Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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The Eighth Circuit reversed the district court's denial of qualified immunity and statutory immunity to a police trooper in an action alleging excessive force under 42 U.S.C. 1983 and assault and battery under state law. The court held that it was reasonable for the trooper to believe that plaintiff was attempting to evade arrest by flight where the trooper knew that multiple officers had attempted to stop a white male riding a black motorcycle with no license plate for speeding and that the suspect had evaded arrest multiple times by fleeing at a high rate of speed. Furthermore, the court concluded that there can be little doubt but that a reasonable officer could conclude that fleeing from four other officers at speeds exceeding 100 miles per hour in evening traffic demonstrates an extreme indifference to the value of human life. Likewise, because the trooper believed plaintiff had fled from no fewer than four other officers, traveling at speeds exceeding 100 miles per hour in evening traffic, he could reasonably conclude that defendant posed an immediate threat to the safety of the officers and others. The court also held that it was not clearly established at the time that it constituted excessive force in violation of the Fourth Amendment to use a taser, without warning, against a suspect perceived as attempting to flee from officers. Therefore, the trooper was entitled to qualified immunity on the section 1983 excessive force claim. The court also held that the trooper was entitled to statutory immunity under Arkansas law, because plaintiff failed to produce sufficient evidence to create a triable issue of fact regarding malice. View "Boudoin v. Harsson" on Justia Law

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The Eighth Circuit affirmed the district court's grant of a preliminary injunction, holding that the district court did not err in finding that plaintiffs were likely to succeed on the merits of their claim that Arkansas's recent amendments to the requirements for new political parties to appear on the next general-elections ballot on a whole-ballot basis were unconstitutional. The court also held that, assuming a compelling interest exists, and taking the general boundaries established by precedent, a regime containing (1) a substantial signature requirement, (2) a limited rolling window for obtaining signatures, and (3) a deadline 425 days removed from the general election is not narrowly tailored to a generalized interest in regulating the integrity of elections. Although plaintiffs did not make an overwhelming showing as to the actual burdensomeness of the current regime on their own particular ability or inability to comply, the court held that their showing was sufficient and found no clearly erroneous determinations by the district court. Finally, the district court did not abuse its discretion in fashioning the injunctive relief. View "The Libertarian Party of Arkansas v. Thurston" on Justia Law

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The Eighth Circuit granted defendants' petition for rehearing en banc of the panel's qualified immunity ruling. In this case, plaintiffs filed a 42 U.S.C. 1983 action against the City, the County, and officials, alleging violations of their constitutional right to privacy and of Arkansas tort law in connection with defendants' decisions to release information identifying them as victims of childhood sexual abuse. Plaintiffs are sisters and stars of the popular reality show 19 Kids and Counting. Plaintiffs were interviewed along with others as part of a police investigation into sexual misconduct by plaintiffs' brother. Reviewing de novo, the court reversed the denial of qualified immunity and held that the asserted due process right to informational privacy was not clearly established at the time. The court reinstated the remainder of the court's opinion. View "Dillard v. Hoyt" on Justia Law

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Plaintiff, a Satanist, filed suit challenging a Missouri law requiring her to certify that she has had a chance to review certain information before having an abortion. Plaintiff alleged that Missouri's informed-consent law violates the Establishment and Free Exercise Clauses of the First Amendment. The Eighth Circuit affirmed the district court's dismissal of plaintiff's First Amendment claims. As a preliminary matter, the court did not permit plaintiff to plead a new undue burden claim at this stage in the proceedings because Missouri lacked fair notice of the claim based on the complaint itself. On the merits, the court held that the statute's requirement that every woman seeking an abortion in Missouri must first receive a state-authored informed-consent book does not violate the Establishment Clause because alignment to a religious belief alone is not enough to show a violation. The court also held that the requirement that plaintiff certify that she had a chance to view an ultrasound at least 24 hours prior to the procedure and that she received the informed consent booklet does not violate her free-exercise rights. In this case, plaintiff makes no argument that the informed-consent law is anything other than neutral and generally applicable. View "Doe v. Parson" on Justia Law

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Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging a claim for unreasonable search in violation of the Fourth and Fourteenth Amendments. The district court granted the officer qualified and official immunity. Reviewing de novo, the Eighth Circuit held that it lacked jurisdiction to review the appeal based on the incomplete record. Accordingly, the court dismissed the appeal and remanded to the district court for further proceedings. View "M.A.B. v. Mason" on Justia Law

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In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released. The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed. View "McKay v. City of St. Louis" on Justia Law

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Plaintiff filed suit against several prison officials in their individual capacities under 42 U.S.C. 1983, challenging a disciplinary adjudication, conditions of confinement, adequacy of medical treatment, and alleged retaliatory acts. The district court denied motions to dismiss and for summary judgment. The Eighth Circuit held that officials were entitled to a ruling on their defense of qualified immunity as to the Eighth Amendment claims in Count II. Because the order granting the motion for reconsideration effectively denied the officials' motion to dismiss without ruling on qualified immunity, the court remanded the case for further proceedings to address the question of qualified immunity on Count II. As to the remaining claims, the court held that the district court did not abuse its discretion by determining that the officials failed to properly plead or carry their burden of proof as to any defenses of privileges and immunities. Accordingly, the court rejected the challenge to the order denying summary judgment on the remaining counts. View "Spann v. Lombardi" on Justia Law

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A student and her parents filed suit against the Minnesota Department of Education, alleging that the school district's failure to classify the student as disabled denied her the right to a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The ALJ concluded that the school district's treatment of the student violated the IDEA and related state special-education laws. The district court then denied the school district's motion for judgment on the administrative record and granted, in part, the student's motion for judgment on the record, modifying the award of compensatory education. The Eighth Circuit held that the district court did not abuse its discretion in denying the school district's request for supplementation of the record; the school district's evaluation of the student was insufficiently informed and legally deficient; the student is eligible for special education and a state-funded FAPE like every other child with a disability; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; and the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services. However, the court reinstated the ALJ's award of compensatory education costs. View "Independent School District No. 283 v. E.M.D.H." on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment to plaintiff's former employer, Con-E-Co, on plaintiff's sex discrimination claim, her sexual harassment claim, and her retaliation claims under Title VII of the Civil Rights Act of 1964, and the Nebraska Fair Employment Practice Act. The court held that plaintiff failed to establish a prima facie case of sex discrimination because she did not demonstrate that she met Con-E-Co's legitimate job expectations or that Con-E-Co treated her differently than similarly situated male employees; the district court did not err in granting summary judgment to Con-E-Co regarding her sexual harassment claim based on vulgar behavior directed at her by her coworkers, because plaintiff failed to demonstrate that she subjectively perceived the alleged harassment as abusive; and plaintiff failed to establish a prima facie case for retaliation in response to either her race discrimination or sex discrimination complaints. View "Gibson v. Concrete Equipment Co., Inc." on Justia Law

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After Map Kong was fatally shot by police in Burnsville, Minnesota, plaintiff filed suit against the city and the officers under 42 U.S.C. 1983 and state law. The district court denied defendants' motion for summary judgment based on qualified immunity and official immunity. The Eighth Circuit reversed, holding that the district court erred in denying the officers qualified immunity. The court held that, even if the facts showed that the officers had violated Kong's Fourth Amendment right, the law at the time of the shooting did not clearly establish the right. In this case, Kong ran toward bystanders with a knife against the officers' repeated orders to drop the weapon; there was at least one pedestrian visible on the body-camera footage; and a steady flow of vehicles through the parking lot meant that citizens might quickly approach or step out of their vehicles. Therefore, the court held that a reasonable officer would have believed the law permitted shooting Kong under these circumstances. The court also held that, even if the officers acted negligently, they did not intentionally disregard the police department's policy on crisis intervention for persons. Therefore, the officers are entitled to official immunity and the district court erred in denying summary judgment on the state-law negligence claim. Furthermore, the city is entitled to vicarious official immunity. View "Sok Kong v. City of Burnsville" on Justia Law