Justia Constitutional Law Opinion Summaries

Jim Bakker and Morningside filed suit against several out-of-state defendants in Missouri federal court, alleging that defendants, while acting in their official capacities, violated their First, Fifth, and Fourteenth Amendment rights. In February 2020, as the Covid-19 pandemic was beginning in the United States, Jim Bakker and Morningside began advertising a product called Silver Solution on the Jim Bakker Show. Bakker and Morningside claimed that Silver Solution "has been proven by the government that it has the ability to kill every pathogen it has ever been tested on;" that it "has been tested on other strains of the coronavirus and has been able to eliminate it within 12 hours;" and that it is "patented, it works, we have tested it, it works on just about everything." Bakker and Morningside allege that defendants' investigations into Silver Solution violate their constitutional rights and that the state statutes defendants have acted under are unconstitutional.The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss based on lack of personal jurisdiction. Assuming defendants fell under Missouri's long-arm statute, the court concluded that asserting personal jurisdiction in this case violates due process where the only contact with Missouri were letters and emails directed at Morningside Church and Bakker, rather than the forum state. Therefore, after considering the five factor test for assessing the sufficiency of a defendant's contacts, the court concluded that Bakker and Morningside have not demonstrated that defendants' conduct connects them to the forum in a meaningful way. View "Morningside Church, Inc. v. Rutledge" on Justia Law

Plaintiff, a Missouri resident, filed suit in state court against her former employer, Ferrellgas, a propane supplier, as well as James Ferrell and Pamela Brueckmann, Kansas residents and employees and officers of Ferrellgas. Plaintiff alleged gender discrimination claims under the Missouri Human Rights Act against Ferrellgas (Counts I and II), and tort claims against all defendants (Counts IIIVI). After removal to the district court, the district court granted defendants' motion to compel arbitration in part.The Eighth Circuit reversed, concluding that the district court erred in concluding that no language in plaintiff's employment agreement suggested that she consented to arbitrate tort claims arising from actions which predated her employment. The court explained that, though plaintiff's claims are based on alleged misrepresentations and omissions made before and at the time she accepted employment, they are subject to arbitration because they arise out of and relate to the resulting employee agreement and employee relationship. The court also concluded that Ferrell and Brueckmann, officers and agents of Ferrellgas who were not parties to the Employee Agreement, may enforce the arbitration clause. The court concluded that a signatory plaintiff cannot avoid arbitration when she treated signatory and non-signatory defendants as a single unit. In this case, each of plaintiff's tort claims against defendants is a single one that should be referred in its entirety to arbitration. View "Morgan v. Ferrell" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's political retaliation claim related to disciplinary measures and his ultimate termination from the Sheriff's Office. The court concluded that there was no error in the district court's determination that collateral estoppel barred plaintiff from pursuing his political retaliation claim based on those issues he raised in his termination appeal; the district court could give the Iowa Civil Service Commission's determination preclusive effect; and plaintiff failed to make a prima facie case that his two-day suspension was political retaliation because he could not establish a causal connection between the suspension and his political campaign. View "Charleston v. McCarthy" on Justia Law

The Eighth Circuit reversed the district court's grant of the University's motion to dismiss plaintiffs' action under Title IX of the Education Amendments of 1972 for failure to state a claim. Plaintiffs, former players of the University's women's ice hockey team, filed suit after the University cut its women's ice hockey team but not its men's ice hockey team.Given the regulatory structure and its textual content, the court disagreed with the district court's reasons for dismissing the complaint. The court explained that, when applying the 1979 Interpretation of the implementing regulation, the district court improperly relied on a compliance test from the Levels of Competition provision (VII.C.5) as the only way to analyze a claim under the separate, unrelated Selection of Sports provision (VII.C.4). The court concluded that the 1979 Interpretation's Contact Sports Clause's plain text is not inconsistent with the regulation's Separate Teams Provision. By disregarding the plain text, the court concluded that the district court erred in its analysis.Ultimately, the court concluded that the district court's primary reasons for dismissing the complaint rested on an incorrect view of the law. In this case, it appears that the district court saw the Contact-Sports-Clause claim as futile, not novel. Therefore, no set of facts could have convinced the district court to give the athletes a second look. But given a level playing field, the court concluded that the athletes may be able to state an actionable Title IX claim. The court remanded for the district court to apply the law to plaintiffs' complaint in the first instance. View "Berndsen v. North Dakota University System" on Justia Law

Plaintiffs filed suit challenging Iowa Code Sec. 717A.3A(1)(a)-(b), which makes it a crime for a person to gain access to an agricultural production facility by false pretenses and to make false statements on an employment application to such a facility, on First Amendment grounds. The district court ruled that both provisions were unconstitutional and enjoined their enforcement.The Eighth Circuit concluded that the provisions providing that a person is guilty of agricultural production facility fraud if they obtain access to the facility by false pretenses is consistent with the First Amendment because it prohibits exclusively lies associated with a legally cognizable harm - namely trespass to private property. The court explained that the proscription of the Employment Provision does not require that false statements made as part of an employment application be material to the employment decision. Therefore, the statute is not limited to false claims that are made "to effect" an offer of employment; it allows for prosecution of those who make false statements that are not capable of influencing an offer of employment. The court concluded that, given the breadth of the Employment Provision, it proscribes speech that is protected by the First Amendment and does not satisfy strict scrutiny. Accordingly, the court affirmed in part and reversed in part, vacating the injunction against enforcement of the access provision. View "Animal Legal Defense Fund v. Reynolds" on Justia Law

Plaintiffs filed suit against Peco Foods and Jonathan and DeAnn Vaught, seeking an order that would prevent Peco Foods and the Vaughts from bringing a civil suit against plaintiffs under an Arkansas statute, Ark. Code Ann. 16-118-113. Plaintiffs, who describe themselves as "nonprofit organizations dedicated to reforming industrial animal agriculture," claim that the statute violates their rights to free speech under the First Amendment. In this case, two lead organizations allege that they have "specific and definite plans" to investigate Peco Foods's chicken slaughterhouses and the Vaughts' pig farm. The district court dismissed the action based on lack of Article III standing.The Eighth Circuit reversed, concluding that the complaint adequately alleges the elements of Article III standing where plaintiffs allege that, but for the statute, the lead organizations would send an investigator to gather information and take video and audio recordings in the facilities owned by Peco Foods and the Vaughts; that all plaintiffs would use the results of the investigations in their advocacy; and that this conduct is arguably affected with a constitutional interest, because "the creation and dissemination of information are speech within the meaning of the First Amendment." The complaint also alleges an intention to engage in a course of conduct arguably proscribed by the Arkansas statute, and the complaint sufficiently alleges a credible threat of enforcement. Accordingly, the court remanded for the district court to consider the merits in the first instance. View "Animal Legal Defense Fund v. Vaught" on Justia Law

The Eighth Circuit affirmed the district court's denial of the 28 U.S.C. 2254 petition for habeas relief as procedurally defaulted. In this case, petitioner's ineffective-assistance-of-counsel claim was first procedurally defaulted on appeal, not at the initial-review collateral proceeding, which makes the Martinez exception inapplicable to petitioner's case. Therefore, with no excuse for the procedural default, federal habeas review of the claim is barred. View "Hartman v. Payne" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the employer in an action brought by plaintiff, alleging that the employer violated the Nebraska Equal Pay Act and the Nebraska Fair Employment Practices Act by giving her male counterparts better pay despite her stronger work performance.The court concluded that the facts presented were insufficient to establish plaintiff's prima face case under the Nebraska Equal Pay Act because nothing in the record suggests that her position required her to take on the additional duties and responsibilities of her higher-ranked coworkers. Because plaintiff's evidence was insufficient either to establish her prima facie case under the Nebraska Fair Employment Practices Act or to show that the employer's reasons for the pay disparity were pretextual, the district court properly granted the employer's motion for summary judgment. View "Perry v. Zoetis LLC" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a petition for writ of habeas corpus where petitioner challenged his 2000 felon-in-possession conviction under Rehaif v. United States, 588 U.S. ---, 139 S. Ct. 2191 (2019). The court agreed with the district court that petitioner failed to show that 28 U.S.C. 2255's remedy was ineffective or inadequate to test the legality of his detention—a prerequisite in his case to habeas relief. In this case, section 2255's remedy was itself perfectly capable of facilitating petitioner's argument where section 2255 authorizes a motion challenging a sentence upon the ground that the sentence was imposed in violation of the laws of the United States. View "Jones v. Hendrix" on Justia Law

Plaintiff filed suit against Officers Kuykendall and Henry, arguing that they violated his Fourth and First Amendment rights. After the district court denied defendants' motion for summary judgment on the basis of qualified immunity, they filed this interlocutory appeal.Concluding that it has jurisdiction under the collateral order doctrine, the Eighth Circuit reversed the district court's denial of defendants' motion for summary judgment. The court concluded that John Doe's and the third party's reports were sufficient to have provided probable cause to arrest plaintiff for assault in the fourth degree under Missouri law. In this case, the facts that plaintiff directs the court to do not diminish the officers' probable cause to believe, at the time of plaintiff's arrest, that he had committed a crime. Furthermore, the fact that no formal charges were initiated against plaintiff does not retroactively diminish the reasonableness of the officers' belief. Even if the officers were mistaken that probable cause existed, that mistake was "objectively reasonable" and arguable probable cause exists, entitling them to qualified immunity. Finally, the officers were also entitled to qualified immunity on plaintiff's First Amendment retaliation claim. View "Just v. Kuykendall" on Justia Law