Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's denial of defendants' request to reconsider its previous denial of their motion for summary judgment based on qualified immunity. In this case, an inmate at the ADC filed suit against defendants, alleging deliberate indifference to his painful dental condition. Because defendants did not timely appeal the district court's denial of summary judgment, the court only had jurisdiction to review the district court's order denying reconsideration under Rule 60(b). The court held that the district court did not abuse its discretion in denying the reconsideration under Rule 60(b) where, unlike the defendants in Cullor v. Baldwin, 830 F.3d 830 (8th Cir. 2016), the defendants here have not shown that they tried to get plaintiff treatment after they were alerted to his condition. The court held that defendants were constitutionally obligated to see that the inmates in their custody who need dental care receive it and were deliberately indifferent to plaintiff's serious dental condition. View "Williams v. York" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner after he was convicted of raping an adult woman with the mental capacity of a young child and sentenced to seventy years in prison as a habitual offender. The court held that, under Arkansas law, parole-eligibility determinations by the Department of Corrections did not constitute a modification of a prison sentence. Therefore, trial counsel's deficient performance in this case did not deprive petitioner of a due process claim that Ark. Code Ann. 16-93-609(b) should not apply when the jury, court, and defendant were unaware of the Act and did not intend for the Act to apply to the judgment. Although the state court improperly instructed the jury that petitioner would be eligible for parole after serving 70% of his sentence if sentenced to a term of years, petitioner was not prejudiced under Strickland v. Washington when his trial counsel failed to correct the error. View "Stewart v. Kelley" on Justia Law

The Eighth Circuit granted rehearing en banc and vacated the panel opinion in Faidley v. United Parcel Serv. of Am., Inc., 853 F.3d 447 (8th Cir. 2017).The court affirmed the district court's grant of summary judgment for UPS in an action alleging that UPS violated the Iowa Civil Rights Act (ICRA) when it placed him on medical leave from his long time position as a package car driver and then failed to reasonably accommodate his physical disability. The court held that UPS did not violate the Americans with Disabilities Act (ADA) or ICRA by refusing plaintiff's request for an eight-hour work day because that accommodation would have made him unqualified to perform the essential job functions of a package car driver. The court also held that no reasonable jury could find that UPS's decision to instead pursue reassignment to full-time jobs which plaintiff had suggested, and for which he was immediately qualified, was disability discrimination; UPS did not violate the ADA when it refused to accommodate an expert's restrictions of working certain hours per day; and a reasonable jury could not find that UPS acted in bad faith. View "Faidley v. United Parcel Service" on Justia Law

The Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment based on qualified immunity and state statutory immunity. Plaintiff had filed suit against defendant and others, alleging claims under 42 U.S.C. 1983 for deliberate conduct that shocks the conscience and a state law claim for outrage. The court held that plaintiff failed to demonstrate sufficient facts to give rise to a triable question as to an alleged violation of a constitutional right. In this case, while law enforcement corruptly conducting an investigation with a view towards presenting knowingly false charges against an innocent person might well represent an instance of conscience-shocking behavior, plaintiff has not presented any evidence beyond surmise that would allow a reasonable finder of fact to conclude that this happened. Therefore, the district court erred in denying qualified immunity to defendant. Likewise, plaintiff's state law claim failed for the same reasons as the federal claim. The district court did not err in denying summary judgment for defendant on the ground of state statutory immunity. View "Williams v. Mannis" on Justia Law

The Eighth Circuit affirmed the district court's ruling that the City was not immune from a 42 U.S.C. 1983 suit in a putative class action alleging that the City's policy or custom of automatically issuing arrest warrants was unconstitutional. In this case, the City automatically issues an arrest warrant whenever someone ticketed for violating its traffic and vehicle laws fails to pay a fine or appear in court. The court held that municipalities, unlike States, did not enjoy a constitutionally protected immunity from suit under the Eleventh Amendment; the court rejected the City's contention that it enacted or maintained the contested practices as an arm of the State; and the court rejected the City's contention that it was also immune from suit since all of the individuals the complaint identified as participating in the contested practices were personally immune from suit. The court has long held that a municipality may be held liable for its unconstitutional policy or custom even when no official has been found personally liable for his conduct under the policy or custom. View "Webb v. City of Maplewood" on Justia Law

Plaintiff filed suit alleging that he was improperly rejected for the position of Criminal Investigator with the USPS in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and that he should have been given preference for the position due to his status as a veteran. The district court granted the Postmaster General’s motion to dismiss the action under Federal Rule of Civil Procedure 12(b)(6). The Eighth Circuit held that the district court erred in dismissing the ADEA claim because plaintiff alleged a prima facie case of discrimination where he demonstrated that he had the educational and professional experience required for the position. Accordingly, the court reversed as to the ADEA claim and remanded for further proceedings. The court affirmed in all other respects. View "McPherson v. Brennan" on Justia Law

Defendant was committed to the custody of the Missouri Department of Mental Health for treatment after he was found not guilty by reason of insanity under Missouri state law when he fired shots in the direction of two officers. Plaintiff filed a 42 U.S.C. 1983 action against defendants, alleging that he had been deprived of his substantive due process right to liberty during his in-patient commitment as well as during his period of conditional release. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants based on qualified immunity, holding that the evidence viewed in the light most favorable to plaintiff did not show that defendants' actions "shocked the conscience." In this case, plaintiff gave no reason to believe any medical opinion was offered in bad faith and the evidence did not suggest that any of defendants' representations to the circuit court were inspired by malice or otherwise untruthful. Furthermore, the ultimate decision to grant release lay with the circuit court and it repeatedly declined to grant release. View "Andrews v. Schafer" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an age discrimination claim. The court held that the district court did not abuse its discretion in deciding not to admit a Department of Corrections internal investigation report because plaintiff was allowed to elicit the content of the report during her questioning of the Warden and providing the report to the jury would have added little beyond the information already in evidence. Therefore, plaintiff failed to establish reversible error in how the district court handled this evidentiary issue. View "Parker v. Arkansas Department of Correction" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss an action filed by plaintiff, challenging the termination of his employment from the University. The court held that plaintiff's speech stemmed from his professional responsibilities and was made in furtherance of those responsibilities, and was therefore not protected under the First Amendment; the pre- and post-termination procedures did not violate plaintiff's Fourteenth Amendment due process rights; plaintiff failed to establish a substantive due process claim because he failed to show that the University President's decision to terminate him was both conscience shocking and in violation of one or more fundamental rights; the district court properly dismissed the individual capacity claims against the University President based on qualified immunity; and the district court properly dismissed the claims against defendants in their official capacity. View "Groenewold v. Kelley" on Justia Law

Plaintiff filed a class action against Harne defendants under 42 U.S.C. 1983, alleging that the State's failure to share annual payments under a Settlement Agreement, where Minnesota released and forever discharged tobacco companies from claims that they violated state consumer protection statutes in exchange for substantial period payments, constituted a taking in violation of the Fifth Amendment. The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss, holding that res judicata barred the claim. In this case, plaintiff's takings claim in federal court was identical to the federal takings claims asserted in Harne v. State, No. A14-1985, 2015 WL 4523895; Harne involved the same parties; under Minnesota law, the dismissal of the claims in Harne as time-barred was a final judgment on the merits; and plaintiff and Harne actually litigated their federal claims in Harne. View "Foster v. Minnesota" on Justia Law