Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims of false arrest, excessive force, and denial of medical care. The court affirmed the district court's judgment and held that plaintiff failed to meet his burden of showing the necessity to disqualify the entire City of Lincoln Attorney's Office and thus the district court did not abuse its discretion by denying the motion to disqualify. The court also held that the district court did not err by granting qualified immunity to the officers and rejected plaintiff's claims of evidentiary errors. In this case, the false arrest claim failed because the officers had probable cause to arrest plaintiff for obstruction of justice; there were no genuine disputes of material fact regarding the excessive force claim; and the district court correctly dismissed plaintiff's claim against one of the officers from suit for denial of medical care. View "Awnings v. Fullerton" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the school district in an action under Section 504 of the Rehabilitation Act. The court held that, where parents refuse special education services for their child under the Individuals with Disabilities Education Act (IDEA) and bring suit under another act, they must first exhaust their administrative remedies under the IDEA if the relief they seek in the suit is also available under the IDEA. Therefore, because plaintiffs failed to exhaust their administrative remedies under the IDEA in this case, the school district was entitled to summary judgment. View "E. D. v. Palmyra R-I School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for defendants in an action alleging racial discrimination in violation of 42 U.S.C. 1981 and 1983, Title VI of the Civil Rights Act of 1964, and the Equal Protection Clause of the Fourteenth Amendment. The court held that, even assuming that plaintiff successfully stated a prima facie case of discrimination, she could not survive summary judgment because she failed to rebut the nondiscriminatory reasons defendants offered for their conduct. In this case, defendants offered legitimate, non-discriminatory reasons for the differing airport lease terms at issue where the airport needed flexibility in its redevelopment efforts, and was concerned over the physical state of plaintiff's building and whether a hobby shop was an FAA-approved aeronautical use. View "Lucke v. Solsvig" on Justia Law

The Eighth Circuit affirmed the district court's grant of qualified immunity to defendant, a jailer, in an action alleging excessive force under 42 U.S.C. 1983 and assault and battery under Iowa law. The court held that the district court did not err in determining that the jailer was entitled to qualified immunity on the excessive force claim during the booking procedure where the amount of force the jailer used was objectively reasonable in light of the need to maintain order and institutional security, and the jailer's reasonable belief that plaintiff posed a security threat. Likewise, the court held that the district court did not err in granting summary judgment on the state law claim where the amount of force was objectively reasonable. View "Parrish v. Dingman" on Justia Law

Plaintiff filed suit against his former employer for race and age discrimination under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act (ADEA), the Arkansas Civil Rights Act, and for promissory estoppel. The Eighth Circuit affirmed the district court's grant of the company's motion to strike portions of plaintiff's statement of material disputed facts and grant of summary judgment.The court held that the district court did not abuse its discretion in striking paragraphs of plaintiff's statement of material fact as unsupported by the record or irrelevant and immaterial; the district court properly granted the employer summary judgment on claims arising more than 180 days before plaintiff filed his EEOC charges; the district court properly granted the employer summary judgment on the failure to rehire claim because plaintiff took no action, never applied for reemployment, and believed he could not perform the duties of the position; the Arkansas Civil Rights Act claims were time-barred; and there was no factual basis for the promissory estoppel claim. View "Kirklin v. Joshen Paper & Packaging of Arkansas Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Cargill in an action alleging that the company discriminated against a former employee in violation of the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA). The court held that plaintiff failed to present direct and indirect evidence of disability discrimination; plaintiff was not a qualified individual protected by the ADA because she failed to demonstrate that at the time of her termination she could regularly and reliably attend work, an essential function of her employment; and the ADA's protections did not extend to providing plaintiff with her desired accommodation of more time off following her 194 days of unplanned absences. View "Lipp v. Cargill Meat Solutions Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRAThe court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed. View "Hustvet v. Allina Health System" on Justia Law

The Eighth Circuit affirmed the district court's order granting Steak 'n Shake's motion for summary judgment on plaintiff's Americans with Disabilities (ADA) discrimination claim and his Missouri Workers' Compensation claim. The court held that plaintiff failed to show that he was a qualified individual within the meaning of the ADA. In this case, although he believed that he could perform the essential job functions of a fountain operator, plaintiff's permanent medical restrictions barred him from performing the duties described in the job description. Likewise, plaintiff could not perform the duties of other positions he identified as alternative jobs. View "Denson v. Steak 'n Shake, Inc." on Justia Law

Blytheville police responded to a call. The suspect fled his vehicle on foot. A crowd gathered. While Officer Dannar was securing the scene, a man (Reddick) approached. Dannar told him to stop, stating, “the car, you’re not getting it.” Dannar later explained past experiences where persons who have no legitimate interest in a vehicle falsely claim ownership. Reddick did not remove his hands from his large, bulky coat pockets. Sgt. St. Laurent arrived and approached Reddick, who was standing slightly outside the crime scene with his hands in his pockets. St. Laurent thought Reddick was “evasive.” Reddick claimed not to have any identification on him. In response to St. Laurent's repeated requests to remove his hands from his pockets, Reddick would briefly comply but kept placing them back in his pockets. St. Laurent later testified that those carrying a weapon will frequently touch it. St. Laurent announced that he would pat Reddick down as a safety precaution and asked whether he had anything on him that an officer should know about. Reddick hesitated before saying, “No.” As Reddick turned around, his coat swung out, leading St. Laurent to believe that something of some substance was in Reddick’s pocket. St. Laurent found a .38 caliber revolver. The Eighth Circuit affirmed the denial of a motion to suppress and Reddick’s conviction as a felon in possession of a firearm. The officer conducted a valid “Terry” stop; the circumstances met the threshold minimal level of justification and supported the officers' reasonable suspicion that Reddick was engaged in criminal activity. View "United States v. Reddick" on Justia Law

Moore-Jones passed Arkansas State Trooper Quick’s marked police car. Quick checked and found her registration was expired and began a traffic stop, which was recorded on his dash-cam. Quick pulled behind Moore-Jones, activating his emergency lights, spotlight, and sirens at 8:23 p.m. She decelerated and pulled onto the shoulder, which was narrow and unlit. She returned to the road, accelerating to 35-38 MPH, her speed for the rest of the pursuit. The posted speed limit was 55 MPH. At 8:24, she continued past the last exit before the nearest city. After the exit, Quick began a Precision Immobilization Technique (PIT) maneuver, striking Moore-Jones's right-rear fender with his left-front bumper, causing her car to spin into a ditch, hitting a cement culvert. Moore-Jones and her child and were treated and released at a hospital. She was cited for expired tags and failure to yield to an emergency vehicle, both misdemeanors. She sued Quick for excessive force and assault and battery. The Eighth Circuit held that Quick is entitled to qualified immunity. The right to be free from a PIT maneuver in these circumstances was not sufficiently definite. From a reasonable officer’s perspective, Moore-Jones refused to comply with commands to pull over. At the time, Quick was justified in using some force to secure compliance. View "Moore-Jones v. Quick" on Justia Law