Justia Constitutional Law Opinion Summaries

Plaintiffs Dindinger, Loring, and Freund filed suit against Allsteel, alleging claims of sex-based wage discrimination under the Equal Pay Act, 29 U.S.C. 206(d); Dindinger and Loring also brought claims of sex-based wage discrimination under the Iowa Civil Rights Act, Iowa Code 216.6A, and Title VII of the Civil Rights Act, 42 U.S.C. 2000e; and Loring additionally brought a claim of sex-based discrimination for failure to promote under Title VII. On appeal, Allsteel challenged the district court's denial of its motion for a new trial and grant of plaintiffs' motions for attorney's fees and costs. The court concluded that the district court correctly instructed the jury that Allsteel could not rely on economic conditions to establish its affirmative defense to the Equal Pay Act claim that a factor other than sex justified the pay discrepancies between plaintiffs and their male comparators; even if the court were to agree that economic conditions could be a factor other than sex justifying a pay differential in some circumstances, Allsteel did not present evidence to establish such a defense here; and because Allsteel did not present evidence that economic conditions caused the pay differentials plaintiffs experienced, the district court did not abuse its discretion in instructing the jury that Allsteel could not rely on economic conditions to establish an affirmative defense. The court also concluded that the district court did not abuse its discretion by admitting "me-too" evidence; limiting Allsteel's ability to offer evidence regarding the audit; and by admitting testimony from Loring's supervisor. Finally, the court concluded that the district court did not abuse its discretion in regard to attorney's fees, but remanded the issue of costs with instructions to determine whether charging clients separately for Westlaw research is the prevailing practice in Iowa. Accordingly, the court remanded as to this issue and affirmed in all other respects. View "Dindinger v. Allsteel, Inc." on Justia Law

After Mark A. Sveen designated his then-wife, Kaye L. Melin, as the primary beneficiary of his life insurance policy, and his children as contingent beneficiaries, Minnesota extended its revocation-upon-divorce statute to life insurance policies. When Mark died in 2011, his children and Melin cross-claimed for the proceeds. The district court granted summary judgment to the children. The court concluded that a contested beneficiary like Melin has standing; this court has held in Whirlpool Corp. v. Ritterthat a revocation-upon-divorce statute like the one here violates the Contract Clause when applied retroactively; and thus the court's previous opinion forecloses any conclusion other than that the statute here was unconstitutional when applied retroactively. Accordingly, the court reversed and remanded for further proceedings. View "Melin v. Sveen" on Justia Law

Plaintiff, a former transport deputy for the county, filed suit against Sheriff Andy Shock, in his individual and official capacities, for unlawful employment termination under state and federal law. Plaintiff filed suit under 42 U.S.C. 1983, alleging the deprivation of his First Amendment right to free association. The court affirmed the district court's dismissal of plaintiff's claim against the sheriff in his official capacity because, under Arkansas law and the policies promoted by the county, the sheriff did not act as a final policymaker in the employment decisions of the sheriff's office where such decisions were subject to review by the quorum court. However, the court vacated the finding of qualified immunity for the sheriff in his individual capacity because the district court should have applied the Elrod-Branti analysis to determine whether a government employer could violate an employee's First Amendment rights even if acting under the mistaken belief that the employee was affiliated with a certain candidate. The court explained that the Elrod-Brandi test applied when a constitutional right at issue involved joining, working for or contributing to the political party and candidates of the employee's choice. Therefore, the court remanded that issue for the district court to apply the analysis in the Elrod-Branti line of cases. The court otherwise affirmed the judgment. View "Thompson v. Shock" on Justia Law

Plaintiff filed suit against CSM, alleging civil rights violations after she was terminated. The district court granted summary judgment to CSM. The court concluded that plaintiff failed to establish the causation element of her prima facie case of retaliation and reprisal based on the attenuated temporal proximity of the decline in her work performance and the her complaints, and the lack of evidence from which a jury could infer a discriminatory motive. Therefore, the district court properly granted summary judgment to CSM on these claims. The court also concluded that the district court properly dismissed plaintiff's gender discrimination claims where plaintiff had a history of satisfactory performance and the evidence demonstrated that her supervisors and coworkers had on numerous occasions informed her of perceived deficiencies in her work. Finally, the court concluded that the district court properly granted summary judgment to CSM on plaintiff's hostile work environment claim where she failed prove that the comments at issue were so objectively and subjectively offensive that they altered the terms and conditions of her employment. Accordingly, the court affirmed the judgment. View "Liles v. C.S. McCrossan, Inc." on Justia Law

Plaintiff filed suit alleging that BNSF violated the Federal Rail Safety Act (FRSA), 49 U.S.C. 20109, when it terminated his employment for harassing a co-worker and threatening a supervisor. The district court ultimately granted BNSF summary judgment on the merits and dismissed the complaint with prejudice. The court affirmed the dismissal of plaintiff's retaliation claim because he failed to submit evidence that would permit a reasonable jury to infer that his FRSA-protected activities were a contributing factor in BNSF's decision to discharge him for harassing and intimidating a co-worker. Because BNSF did not sufficiently develop its alternative waiver argument, did not raise a laches or estoppel defense in the district court or on appeal, and presented insufficient proof (if any) on these fact intensive issues, the court left these questions for another day. Accordingly, the court affirmed the judgment. View "Gunderson v. BNSF Railway" on Justia Law

Plaintiff, on behalf of her minor son J.M., filed suit against the School District, alleging unlawful use of isolation and physical restraints, in violation of the Equal Protection Clause of the Fourteenth Amendment; 42 U.S.C. 1983 and 1988; the Americans with Disabilities Act (ADA), 42 U.S.C. 12182; Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq.; and the Missouri Human Rights Act (MHRA), RSMo 213.010 et seq. The district court dismissed the federal claims and declined to exercise supplemental jurisdiction over the MHRA claim. In this case, plaintiff did not file an Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., due process complaint, request a due process hearing, or engage in the exhaustion procedures under the IDEA. The court concluded that because the complaint sought relief available under the IDEA, denial of a free appropriate public education (FAPE), the claims were subject to exhaustion, barring an applicable exception. The court rejected plaintiff's futility and inadequate remedy arguments and affirmed the district court's dismissal of the complaint for failure to exhaust administrative remedies. View "J.M. v. Francis Howell School District" on Justia Law

After Jerome Harrell died while in custody at the county jail, Harrell's estate filed suit against the county and various correctional officers under 42 U.S.C. 1983, alleging violations of Harrell's constitutional rights as well as other claims. The district court granted summary judgment for defendants. The court concluded that genuine issues of fact remain on the question of whether defendants Armstrong and Culloton were deliberately indifferent to Harrell's serious medical needs when they allowed him to scream, howl, and bang against his cell door for eight hours without attempting to talk to him or seek medical intervention. Therefore, the district court erred by granting summary judgment to Armstrong and Culloton on the ground that they were entitled to qualified immunity, and the court reversed as to this issue. The court concluded that defendants were entitled to qualified immunity on the trustee's excessive force claim where, among other things, Harrell was actively resisting the extraction procedure by ignoring directives to lie down on his bunk and resisting defendants' efforts to subdue him once they entered his cell, and defendants' testimony about the degree of Harrell's resistance was corroborated. Under the totality of these circumstances, none of the defendants' actions, either singly or in combination, amounted to an objectively unreasonable application of force. Therefore, the court affirmed as to the excessive force claim. Because the court was remanding some of the federal claims, the court also vacated the dismissal of the state law claims and remanded. View "Ryan v. Armstrong" on Justia Law

Plaintiff, an African American female, filed suit against DHS, alleging disparate treatment on account of race, and retaliation in violation of Title VII, 42 U.S.C. 2000e-2 and 2000e-3(a). The district court dismissed the claims. On appeal, plaintiff argued that the district court erred in dismissing her claim for disparate treatment "on account of her race, when she was disciplined for something that a Caucasian female employee did not accomplish." The court concluded that plaintiff's claim of discipline did not allege that the Caucasian employee was not disciplined or received less discipline. The court explained that without an allegation of disparate treatment, this claim failed. The court concluded, however, that the district court erred in dismissing the retaliation claim where plaintiff alleged but-for causation. The court explained that plaintiff's claim permitted the court to infer more than the mere possibility of misconduct. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Wilson v. Arkansas DHS" on Justia Law

Plaintiff filed suit against his employer, Optomec, alleging that he was terminated on account of his age in violation of the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01 et seq. The court affirmed the district court's grant of summary judgment in favor of Optomec because plaintiff failed to establish a prima facie case of age discrimination. The court reasoned that, even if he had, there was insufficient evidence to suggest the lawful reason Optomec gave for its decision was pretext for an underlying unlawful motive. In this case, Optomec's reasons for firing plaintiff was that he lacked the skill set and potential Optomec wanted from lab technicians to account for the company's anticipated growth. Accordingly, the court affirmed the judgment. View "Nash v. Optomec, Inc." on Justia Law

Plaintiffs filed suit against the Minnesota Secretary of State and others, challenging a statute prohibiting the wearing of political insignia at a polling place, Minnesota Statute 211B.11. This court reversed the dismissal of plaintiffs' as-applied First Amendment claim in Minnesota Majority v. Mansky, 708 F.3d 1051, 1059 (8th Cir. 2013). The district court, on remand, granted summary judgment for defendants. The court concluded that the statute and Policy are viewpoint neutral and facially reasonable. The court noted that the statute and Policy prohibit more than election-related apparel. The court explained that, even if Tea Party apparel was not election-related, it was not unreasonable to prohibit it in a polling place. In order to ensure a neutral, influence-free polling place, all political material was banned. In this case, EIW offered nothing to rebut evidence that the Tea Party has recognizable political views. The court concluded that the district court properly granted summary judgment because no reasonable trier of fact could conclude that the statute and Policy as applied to EIW violated its First Amendment rights. Accordingly, the court affirmed the judgment. View "Minnesota Voters Alliance v. Mansky" on Justia Law