Justia Constitutional Law Opinion Summaries

After plaintiff's son was denied coverage related to gender reassignment services and surgery, plaintiff filed suit against Essentia and the health insurance plan's third party administrator for sex based discrimination in violation of Title VII of the Civil Rights Act of 1964, the Minnesota Human Rights Act (MHRA), and the Affordable Care Act (ACA). The Eighth Circuit held that plaintiff was not discriminated against on the basis of her own sex, and the protections of Title VII and the MHRA do not extend to discrimination based on her son's sex. Therefore, the court affirmed as to this issue. The court reversed the district court's dismissal of plaintiff's ACA claim based on lack of Article III standing, holding that plaintiff has alleged an injury cognizable under Article III because she contends that defendants' discriminatory conduct denied her the benefits of her insurance policy and forced her to pay out of pocket for some of her son's prescribed medication. View "Tovar v. Essentia Health" on Justia Law

Plaintiff filed suit against Frederick Tucker and the county sheriff, alleging unlawful retaliation after she supported a different candidate in an election for presiding judge. The Eighth Circuit affirmed the district court's denial of summary judgment to Tucker based on qualified immunity, holding that plaintiff provided sufficient evidence for a reasonable fact finder to conclude that Tucker violated plaintiff's right to support an electoral candidate of her choice. Furthermore, the First Amendment right was clearly established at the time. View "Jenkins v. Tucker" on Justia Law

Michael Dooley's estate filed suit under 42 U.S.C. 1983, alleging that a deputy sheriff used excessive force when he shot and killed Dooley. The Eighth Circuit affirmed the grant of summary judgment to the deputy, holding that the district court did not err in ruling that the deputy's use of deadly force was objectively reasonable as a matter of law. In this case, the deputy was responding to a potentially dangerous situation where Dooley was dressed in military uniform and carrying a rifle. Although new information came to light after the shooting that the rifle was actually a pellet gun, a reasonable officer in the deputy's position could believe that Dooley was pointing a gun at the deputies and that they were in serious risk of harm. Furthermore, the district court did not err by granting summary judgment for defendant on plaintiffs' state tort claims because the use of force was reasonable and permitted by law. View "Dooley v. Tharp" on Justia Law

Plaintiff filed suit against McGraw-Hill, alleging claims of employment discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 1981, and the Missouri Human Rights Act. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of McGraw-Hill, holding that plaintiff failed to show a pretext for discrimination on his claim that two white counterparts were paid a higher salary; plaintiff failed to establish a case of salary discrimination on his claim that he was denied a spot bonus where no similarly situated employee was treated differently; in regard to the hostile work environment claim, plaintiff failed to show a causal connection between the alleged acts of harassment and his race; one race-related comment that plaintiff allegedly overheard did not constitute harassment sufficiently severe and pervasive to support a hostile work environment claim; and, in regard to the discriminatory discharge claim, even if plaintiff established a prima facie case of discriminatory discharge, he did not meet his burden to show that McGraw-Hill's proffered reason for discharging him was pretext for discrimination. In this case, plaintiff's documented performance deficiencies constituted a legitimate, nondiscriminatory reason for discharging him. Finally, any claim of retaliation failed because plaintiff failed to show a causal connection between the alleged retaliatory act and protected conduct. View "Stone v. McGraw-Hill Global Financial" on Justia Law

The Eighth Circuit affirmed the grant of summary judgment based on qualified immunity and official immunity to Officer Heady in plaintiff's suit alleging excessive use of force under 42 U.S.C. 1983, as well as common law negligence and battery. In this case, it was objectively reasonable for Heady to believe that plaintiff's reach for the gearshift was an attempt to shift the car to drive and to flee; he had reason to believe that plaintiff was intoxicated and a potential threat to public safety; and when the brake lights to the SUV turned on, Heady said "no, no, no," reached into the car, and turned off the ignition. Therefore, Heady was justified in using force to remove plaintiff from the vehicle. View "Boude v. City of Raymore" on Justia Law

The Eighth Circuit affirmed the denial of a 28 U.S.C. 2255 motion for post-conviction relief, holding that petitioner's claim, that he was denied due process when the district court entered an amended judgment that modified the restitution order without ensuring that he was given notice and an opportunity to be heard, was not cognizable under section 2255. The Eighth Circuit explained that the district court's order amending the judgment did not result in a new sentence or judgment because there was no substantive proceeding that adjudicated petitioner's guilt or determined the appropriate punishment. Further, the district court did not alter the amount of petitioner's restitution obligation or otherwise change his sanction. Therefore, the district court correctly dismissed petitioner's successive motion for lack of authorization from the court of appeals. View "Dyab v. United States" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's request for a broader preliminary injunction against the enforcement of rules of the Iowa State Fair that forbid impeding traffic and bringing signs attached to poles and sticks to the Fair. The Eighth Circuit concluded that, whatever level of precision might be required for Fair rules to satisfy due process, plaintiff was not likely to succeed on his claim; a person of ordinary intelligence in plaintiff's position was on fair notice; plaintiff was well informed that carrying a sign on a pole violates a rule against carrying signs attached to sticks or poles; plaintiff was not likely to succeed on a claim that the Fair's rules impermissibly encourage arbitrary and discriminatory enforcement because he failed to present evidence demonstrating that the Fair authorities have discriminated in favor of others who are similarly situated to him; that the rules were unwritten does not deprive plaintiff of fair notice prospectively; and plaintiff failed to show that he was likely to suffer irreparable harm. View "Powell v. Ryan" on Justia Law

The Eighth Circuit affirmed the grant of summary judgment in favor of the YMCA in plaintiff's public accommodation suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff argued that the YMCA's blanket policy of requiring a child's individualized education program (IEP) before admitting the child to its summer camp programs was discriminatory because the IEP in effect serves to screen out children with disabilities from the YMCA summer camp programs. The district court correctly determined that the YMCA took no adverse action against plaintiff's child. Assuming that plaintiff's request to provide less information than the entire IEP was a request for an accommodation, plaintiff failed to establish that the YMCA failed to unreasonably accommodate the child where the YMCA offered to modify the policy as long as it obtained the information it deemed necessary to accommodate the child. View "Koester v. Young Men's Christian Assoc." on Justia Law

The Eighth Circuit reversed and remanded the district court's grant of summary judgment in a suit against employees of a juvenile home, concluding that the district court erred by holding as a matter of law that defendants were entitled to qualified immunity. Plaintiff alleged that defendants violated his constitutional rights by housing him in prolonged solitary confinement, failing to educate him, and allowing him to be sexually abused. In this case, the district court addressed only the fact of juvenile court supervision in determining that defendants were entitled to qualified immunity, and its opinion did not contain sufficient detail to allow the court to review whether defendants were entitled to qualified immunity. View "Bradford v. Avery" on Justia Law

In three consolidated cases, the court concluded that the motion for relief and the petition for writ constitute second or successive habeas applications, and denied authorization for the district court to consider them; petitioner's claim that his counsel was ineffective for failing to undertake an investigation into juror bias or misconduct was sufficiently similar to a habeas corpus application; and, even if the court were to conclude that the motion was not a second or success habeas petition, petitioner has not shown extraordinary circumstances that would justify relief. The court denied petitioner's application for a certificate of appealability as moot; petitioner's protective application to file a second or successive habeas petition; and motions for stay of execution that were currently pending in each of the three cases. View "Williams v. Kelley" on Justia Law