Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's finding that plaintiff failed to allege a claim that a state prosecutor retaliated against him for seeking unpaid overtime compensation. The court held that plaintiff waived his First Amendment retaliation claim by failing to brief the issue; because plaintiff is not an employee under section 215(a)(3) of the Fair Labor Standards Act, the district court did not err in dismissing his claim; because plaintiff failed to point to any alteration or extinguishment of a right or legal status on appeal, he failed to state a due process claim; and because plaintiff failed to allege a conspiracy under 42 U.S.C. 1985(2), his sections 1985(3) and 1986 claims also failed. Finally, the court held that there was no error in dismissing plaintiff's state law claims and in denying him leave to file a third amended complaint. View "Liscomb v. Boyce" on Justia Law

Plaintiff filed suit against the sheriff and sheriff's deputies, alleging that they violated his constitutional right to be free from unreasonable searches and seizures and his right to due process.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that the deputies were entitled to qualified immunity because a reasonable officer could believe that the location of the keys to a seized vehicle was reasonably related to the suspected crime because it could provide evidence that plaintiff himself placed the car on the property rather than someone else; the seizure of antique handguns, guns in unopened boxes, and holsters were covered under the second warrant authorizing the seizure of any and all handguns in plaintiff's home; the second warrant was sufficiently particular; the sheriff was entitled to summary judgment on claims against him in his individual capacity and in his official capacity; and plaintiff had an adequate state court remedy to obtain the return of the seized items. View "Thiel v. Korte" on Justia Law

Within two months after plaintiff filed suit against Holiday seeking declaratory and injunctive relief for violations of Title III of the Americans with Disabilities Act, Holiday remedied the violations. Three months later, plaintiff filed an amended complaint.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Holiday, holding that the post-suit alterations mooted plaintiff's accessibility claims. Furthermore, because there was no fair notice of the flared-sides issue, the disputed measurements are not a genuine issue of material fact. The court also held that the district court correctly ruled that nominal damages are not available under Title III of the ADA, and that requesting them does not affect mootness. View "Hillesheim v. Holiday Stationstores, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of prison officials in a 42 U.S.C. 1983 action brought by plaintiff, alleging violation of his due process rights in connection with discipline imposed on him. The court held that the conditions of confinement that plaintiff faced during administrative segregation and upon his transfer to the Iowa State Penitentiary did not amount to an atypical and significant deprivation when compared to the ordinary incidents of prison life.The court held that the transfer to a higher security facility alone is insufficient to establish an atypical and significant hardship, and thus the court must examine the conditions of confinement. In this case, plaintiff failed to set forth facts describing his conditions of confinement while in administrative segregation and disciplinary detention. Furthermore, plaintiff's reference to his loss of employment, wages, security classification, security points, and inmate tier status upon his transfer did not amount to atypical and significant hardship under precedent. View "Smith v. McKinney" on Justia Law

Plaintiff, a former detainee at the detention center, filed suit against the sheriff and nurse, alleging that defendants delayed his access to adequate medical treatment for a serious condition while he was detained.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that there was insufficient evidence to support a submissible case. In this case, the nurse's actions demonstrated concern for plaintiff's condition and showed repeated efforts to make arrangements for surgery. Even if the nurse could be second-guessed for not acting more aggressively when the doctor's office delayed, her handling of the situation was at most negligent and does not amount to deliberate indifference that violates the Due Process Clause. Because plaintiff has not presented sufficient evidence that the nurse was deliberately indifferent to his serious medical needs, it follows that the sheriff did not violate plaintiff's rights by supposedly turning a blind eye to his complaints about the nurse. Likewise, claims against defendants in their official capacities, which are treated as claims against the municipality, failed for lack of a constitutional violation. View "Morris v. Cradduck" on Justia Law

Plaintiff filed suit against UND Law under Title II of the Americans With Disabilities Act of 1990 (ADA), alleging that UND Law discriminated against him because of his mental illness when it rejected his admission application.The Eighth Circuit affirmed the district court's grant of summary judgment to UND Law, holding that plaintiff failed to show that UND Law's legitimate, nondiscriminatory reason for rejecting plaintiff's application was pretext for discrimination. The court reasoned that UND Law's holistic approach to application reviews did not discriminate against plaintiff in determining that he would not be a good fit for UND Law. In this case, plaintiff had dropped out of law school three times, had a very low undergraduate GPA, and submitted out-of-date recommendation letters. View "Power v. University of North Dakota School of Law" on Justia Law

The Eighth Circuit affirmed the district court's determination that Minn. Stat. Sec. 216B.246, subdiv. 2, which grants incumbent electric transmission owners the right of first refusal (ROFR) to construct, own and maintain electric transmission lines that connect to their existing facilities does not violate the dormant Commerce Clause.The court held that the statute was not facially discriminatory and had no discriminatory purpose nor effect. Furthermore, the court dismissed the undue burden claim, because the court could not say that the burden imposed by the ROFR law is clearly excessive in relation to Minnesota’s legitimate state interests in regulating its electric industry and maintaining the status quo. View "LSP Transmission Holdings, LLC v. Sieben" on Justia Law

Plaintiffs filed a putative class action alleging that defendants deceived plaintiffs into believing their products were approved by the FDA. After the district court remanded the case back to state court, the Eighth Circuit granted defendants' petition for review under 28 U.S.C. 1453(c)(1), limiting review to the issue of federal question jurisdiction.The court held that federal question jurisdiction exists in this case, because plaintiffs rely explicitly on federal law throughout their pleadings and their prayer for relief invokes federal jurisdiction where it seeks injunctive and declaratory relief that necessarily requires the interpretation and application of federal law, including the Food Drug and Cosmetic Act. Therefore, based on the allegations in the complaint and relief sought, the court found that a federal issue surrounding the state law claims is necessarily raised, actually disputed, substantial, and capable of resolution in federal court without disrupting the federal-state balance approved by Congress. Accordingly, the court vacated and remanded for further proceedings. View "Wullschleger v. Royal Canin U.S.A., Inc." on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to dismiss plaintiff's action alleging a claim under the Americans with Disabilities Act (ADA). The court held that the district court erred by dismissing plaintiff's claim where plaintiff's allegations were sufficient to state a claim based on the statutory elements of the ADA. In this case, plaintiff has plausibly alleged that defendant refused to consider rehiring him because of his disability. The court also held that plaintiff's request for leave to amend was not futile and should have been granted. View "Cook v. George's, Inc." on Justia Law

Plaintiff, a former police officer, filed a 42 U.S.C. 1983 action against the city and the chief of police, alleging unlawful retaliation for exercising his First Amendment right to participate in a media interview, deprivation of his right to pretermination process, and violation of his rights under the North Dakota Constitution.The Eighth Circuit affirmed the district court's grant of defendants' motion for summary judgment. The court held that the district court properly granted summary judgment on the First Amendment claim where plaintiff failed to prove his speech as a public employee was protected by the First Amendment. In this case, the district court found that plaintiff was not speaking as a citizen in a local news interview; plaintiff's speech during the interview was not on a matter of public concern because his asserted desire was to clear the name of his Facebook alias, which was a purely private interest; and even assuming plaintiff was a citizen commenting on a matter of public concern, his speech at the interview was not First Amendment protected, because it created great disharmony in the workplace, interfered with plaintiff's ability to perform his duties, and impaired his working relationships with other employees. The court also held that plaintiff was not deprived of his right to due process, and declined to exercise supplemental jurisdiction over the state law claims. View "Nagel v. City of Jamestown" on Justia Law