Justia Constitutional Law Opinion Summaries

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

Plaintiff John Young and the Commission entered into a Prosecutor/County Lease Agreement covering plaintiff's office building. After the Commission passed an ordinance that mandated that every resident of the county be assigned a permanent 911 address, John and Georgetta Young filed suit alleging claims centered on their contention that defendants retaliated against them for their address complaints. On appeal, plaintiffs challenge the district court's holding that defendants were protected by legislative immunity or, in the alternative, by qualified immunity. The court concluded that the district court correctly ruled that the Commissioners were entitled to legislative immunity for denying plaintiff's budget request, terminating the Agreement, and ceasing the $350.00 monthly rental payments. Furthermore, the district court properly found that the Commissioners are entitled to qualified immunity as to their request that the state attorney general review the legality of the Agreement. Accordingly, the court affirmed the district court's grant of summary judgment for the Commissioners. View "Young v. Mercer County Commission" on Justia Law

Ramon Mendoza, a naturalized United States citizen, challenged the district court's grant of summary judgment for ICE agent Justin Osterberg, the County, the County employees, and Sheriff Davis on numerous claims based on an improper immigration detainer that was issued and later withdrawn. The detainer was withdrawn once Osterberg confirmed that Mendoza was not in fact Ramon Mendoza-Gutierrez, an aggravated felon. The court concluded that Osterberg had arguable probable cause to issue the ICE detainer and was entitled to qualified immunity on plaintiff's Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics claim; the sheriff was entitled to qualified immunity because he had no direct participation in the alleged violations; there was no violation of Mendoza's constitutional rights and the County employees are entitled to qualified immunity; the district court properly granted summary judgment for Sheriff Davis and the County on plaintiff's claims of supervisory and municipal liability under 42 U.S.C. 1983 where employees received instructive memorandum and on-the-job training; the actions in this case cannot reasonably be attributed to a defective governmental policy or custom; even if there were no policies or training on how to handle ICE detainers, there was no constitutional violation; there was no Fifth Amendment due process violation; and there was no evidence of defendants' conspiracy in violation of section 1984(3). Accordingly, the court affirmed the judgment. View "Mendoza v. Davis" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging violations of his constitutional and statutory rights by defendants. Plaintiff also sought certification of a class action suit against the United States Attorney General on behalf of African-Americans in Arkansas subjected to equal protection and due process violations. The district court granted summary judgment in favor of defendants. Plaintiff alleged that the AG Defendants violated his due process rights when they accessed his sealed trial records. The district court concluded, however, that none of the actions taken by the AG Defendants amount to a brutal abuse of power. In this case, the AG Defendants acted reasonably, particularly in light of Arkansas caselaw allowing the use of expunged records to impeach testimony when the actual innocence of the witness has not been shown. Because the AG Defendants' conduct failed to shock the conscience, no substantive due process violation occurred. Furthermore, because plaintiff had no state-created liberty interest created by the Arkansas expungement statute for the AG Defendants to violate, the AG Defendants were entitled to qualified immunity on the procedural due process claim. The court rejected plaintiff's defamation claim against Attorney General McDaniel because he is entitled to absolute legislative immunity. Finally, plaintiff's Brady v. Maryland claims, brought under 42 U.S.C. 1983, are time-barred. Accordingly, the court affirmed the judgment. View "Buckley v. Ray" on Justia Law

After the Iowa State University (ISU) student chapter of the National Organization for the Reform of Marijuana Laws (NORML ISU) had several of its trademark licensing requests denied because its designs included a cannabis leaf, two members of the student group filed a 42 U.S.C. 1983 action, alleging various violations of their First and Fourteenth Amendment rights. The district court granted plaintiffs summary judgment in part and entered a permanent injunction against defendants. The court concluded that plaintiffs suffered an injury in fact in their individual capacities, and that they therefore have standing to bring this action. The court reasoned that plaintiffs' allegations that ISU violated their First Amendment rights by rejecting their designs and therefore preventing their ability to spread NORML ISU's message are sufficient to establish an injury in fact. The court also concluded that qualified immunity is not an issue here because this appeal solely concerns plaintiffs' request for injunctive relief; the district court did not err by concluding that defendants violated plaintiffs' First Amendment rights because defendants engaged in viewpoint discrimination and did not argue that their administration of the trademark licensing program was narrowly tailored to satisfy a compelling governmental interest; and NORML ISU's use of the cannabis leaf does not violate ISU's trademark policies because the organization advocates for reform to marijuana laws, not the illegal use of marijuana. Accordingly, the court affirmed the judgment. View "Gerlich v. Leath" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging, inter alia, excessive force after a police officer, Robert Hinman, shot him. The district court granted summary judgment to Officer Hinman, Chief Stuart Thomas, and the City of Little Rock. The court noted the tragic nature of the events where plaintiff was trying to defuse a situation where his former schoolmate had pulled out a gun and pointed it at a crowd. Plaintiff was in possession of the gun because he had taken it away from his schoolmate. Plaintiff was shot several times and is now paralyzed from the neck down. The court held that Officer Hinman's use of deadly force was objectively reasonable and the district court did not err in granting his motion for summary judgment based on qualified immunity. In this case, the officer instructed plaintiff to stop but plaintiff did not hear him, plaintiff continued to run toward another officer with the gun in plaintiff's hand, and plaintiff was two to three feet from the other officer before Officer Hinman fired his gun. Because the court concluded that Officer Hinman did not violate plaintiff's constitutional rights, the court rejected plaintiff's claims against Chief Thomas and the City. Accordingly, the court affirmed the judgment. View "Malone v. Hinman" on Justia Law

Plaintiff filed suit against the Civic Center and the City after his lease for a concession stand was terminated and his property was seized. Plaintiff alleged municipal liability based on the decision of the policymaker. The court explained that the district court must identify the final policymaker in accordance with South Dakota state law and local Rapid City ordinances. Because the district court failed to do so in this case, the jury rendered a verdict against defendants that lacked a legally sufficient basis. Therefore, the court reversed the district court's ruling on the Civic Center's renewed motion for judgment as a matter of law, vacated the jury's verdict, and remanded for a new trial. View "Soltesz v. Rushmore Plaza Civic Center" on Justia Law