Justia Constitutional Law Opinion Summaries

Plaintiff filed suit challenging the constitutionality of a traffic ordinance in St. Louis. Plaintiff's claims arose from her attendance at an event called the Women's March in 2017 where she was arrested for failing to move to the sidewalk. An officer arrested her for violating section 17.16.275 of the Revised Code of St. Louis, which prohibits obstructing traffic. After the charges were dismissed, plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of the ordinance under the First and Fourteenth Amendments.The Eighth Circuit reversed the district court's grant of plaintiff's motion for partial summary judgment. The court concluded that the St. Louis ordinance does not forbid all expressive activities on streets and sidewalks. Instead, it merely forbids a person to position herself in a way that obstructs the reasonable flow of traffic. Therefore, plaintiff has not established that the ordinance unduly restricts free speech in light of the City's legitimate interest in regulating traffic. The court also concluded that the ordinance is not void for vagueness and thus is not unconstitutional on its face. The court further concluded that the ordinance is not unconstitutional as applied to plaintiff where the record does not support a conclusion that police invidiously discriminated against plaintiff based on her speech by selectively enforcing the traffic ordinance. The court remanded with directions to enter judgment for the City. View "Langford v. City of St. Louis" on Justia Law

Plaintiff filed suit challenging the constitutionality of Arkansas' limits on which candidates can appear on its general-election ballot, Ark. Code 7-7-101. After the district court entered judgment upholding the challenged provisions, plaintiff appealed. While the appeal was pending, the 2020 general election came and went.The Eighth Circuit dismissed plaintiff's appeal as moot, concluding that the "capable-of-repetition-yet-evading-judicial-review" exception to mootness did not apply. The court explained that plaintiff's interest in this case was predicated on his status as an Independent candidate; without such a candidacy, the challenged provisions do not apply to him. However, plaintiff's 2020 Independent candidacy has ended and he has not indicated whether he intends to run as an Independent again. Therefore, this case is no longer "live." Furthermore, plaintiff has failed to show that he is reasonably likely to be subject to the challenged statutory provisions again. View "Whitfield v. Thurston" on Justia Law

Plaintiff filed suit against defendant, asserting claims of First Amendment retaliation and Fourth Amendment unreasonable seizure under 42 U.S.C. 1983 and claims under the Arkansas Civil Rights Act (ACRA), for violating rights secured by Article II, 6, 8, 9, and 15 of the Arkansas Constitution. Plaintiff's claims stems from his arrest by defendant for disorderly conduct after plaintiff yelled an expletive at him from a moving vehicle.The Eighth Circuit affirmed the district court's judgment, concluding that the district court did not err by dismissing plaintiff's ACRA claim because plaintiff presented no evidence on summary judgment that defendant acted maliciously; the district court did not err in regards to its punitive damages rulings where plaintiff failed to produce sufficient evidence that defendant's conduct warranted the imposition of punitive damages, and plaintiff's trial testimony failed to establish facts meeting the punitive-damages standard; the district court did not abuse its discretion in denying plaintiff's motion for a new trial; and the district court did not abuse its discretion in awarding attorney's fees in this nominal damages case. View "Thurairajah v. Cross" on Justia Law

Plaintiff filed suit alleging that he was injured during the course of an arrest made by defendant, an officer, at a college board meeting. After the district court denied defendant's motion for summary judgment based on qualified immunity, defendant filed this interlocutory appeal.The Eighth Circuit dismissed the appeal based on lack of jurisdiction, concluding that material factual disputes that are incapable of being resolved on this record are at the heart of defendant's arguments. The court explained that, in order to reach defendant's "legal argument" that he responded reasonably and did not violate clearly established law, the court would have to exceed its jurisdiction and cast aside the district court's factual findings, analyze the factual record, and resolve genuine factual disputes against the non-moving party. View "Taylor v. Caples" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the City of Ferguson, alleging violations of his First, Fourth, and Fourteenth Amendment rights. Plaintiff's claims stemmed from nine citations he received from the officer at a park. The district court found that the officer was not entitled to qualified immunity and thus denied defendants' joint motion for summary judgment.After determining that it had jurisdiction, the Eighth Circuit vacated the district court's order denying defendants' joint motion for summary judgment and remanded so that the district court may further consider the officer's asserted entitlement to qualified immunity. In this case, when discussing plaintiff's Fourth Amendment seizure claim, the district court commenced its analysis by citing case law that outlined the general legal standards for probable cause and reasonable suspicion, but it largely failed to apply this case law, or more analogous cases, to plaintiff's version of the facts. Furthermore, the district court failed to conduct the materiality inquiry by framing legal questions as factual ones; the court was unable to discern whether the district court applied the clearly established prong at all, much less conducted a "thorough determination;" the district court defined the relevant law at too high a level of generality to conduct a proper clearly established analysis; and the district court's excessive force analysis fails to identify a specific right or factually analogous cases. Finally, the court dismissed the City's appeal for lack of jurisdiction. View "Watson v. Boyd" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action alleging claims of wrongful arrest and wrongful detention. After responding to a 911 call reporting an assault and robbery, officers arrived at an apartment complex and conducted a brief investigation, arresting plaintiff and two others for second degree robbery. During the continuing investigation after plaintiff's arrest, the police department obtained surveillance video that demonstrated that plaintiff was not in the victim's apartment at the time of the assault and robbery. Prosecutors later dropped the charges against plaintiff. The district court denied defendants' motion for summary judgment based on qualified immunity.The Eighth Circuit reversed, concluding that the record supports the conclusion that the officers had arguable probable cause to arrest plaintiff for the assault based on the victim's identification of plaintiff as one of his attackers. In this case, the record evidence does not create a factual dispute, and thus the officers are entitled to qualified immunity on the unlawful arrest claim. In regard to plaintiff's claim that defendants wrongful detained him, the court noted that this decision was not made by the named defendants but, rather, by the city prosecuting attorney. Therefore, the court concluded that plaintiff lacked standing to pursue his claim against the named defendants. View "Ngong Garang v. City of Ames" on Justia Law

The Eighth Circuit affirmed the district court's judgment in an action brought by plaintiffs, on behalf of their son, Tanner, who was arrested when he was 15 years old on charges that were later dismissed. Plaintiffs alleged violations of 42 U.S.C. 1983 and Iowa state law stemming from the officers' arrest of Tanner after he was accused of sexual assault. The court concluded that the officers had probable cause to arrest Tanner and were therefore entitled to summary judgment on the Fourth Amendment claim. The court explained that, when the officers arrested Tanner, they had probable cause to believe that he had committed the crime of third-degree sexual abuse under Iowa law.The court also affirmed the district court's grant of summary judgment on the Fourteenth Amendment claims, concluding that nothing in the officers' statements or actions indicates that they acted recklessly as they investigated the allegations against Tanner. Finally, because the officers had probable cause for the arrest, the court concluded that plaintiffs' state law claims for false arrest and malicious prosecution fail and defendants were entitled to summary judgment on the claims. View "Walz v. Randall" on Justia Law

After Jerome Goode led police on a twenty-five-mile car chase, the chase ended in his death and the deaths of passengers Lavoy Steed and Leon Haywood. Steed's next friend filed a 42 U.S.C. 1983 action against Missouri State Troopers Fowler and Ashby, alleging that the traffic stop that precipitated the chase and an attempt to halt Goode's vehicle with spike strips were unconstitutional seizures in violation of the Fourth Amendment.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the troopers, concluding that Trooper Fowler had probable cause to stop the vehicle where dashcam footage shows the vehicle going close to ninety miles per hour. Even assuming that the trooper misinterpreted the speed reading, he would still be entitled to qualified immunity because he had at least arguable probable cause to believe the vehicle was speeding. The court also concluded that the record clearly establishes that the troopers did not apply physical force by trying to use the spike strips, and thus there was no seizure. View "Steed v. Missouri State Highway Patrol" on Justia Law

The Eighth Circuit affirmed the district court's denial of the officers' motion for summary judgment in a 42 U.S.C. 1983 action brought by plaintiff, who had been arrested at a protest, alleging violations of his First and Fourth Amendment rights and conspiracy to violate his rights, and under Missouri state law. Plaintiff and his wife were documentary filmmakers who were covering protests in downtown St. Louis, Missouri, following Officer Jason Stockley's acquittal of charges arising from the death of Anthony Lamar Smith.The court concluded that, viewing the evidence in the light most favorable to plaintiff, a reasonable jury could conclude that Officer Biggins used excessive force during plaintiff's arrest, that he acted with an "actual intent to cause injury" to plaintiff, and that his use of excessive force was done in retaliation for plaintiff's First Amendment activity. Therefore, the district court did not err in denying summary judgment based on qualified immunity to Officer Biggins on plaintiff's First and Fourth Amendment claims, nor did the district court err in denying summary judgment based on official immunity to Officer Biggins on plaintiff's state law assault and battery claim. The court declined to consider the officers' argument concerning application of the intracorporate conspiracy doctrine because it was raised for the first time on appeal. View "Burbridge v. Biggins" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer unlawfully arrested him and used excessive force during the arrest. Plaintiff's claims stemmed from an incident where the officer issued tickets to him for illegal parking and resisting arrest. Plaintiff pleaded guilty to illegal parking by signing the ticket at the police station, and the City later dismissed the charge of resisting arrest.The Eighth Circuit affirmed the denial of summary judgment on plaintiff's unlawful arrest claim where there is a genuine dispute of material fact about whether the officer entered plaintiff's home without a warrant to effect the arrest. In regard to plaintiff's separate Fourth Amendment claim premised on the alleged use of excessive force, the court concluded that the officer is entitled to qualified immunity because an officer could reasonably believe that plaintiff was resisting arrest. The court explained that, under the circumstances, it was not clearly established at the time that officers were forbidden to use force, including a taser, to arrest a suspect who resisted, ignored instructions, and walked away from the officer. The court noted that any damages that plaintiff suffered because of his arrest are subsumed within his unlawful arrest claim. Therefore, even without a freestanding claim for use of excessive force, plaintiff may recover any damages that he suffered from the officer's use of a taser if plaintiff succeeds on his claim alleging unlawful arrest based on an unjustified entry into the home. View "Gerling v. Waite" on Justia Law