Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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Plaintiff, a former police officer, filed a 42 U.S.C. 1983 action against the city and the chief of police, alleging unlawful retaliation for exercising his First Amendment right to participate in a media interview, deprivation of his right to pretermination process, and violation of his rights under the North Dakota Constitution. The Eighth Circuit affirmed the district court's grant of defendants' motion for summary judgment. The court held that the district court properly granted summary judgment on the First Amendment claim where plaintiff failed to prove his speech as a public employee was protected by the First Amendment. In this case, the district court found that plaintiff was not speaking as a citizen in a local news interview; plaintiff's speech during the interview was not on a matter of public concern because his asserted desire was to clear the name of his Facebook alias, which was a purely private interest; and even assuming plaintiff was a citizen commenting on a matter of public concern, his speech at the interview was not First Amendment protected, because it created great disharmony in the workplace, interfered with plaintiff's ability to perform his duties, and impaired his working relationships with other employees. The court also held that plaintiff was not deprived of his right to due process, and declined to exercise supplemental jurisdiction over the state law claims. View "Nagel v. City of Jamestown" on Justia Law

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After plaintiff was sexually assaulted by a deputy acting within the scope of his employment with the sheriff's office, she filed claims of unreasonable search and seizure, equal protection, due process, supervisory liability, and municipal liability under the Civil Rights Act, 42 U.S.C. 1983. The Eighth Circuit reversed the district court's denial of qualified immunity and summary judgment in favor of the sheriff. The court held that the sheriff was entitled to qualified immunity, because prior instances of sexual misconduct were not similar in kind or sufficiently egregious in nature to demonstrate a pattern of sexual assault against members of the public by deputies. Therefore, a reasonable officer in the sheriff's position would not have known that he needed to more closely supervise his deputies, including defendant, or they might sexually assault a member of the public. Furthermore, a reasonable supervisor in the sheriff's position would not know that a failure to specifically train defendant not to sexually assault a woman would cause defendant to engage in that behavior. View "McGuire v. Cooper" on Justia Law

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Plaintiffs, a group of pretrial arrestees who were detained in St. Louis jails, filed a 42 U.S.C. 1983 action, challenging the constitutionality of the procedures by which defendants, state and city officials, set money bail. The Eighth Circuit reversed the district court's grant of plaintiffs' motion for class certification and entry of a preliminary injunction enjoining the enforcement of any monetary condition of release resulting in detention. In this case, the district court resorted to the extraordinary remedy of injunctive relief without adequately considering the new rules and their implementation. The district court abused its discretion by interjecting the power of the federal government into the Missouri Supreme Court's attempt to police its own lower courts, without contemplating what this would mean for federal-state relations. On remand, the district court should consider the effect of the rule changes on the question of whether a preliminary injunction served the public interest in comity between the state and federal judiciaries, as well as the necessity of an injunction. View "Dixon v. City of St. Louis" on Justia Law

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The Eighth Circuit affirmed the district court's denial of a third successive federal habeas corpus petition challenging petitioner's state law murder conviction. The court held that the district court did not err in finding that it lacked jurisdiction to hear the petition because he failed to establish by clear and convincing evidence it was more likely than not that no reasonable jury would have found him guilty beyond a reasonable doubt. Because petitioner failed to make out a colorable claim under 28 U.S.C. 2254(e)(2)(B), he was not entitled to an evidentiary hearing. View "Rhodes v. Smith" on Justia Law

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Plaintiff filed suit against current and former members of the Missouri State Highway Patrol, alleging that adverse employment actions were taken against him in retaliation for his protected First Amendment speech. The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that plaintiff's non-testimonial speech was not entitled to First Amendment protection. In this case, although it was undisputed that plaintiff spoke as a private citizen and his speech was of public concern, the highway patrol has shown sufficient evidence of disruption to the efficiency of its operations. Under the Pickering balancing test, the court held that the factors weighed in favor of the highway patrol's interest in efficiency and indicated that plaintiff's speech activity was more likely than not impeding his ability to perform his job duties as a police officer. Therefore, defendants were entitled to qualified immunity regarding plaintiff's speech to the family of the victim of a drowning accident, on social media, and to the news reporter. The court also held that the remaining testimonial speech was not a substantial or motivating factor in the adverse employment actions against plaintiff. Finally, plaintiff's civil conspiracy and failure to supervise claims failed as a matter of law. View "Henry v. Johnson" on Justia Law

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Ali shot and killed three people during an attempted robbery in Minneapolis. He was given three consecutive life sentences, each permitting his early release after 30 years so that Ali must remain in prison for at least 90 years. Relying on recent Supreme Court precedent, Ali argued that the Eighth Amendment forbids life-without-parole sentences for juvenile defendants unless they are irreparably corrupt and that a sentencing court must conduct a hearing to consider the juvenile defendant’s youth as a mitigating factor before imposing a life-without-parole sentence. Ali claimed his sentence was the “functional equivalent” of life-without-parole. The Minnesota Supreme Court rejected Ali’s argument. The Eighth Circuit affirmed the denial of Ali’s petition for habeas relief under 28 U.S.C. 2254. Ali’s case is distinguishable from the Supreme Court cases; Ali received three life sentences for three separate murders, each permitting possible release. Ali does not face a life-without-parole sentence and the Supreme Court has not “clearly established” that its ruling apply to consecutive sentences functionally equivalent to life-without-parole. View "Ali v. Roy" on Justia Law

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Plaintiff filed suit against the city and others, seeking damages and injunctive and declaratory relief under 42 U.S.C. 1983, alleging unlawful arrest, detention, and prosecution, and the setting of an excessive cash-only bond that plaintiff was unable to pay due to indigency. The Eighth Circuit affirmed the district court's dismissal of the section 1983 claims and held that the municipal judge was entitled to absolute judicial immunity from plaintiff's arrest and detention damage claims based on an invalid warrant issued by the court clerk; the judge's practice of setting a bond schedule conditioning the pretrial release of persons accused of municipal ordinance violations was a judicial act within his jurisdiction to which judicial immunity attaches; and the district court correctly concluded that the clerk was entitled to quasi-judicial immunity. Even if the court considered the judge's judicial bond practice to be part of municipal custom or usage, the court would still affirm the dismissal of the claim because there was no evidence of deliberate indifference to plaintiff's rights as an indigent arrestee. Finally, the court held that there was insufficient evidence for a reasonable jury to find a meeting of the minds between defendants on the conspiracy claim. View "Hamilton v. City of Hayti" on Justia Law

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Plaintiff filed suit against the city under 42 U.S.C. 1983, alleging that it had jailed her without inquiring into whether she had the means to pay the fines imposed and without appointing counsel for her. The district court dismissed plaintiff's claims on the ground that a judgment in her favor would necessarily imply the invalidity of her conviction or sentence under Heck v. Humphrey, 512 U.S. 477, 487 (1994). The Eighth Circuit affirmed the dismissal of plaintiff's claims, although on different grounds. The court held that the judicial decisions of a duly elected judge are not the kind of decisions that expose municipalities to section 1983 liability. Furthermore, neither the city council nor the mayor has the power to set judicial policy for Arkansas district court judges or the power to ratify their decisions even if the city's policymakers knew of the judge's conduct and approved of it. In this case, the court held that the district court did not err by dismissing plaintiff's claims about the district court's failure to inquire into her indigency and failure to appoint counsel, along with her related, derivative claims about the practices in the Sherwood District Court. View "Williams v. City of Sherwood" on Justia Law

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The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining the enforcement of Ark. Code Sec. 7-6-203(b)(1), which provides that candidates can only accept contributions within two years of an election. Plaintiff, who wished to donate to candidates running for state office in Arkansas's 2022 election, alleged that this blackout period violates her First Amendment rights. The court held that plaintiff alleged Article III standing because the allegations in her complaint and affidavit established that she intended to engage in a course of conduct arguably affected with a constitutional interest, but proscribed by a statute, and that there was a credible threat of prosecution if she donated to a candidate. The court also held that the district court correctly determined that, at this early stage of the litigation, plaintiff was likely to succeed on the merits, because Arkansas failed to show how the blackout period advances its anti-corruption interest. View "Jones v. Jegley" on Justia Law

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In this interlocutory appeal, the Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer who stopped, frisked, and handcuffed a person who had been watching another police officer perform traffic stops. The court agreed with the district court that genuine issues of material fact preclude the officer from receiving qualified immunity at this stage. In this case, under Walker v. City of Pine Bluff, 414 F.3d 989 (8th Cir. 2005), the officer violated plaintiff's clearly established right to watch police-citizen interactions at a distance and without interfering. View "Chestnut v. Wallace" on Justia Law