Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants in an action alleging claims under the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25. The court held that the district court properly dismissed plaintiff's claims against Defendant Kopp as untimely under the applicable statute of limitations; plaintiff failed to state a claim for direct municipal liability against Duluth because she failed to plead sufficient facts supporting an inference that the City knowingly allowed Kopp to access the database for any reason other than her official duties; and plaintiff failed to preserve any vicarious liability claim. View "Loeffler v. City of Duluth" on Justia Law

Patrolling I-30, Arkansas State Police Corporal Goodman stopped a Tornado bus for following too closely. Goodman regularly received High-Intensity Drug Trafficking Area summaries that reported seizures from Tornado buses; traffickers were storing drugs in unlabeled luggage. Goodman observed that bus driver was “pretty nervous” and said he was driving to Milwaukee from southern Texas while passenger manifest indicated the destination was Chicago. Goodman thought it suspicious that the company would undertake a costly cross-country trip with only four passengers. The driver consented to a search and opened doors to a luggage compartment. Goodman saw six bags with name tags plus “a black bag all by itself with no apparent markings" and no name tag. Goodman opened the black bag and reached inside, feeling what he believed was a false bottom. While trying to access the hidden compartment, Goodman saw a tag bearing Tuton’s name trapped beneath the bag’s collapsed handle. Goodman stopped searching, requested a canine unit, and questioned the passengers. Goodman testified that Tuton was “very nervous,” said his journey began in El Paso, and gave answers that “didn’t make sense.” Goodman did not ask Tuton for consent to search. About four minutes after Goodman requested the canine unit, Corporal Rapert arrived with his dog, Hemi. Hemi jumped into the luggage compartment and immediately showed behavioral changes. Rapert concluded Hemi had given a “profound alert,” but did not give a “final indication” on any bag. Rapert advised Goodman that Hemi’s behavior provided probable cause to search. Officers searched all the bags and, in Tuton’s, found eight pounds of cocaine under the false bottom. The Eighth Circuit affirmed the denial of Tuton’s motion to suppress. Discovery of the cocaine was not caused by Goodman’s prior unlawful search of the bag; Hemi’s sniff and alert were unaffected by that search. View "United States v. Tuton" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the United States and the Deputy U.S. Marshals in their individual and official capacities on plaintiff's claims for false arrest, false imprisonment, abuse of process, and assault and battery under the Federal Tort Claims Act (FTCA). In this case, plaintiff was mistakenly arrested when defendants were executing an arrest warrant for another individual. Applying Missouri tort law, the court held that none of plaintiff's proposed facts contradicted a material fact that the district court relied on in conducting its summary judgment analysis; the district court did not err in granting summary judgment on the false arrest and false imprisonment claim where plaintiff's arrest and 20-minute detention were justified; defendants were also entitled to summary judgment on plaintiff's claims for abuse of process; and the court's prior holding on qualified immunity was dispositive of plaintiff's assault and battery claim. View "Wright v. United States" on Justia Law

Under Missouri campaign finance law, chapter 130, a “campaign committee” is formed to receive contributions or make expenditures solely to support or oppose particular ballot measures, "such committee shall be formed no later than thirty days prior to the election for which the committee receives contributions or makes expenditures." Thirteen days before the November 2014 general election, a group formed MFA as a campaign committee, to accept contributions and make expenditures in support of Proposition 10. MFA sued to enjoin enforcement of the formation deadline, citing the First Amendment. The district court granted MFA a temporary restraining order. MFA received contributions and made expenditures before the election. After the election, MFA terminated as a campaign committee. The Eighth Circuit affirmed summary judgment in favor of MFA. While a formation deadline by itself might not expressly limit speech, the deadline here is more than a disclosure requirement because it prohibits (or significantly burdens) formation of a campaign committee, a requisite for legally engaging in speech, even if the individual or group is willing to comply with organizational and disclosure requirements. Even if the state’s interest in preventing circumvention of chapter 130’s disclosure regime is compelling, the formation deadline is unconstitutional because it is not narrowly tailored, given its burden on speech and its modest effect on preventing circumvention of the disclosure regime. View "Missourians for Fiscal Accountability v. Klahr" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Walmart in an action alleging employment discrimination. The court held that plaintiff failed to file a charge of discrimination with the EEOC within 180 days of the alleged Americans with Disabilities Act (ADA) violation. The court also held that plaintiff's failure to file his EEOC claim within 180 days was not the result of any misconduct by Walmart. In this case, failing to respond to a settlement demand made ten days before the statutory deadline, and accompanied by a statement that the employee would file a charge with the EEOC if the matter could not be settled, was not conduct that the employer should unmistakably have understood would cause the employee to miss the filing deadline. View "Rodriguez v. Wal-Mart Stores, Inc." on Justia Law

After plaintiffs were exonerated for the murder of Helen Wilson in 2008, they filed a 42 U.S.C. 1983 action, alleging that their arrests and imprisonment were the result of a reckless investigation and manufactured false evidence, as well as parallel conspiracy claims under 42 U.S.C. 1985. Plaintiffs were awarded approximately $28.1 million in damages. The Eighth Circuit held that it would not review or reverse its prior rulings as to whether Gage County could be held liable; the evidence was sufficient to support the jury's verdict finding Gage County liable; the facts developed at trial continued to support the district court's conclusion that the sheriff's deputies were not entitled to qualified immunity; the deputies conducted a reckless investigation and fabricated evidence; limited references to plaintiffs' innocence did not warrant a new trial in light of the curative actions and overwhelming evidence; and there was no error in the reckless investigation jury instruction. View "Dean v. Searcey" on Justia Law

Howard, the circuit court clerk, hired Mahn as a deputy clerk. In 2014, Howard did not run for reelection. He supported fellow Democrat McKee. According to Mahn, Howard “summoned [her]” to “forcefully impress upon [her] the need for her to vote for McKee and the Democratic ticket.” She responded, “what you’re threatening is unconstitutional.” Mahn voted in the Republican primary election. She alleges that three weeks later, Howard told her: “ I know how you voted ... this could cause you your job.” Weeks later, Howard terminated Mahn’s employment, citing: “Poor work performance, unable to complete tasks correctly and within given time lines. Abuse of sick leave, insubordination by lying to assigned supervisor.” Mahn alleges that Wesley—Howard’s son, the county clerk—had “access to all voter information.” Mahn brought a First Amendment patronage-discharge claim under 42 U.S.C. 1983 against Jefferson County, Missouri; Howard and Wesley, individually and in their official capacities; and Reuter, in his official capacity as (successor) circuit clerk. The district court rejected the claims on summary judgment. The Eighth Circuit affirmed with respect to Wesley and the county. Besides her speculation that Wesley told Howard how she voted, Mahn has not presented any evidence that he improperly influenced her termination. The court remanded in part. Howard and Reuter have not established Howard would have terminated Mahn anyway for her performance issues. View "Mahn v. Jefferson County" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to a prosecutor and judge in a civil rights action alleging that defendants conspired to deprive plaintiff of his constitutional rights during criminal proceedings related to a 1990 homicide. The court held that the prosecutor was entitled to absolute immunity because the only supported instances of misconduct occurred after he was appointed special prosecutor and were intimately associated with the judicial phase of the criminal process. Likewise, the judge was entitled to absolute judicial immunity as any evidence of alleged misconduct on his part related directly to his official role as a judge. View "Woodworth v. Hulshof" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiffs' 42 U.S.C. 1983 complaint as time-barred. The court held that plaintiffs' claims accrued in October 2011, when they were notified of the allegedly discriminatory decision to install the grinder systems instead of gravity systems at their residences. As such, the installation of the pumps and plaintiffs' continuing responsibility for the additional expenses they entailed, were delayed but inevitable consequences of that decision. Consequently, plaintiffs were on notice as of 2011 and their limitations period expired in October 2014. Therefore, plaintiffs' complaint was time-barred because they did not file this action until May 2016. View "Humphrey v. Eureka Gardens Public Facility Board" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiffs' Fourteenth Amendment and wrongful death claims, as well as plaintiffs' claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act (RA), 29 U.S.C. 701, et seq. Plaintiffs filed suit after Jereme Hartwig committed suicide by hanging himself with a bed sheet in his cell when he was confined at the St. Louis County Justice Center. The court held that plaintiffs failed to show that any defendant was deliberately indifferent to a substantial risk that Hartwig would commit suicide; the clinical psychologist's professional judgment, even if negligent, fell well short of deliberate indifference; the corrections officer's failure to recall the details of her monitoring at a deposition three years later did not create a genuine issue that she failed to conduct the hourly monitoring of inmates under the jail's suicide prevention policy; in regard to the Missouri wrongful death claim, the jailer performed her duties in accordance with the suicide prevention policy and did not breach a ministerial duty; and the ADA and Rehabilitation Act claims failed to state a claim. View "A.H. v. St. Louis County, Missouri" on Justia Law