiff's version of the events immediately preceding his firing fails to create a genuine issue of material fact regarding the credibility of CSL’s stated basis for terminating his employment. Because plaintiff admitted that he failed to comply with CSL’s policies, no genuine issue of material fact remained with respect to the credibility of CSL’s assertion that plaintiff’s failure was the basis for the termination of his employment. Because plaintiff failed to show how he and a female employee engaged in similar conduct, there is no genuine issue of material fact as to whether CSL treated plaintiff less favorably than similarly situated female employees. Further, no genuine issue of material fact remained as to whether CSL treated plaintiff unfavorably relative to similarly situated employees; without facts connecting the comment at issue, made by one of Denn’s peers, to CSL’s decision to fire Denn, the statement does not give rise to a genuine issue of material fact regarding Denn’s discrimination claim; and the fact that other male employees were disciplined was insufficient to render summary judgment improper. In regard to the retaliation claim, the court concluded that plaintiff failed to point to any evidence showing that his discrimination complaint was a “contributing factor” to any adverse action taken by CSL. Accordingly, the court affirmed the judgment. View "Denn v. CSL Plasma" on Justia Law

Plaintiff filed suit against her former employer, alleging claims of gender discrimination under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment to defendants. The court concluded that there is a genuine issue of material fact as to whether Defendant John Daugherty was sufficiently involved in the decision to terminate plaintiff to qualify as a decision maker, given that the evidence showed that he participated in the investigation leading up to her termination, and that he was the one who ultimately told her she was terminated; there is a genuine issue of material fact as to whether Daugherty had earlier told plaintiff that she should step down because she was “a female” and “a single mom,” that it was “a man’s world,” and that she needed to “man up;" and because the court construed such comments, if made by a decisionmaker, as direct evidence of discriminatory animus, the court concluded, under a mixed-motive analysis, plaintiff may be entitled to some of the remedies she sought in her complaint. Accordingly, the court reversed and remanded. View "Morrow v. Zale Corp." on Justia Law

The ACLU filed suit against the director of the Missouri Department of Corrections, in his official capacity, under 42 U.S.C. 1983, alleging that Mo. Rev. Stat. 546.720 is unconstitutional as applied to department records the ACLU obtained under the Missouri Sunshine Law, Mo. Rev. Stat. 610.010 et seq., and then posted on its website. Section 546.720 prohibits the disclosure of the identities of individuals who participate in executions. On appeal, the director challenged the district court's order denying immunity. The court concluded that the ACLU has alleged an injury in fact because it has shown an objectively reasonable fear of legal action that chills its speech. The court concluded, however, that the ACLU’s injury is not fairly traceable to the director because he does not possess any statutory authority to enforce section 546.720, and the ACLU's injury is fairly traceable only to the private civil litigants who may seek damages under the statute and thereby enforce the statute. Therefore, the court concluded that the ACLU lacks standing. The court also concluded that the director is also immune from suit because he lacks authority to enforce the challenged statute. In this case, the director’s authority to define the members of the execution team is not an enforcement action within the meaning of Ex Parte Young and its progeny. Accordingly, the court reversed the district court's judgment. View "Balogh v. Lombardi" on Justia Law

SEARK, operator of two hospice-care facilities, voluntarily entered into a provider agreement with the Secretary of Health and Human Services to receive Medicare reimbursement pursuant to the Medicare Act, 42 U.S.C. 1395c, 1395f(a)(7), 1395cc. The Act annually caps Medicare reimbursement. SEARK filed suit after the Secretary sent it seven demands for repayment, arguing that the cap violates the Takings Clause of the Fifth Amendment. The district court concluded that SEARK’s voluntary participation in the Medicare program precludes a takings claim. The court concluded that SEARK has not met its burden to prove the demands for repayment based on the statutory cap are a taking where the reimbursement cap allocates the government's capacity to subsidize healthcare; SEARK presented no evidence to suggest the cap makes it impossible to profitably engage in their business; and SEARK voluntarily chose to participate in the Medicare hospice program. Accordingly, the court affirmed the judgment. View "Southeast Arkansas Hospice v. Burwell" on Justia Law

Plaintiff, an independent lease truck driver for FMC Transport, filed suit against FMC Transport, alleging racial discrimination in violation of 42 U.S.C. 1981. The district court granted summary judgment in favor of FMC Transport. FMC Transport's accident review board had concluded that plaintiff's accident was preventable and the company later terminated him. Although plaintiff is a member of a protected class and he did suffer an adverse employment action, and even if he did meet FMC Transport's legitimate expectations, the court concluded that he failed to present evidence that supports an inference of discrimination. Further, plaintiff has not established a prima facie case of racial discrimination under the McDonnell Douglas framework, because he has not shown that the circumstances of his termination gave rise to an inference of discrimination. Accordingly, the court affirmed the judgment. View "Macklin v. FMC Transport, Inc." on Justia Law

Plaintiff, a member of the Westboro Baptist Church, filed suit in 2006 against Missouri state and state officials after the Missouri General Assembly enacted statewide restrictions on pickets and protests near funerals and funeral processions. In 2014, Missouri appealed the statute at issue while plaintiff's Rule 59(e) motion remained pending in district court. In this appeal, plaintiff challenged the district court's adverse judgments on her due process claim as well as the court's award of attorneys' fees. The court vacated the district court's judgment on the due process claim and remanded with instructions to dismiss her claim as moot. In regard to the attorneys' fees, the court concluded that the district court's 2/14th calculation was an abuse of discretion because its arithmetically simplistic fee calculation did not accurately reflect her degree of success of her interrelated claims. Moreover, even if the court accepted the district court's basic mathematical approach, its 2/14th calculation is inaccurate because it did not address whether it counted consent judgments, mooted claims, and dismissed claims as prevailing, neutral, or unsuccessful claims. Accordingly, the court reversed the district court's award of attorneys' fees. View "Phelps-Roper v. Koster" on Justia Law

This case stemmed from a government investigation of Mountain Pure's bottling facility. Mountain Pure and its employees filed suit against defendants, government agents, under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging violations of their Fourth Amendment rights. The district court granted summary judgment for defendants. The court concluded that the district court did not err in granting Defendants Roberts and Spradlin summary judgment on Mountain Pure's excessive force claim, nor did the district court err in granting the agents summary judgment on Mountain Pure's claim alleging unlawful seizure of its property. In regard to the individual employees' arguments that the district court erred in granting summary judgment against them on their claims alleging unlawful detention, unlawful seizure of their property, and excessive force, the court concluded that: the detention of the employees during the execution of the search warrant was reasonable where detaining the employees prevented them from fleeing in the event that incriminating evidence was found and ensured that they would be present to assist with the completion of the search such as by opening locked file cabinets to avoid the use of force, and detention of the employees in the break room was not particularly intrusive; the length of the detentions here was reasonable given that the search took nearly twelve hours and the government had a legitimate interest in detaining the employees during the search; the employees' argument that qualified immunity should not apply in Roberts' and Spradlin's case is rejected where there is no evidence showing that the interrogations at issue prolonged the employees' detentions beyond a reasonable time; Roberts and Spradlin did not act unreasonably in detaining them incommunicado by denying them access to telephones; the district court did not err in concluding that qualified immunity barred the employees' claims alleging an unlawful seizure of their property; and the district court did not err in granting summary judgment for Roberts and Spradlin on Bush, Morgan, and Stacks' excessive force claims. Accordingly, the court affirmed the judgment. View "Mountain Pure v. Roberts" on Justia Law

Plaintiff, an inmate at USMCFP, filed suit alleging that defendant was deliberately indifferent to his serious medical needs by failing to respond in a timely manner when the artery comprising his dialysis access port ruptured. The court affirmed the district court's grant of summary judgment to defendant on plaintiff's deliberate indifference claim where plaintiff provided no evidence showing that any delay in treatment had a detrimental effect; the district court did not err in denying plaintiff additional time for discovery; and the district court did not err in denying plaintiff's motion for leave to amend his complaint because amendment would be futile. Accordingly, the court affirmed the judgment in its entirety. View "Jackson v. Riebold" on Justia Law

Higgins and the Union filed suit under 42 U.S.C. 1983 and Missouri law against the District, alleging violations of the United States and Missouri Constitutions and state law. The district court dismissed the federal claims under Rule 12(b)(6) and declined to exercise jurisdiction as to the state law claims. The court concluded that the Union does not have standing in this case to pursue its claims on behalf of its members. In regard to Higgins, the court concluded that Higgins failed to state an equal protection claim where the District explicitly reserved the right to award the contract at issue in its best interest, and to select a bidder other than the lowest. The court also concluded that Higgins failed to state a claim for deprivation of due process where, under Missouri law, an unsuccessful bidder obtains no property right in the award of a construction contract, and Higgins failed to state a violation of the First Amendment where it does not provide any plausible account of how the District interfered with Higgins's ability to associate with the Union or with its employees who are members of the Union. Accordingly, the court affirmed the judgment. View "Higgins Electric, Inc. v. O'Fallon Fire Protection Dist." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and 1985 against the City, code inspector Peterson, and chief code inspector Denker, and various other defendants, alleging federal and state constitutional violations, and that defendants conspired to deter her from seeking judicial relief from their conduct and to deprive her of equal protection of the law and equal privileges and immunities under the law. The district court granted defendants' motion to dismiss. The court concluded that plaintiff's allegations of sexual harassment against Peterson failed to state a claim of municipal liability under section 1983; plaintiff failed to state a claim with respect to the alleged actions of Denker and the unidentified Jane and John Does - either in connection with her sexual harassment claim against Petersen or as an independent claim that these defendants violated her federally protected rights; and plaintiff failed to state a claim independent of Petersen’s alleged sexual harassment. Because plaintiff’s complaint contained no facts showing that Denker or any unnamed City employee violated her constitutional rights, the court did not reach whether Denker, as chief code inspector, was a policymaking official or whether his role in the alleged conduct permits an inference that the City adopted a policy targeting plaintiff. Further, plaintiff failed to allege a conspiracy under section 1985 because the City could not conspire with itself through its agents acting within the scope of their employment. Accordingly, the court affirmed the judgment. View "Kelly v. City of Omaha" on Justia Law