Justia Constitutional Law Opinion Summaries

After plaintiff was removed from the Board of Trustees of Drake University, he filed suit alleging Title IX retaliation, disability retaliation, and breach of contract. Plaintiff's removal stemmed from conflicts of interests following the University's findings that plaintiff's son was responsible for alleged sexual misconduct and expelled from the University.The Eighth Circuit held that plaintiff's removal from the Board cannot support a Title IX retaliation claim against the University. In this case, the Board was acting in a manner separate and distinct from the University itself and thus plaintiff cannot hold the University liable under Title IX for the separate decision of the Board regarding its own internal affairs. The court also held that plaintiff's claim that the University retaliated against him by prohibiting him from serving as his son's advocate during the campus hearings failed, where, at no time did the son request that his father serve as his personal representative under the Code of Conduct and that such request was denied. Furthermore, without a nexus, plaintiff's claim of Title IX retaliation by the University failed. The court held that none of the actions plaintiff alleges the University took against him in retaliation were part of an education program or activity, and therefore he lacks standing to bring suit under 20 U.S.C. 1681(a). The court declined to expand Title IX's reach.The court held that plaintiff's disability retaliation claim failed because the Board voted to remove plaintiff due to his pervasive conflict of interest with the University and only after plaintiff refused to take a leave of absence from the Board. Finally, the court held that plaintiff's contract claim failed because plaintiff served on the Board as an unpaid, uncompensated volunteer. View "Rossley v. Drake University" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against ISC, alleging that ISC transported plaintiff, a pretrial detainee subject to extradition, for eight continuous days across twelve states, with only momentary breaks for bathroom use.The Eighth Circuit held that ISC is not entitled to summary judgment on the current record based on the standards applicable to pretrial detainees under Bell v. Wolfish, 441 U.S. 520, 535 n.16 (1979). In this case, prior to being found guilty of any offense, plaintiff was subjected to painful, unsanitary, and severe conditions and restraints for over one week. Viewing the totality of the circumstances, the court held that the conditions of plaintiff's confinement were far from de minimis and a jury could reasonably conclude that, on this record, the conditions were arbitrary or excessive when compared to the government's perceived goal of securely transporting plaintiff to his destination. View "Stearns v. Inmate Services Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of the school district's motion to dismiss in part and motion for summary judgment in an action brought under section 504 of the Rehabilitation Act, the Individuals with Disabilities Education Act (IDEA), and Title II of the Americans with Disabilities Act.The court held that the district court did not err in dismissing plaintiffs' request for attorneys' fees as time barred by the 90-day statute of limitations in Arkansas Code section 6-41-216(g), Arkansas's statutory framework for IDEA compliance. The court explained that the claim for attorneys' fees is ancillary to judicial review of the administrative decision. The court also held that the district court did not err by granting summary judgment to the school district where there is no genuine issue of material fact about whether the school district acted in bad faith or with gross misjudgment with respect to plaintiffs' claim that their son was the victim of peer and teacher bullying. View "Richardson v. Omaha School District" on Justia Law

Iowa inmate Napolean-Ahmed Mbonyunkiza was a practicing Muslim whose religious beliefs forbade consumption of pork or pork by-products. In 2017, he filed four separate grievances against the Newton Correctional Facility claiming he had eaten or was served food containing pork. Unsatisfied with the outcome of the grievances, Mbonyunkiza filed a 42 U.S.C. 1983 action in federal district court, alleging violation of his First Amendment rights. The district court granted summary judgment in favor of the correctional facility. The Eighth Circuit, reviewing the grant of summary judgment de novo, concluded Mbonyunkiza failed to show defendants deprived him of a constitutional right and therefore affirmed. View "Mbonyunkiza v. Beasely" on Justia Law

The National Credit Union Administration Board ("NCUAB"), the self-appointed conservator of Citizens Community Credit Union ("Citizens"), repudiated a letter of credit Citizens issued to Granite Re, Inc. Granite filed a complaint for damages against the NCUAB, claiming wrongful repudiation and wrongful dishonor of a letter of credit. The NCUAB moved to dismiss with prejudice, arguing 12 U.S.C. 1787(c) authorized it to repudiate the letter of credit with no liability for damages, and section 1787(c) preempted conflicting North Dakota Law. The district court agreed and dismissed the complaint. The Eighth Circuit determined that were it to adopt the NCUAB's construction of section 1787(c), the NCUAB could "quietly appoint itself conservator and repudiate letters of credit with no liability to the injured beneficiary. Absent the ability to predict an impending conservatorship, a clean letter-of-credit beneficiary like Granite is subject to repudiation with no recourse." The Court determined NCUAB's construction was inconsistent with the language of the statue, which provided a limited remedy for damages determinable at the point of conservatorship, but did not negate recovery entirely. The Court also determined it was premature to declare section 1787(c) preempted North Dakota law. The Court reversed the trial court's judgment and remanded for further proceedings. View "Granite Re, Inc. v. Nat'l Credit Union Adm. Board" on Justia Law

Based on a report by the burglary victim, Goffin’s uncle, Officer Ashcraft tried to arrest Goffin for burglary and stealing handguns, bullets, and prescription pain medication. Before the arrest, several witnesses told Ashcraft that Goffin was armed, possibly intoxicated, and dangerous. When Goffin broke free from arrest, fled toward a group of bystanders, and moved as though he was reaching into his waistband, Ashcraft shot him once in the back. Goffin claims (and Ashcraft disputes) that he was patted down by another officer (Hines) just before he fled. The pat-down removed nothing from Goffin; the officer failed to discover that Goffin was carrying a loaded magazine and extra bullets. Officer Hines claims that Goffin fled before he completed the pat-down. Stolen guns were discovered within reach of where Goffin had been sitting in acar, but Goffin did not have a weapon on him. In Goffin’s suit under 42 U.S.C. 1983, the Eighth Circuit affirmed summary judgment for the defendants. Officer Ashcraft is entitled to qualified immunity because it was not clearly established at the time of the shooting that a pat-down that removes nothing from a suspect eliminates an officer’s probable cause that the suspect poses a threat of serious physical harm. View "Goffin v. Ashcraft" on Justia Law

The Eighth Circuit granted a writ of mandamus in part and directed the district court to dissolve a Temporary Restraining Order (TRO) enjoining the State from enforcing a COVID-19-related health directive against a provider of surgical abortions. The Arkansas Department of Health (ADH) issued a directive requiring that all non-medically necessary surgeries be postponed in response to Executive Order 20-03, directing the ADH to do everything reasonably possible to respond to and recover from the COVID-19 virus.After adopting the Fifth Circuit's reasoning in In re Abbott, No. 20-50264, 2020 WL 1685929 (5th Cir. April 7, 2020), the court held that the State is entitled to mandamus relief because it has satisfied its burden in demonstrating that it has no other means to obtain the relief that it seeks, the State is clearly and indisputably entitled to the writ, and entry of the writ is appropriate under the circumstances.In Jacobson v. Massachusetts, 197 U.S. 11 (1905), the Supreme Court held that, when faced with a public health crisis, a state may implement measures that infringe on constitutional rights, subject to certain limitations. The court found that the district court's failure to apply the Jacobson framework produced a patently erroneous result. In this case, the directive bears a real and substantial relation to the State's interest in protecting public health in the face of the COVID-19 pandemic; the directive is not, beyond all question, a prohibition of pre-viability abortion in violation of the Constitution because it is a delay, not a ban, and contains emergency exceptions; and the district court clearly abused its discretion in finding that the provider is likely to prevail on its argument that the directive will likely operate as a substantial obstacle to a woman's choice to undergo an abortion in a large fraction of the cases in which the directive is relevant. The court declined to exercise its mandamus power to direct the district court to dismiss the supplemental complaint, and denied the emergency motion to stay the ex parte TRO and for a temporary administrative stay as moot. View "In Re: Leslie Rutledge" on Justia Law

The Eighth Circuit affirmed the magistrate judge's grant of summary judgment in favor of law enforcement officers and the City, in a 42 U.S.C. 1983 action brought by plaintiff after the death of her son. The court held that the officers' actions did not amount to constitutionally excessive force. In this case, the undisputed facts show that the officers discovered the son acting erratically, and even though the son was held in a secure cell, it was objectively reasonable for the officers to fear that he would intentionally or inadvertently physically harm himself. Furthermore, the son actively resisted the officers' attempts to subdue him, and officers held him in the prone position only until he stopped actively fighting against the restraints and the officers. Therefore, the court held that the officers are entitled to qualified immunity on plaintiff's excessive force claim. View "Lombardo v. City of St. Louis" on Justia Law

Plaintiffs, health care providers and their patients, filed suit against Iowa's Department of Public Health and its Health Facilities Council, alleging that Iowa's Certificate of Need laws violate the Fourteenth Amendment's Due Process, Equal Protection, and Privileges and Immunities Clauses.The Eighth Circuit held that plaintiffs' Privileges and Immunities Clause claim was foreclosed by the Slaughter-Houses cases. Applying rational basis review to the Certificate of Need (CON) regime and capital expenditures exemption, the court held that Iowa's CON requirement is rationally related to a legitimate state interest in full-service hospital viability. Furthermore, Iowa's decision to exempt competitors who are non-hospital CON-holders is rationally related to its interest in protecting the viability of full-service hospitals. Therefore, the court affirmed the district court's orders dismissing plaintiffs' Privileges and Immunities claim and granting summary judgment in favor of the state defendants on the remaining claims. View "Birchansky v. Clabaugh" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims of racial discrimination and retaliation, disability discrimination, whistleblower retaliation, and breach of fiduciary duty. The court held that plaintiff's discrimination claim failed because Mid Dakota offered a legitimate nondiscriminatory reason for its actions: his inability to get along with others; plaintiff's Title VII retaliation claims failed because he failed to show he was retaliated against for reporting racial slurs and racially charged comments; plaintiff's False Claims Act retaliation claim failed because there was no evidence, direct or otherwise, that his decision to report the allegedly fraudulent billing practices of a colleague caused—much less solely caused—Mid Dakota to force him out; and plaintiff's claim under the North Dakota Business Corporation Act failed because he was an at-will employee. View "Bharadwaj v. Mid Dakota Clinic" on Justia Law