Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Walmart in an action brought by plaintiff, alleging age discrimination under the Iowa Civil Rights Act (ICRA). The court assumed that plaintiff met his prima facie burden under the McDonnell Douglas standard, but concluded that Walmart offered a legitimate, non-discriminatory reason for terminating his employment, the violation of the Hazardous Materials Endorsement policy while on a Third Written (a policy meaning he could be fired if disciplined again). The court also concluded that plaintiff's evidence was insufficient to allow a reasonable juror to find that Walmart's proffered reason for firing him was pretextual. View "Gardner v. Wal-Mart Stores, Inc." on Justia Law

Plaintiffs, parents of LD, filed suit against the school district and others after their daughter LD, a 13-year-old, 7th grade student, was sexually abused by her teacher, Brian Robeson.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the school district and the principal. The court concluded that plaintiffs failed to present any evidence that the principal had actual notice of the abuse, and the principal and the school district were entitled to summary judgment on plaintiffs' Title IX and 42 U.S.C. 1983 claims. The court also concluded that the district court did not err by granting summary judgment in favor of the school district and principal on plaintiffs' Nebraska Political Subdivisions Tort Claims Act where plaintiffs' claim arose out of Robeson's sexual assault of LD, an intentional tort to which the Act's intentional tort exception applies. The court further concluded that the district court did not err in granting summary judgment in favor of the principal on plaintiffs' aiding and abetting intentional infliction of emotional distress claim where nothing in the record, even when viewed in the light most favorable to plaintiffs, indicates that the principal encouraged or assisted Robeson in inflicting emotional distress on LD.The court joined its sister circuits in finding that there is no right to a jury trial on the issue of damages following entry of default judgment. The court affirmed the district court's order denying plaintiffs' request for a jury trial on the issue of damages against Robeson. Finally, the court affirmed the $1,249,540.41 amount of damages awarded against Robeson. View "KD v. Douglas County School District No. 001" on Justia Law

Plaintiff, a tenured professor, filed suit against the University, a faculty union, and the Board of Trustees, alleging First and Fourteenth Amendment violations. Plaintiff claimed that the designation of IFO as plaintiff's exclusive representative violates the First Amendment by wrongly compelling her to speak through and associate with an entity with which she disagrees. Plaintiff also claimed that granting preferences to IFO members to serve on meet-and-confer committees discriminates against her and others who declined to associate with the union.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. Because plaintiff properly concedes that the district court correctly rejected her compelled-speech claim (Count I) under Minnesota State Board of Community Colleges v. Knight, 465 U.S. 271 (1984), the court affirmed the district court's grant of summary judgment on her Count 1 claims. Furthermore, the district court correctly rejected plaintiff's invitation to read Count II as an unconstitutional-conditions claim for three reasons: first, the complaint's text does not support this reading; second, there are inconsistencies in plaintiff's filings; and plaintiff's claim that IFO's meet-and-confer rights under Minnesota law discriminate against her associational preferences is similar to Knight. Finally, the court concluded that the district court did not abuse its discretion in denying plaintiff's request for leave to amend her complaint, which she made in her Rule 59(e) motion to vacate the judgment. View "Uradnik v. Inter Faculty Organization" on Justia Law

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

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

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

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

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

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

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