Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's discriminatory discharge and failure to accommodate claims under the Minnesota Human Rights Act (MHRA) against his former employer.In regard to plaintiff's disability-discrimination claim, the court concluded that the employer articulated a legitimate, non-discriminatory basis for his termination and plaintiff failed to establish a factual dispute as to pretext where the record is replete with evidence concerning his deficient performance, none of which was related to his disability or his period of leave. In regard to plaintiff's failure-to-accommodate claim, the court concluded that there is no evidence in the record suggesting that plaintiff's performance issues were linked to his disability, and the record simply does not support that an accommodation would have allowed him to perform the essential functions of his position. View "Vinh v. Express Scripts Services Co." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a complaint challenging a COVID-19 public health order entered by St. Louis County in April 2020 which included provisions limiting the size of gatherings in churches. Plaintiffs allege that the order violated their rights to free exercise of religion, freedom of expression, freedom of association, and freedom of assembly under federal and state law. The district court concluded that plaintiffs lacked Article III standing on these claims because they did not adequately allege that an order of the court would redress their injuries.The court concluded that the district court properly construed the complaint and correctly dismissed it for lack of an Article III case or controversy. The court explained that the district court properly limited its analysis to whether plaintiffs alleged a redressable injury arising from their inability to participate in religious activities with ten or more persons at their respective churches. The court agreed with the district court that the complaint does not adequately allege that an injunction against enforcement of the April 2020 Public Health Order would have redressed plaintiffs' injuries. The court stated that, without a sufficient factual allegation that plaintiffs' churches would allow ten or more persons to gather if the Order were enjoined, the complaint did not adequately allege Article III standing.The court also concluded that, even if plaintiffs had adequately alleged Article III standing in May 2020, any controversy over the Public Health Order of April 20, 2020, is now moot. In this case, given the developments since May 2020, there is no reasonable expectation that the County will reinstate its Order of April 2020 and limit religious gatherings to fewer than ten persons. Furthermore, there have also been developments in the law. View "Hawse v. Page" on Justia Law

Plaintiff, a former employee of the Pine Bluff Arsenal, filed suit against the Army under Title VII of the Civil Rights Act of 1964, alleging that she was subject to a hostile work environment based on sex and that the Army retaliated against her after she reported sexual harassment. The district court entered summary judgment in favor of the Army.The Eighth Circuit concluded that the district court did not err in granting summary judgment in favor of the Army on plaintiff's hostile work environment claim where she failed to establish that the harassment she experienced was sufficiently severe or pervasive to alter the conditions of her employment and create an abusive working environment. However, the court concluded that the district court erred in granting summary judgment in favor of the Army on plaintiff's retaliation claim where she presented enough admissible evidence to raise a genuine doubt as the legitimacy of the Army's stated motive for her termination. Accordingly, the court remanded this claim for further proceedings. View "Hairston v. Wormuth" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the City in an action brought by plaintiffs, challenging its enforcement of the City's zoning regulations against them. Plaintiffs' claims stemmed from the City's enforcement of commercial zoning regulations.Even assuming zoning-enforcement decisions are susceptible to class-of-one challenges, the court concluded that plaintiffs have not shown that the City lacked a rational basis for its differential treatment of plaintiffs and other property owners. In this case, plaintiffs have not shown that they are identical or directly comparable to the comparator property owners in every material respect. The court also concluded that plaintiffs did not present sufficient evidence of affirmative misconduct to withstand summary judgment on their equitable-estoppel claim. View "Bruning v. City of Omaha" on Justia Law

The Eighth Circuit affirmed the district court's denial of a petition for writ of habeas corpus where petitioner alleged that his trial counsel was ineffective for not providing closing argument during the penalty phase of his capital-murder trial. Petitioner, though advised otherwise, insisted that his trial counsel forgo closing argument.The panel concluded that petitioner's informed, voluntary decision prevented his attorney's reluctant compliance with petitioner's wishes from subsequently becoming ineffective assistance of counsel. The court explained that the nature of the decision to forego oral argument, whether fundamental or one of trial strategy, does not alter this result. Therefore, petitioner's ineffective assistance-of-counsel claim is procedurally defaulted and barred. View "Taylor v. Steele" on Justia Law

Plaintiff, a tenured professor, filed suit against MSCU, the University, and five University employees, under 42 U.S.C. 1981 and 1983, claiming various discrimination and retaliation counts. Plaintiff's complaint stemmed from a series of decisions made between 2013 and 2016 about faculty class schedules, resource allocation, and participation in certain programs. Plaintiff, a Black man born in Nigeria, claimed the individual defendants made these adverse decisions against him because of his race and national origin. Plaintiff also claimed the individual defendants retaliated against him for an earlier lawsuit against the University, and for reporting a University employee's alleged discriminatory conduct.The Eighth Circuit affirmed the district court's dismissal of plaintiff's freestanding section 1981 claims, concluding that he was barred from asserting section 1981 retaliation claims against state actors. The court also affirmed the district court's dismissal of plaintiff's section 1983 claims, concluding that plaintiff failed to provide direct evidence of retaliation and thus failed to establish causation. View "Onyiah v. St. Cloud State University" on Justia Law

Following the death of Justin Stufflebean after he allegedly was denied necessary medication while incarcerated, his parents filed suit alleging that the County and others were liable for wrongful death under Missouri law. The district court denied the County's motion to dismiss, concluding that the County had waived sovereign immunity by purchasing liability insurance that covered the wrongful-death claim.The Eighth Circuit affirmed the district court's denials of the County's motion to dismiss, as well as a related motion for reconsideration, concluding that Mo. Rev. Stat. 537.610(1)'s plain text, bolstered by the statute's purpose and Missouri caselaw, shows that the County's acquisition of liability insurance in this case constitutes a waiver of its sovereign immunity. In this case, the County entered into an inmate-health-services contract with ACH; the contract contained an agreement to pay ACH approximately $300,000 per year; and, in exchange, ACH agreed to provide various services. View "Davis v. Buchanan County, Missouri" on Justia Law

The Eighth Circuit affirmed the district court's holding that University employees violated InterVarsity's First Amendment rights and denial of qualified immunity. In this case, the University deregistered InterVarsity as a Registered Student Organization based on the University's determination that InterVarsity had violated the University's Policy on Human Rights by requiring its leaders to subscribe to certain religious beliefs.The court agreed with the district court that the University's policy was reasonable and viewpoint neutral, but not as applied to InterVarsity. The court explained that the University's choice to selectively apply the policy against InterVarsity suggests a preference for certain viewpoints over InterVarsity's. Furthermore, these rights were clearly established at the time of the violation. View "Intervarsity Christian Fellowship/USA v. University of Iowa" on Justia Law

On remand from the Supreme Court in light of Caniglia v. Strom, 593 U.S. ---, 141 S. Ct. 1596 (2021), the Eighth Circuit affirmed the district court's grant of summary judgment for the officers and the City in this action under 42 U.S.C. 1983 and Minnesota state law.The court concluded that it was well established at the time that the community-caretaking exception was a standalone doctrine that could justify the officers' warrantless entry into a home. In the circumstances here, the court concluded that the officers' warrantless entry did not violate plaintiff's Fourth Amendment rights under the then-extant community-caretaking jurisprudence. Therefore, the officers were entitled to qualified immunity with respect to the Fourth Amendment warrantless-entry claim.In regard to plaintiff's claim that the officers violated her Fourth Amendment right to be free from unreasonable seizures when they seized her for a mental-health evaluation, the court affirmed summary judgment and concluded that probable cause of dangerousness is the standard that must be met for a warrantless mental-health seizure to be reasonable under the Fourth Amendment. Furthermore, assuming the officers lacked probable cause here, they may still be entitled to qualified immunity given the ambiguity in the court's case law about the requisite standard. Finally, the officers are entitled to qualified immunity because their actions did not violate clearly established law under the lower reasonable-belief standard some of the court's precedents suggested was the requisite standard.In regard to plaintiff's claim of retaliatory arrest, the court affirmed summary judgment because no reasonable jury could conclude that retaliatory animus was a but-for cause of plaintiff's arrest. In regard to plaintiff's claim that the City's policy concerning seizures for emergency mental-health evaluation was facially unconstitutional, the district court affirmed summary judgment because the policy requires probable cause that the person is a threat to self or others. The court rejected plaintiff's inadequate-training claim and concluded that the officers were entitled either to statutory or official immunity on the state law claims. View "Graham v. Barnette" on Justia Law

Plaintiff filed suit against Union Pacific in Missouri state court, alleging age discrimination, constructive discharge, and hostile work environment claims under the Missouri Human Rights Act (MHRA). Plaintiff also filed suit against Missouri resident Foster B. McDaniel, claiming that McDaniel aided and abetted Union Pacific in its discriminatory acts. After Union Pacific removed to federal court, the district court granted McDaniel's motion to dismiss and denied plaintiff's motion to remand. The district court later granted Union Pacific's motion for summary judgment on plaintiff's hostile work environment claim.The Eighth Circuit affirmed, concluding that the district court did not err in dismissing McDaniel on the basis of fraudulent joinder because plaintiff's complaint failed to make a colorable claim that McDaniel directly oversaw or was actively involved in discrimination. The court also concluded that the district court did nor err in determining plaintiff did not administratively exhaust his constructive discharge claim. Finally, the court concluded that the district court did not err in granting Union Pacific summary judgment on plaintiff's hostile work environment claim because plaintiff failed to establish age-related harassment sufficiently severe or pervasive to establish the existence of a hostile work environment. View "Henson v. Union Pacific Railroad Co." on Justia Law