Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against the Marshals seeking damages pursuant to Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. Plaintiff alleged that the Marshals’ false arrest, unreasonable search and seizure, and use of excessive force violated his Fourth and Fifth Amendment rights. On remand, the district court denied in part the Marshals' motion for summary judgment. The court held that the Marshals are entitled to qualified immunity on plaintiff’s excessive force claim because it was not clearly established in April 2009 that the use of a Tazer against a suspected armed and dangerous felon violated the Fourth Amendment. The court also held that the Marshals are entitled to summary judgment on plaintiff's claims for unreasonable seizure where the twenty-minute detention was not an unreasonable seizure under the Fourth Amendment. Accordingly, the court reversed the judgment denying the Marshals' motion for summary judgment and remanded for an order granting qualified immunity to Deputies Franklin and Wallace. View "Wright v. Franklin" on Justia Law

The US filed suit on behalf of the USDA to enjoin dissolution of the Benton County Sewer District No. 1. A Voter Representative Group seeks to intervene. The district court denied the motion. The court affirmed, concluding that the Group does not have Article III standing. The court rejected the Group's claims that it has an interest in upholding the vote to dissolve the District and immediately dissolving the District; an interest in opposing the repayment of the revenue bond the District issued to the USDA; an interest in opposing the State’s claims under the Missouri law; and an interest in proposing on-site sewage treatment alternatives. View "United States v. Geranis" on Justia Law

Plaintiff, an incarcerated felon, filed suit against defendants, alleging that the Arkansas Freedom of Information Act, Ark. Code Ann. 25-19-105(a)(1)(B), violates the equal protection and due process clauses of the Fourteenth Amendment. An employee of the police department denied plaintiff's request for information regarding an individual plaintiff had assaulted because the Act only permits an incarcerated felon to request information of public record through an attorney. The court concluded that the district court did not err by granting summary judgment to defendants because the Act does not violate the equal protection clause where the Act's limitation on those who many benefit from the law is rationally related to at least two legitimate government purposes: the prevention of unlawful use of the statute like harassing or threatening a witness or victim and conserving government resources; the Act does not violate plaintiff's due process right to access the courts because he has not shown that he will suffer an actual injury as a result of the Act's exclusion; and the district court did not abuse its discretion in denying plaintiff's Rule 60(b) motions because his claims failed on the merits and he was not entitled to additional discovery. Accordingly, the court affirmed the judgment. View "Gregory Holt v. Michelle Howard" on Justia Law

Spectra filed suit against the City, alleging that the City violated federal and Missouri law by requiring Spectra to comply with a local ordinance governing public rights of way. Determining that Spectra's 42 U.S.C. 1983 claim is properly before the court, the court concluded that section 253 of the Telecommunications Act of 1996, 47 U.S.C. 253, does not authorize a private right of action for damages under section 1983. Therefore, the district court did not err in dismissing Spectra's section 1983 claim. The court also concluded that the district court properly abstained under Colorado River, which permits federal courts to decline to exercise jurisdiction over cases where "parallel" state court litigation is pending, meaning that there is "a substantial likelihood that the state proceeding will fully dispose of the claims presented in the federal court." Finally, the court concluded that the district court did not abuse its discretion in denying the City's first request for attorney fees and the City's renewed fee request. Spectra did not continue actively to pursue its section 1983 claim after the district court dismissed it, but simply reasserted it for the purpose of preserving its rights on appeal. Accordingly, the court affirmed the judgment. View "Spectra Commc'n Grp. v. City of Cameron, MO" on Justia Law

Plaintiff appealed the dismissal of his disability discrimination and constructive discharge claims against SNS. The court concluded that, viewing the facts in the light most favorable to plaintiff, a reasonable person would not have found his work environment intolerable. Therefore, the district court did not err by granting summary judgment to SNS on plaintiff's claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. The court concluded that the fact that an employee is disciplined in accordance with an employment policy is not enough to prove a constructive discharge claim under the MHRA. In this case, while one of plaintiff's supervisors laughed when asked about plaintiff's future at SNS and another supervisor told plaintiff that "this" would continue if he did not resign, the evidence was insufficient to create a material factual dispute about whether plaintiff's work environment was intolerable. The court also concluded that plaintiff did not give SNS a reasonable opportunity to resolve any problems with supervisors and plaintiff admits that he never complained about his supervisors during his employment. Therefore, the district court properly granted SNS summary judgment on plaintiff's constructive discharge claim. The court affirmed the judgment. View "Cosby v. Steak N Shake" on Justia Law

Plaintiffs sell technology that permits computers to identify license-plate numbers in digital photographs taken by cameras mounted on vehicles. The cameras automatically photograph everything the vehicles encounter, with GPS coordinates; software provides notice if a photographed vehicle is subject to repossession. The information is sold to clients, including automobile finance and insurance companies and law enforcement. Arkansas’s Automatic License Plate Reader System Act prohibits use of automatic license plate reader systems and permits any person claiming harm from a violation to seek damages from the violator. Vigilant and its affiliates sued, arguing that “use of [automatic license plate reader] systems to collect and create information” and dissemination of the information constitutes speech and that the Act impermissibly restricts this speech based on content—license-plate data—and on the identity of the speaker, because it exempts some entities, such as law enforcement agencies. The district court dismissed, ruling that state officials were immune from suit under the Eleventh Amendment. The Eighth Circuit affirmed on the ground that the plaintiffs lack standing, so there is no Article III case or controversy. State officials do not have authority to enforce the Act, so they do not cause injury; the Act provides for enforcement only through private actions for damages. View "Digital Recognition Network, Inc. v. Hutchinson" on Justia Law