Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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The Eighth Circuit affirmed the district court's grant of summary judgment to the Commission in an action brought by plaintiff, alleging that the Commission discriminated against her in violation of Title VII. Plaintiff argues that her suspension, probation, and termination were discrimination based on race and national origin. The Commission stated that plaintiff's termination was due to failure to comply with requests to provide company passwords to agency programs and documents. The court concluded that plaintiff did not show evidence of pretext or that she could satisfy the McDonnell Douglas burden-shifting framework before the district court or in her opening brief, and thus she cannot prove a circumstantial case of discrimination. View "Towery v. Mississippi County Arkansas Economic Opportunity Commission, Inc." on Justia Law

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The Eighth Circuit held that the district court did not abuse its discretion in granting preliminary injunctions enjoining enforcement of the Gestational Age Provisions and the Down Syndrome Provision of Missouri House Bill 126. The Gestational Age Provision provides, in relevant part, that "no abortion shall be performed or induced upon a woman at eight weeks gestational age or later, except in cases of medical emergency." The Down Syndrome Provision prohibits abortions if the provider "knows that the woman is seeking the abortion solely because of a prenatal diagnosis, test, or screening indicating Down [s]yndrome or the potential of Down [s]yndrome in an unborn child."As a preliminary matter, the court concluded that RHS has standing because the provisions at issue directly target physician conduct and put physicians at risk of civil and criminal sanctions. The court concluded that the Gestational Age Provisions do not merely have "the incidental effect of making it more difficult or more expensive to procure an abortion" before viability. Rather, the Gestational Age Provisions are bans, and the court agreed with the district court that RHS is likely to succeed on the merits of this claim. The court also concluded that, unlike a regulation, the Down Syndrome Provision does not set a condition that—upon compliance—makes the performance of a pre-viability abortion lawful, thus preserving the constitutional right to elect the procedure. Rather, it bans access to an abortion entirely. Therefore, RHS is likely to succeed on the merits of its challenge to the Down Syndrome Provision. The court concluded that the remaining Dataphase factors - irreparable harm, balance of hardships and public interest - also supported the grant of the preliminary injunction. View "Reproductive Health Services of Planned Parenthood of the St. Louis Region, Inc. v. Parson" on Justia Law

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The Eighth Circuit affirmed the district court's judgment following a jury verdict in favor of the City on plaintiff's claim of hostile work environment based on religion. At issue is whether the district court abused its discretion in precluding plaintiff from introducing testimony and a report by the City's retained but non-testifying expert psychiatrist who had conducted an independent medical examination of plaintiff.The court concluded that the expert's report would have been cumulative with other testimony regarding causation and damages, and any discussion of damages was immaterial because the jury never reached that issue. Therefore, the exclusion did not result in fundamental unfairness in the trial of the case, and the court need not consider whether the district court abused its substantial case management and discovery discretion in excluding the expert's independent medical examination report and testimony, an issue the court has not previously addressed. View "Cooper v. City of St. Louis, Missouri" on Justia Law

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HRDC filed suit against Baxter County under 42 U.S.C. 1983, alleging that the Jail's postcard-only policy violates HRDC's First Amendment right to communicate with Jail inmates. HRDC also alleged that the Jail's rejection of HRDC's mailings violated HRDC's Fourteenth Amendment procedural due process rights to notice and an opportunity to appeal the Jail's decisions. The district court initially granted partial summary judgment in favor of HRDC. After a bench trial, the district court held that the postcard-only policy was reasonably related to legitimate penological goals and did not violate HRDC's First Amendment rights. The district court awarded HRDC four dollars in nominal due process damages for its four discrete August 2016 mailings.The Eighth Circuit affirmed the due process ruling and concluded that the district court did not err in granting only nominal damages where HRDC failed to prove actual injury flowing directly from the technical due process violation in August 2016. The court vacated the First Amendment ruling where the district court made no finding of fact regarding whether HRDC proved its assertion that the postcard-only policy results in "a de facto total ban" on Jail inmates accessing HRDC's materials. The court explained that it is necessary for the court to have a finding on what, if any alternative means are available to HRDC to exercise its First Amendment interest in access to prisoners. Therefore, the court remanded for further proceedings. View "Human Rights Defense Center v. Baxter County, Arkansas" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment to defendants in a 42 U.S.C. 1983 action brought by plaintiff, an Iowa Department of Corrections inmate, alleging that defendants violated his Eighth Amendment rights by acting with deliberate indifference to his serious medical needs and safety. Plaintiff claimed that defendants delayed treatment for a sore on his right foot, allowing it to become a major medical crisis resulting in a below-the-knee amputation.The court concluded that plaintiff failed to provide evidence from which a trier of fact could draw an inference that defendants provided care that was grossly inappropriate or intentional maltreatment. In this case, plaintiff's unsupported medical conclusions cannot create a question of fact about whether defendants' medical decisions were reasonable, negligent, grossly negligent, or so ineffective as to be criminally reckless, rising to the level of deliberate indifference. The court explained that, without medical evidence, no reasonable jury could conclude that the providers were deliberately indifferent to his serious medical need. View "Redmond v. Kosinski" on Justia Law

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Petitioner, an Arkansas prisoner under a sentence of death for capital murder, petitioned for habeas corpus in the federal district court. In a previous appeal, the Eighth Circuit affirmed the dismissal of several claims, but remanded for further proceedings on four claims alleging ineffective assistance of counsel under the Sixth Amendment. The court also remanded for further proceedings on petitioner's claim that he is ineligible for the death penalty, due to intellectual disability, under the Eighth Amendment and the rule of Atkins v. Virginia, 536 U.S. 304 (2002). On remand, the district court rejected the Atkins claim, but granted relief on two of the ineffective-assistance claims and set aside petitioner's sentence. Both parties appealed.The Eighth Circuit reversed the grant of relief based on alleged ineffective assistance of counsel. In this case, petitioner's federal claim that trial counsel failed to obtain a timely psychological evaluation of him was presented in the state postconviction court and defaulted when he declined to appeal on that ground. As such, the procedural default cannot be excused based on alleged ineffectiveness of state postconviction counsel. Likewise, the third claim cannot be excused based on alleged ineffectiveness of state postconviction counsel. The court affirmed the denial of relief under the Eighth Amendment, concluding that the district court considered the Atkins claim under both the DSM-IV-TR and DSM-V criteria, reached the same conclusion based on each, and thus there was no legal error. The court rejected petitioner's remaining challenges to the district court's analysis of his intellectual functioning, including additional indicia of intellectual disability, expert and witness testimony, adaptive strengths and weaknesses, and adaptive functioning deficits. View "Sasser v. Payne" on Justia Law

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Plaintiffs, ten former University of Minnesota football players, appealed the dismissal of their Amended Complaint against the University and two University officials, asserting a variety of claims arising out of the University’s investigation of a complaint of sexual assault and harassment by another student, Jane Doe. Plaintiffs are African-American males who alleged that the University targeted them on the basis of their sex and race and unfairly punished them in response to Jane's accusations. The district court dismissed all claims.The Eighth Circuit concluded that plaintiffs' complaint alleged a number of circumstances which, taken together, are sufficient to support a plausible claim that the University discriminated against plaintiffs on the basis of sex. In this case, plaintiffs alleged that the University was biased against them because of external pressures from the campus community and the federal government, and plaintiffs alleged historical facts that reinforce the inference of bias in this specific proceeding. Therefore, the court reversed the district court's dismissal of plaintiffs' Title IX discrimination claims.The court affirmed the district court's dismissal of the Title IX claims for retaliation where plaintiffs did not plausibly allege that their request for a Student Sexual Misconduct Subcommittee hearing was tantamount to a complaint of sex discrimination, and even if a request for a hearing made by a person accused of sexual misconduct could amount to protected activity, the Amended Complaint did not plausibly plead prima facie retaliation claims. The court also affirmed the dismissal of the race discrimination claims where the Amended Complaint did not plausibly allege a comparator similarly situated to plaintiffs in all relevant aspects; affirmed the dismissal of plaintiffs' due process claims where plaintiffs failed to exhaust the existing procedures for appealing the University's disciplinary decision and failed to allege prehearing deprivations or deprivation of protected property or liberty interests in violation of due process; and affirmed the dismissal of the contract and negligence claims on Eleventh Amendment grounds. View "John Does 1-2 v. Regents of the University of Minnesota" on Justia Law

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The Eighth Circuit affirmed the district court's sua sponte grant of judgment as a matter of law to defendants in an action brought by plaintiff against prison officials, alleging that they failed to protect him from his fellow inmates after he was labeled a snitch.Even assuming the court agreed with plaintiff that Federal Rule of Civil Procedure 50(a) requires a motion, the court did not think that requirement is clear or obvious under its case law. The court concluded that the district court did not err in directing a verdict in favor of the five defendants who were not on the Classification Committee. In this case, plaintiff cannot show that defendants acted with deliberate indifference by entrusting the decision to the Classification Committee—the prison's selected arbitrator. The court explained that, even if they disagreed with the choice, there is nothing to suggest that four of the defendants had any power to circumvent the ruling of the Classification Committee and it was a close call with the fifth defendant. Finally, the court concluded that the district court did not abuse its discretion by denying plaintiff's motions for continuance by ensuring an expeditious disposition of the case and while affording significant time to allow plaintiff to prepare. View "Axelson v. Watson" on Justia Law

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After defendant, a police officer, shot plaintiff in the course of investigating a potential domestic disturbance, plaintiff filed suit under 42 U.S.C. 1983, alleging violations of the Fourth and Fourteenth Amendments.The Eighth Circuit affirmed the district court's denial of defendant's motion for summary judgment on plaintiff's excessive force claim, agreeing with the district court that genuine issues of material fact precluded a grant of qualified immunity. Construing the disputed record in plaintiff's favor, the court concluded that a jury could conclude that no reasonable officer would have thought deadly force was necessary in that moment to protect plaintiff's wife from imminent danger. Furthermore, plaintiff's demeanor and conduct are in dispute. In this case, defendant opened the door and instantaneously shot plaintiff. Therefore, under these circumstances, no reasonable officer would have believed that he had probable cause to use deadly force. Furthermore, plaintiff's right to be free from excessive force under these circumstances was also clearly established at the time. View "Banks v. Hawkins" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, a police officer, used excessive force against him during a traffic stop. A jury found in favor of plaintiff, awarding compensatory and punitive damages. Defendant appealed.The Eighth Circuit concluded that, viewing the facts in the light most favorable to the verdict, defendant's prolonged use of his taser was not an objectively reasonable use of force. In this case, although plaintiff initially resisted defendant's attempts to remove him from the car, he did not physically hit or verbally threaten defendant. Furthermore, plaintiff, who was 17 years old at the time, posed at most a minimal safety threat to defendant. The court also concluded that plaintiff's right to be free from excessive, prolonged use of a taser was clearly established at the time. Accordingly, the court affirmed the district court's denial of defendant's motion for judgment as a matter of law on the prolonged taser claim.The court rejected defendant's evidentiary claims of error, concluding that the district court did not abuse its discretion in admitting testimony from a vocational rehabilitation expert and testimony from an economist based on the vocational expert's opinion. Finally, the court concluded that the district erred in reducing the punitive damages award. While the court concluded that the district court correctly found that the jury's initial punitive damages award was disproportionate, the court disagreed that the reduced award of $236,500 sufficiently reflected the reprehensibility of defendant's conduct. In this case, the 9:1 ratio comports with due process while achieving the statutory and regulatory goals of retribution and deterrence. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Masters v. Runnels" on Justia Law