Justia Constitutional Law Opinion Summaries

The Eighth Circuit reversed the district court's denial of petitioner's motion to vacate his conviction under 28 U.S.C. 2255, based on the ineffective assistance of counsel under Strickland v. Washington. Taking petitioner's assertions as true, the court held that counsel provided false assurance that petitioner's conviction for robbery would not result in his removal from this country and nothing in the record contradicted petitioner's factual assertions about counsel's advice. Furthermore, petitioner showed prejudice by asserting that he would have rejected the plea and insisted on trial but for counsel's misadvice.Therefore, the court held that the record did not conclusively show that petitioner was entitled to no relief and the district court abused its discretion by denying relief without an evidentiary hearing. Accordingly, the court remanded for an evidentiary hearing. View "Dat v. United States" on Justia Law

Plaintiff filed suit against her former employer, alleging violations of the Minnesota Human Rights Act (MHRA) and the Family Medical Leave Act (FMLA). The Eighth Circuit affirmed the district court's dismissal of plaintiff's MHRA claims on alternative grounds. The court held that, assuming that the company took adverse action against plaintiff during a meeting when the CEO raised an "exit strategy," plaintiff failed to show that the action was taken because of protected opposition to an unlawful employment practice under the MHRA. Furthermore, the decision to arrange an exit strategy was not motivated by plaintiff's marital status. View "Harrell v. Handi Medical Supply, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner based on double jeopardy grounds. Before petitioner was tried and convicted in state court, a jury had been impaneled in the prosecution of the same charge against him but the state trial court declared a mistrial before the trial actually began because the prosecutor sustained an injury.The court held that the Minnesota Court of Appeals' determination that the trial court did not abuse its discretion in granting a mistrial based on manifest necessity was not an unreasonable application of clearly established federal law. In this case, the state court did not violate petitioner's Fifth and Sixth Amendment rights by concluding that the trial court did not abuse its discretion by declaring that manifest necessity justified the mistrial grant. View "Fenstermaker v. Halvorson" on Justia Law

On rehearing en banc, the Eighth Circuit reversed the district court's denial of summary judgment to defendant in a 42 U.S.C. 1983 action brought by plaintiff, alleging that defendant, plaintiff's boss, retaliated against him in violation of the First Amendment. In this case, plaintiff had run against his boss in a primary election and had publicly made statements about the sheriff's department and his plans to improve it. Defendant won the election and then terminated plaintiff's employment, claiming that plaintiff's campaign violated the department's rules of conduct.The court held that defendant was entitled to qualified immunity because he did not violate a clearly established statutory or constitutional right of which a reasonable person would have known. As in Nord v. Walsh. Nord, 757 F.3d 734, defendant could have reasonably believed that plaintiff's speech was at least potentially damaging to and disruptive of the discipline and harmony of and among co-workers in the sheriff's office and detrimental to the close working relationships and personal loyalties necessary for an effective and trusted local policing operation. View "Morgan v. Robinson" on Justia Law

Plaintiff filed suit against several parties, alleging violations of her parental rights over one of her minor children, E.J.K., under the Due Process Clause of the Fourteenth Amendment. E.J.K. obtained a letter from Mid-Minnesota Legal Aid concluding that E.J.K. was legally emancipated under Minnesota law. Although the letter had no legal effect, E.J.K. was able to obtain funding for medical services and other living expenses, as well as gender transition care.The Eighth Circuit held that the district court properly granted judgment on the pleadings for St. Louis County (including the official-capacity claim against the interim director) because plaintiff did not adequately plead a claim under 42 U.S.C. 1983. In this case, plaintiff's conclusory assertion that the County acted based on a policy or custom was insufficient to state a claim. The court also held that plaintiff failed to state a claim for damages against the then-interim director of Public Health and Human Services; neither of the medical provider defendants were acting under state law; the school district's alleged handling of plaintiff's case, assuming it interfered with plaintiff's rights, was insufficient to establish a custom or practice under Monell v. Dep't of Soc. Servs., 436 U.S. 658, 694 (1978); the school principal was entitled to qualified immunity; and declaratory and injunctive relief claims were moot. View "Calgaro v. St. Louis County" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff's 42 U.S.C. 1981 race discrimination claim. The court held that the employer articulated a legitimate, non-discriminatory basis for its hiring selection and plaintiff failed to demonstrate that the stated reason was a pretext for discrimination. In this case, the employer's regional executive selected another individual for a promotion, rather than plaintiff, because the individual scored the highest during the interviews and her duties were more directly relevant to the position. View "Nelson v. USAble Mutual Insurance Co." on Justia Law

Where a jury awarded plaintiff nominal compensatory damages and punitive damages for his claim of hostile work environment against his former employer, the Eighth Circuit affirmed the district court's denial of defendant's post-trial motions and grant of attorney's fees to plaintiff. The court held that the $250,000 award of punitive damages was supported by the record where plaintiff repeatedly complained to supervisors that his manager was using racial slurs and the company did not take action; plaintiff's 42 U.S.C. 1981 claim was timely under the applicable four year statue of limitations where the workplace abuse continued into the limitations period; the punitive damages amount was constitutionally sound in light of the degree of reprehensibility of defendant's misconduct; and the district court did not abuse its discretion in awarding attorney's fees and accepting the attorney's hourly rate as reasonable. View "Bryant v. Jeffrey Sand Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in a 42 U.S.C. 1983 action alleging that he was unlawfully arrested in violation of his Fourth Amendment rights. The court held that law enforcement had probable cause to arrest plaintiff where the totality of the circumstances at the time of the arrest were sufficient for the detective to believe that plaintiff had committed or was committing the offense of possessing child pornography. Therefore, the law enforcement agents were entitled to qualified immunity. Finally, because there was no constitutional violation, no municipal liability attached to the county and the city. View "Nader v. City of Papillion" on Justia Law

The Eighth Circuit reversed the district court's denial of summary judgment to the acting county sheriff and the county in an action brought by plaintiff alleging violation of her First Amendment right to intimate association. Plaintiff contended that the sheriff had terminated her based on her marriage to her husband, who had been terminated shortly before plaintiff.The court held that the sheriff's termination of plaintiff did not amount to a constitutional violation, because the fact that the marriage was a motivating factor in the decision to terminate plaintiff did not mean that the sheriff directly and substantially interfered with their marriage. In this case, the husband was terminated for sexually harassing other employees. Plaintiff was placed on administrative leave before the sheriff determined that her return would create a hostile work environment due to her loyalty to her husband. The court also held that, because the sheriff did not commit an unconstitutional act, no municipal liability attached to the county. View "Muir v. Decatur County, Iowa" on Justia Law

Correction officers who disregard visible and self-reported symptoms medical professionals believe to be flu symptoms are not deliberately indifferent to an obvious need for immediate medical attention. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiff's 42 U.S.C. 1983 claims against correctional officers, alleging that they were deliberately indifferent to his medical needs after he suffered a stroke. In this case, while the officers were less than sympathetic to plaintiff's continuing illness, they were not deliberately indifferent to an obvious need for immediate medical attention that was sufficient to establish a cognizable claim under the Eighth Amendment. View "Roberts v. Kopel" on Justia Law