Justia Constitutional Law Opinion Summaries

After her fifteen year old son was shot and killed by a police officer, plaintiff filed suit against the officer, the police chief, and the city, alleging claims under 42 U.S.C. 1983 and state law. The district court granted summary judgment for the police chief and the city. A jury found that the officer violated the boy's Fourth Amendment right to be free from excessive force and returned a verdict in favor of plaintiff.The Eighth Circuit affirmed, holding that plaintiff failed to establish a municipal custom based on failure to prevent police misconduct; plaintiff failed to show that the city acted with deliberate indifference to the rights of persons with whom its officers came into contact; the district court did not err by requiring plaintiff to establish a pattern of constitutional violations to prove her claim; plaintiff's evidence of officer-involved shootings did not establish deliberate indifference to a pattern of excessive force; and the district court likewise did not err in granting summary judgment on plaintiff's failure to train or supervise claim. The court also held that plaintiff's evidence was insufficient to hold the police chief individually liable; there was no genuine issue of material fact that a plainly obvious consequence of the hiring decision would be the officer's unjustified use of deadly force; and the evidence failed to show the chief had notice that the officer's training and supervision were inadequate and likely to result in the use of excessive force. View "Perkins v. Hastings" on Justia Law

After the sheriff's department decided not to reinstate plaintiff, she filed suit against the county alleging retaliation and sex, pregnancy, and disability discrimination, in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), and the Nebraska Fair Employment Practice Act (NFEPA). The Eighth Circuit affirmed the district court's dismissal of her claims and held that her Title VII claim failed because she did not plead any facts showing that another candidate was similarly situated or went through a reinstatement process. Because her state claim mirrored her Title VII claim, it likewise failed. View "Jones v. Douglas County Sheriff's Department" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the City in an employment discrimination suit under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA). The court held that plaintiff was not entitled to return to the Senior Accountant position because he did not return to work prior to the expiration of his Family Medical Leave Act (FMLA) leave; there was no medical reason why plaintiff needed to be reinstated to his former position; and thus he failed to show that returning to his original position was a reasonable accommodation.The court also held that plaintiff's request that he be allowed to work from home was not a reasonable accommodation in light of his testimony that he could work at City Hall but that it "would have been easier" to work from home; plaintiff failed to make a facial showing that he could perform the essential functions of the job remotely; plaintiff failed to show that the City eliminated his position because of his disability or that the City terminated him because of his disability; there was no genuine issue of material fact that the City engaged in anything but a good-faith interactive dialogue; and his retaliation claim failed. View "Brunckhorst v. City of Oak Park Heights" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of petitioner's motion under 28 U.S.C. 2255 based on the one year statute of limitations period. The court held that it was reasonably debatable whether the holding in Johnson v. United States, 135 S. Ct. 2551 (2015), regarding the Armed Career Criminal Act extends to the former mandatory guidelines and thus petitioner could not benefit from a renewed limitations period under section 2255(f)(3). In this case, the right petitioner asserted: a right under the Due Process Clause to be sentenced without reference to the residual clause of USSG 4B1.2(a)(2) under the mandatory guidelines, was not dictated by Johnson. View "Mora-Higuera v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to correct his sentence under 28 U.S.C. 2255 because it was time-barred. The court held that the motion was untimely because Johnson v. United States, 135 S. Ct. 2551 (2015), did not newly recognize the right petitioner asserted: a right under the Due Process Clause to be sentenced without reference to the residual clause of USSG 4B1.2(a)(2) under the mandatory guidelines. View "Peden v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate, set aside or correct his sentence under 28 U.S.C. 2255. The court held that counsel's conflict did not adversely affect the adequacy of his representation of petitioner at trial; the district court did not clearly err in finding that counsel's strategy was reasonable in the circumstances, the evidence of petitioner's guilt was overwhelming, and alternative strategies petitioner proposed were not objectively reasonable; and petitioner failed to show that the conflict diminished counsel's credibility in the jury's eyes. The court also held that the district court did not clearly err by finding that counsel did not know that the funds at issue were stolen and that there was insufficient evidence to support a reasonable inference that petitioner knew, or should have known, that the funds at issue were illegitimate. Finally, the district court did not clearly err by finding that emails were insufficient to raise an inference that counsel was entangled with the conspiracy. View "Kiley v. United States" on Justia Law

Plaintiff appealed the district court's dismissal of her 42 U.S.C. 1983 action alleging that the City deprived her of her constitutional rights. Plaintiff's amended complaint alleged that she was arrested, her car was towed, and she was held at the police station until it was discovered that she had paid certain fines.The Eighth Circuit held that the district court erred because, whether or not the clerk had absolute or qualified immunity, that immunity did not foreclose an action against the City if the complaint adequately alleged an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee. Although the record has not been developed with respect to the clerk's duties and responsibilities, the source of the clerk's pay, or the degree that state or local officials exercised over the clerk, the court held that the complaint at least stated a plausible claim of wrongdoing. Therefore, the court remanded for further proceedings. View "Evans v. City of Helena-West Helena" on Justia Law

Plaintiffs filed a putative class action against the City, alleging several constitutional violations under 42 U.S.C. 1983 stemming from the City's alleged detention of plaintiffs for their inability to pay traffic fines. The City subsequently sought interlocutory review of the district court's denial of the City's motion to dismiss based on sovereign immunity. The Eighth Circuit dismissed the appeal for lack of jurisdiction because the City disclaimed any sovereign immunity for itself and sought only to invoke the sovereign immunity of a nonparty. View "Fant v. City of Ferguson" on Justia Law

Plaintiffs filed a class action against the State of Missouri and others, alleging that the state failed to meet its constitutional obligation to provide indigent defendants with meaningful representation. The Eighth Circuit reversed the district court's denial of the State and the governor's motion to dismiss based on sovereign immunity and legislative immunity.The court held that the Missouri Supreme Court would apply long-established principles to cases involving prospective equitable relief and hold that the state was immune; neither the statute nor the Missouri Constitution's general-enforcement provision make the governor an Ex parte Young defendant; to the extent plaintiffs claim that the governor's general enforcement authority and appointment authority were non-legislative acts that lead to a constitutional violation, the governor was subject to sovereign immunity for those acts because they did not satisfy Ex parte Young; and even if the governor's appropriation-reduction authority was not shielded by sovereign immunity through Ex parte Young, legislative immunity, a separate defense, foreclosed suit against the governor. View "Church v. Missouri" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against defendants after William Collin Spradling was shot and killed during an investigation. Plaintiff's action was filed outside the Arkansas statute of limitations. The court affirmed the district court's judgment and held that the limitations period was not equitable tolled because the undisputed facts placed plaintiff on objective notice of the need to investigate the shooting. In this case, a witness had informed plaintiff outlining inconsistencies she believed existed in the file and plaintiff did not file suit until after the limitations period had expired. View "Spradling v. Hastings" on Justia Law