Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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Plaintiff, a former student at the University, filed suit against the Board of Trustees and several university officials, claiming that they violated his rights in a disciplinary action against him. This case stemmed from another University student's accusation against plaintiff for sexual assault. After the initial decision by the Title IX coordinator finding no misconduct, the other student herself publicly criticized the University's decision. Plaintiff alleges, among other things, that the University was under pressure and fearful of sanctions from the Office for Civil Rights, so it took steps harmful to him to alleviate and lessen the scrutiny that it was attracting from the other student's media blitz and protests. The district court granted defendants' motion to dismiss.The Eighth Circuit held that the complaint stated a claim under Title IX of the Education Amendments of 1972 that is plausible on its face. First, the allegations in the complaint support an inference that the hearing panel reached an outcome that was against the substantial weight of the evidence. Second, the panel's chosen sanctions are allegedly contrary to the ordinary disposition in cases of sexual assault by force. Third, plaintiff alleged that the University was under pressure on multiple fronts to find males responsible for sexual assault. The court held that these circumstances, taken together, are sufficient to support a plausible claim that the University discriminated against plaintiff on the basis of sex. However, the court held that plaintiff's due process claims against the University officials in their official and individual capacities were properly dismissed. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Doe v. University of Arkansas - Fayetteville" on Justia Law

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A.C.'s Westside eighth-grade class watched a video about athletes kneeling during the national anthem. During a “critical thinking” discussion, the teacher insisted that A.C. share her ideas. A.C. stated that “kneeling was disrespectful to law enforcement and military," and questioned that violence could have stemmed from music lyrics including "F-the Police, and the use of the N-word.’” A.C. stayed home the next day due to illness. The teacher allegedly told students that A.C. was a racist and was on suspension. A.C. was subjected to bullying. After meeting with school officials, her parents removed A.C. from school. A.C. attempted suicide. Her parents contacted eight lawyers. but were unable to retain one.On behalf of A.C., they filed the pro se 42 U.S.C. 1983 lawsuit. The court ruled that they could not serve pro se as A.C.’s representatives and lacked standing to bring individual claims that only derive from alleged violations of their child’s constitutional rights. They contacted 27 more lawyers and organizations. They refiled, requesting court-appointed counsel. The district court refused, reasoning that the claims were “not likely to be of substance,” and that A.C. lacked standing for declaratory and injunctive relief, as she was no longer a student at Westside. The Eighth Circuit affirmed that the parents may not represent A.C. pro se but remanded with directions to appoint counsel. The court did not err in considering the potential merit of the claims and other relevant factors in deciding whether to request counsel but the allegation of First Amendment retaliation is a serious claim on which the plaintiffs and the court would benefit from the assistance of counsel. View "Crozier v. Westside Community School District" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action brought by a student and Turning Point USA, alleging that defendants violated plaintiffs' rights under the Free Speech Clause of the First Amendment. Plaintiffs aimed to recruit students for a local Turning Point chapter by setting up a table at the Union Patio. University administrators then asked that the student take down her table.The court held that the patio is a limited designated public forum in which speech restrictions must be reasonable and viewpoint neutral. Furthermore, the Tabling Policy was not viewpoint-discriminatory. The court held that the Tabling Policy, as applied to the student, is unconstitutional because the distinction between registered student organizations and individual students is not reasonable, when the sole justification offered for the distinction provides no meaningful reason for differentiating the two. Therefore, plaintiffs have put forward sufficient facts to show a constitutional violation. However, the court held that defendants were properly granted qualified immunity because the student's First Amendment right to access a limited public forum, which she was unjustifiably denied, was not clearly established at the time. View "Turning Point USA at Arkansas State University v. Rhodes" on Justia Law

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Plaintiff filed suit asserting Title IX violations and various state law claims against the University after it began disciplinary proceedings that resulted in plaintiff's suspension. The disciplinary proceedings arose from a fellow student's accusation against plaintiff of sexual misconduct.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the University. The court held that, while the district court erred by rejecting Rollins v. Cardinal Stritch Univ., 626 N.W.2d 464, 470 (Minn. Ct. App. 2001), and formulating a reasonable care standard that no Minnesota court has adopted, even applying the more permissive reasonable care standard, no reasonable jury would find the investigators' actions showed bias against plaintiff. In this case, no reasonable jury would find bias because the investigators did question the accuser about inconsistencies in her story and found her to be credible. Furthermore, no implication of bias arises by asking the accuser to preserve evidence or by offering her mental health services. View "Doe v. University of St. Thomas" on Justia Law

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Plaintiff filed suit against Allied Pilots in state court for conversion and unjust enrichment, arguing that he was entitled to keep his whole profit sharing payment rather than give some of it to the union for "dues." The union removed to federal court, contending that plaintiff's claims are preempted by the Railway Labor Act (RLA). The district court held that state law claims fell away due to preemption and the federal claims did not survive summary judgment.The Eighth Circuit reversed and held that the district court erred by relying on the complete-preemption doctrine, finding that the RLA wholly displaced plaintiff's state law claims. In this case, the RLA does not require disputes between an employee and a union to be heard by an adjustment board, so there is no federal cause of action at all, much less an exclusive one. Accordingly, the court vacated the district court's judgment and instructed the district court, on remand, to return this case to state court. View "Krakowski v. Allied Pilots Ass'n" on Justia Law

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Plaintiffs, six former inmates of the Faulkner County Detention Center, filed suit against the County and two jail employees under 42 U.S.C. 1983, alleging that their conditions of confinement were unconstitutional because of mold in and around the jail's shower.The Eighth Circuit reversed in part and held that the district court erred in denying the individual jail employees summary judgment based on qualified immunity. The court held that the only thing clearly established in this case is that the definition of the asserted constitutional right embraced by the district court — a right to sanitary prison conditions — was impermissibly broad. The court also held that a finding that such a right was clearly established based on this general definition was therefore in error. Because the right at issue has not been properly defined and there are genuine disputes of material fact at play, it is not possible for the court to determine whether the individual officers committed a constitutional violation in the detention center due to the presence of Cladosporium. Finally, the court held that it lacked jurisdiction to reach the County's appeal where the question of whether the County was liable for failing to train its officers is not inextricably intertwined with the matter of qualified immunity. View "Thurmond v. Andrews" on Justia Law

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The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's 42 U.S.C. 1983 claim against the City for depriving plaintiff of her constitutional right to a prompt first appearance in a criminal proceeding. Plaintiff alleged that a district court lacks jurisdiction to conduct a first appearance for a defendant who was arrested and charged in a separate county or judicial district.The court held that any Arkansas district court may perform pretrial functions as necessary and as authorized by the Arkansas Rules of Criminal Procedure. Because the Ashley County district judge had jurisdiction and authority to conduct the first appearance, the court held that plaintiff's constitutional claim necessarily fails. Furthermore, because the City discovered new evidence and presented it promptly to the court, the district court did not abuse its discretion in finding the doctrine of equitable estoppel inapplicable here. The court also held that the doctrine of equitable estoppel is not properly invoked here because there has been no showing that the City knew of plaintiff's first appearance before the new evidence was discovered or that the City tried to induce her to act to her detriment. View "Green v. Byrd" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Abbott in an action brought by a former employee, alleging a failure-to-accommodate claim under the Minnesota Human Rights Act (MHRA). The court held that plaintiff has not made a facial showing that reasonable accommodation is possible and that the accommodation will allow him to perform the essential functions of the job. In this case, plaintiff requested that he be permitted to use electric forklifts in place of manual pallet jacks, but he has not presented evidence that this accommodation would allow him to perform the essential functions of an M&I Specialist. View "Collins v. Abbott Laboratories, Inc." on Justia Law

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After plaintiffs received criminal citations for trespassing and traffic violations while hunting, they filed suit alleging unreasonable search and seizure under the Fourth Amendment and Iowa Constitution, as well as violations of their substantive due process rights.The Eighth Circuit affirmed the district court's dismissal of the unreasonable seizure claim for failure to state a claim where the district court found no seizure under the prevailing federal standards because the officers were alleged only to have issued or verified citations. The court also affirmed the district court's grant of summary judgment to the officers on the unreasonable search claims where the district court did not err in considering summary judgment for the unreasonable search claims under the Iowa Constitution; the district court properly refused to consider plaintiffs' claim that the warrants for their Facebook records were overbroad; and the district court properly ruled that plaintiffs' allegation that defendants placed a GPS tracker on one of the plaintiff's vehicles is, at best, speculative and contradicts all objective evidence on the record. Finally, the court affirmed the district court's grant of summary judgment on the substantive due process claims where plaintiffs point to no evidence in the record that the officers intentionally or recklessly failed to investigate in a way that shocks the conscience. View "Wendt v. Iowa" on Justia Law

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Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force in seizing plaintiff's 16 year old son. The officer shot the son and the son sustained serious injuries paralyzing him below the waist.The Eighth Circuit reversed the district court's denial of the officer's motion for summary judgment, holding that the seizure was not unreasonable. The court held that, under the circumstances, a reasonable officer was justified in discharging his firearm where the son was carrying a gun that moved while he ran, the officers were investigating a report of a stolen firearm, and the son was fleeing from police who had arrived at the apartment building. Given the convergence of events and the split-second decision for the officer, the court stated that it was not unreasonable for the officer to use force as he did. View "Liggins v. Cohen" on Justia Law