Justia Constitutional Law Opinion Summaries

Two male students filed suit against Minnesota's high school athletic league and others, alleging that the league unlawfully discriminated against them on the basis of sex through its rule prohibiting boys from participating on high school competitive dance teams. The Eighth Circuit reversed the district court's denial of the students' motion for preliminary injunction and directed the district court to enter a preliminary injunction.The court held that the heightened, likely-to-prevail standard did not apply to the boys' preliminary injunction motion, but instead, whether the boys have a fair chance of prevailing. On the merits, the court held that the boys had more than a fair chance of prevailing on the merits of their equal protection claim where the league has not asserted an exceedingly persuasive justification for keeping them from participating on high school competitive dance teams. Furthermore, the remaining Dataphase factors favored a preliminary injunction. View "D.M. v. Minnesota State High School League" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the City in an action alleging that the City discriminated against plaintiff based on her race when it denied her applications for rezoning to open a beauty salon in a residential neighborhood. The court held that plaintiff's race discrimination claim under the Equal Protection Clause failed because plaintiff failed to produce evidence that the City's decision constituted racial discrimination and the City's interest in preserving the neighborhood's residential character from increased commercialization was supported by the record.In a class-of-one challenge to local zoning decisions, courts are not entitled to review the evidence and reverse the commission merely because a contrary result may be permissible. Instead, the court is authorized only to ascertain whether there has been a transgression upon the property owner's constitutional rights. In this case, the court held that plaintiff's class-of-one discrimination claim failed to meet this standard where she failed to identify how any purported comparators were similarly situated in all material respects. View "Mensie v. City of Little Rock" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff and her three minor children's complaint against Children's Healthcare and a doctor. The action stemmed from the doctor's report to child protective services stating her concerns that plaintiff was harming one of the children. The juvenile court adjudicated that the child was in need of protection or services and ordered that he be placed in foster care.In this action, plaintiff sought relief under Minnesota and federal law, alleging that the doctor's report was false and caused the child to be separated from his family. The court applied Minnesota's law on collateral estoppel and held that the report's veracity was a central issue in the state court proceedings. Because the juvenile court implicitly ruled that the report was credible in its entirety, the court held that plaintiff was precluded from relitigating the issue. View "Peschong v. Children's Healthcare" on Justia Law

Plaintiff, an inmate, appealed the district court's grant of summary judgment for defendants on his claims under 42 U.S.C. 1983 and the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court held that plaintiff failed to administratively exhaust some claims, and he failed to show a violation of his rights under RLUIPA and the First Amendment on the claims he exhausted. The court also held that the district court properly granted summary judgment on plaintiff's retaliation claims against five defendants because plaintiff did not allege any facts connecting those defendants to the challenged actions.However, the court held that a genuine issue of material fact remained as to plaintiff's retaliation claims against seven other defendants where plaintiff presented evidence that these specific defendants placed him in administrative segregation and prevented him from providing his attorney with legal documents shortly after he filed a previous lawsuit against prison officials and they knew of the lawsuit. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Bitzan v. Bartruff" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the Housing Authority and plaintiff's supervisor in an action alleging various discrimination, retaliation, and constitutional claims. Plaintiff resigned from his job after he failed a drug test and his employer sought documentation of the prescription medications plaintiff was using, as well as a clearance letter from plaintiff's healthcare professionals addressing the issue.The court held that, by not including in his EEOC charge the adverse acts which he maintained forced him to resign, plaintiff failed to administratively exhaust his constructive discharge allegation; plaintiff failed to establish a prima facie case of disability discrimination; plaintiff failed to show that he suffered an adverse employment action because he was suspended before his employer had any reason to suspect that he might be disabled; and plaintiff failed to show that he possessed a property interest in his employment under Arkansas law in order to prevail on his procedural due process claim. View "Voss v. Housing Authority of the City of Magnolia" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and common law, against the Tribe and tribal officers, seeking damages for their violation of his constitutional and civil rights stemming from his arrest and incarceration. The Eighth Circuit affirmed the district court's dismissal with prejudice of claims against the Tribe and the individual defendants acting in their official capacities because those claims were barred by the Tribe's sovereign immunity. The court affirmed the district court's dismissal without prejudice of claims against defendants acting in their individual capacities based on failure to exhaust tribal court remedies. View "Stanko v. Oglala Sioux Tribe" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the University in a Title IX action alleging that plaintiff was excluded from participation in and denied the benefits of the educational programs at the University as a result of its response to her sexual assault by another student. The court assumed, without deciding, that plaintiff's claim survived Iowa's statute of limitations and held that plaintiff's Title IX claim failed on the merits. The court held that there was no genuine dispute as to whether the University was deliberately indifferent after its investigative report concluded that plaintiff was sexually assaulted. In this case, the University was waiting to take action until the hearing process concluded and it had instituted a no-contact order between plaintiff and the other student. View "Maher v. Iowa State University" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to an off-duty police officer and the board of police commissioners in a 42 U.S.C. 1983 action. Plaintiff, a concertgoer, filed suit after he was injured when the officer lifted him over a five foot barrier and dropped him on his neck.The court held that no reasonable jury could find that the officer used excessive force when grabbing plaintiff, lifting him over the barrier, and throwing him to the ground. In this case, the officer had probable cause to arrest plaintiff for disorderly conduct and the officer's actions were reasonable in light of the circumstances. The court also held that the officer was entitled to immunity as to the state law claims under Missouri's doctrine of official immunity. Finally, because there was no constitutional violation, the board was not liable for the officer's actions. View "Kasiah v. Crowd Systems, Inc." on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against police officers, in their individual capacities, alleging that the officers used excessive force and exhibited deliberate indifference to medical needs in an incident that led to the death of her son. The Eighth Circuit reversed the district court's denial of summary judgment based on qualified immunity to the officers and held that the officers' use of force did not violate clearly established law nor did their actions on the scene exhibit deliberate indifference to medical needs. In this case, there was insufficient evidence that a need for medical treatment was so obvious that law enforcement exhibited deliberate indifference by taking the son to jail. Furthermore, the officers were not deliberately indifferent when they called paramedics to assist him. View "Hanson v. Best" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of JBS in an action under the Americans with Disabilities Act (ADA), the Iowa Civil Rights Act (ICRA), and the Iowa Wage Payment Collection Law (IWPCL). Plaintiff alleged a failure to accommodate claim and a termination claim, as well as a claim that JBS intentionally failed to pay plaintiff a portion of his earned wages.The court held that, even if plaintiff was disabled, he was not qualified to perform the essential functions of his job, and his claims failed on that basis. The court explained that lifting was an essential function of the maintenance mechanic position that could not be reasonably accommodated, and plaintiff failed to show that accommodations JBS offered were unreasonable. The court held that plaintiff was not a qualified individual under the ADA and thus his termination claim also failed. Finally, because mere allegations were insufficient to rebut a properly supported motion for summary judgment, the district court properly granted summary judgment as to the IWPCL claim. In this case, JBS's payroll records reflected that plaintiff was correctly paid and any errors were quickly remedied. View "Gardea v. JBS USA, LLC" on Justia Law