Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against his employer, Crete, alleging it violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., by requiring a medical examination and discriminating on the basis of a perceived disability. Crete required its truck drivers with Body Mass Indexes (BMIs) of 35 or greater to get medical examinations to determine whether they had obstructive sleep apnea. When Crete ordered plaintiff to undergo an examination because his BMI was over 35, he refused. The district court granted summary judgment to Crete. The court concluded that the district court property admitted an expert's testimony regarding obesity and obstructive sleep apnea; by the undisputed facts, the sleep study requirement is job-related because it deals with a condition that impairs drivers’ abilities to operate their vehicle; the requirement is also consistent with business necessity; the district court correctly granted Crete summary judgment on the medical-examination claim where Crete carried its burden of showing it defined the class reasonably; and the undisputed evidence shows that Crete suspended plaintiff for refusing to submit to a lawful medical examination, which does not violate the ADA. Accordingly, the court affirmed the judgment. View "Parker v. Crete Carrier Corp." on Justia Law

Plaintiff filed suit against the University of Minnesota, David Andersen, and Ted Swem, alleging sexual harassment under 42 U.S.C. 1983. Swem was a mentor and guide to plaintiff. The district court denied Swem's motion for summary judgment based on qualified immunity. The court determined that it had jurisdiction to review claims raised in this interlocutory appeal based on the purely legal issue of whether the facts, taken most favorably to plaintiff, support a finding that defendant violated her clearly established constitutional rights. On the merits, the court agreed with the district court that Swem is not entitled to qualified immunity and that summary judgment should be denied. Plaintiff has sufficiently shown that Swem’s conduct toward her was unwelcome harassment, and that it was serious enough to alter a term or condition of her employment. She also showed that Swem’s conduct violated a clearly established right, based on the particular facts of this case. Accordingly, the court affirmed the judgment. View "Jenkins v. Swem" on Justia Law

After plaintiff was terminated from her job at ABM, she filed suit against her former employer, alleging that she was unlawfully terminated based on age in violation of the Minnesota Human Rights Act, Minn. Stat. 363A.08. The court concluded that, viewing the evidence in the light most favorable to plaintiff, the district court did not err in granting summary judgment to ABM. In this case, plaintiff did not meet her burden of establishing a genuine issue of material fact that ABM’s proffered legitimate reason for her termination was pretext for age discrimination. View "Haggenmiller v. ABM Parking Serv." on Justia Law

After charges against plaintiff for disorderly conduct and interference with lawful process were dropped, plaintiff filed suit alleging various claims against government officials. The court affirmed the district court's adverse grant of summary judgment on plaintiff's Fourth Amendment claim because the law regarding warrantless misdemeanor arrests for offenses committed outside the presence of the arresting officer is not clearly established under the Fourth Amendment; plaintiff failed to show a violation of any clearly established First and Fourth Amendment right; in regard to claims of unlawful arrest under Minnesota law, the court did not believe that the officers had sufficiently clear knowledge of what was required of them under the circumstances and the officers did not act maliciously or willfully in violating plaintiff's rights; and, likewise, plaintiff's claim under Monell v. Dep’t of Soc. Servs necessarily fails. The court agreed with the district court that the officers are entitled to qualified immunity for plaintiff's federal law claims, official immunity for plaintiff's state law claim, and that plaintiff has not made out a claim under Monell. Accordingly, the court affirmed the judgment. View "Gilmore v. City of Minneapolis" on Justia Law

After plaintiff was convicted of murder and the charges were subsequently dropped when another person confessed to the murder, plaintiff filed a civil damage action against five individuals and Stone County, Missouri, alleging various claims under 42 U.S.C. 1983 and Missouri state law. The district court granted summary judgment and dismissed Stone County, the County Sheriff, and the Sheriff’s criminal investigation supervisor. The court denied the motions of Stone County Prosecutor Matt Selby, lead investigator Karl Wagner, and investigator Orville Choate, who has not appealed, rejecting their claims of absolute, qualified, and official immunity. Selby and Wagner appealed. Plaintiff argues that investigators Wagner and Choate violated his right to due process as defined in Brady v. Maryland. In this case, the district court erred by failing to adopt the more precise mens rea standard adopted in the court's controlling opinion, Villasana v. Wilhoit. Therefore, the district court must apply this controlling standard when the issue again arises on remand, whether before, during, or after trial. The court also concluded that, on this record, it was error to deny Prosecutor Selby qualified immunity because plaintiff failed to present sufficient evidence that Wagner and Selby violated clearly established Fourth Amendment rights of which a reasonable person would have had. Finally, the court concluded that the district court erred in denying Wagner and Selby qualified immunity from the Sixth Amendment damage claim because no section 1983 precedents give these defendants fair and clear warning of what the Constitution requires, and plaintiff failed to put in the summary judgment record evidence of whether defense counsel at trial moved to suppress or exclude testimony by Parker and Pollard because it was obtained in violation of the Sixth Amendment. Accordingly, the court reversed in part and remanded for further proceedings. View "Stewart v. Wagner" on Justia Law

American Family and Liberty Mutual (Appellants) filed suit against the City after a water-main break in the City flooded the basement condominiums and street-level window wells in the the nearby Sexton building. On appeal, Appellants challenge the district court’s decision on their Equal Protection Clause claim, federal takings claim, and state takings claim. The court concluded that the insurance companies are not similarly situated to the uninsured property owners for purposes of an Equal Protection Clause claim. Even if Appellants could demonstrate that they are similarly situated to the uninsured claimants, the court is satisfied that the reasons proffered by the City, including protecting the welfare of its citizens by minimizing the time claimants were without housing and suffering uncompensated damages, as well as minimizing its own costs and litigation risks, demonstrate that its settlement decisions were rationally related to legitimate, government interests. The court also concluded that because Appellants failed to pursue the available mandamus action in state court, both the state and federal takings claims are not ripe for review by the federal district court. Accordingly, the court affirmed the judgment. View "American Family Ins. v. City of Minneapolis" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that the City's failure to develop a conflict-of-interest policy led to a violation of his constitutional rights when prosecutors (the Attorneys) filed a criminal complaint against him while simultaneously representing the victim of his alleged crime in separate civil actions. The district court granted the City’s and the Attorneys’ separate motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court dismissed a remaining state law claim under Minnesota’s doctrine of statutory discretionary immunity. The court affirmed the district court's dismissal of the complaint against the Attorneys based on absolute prosecutorial immunity where the development of a conflicts policy and the determination as to what constitutes a conflict of interest would necessarily require legal knowledge and the exercise of related discretion, features to which the doctrine of absolute immunity applies; reversed the district court's finding that the City is absolutely immune from suit on plaintiff's section 1983 claim where municipalities do not enjoy absolute immunity from suit under section 1983; and reversed as to the supplemental state law claims based on the same reasoning. View "Sample v. City of Woodbury" on Justia Law

Plaintiffs filed separate actions against various Minnesota cities, counties, and law enforcement entities alleging violations of the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2724(a). In separate orders, the district court denied in part defendants’ motions to dismiss, including claims by many defendants that they are entitled to qualified immunity. The City of Minneapolis appeals the denial of qualified immunity in the Karasov action, and numerous Minnesota counties appeal the denial of qualified immunity in the Kampschroers action. After the parties briefed these appeals, the court issued its decision in McDonough v. Anoka County, which squarely addressed the issue of qualified immunity. The court concluded that McDonough is controlling precedent. The court also concluded that its decision that the statutory term “obtain” is unambiguous controls defendants' additional argument that the rule of lenity entitles them to qualified immunity. Accordingly, the court affirmed the judgment. View "Kampschroer v. Ramsey County" on Justia Law

Plaintiffs, Minnesota driver's license holders, filed suit against local entities, Law Enforcement Does, Commissioners, and DPS Does, alleging that defendants violated the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2721-2725, by accessing or disclosing personal information from the DPS database without a permissible purpose. The district courts dismissed the actions for failure to state a claim. The present appeals raise issues similar to those presented in the court's opinion in McDonough v. Anoka County and are governed by the court's holding in that case. McDonough discussed the history, purpose, and applicability of the DPPA. The court addressed the individual complaints in this group of cases and affirmed in part, reversed in part, and remanded for further proceedings. View "Ray v. Anoka County" on Justia Law

Plaintiffs appealed the district court's order granting the District's motion to approve the closure of Wilmot Elementary School and to modify the gifted and talented (GT) requirements for the District. In 1988, plaintiffs filed suit under 42 U.S.C. 1983, alleging race discrimination and other claims. The parties negotiated a settlement and, in 1991, the district court entered a Consent Order disposing of issues remaining in the complaint. In this case, the district court approved closure of Wilmot and modification of the GT program as the proper modification of the Consent Order due to the significant changed circumstances. The court concluded that such modification is suitably tailored where the modifications sought by the school district in light of the (1) demographic changes, (2) decrease in enrollment, (3) cost savings, and (4) educational considerations are in line with the initial Consent Order. Accordingly, the court held that the district court did not abuse its discretion in granting the District's motion to approve closure of Wilmot and to modify the GT requirements. The court affirmed the judgment. View "Mays v. Hamburg Sch. Dist." on Justia Law