Justia Constitutional Law Opinion Summaries

After a police officer shot and killed 17 year old Keagan Schweikle, his parents and others filed suit against the officer, the Chief of Police, and the City under 42 U.S.C. 1983 and Arkansas law. The district court granted qualified immunity to the officers and judgment on the pleadings.The Eighth Circuit affirmed in part and reversed in part, holding that, in light of the circumstances, the officer's actions were not objectively reasonable and Keagan's right to be free from excessive force was clearly established at the time. In this case, the officer shot a non-resisting, non-fleeing minor as he moved his gun in compliance with the officer's commands to drop his gun. Therefore, no reasonable officer could conclude that Keagan posed an immediate threat of serious physical harm. Consequently, the court reversed the dismissal of the Monell claims and vacated the dismissal of the state law claims. Finally, the court held that the parents failed to allege a due process claim under the Fourteenth Amendment to a familial relationship, where they failed to allege that the shooting was directed at their relationship with their son. View "Partridge v. City of Benton" on Justia Law

Plaintiff filed suit challenging Arkansas's ballot access requirements for independent candidates. The Secretary appealed the district court's grant of plaintiff's request for declaratory and injunctive relief. The Eighth Circuit dismissed the appeal as moot, because the state legislature recently amended the challenged statute to accord with the petition filing deadline that plaintiff had sought, and thus no controversy remains. The court held that the equities weighed against vacatur, and the public interest is best served by a substantial body of judicial precedents limiting the burden that those requirements may place on candidates' and voters' First and Fourteenth Amendment rights. View "Moore v. Thurston" on Justia Law

Plaintiff, an Iowa state prisoner, alleged that prison officials violated this Eighth and Fourteenth Amendment rights when they had him civilly committed and forcibly medicated. The Eighth Circuit affirmed the district court's dismissal of plaintiff's wrongful commitment claim and his forced medication claim. The court held that plaintiff's wrongful commitment claim was not cognizable under Heck v. Humphrey, 512 U.S. 477 (1994), and his forced medication claim lacked evidentiary support where he never presented evidence that would have allowed a reasonable factfinder to conclude that his constitutional rights had been violated. View "Thomas v. Eschen" on Justia Law

Plaintiff, an Arkansas state prisoner, filed a 42 U.S.C. 1983 suit against his former parole officer and another police officer, alleging violations of his Fourth Amendment right to be free from unreasonable searches and seizures. The Eighth Circuit reversed the district court's denial of the officers' motions to dismiss, holding that the district court erred in denying the officers qualified immunity. The court held that, even assuming the officers violated the Fourth Amendment by failing to knock and announce their presence before entering plaintiff's dwelling, it was not clearly established in January 2015 that failing to knock and announce before entering the dwelling of a parolee was unlawful. The court also rejected plaintiff's claim that there was a robust consensus of persuasive authority on the question. View "Lane v. Boyd" on Justia Law

The Eighth Circuit granted defendants' petition for rehearing en banc and vacated the previous opinion.The court reversed the district court's ruling that plaintiff had alleged sufficient claims to state 42 U.S.C. 1983 claims against a police officer, the police chief, and the city. The court held that, in the absence of any intentional acquisition of physical control terminating plaintiff's freedom of movement through means intentionally applied, no seizure occurred. In this case, plaintiff was not ordered to stop and to remain in place, plaintiff's decision to remain with his companion during the companion's altercation with the officer rather than complying with the officer's lawful command to return to the sidewalk was that of his own choosing, and plaintiff was able to leave the scene following the discharge of the officer's weapon gives lie to his argument that the place of the officer's vehicle prevented him from doing so. The court also held that the claim of supervisory liability against the police chief and municipal liability against the city failed because there was no constitutional violation. View "Johnson v. City of Ferguson" on Justia Law

Plaintiff filed suit against the sheriff and several other county employees, alleging various claims related to the treatment plaintiff asserted he suffered as a result of his political beliefs and associations. The Eighth Circuit affirmed the district court's grant of summary judgment to the sheriff on the First Amendment discrimination and retaliation claims. The court held that both claims suffered from the same fatal flaw because they lacked an adverse employment action. In this case, none of the complained-of actions, either together or separately, constitute an adverse employment action. View "Charleston v. McCarthy" on Justia Law

Plaintiff filed suit against a police deputy, alleging that the deputy violated plaintiff's rights under the First Amendment, Fourth Amendment, and the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the deputy based on qualified immunity. The court held that the initial encounter at the rest stop presented no colorable claim that plaintiff's Fourth Amendment rights were violated where an objectively reasonable officer would have articulable suspicion to conduct a Terry stop; the seizure of plaintiff on the highway exit ramp did not run afoul of the Fourth Amendment and was reasonably related in scope to the circumstances which justified the interference; pointing a firearm at plaintiff for a few seconds while removing him from his vehicle did not constitute excessive force, and did not violate the Fourth Amendment; and, in light of the deputy's legitimate motive to investigate, plaintiff failed to draw the requisite causal connection to state a First Amendment retaliation claim. View "Clark v. Clark" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of the school district in an action originally alleging that plaintiff's daughter, a young student with autism and significant intellectual deficits, was not provided a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). Plaintiff also brought additional claims for constitutional violations under 42 U.S.C. 1983, disability discrimination and retaliation under section 504 of the Rehabilitation Act, disability discrimination under Title II of the Americans with Disabilities Act (ADA), and violations of Arkansas law.The court found no clear error in the district court's factual findings and gave due weight to the hearing officer's credibility determinations, concluding that the child was not denied a FAPE. The court also held that the district court did not abuse its discretion in denying plaintiff's motions for extensions of time and her motion to accept her summary judgment response out of time. The court also held that some of plaintiff's claims were barred for failure to exhaust and that her retaliation claim based on a violation of the IDEA also failed. View "Albright v. Mountain Home School District" on Justia Law

The Constitution does not imply a cause of action under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), if a federal law-enforcement officer lies, manipulates witnesses, and falsifies evidence. In this case, the allegations were that a federally deputized officer duped prosecutors and a grand jury into believing that plaintiffs were part of a multistate sex-trafficking conspiracy.The Eighth Circuit declined to extend Bivens and remanded with respect to the 42 U.S.C. 1983 claims against defendant for the district court to consider the applicability of section 1983 in the first instance. In regard to the unlawful arrest claim, the court held that defendant was not entitled to qualified immunity because her actions constituted a violation of a clearly established right. In this case, a reasonable officer would know that deliberately misleading another officer into arresting an innocent individual to protect a sham investigation was unlawful, regardless of the difficulties presented by the case. View "Farah v. Weyker" on Justia Law

Plaintiff filed suit against defendants, alleging that they violated her son's constitutional rights when two officers used deadly force against him. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that there was no potentially admissible evidence in the record supporting plaintiff's allegations that the decedent was unarmed, did not point his gun at officers, and did not shoot at an officer. The court also held that the district court correctly ruled that the officers were reasonable in using deadly force. Therefore, the district court properly rejected the assault, battery, and wrongful death claims, as well as properly dismissed the Monell claim. Finally, because the individual officers fulfilled their constitutional obligations, the Board and the Police Chief cannot be liable for failing to train them. View "Smith v. Kilgore" on Justia Law