Justia Constitutional Law Opinion Summaries

Plaintiffs filed suit against defendant, a police officer, after the officer shot and killed Marilyn Denise Ambrose-Boyd during a welfare check. The Eighth Circuit affirmed the district court's grant of summary judgment, holding that the officer was entitled to qualified immunity on the 42 U.S.C. 1983 claims where the officer's use of deadly force was objectively reasonable. In this case, the officer went to Ambrose-Boyd's home after receiving a 911 call report that she was home alone, suicidal, and had a gun. Furthermore, Ambrose-Boyd failed to respond to commands to drop her weapon and raised her gun to another officer's shin level. The court also held that the police chief and the city could not be liable because the officer acted reasonably. View "Rogers v. King" on Justia Law

Plaintiffs filed suit against defendant, a police officer, after the officer shot and killed Marilyn Denise Ambrose-Boyd during a welfare check. The Eighth Circuit affirmed the district court's grant of summary judgment, holding that the officer was entitled to qualified immunity on the 42 U.S.C. 1983 claims where the officer's use of deadly force was objectively reasonable. In this case, the officer went to Ambrose-Boyd's home after receiving a 911 call report that she was home alone, suicidal, and had a gun. Furthermore, Ambrose-Boyd failed to respond to commands to drop her weapon and raised her gun to another officer's shin level. The court also held that the police chief and the city could not be liable because the officer acted reasonably. View "Rogers v. King" on Justia Law

Plaintiffs, Eric Wong and the Disability Support Alliance (DSA), filed suit against Heartwood, alleging public accommodation violations of Title III of the Americans with Disabilities Act (ADA), and the Minnesota Human Rights Act (MHRA), and a "bias offense" that entitled them to recover damages and injunctive relief under Minnesota Statutes 611A.79. The Eighth Circuit held that Wong made a sufficient showing of actual injury for Article III standing; Heartwood more than satisfied any applicable burden of production when it submitted with its motion for summary judgment detailed evidence showing that removal of its access barriers was not readily achievable; and thus the district court did not err in granting Heartwood summary judgment dismissing Wong's Title III claim on the merits. The court also held that the district court properly granted summary judgment dismissing Wong's state claim. Because Heartwood did not violate the MHRA, the district court also properly dismissed this claim. View "Disability Support Alliance v. Heartwood Enterprises, LLC" on Justia Law

Plaintiffs, Eric Wong and the Disability Support Alliance (DSA), filed suit against Heartwood, alleging public accommodation violations of Title III of the Americans with Disabilities Act (ADA), and the Minnesota Human Rights Act (MHRA), and a "bias offense" that entitled them to recover damages and injunctive relief under Minnesota Statutes 611A.79. The Eighth Circuit held that Wong made a sufficient showing of actual injury for Article III standing; Heartwood more than satisfied any applicable burden of production when it submitted with its motion for summary judgment detailed evidence showing that removal of its access barriers was not readily achievable; and thus the district court did not err in granting Heartwood summary judgment dismissing Wong's Title III claim on the merits. The court also held that the district court properly granted summary judgment dismissing Wong's state claim. Because Heartwood did not violate the MHRA, the district court also properly dismissed this claim. View "Disability Support Alliance v. Heartwood Enterprises, LLC" on Justia Law

Plaintiff, an inmate at a correctional center, filed suit against two officers under 42 U.S.C. 1983 for failure to protect in violation of the Eighth Amendment. The jury found for the officers and plaintiff appealed. The court assumed without deciding that plaintiff's offer of proof sufficiently preserved the issue of whether the district court should have allowed cross-examination a corrections guard about a disciplinary report about the guard. The court held that the district court did not abuse its discretion in refusing to permit the cross-examination because the probative value of the evidence was low, and the danger of unfair prejudice and a "mini-trial" was great. The court also held that the district court did not plainly err in admitting evidence of the second incident, which was less probative than the first and similarly risked unfair prejudice and confusion of the issues. Finally, the district court did not abuse its discretion in admitting testimony about plaintiff's aggressive behavior toward cellmates where any error was harmless. View "Walker v. White" on Justia Law

The Eighth Circuit affirmed the district court's denial of intervenor's motion to unseal certain judicial records. The underlying litigation involved an omnibus Eighth Amendment challenge to Missouri's execution protocol where state government agencies filed documents under seal in order to be able to carry out executions. The court held that, under common law, the district court did not abuse its discretion in deciding that the documents at issue should remain sealed and that there was not way to redact the information to preserve certain identities. The court also held that intervenor has not established a First Amendment right to unseal the information where there was no historic tradition of accessibility, and public access to the documents in the instant case would not play a significant positive role in the function of Missouri's execution protocol. Finally, the court held that the district court did not abuse its discretion in electing to review the supplemental briefing in camera, and denying intervenor's subsequent request to review it. View "Flynt v. Lombardi" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment in favor of defendant, a police officer, in a 42 U.S.C. 1983 action. The court held that the district court erred in granting summary judgment on the ground that plaintiff brought his claims against the officer in his official capacity only. In this case, the officer acquiesced in an unexpressed motion to amend the complaint to include individual-capacity claims against him, that a formal motion to so amend the complaint was not necessary, and that the complaint was correspondingly amended. View "Stephens v. Jessup" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment in favor of defendant, a police officer, in a 42 U.S.C. 1983 action. The court held that the district court erred in granting summary judgment on the ground that plaintiff brought his claims against the officer in his official capacity only. In this case, the officer acquiesced in an unexpressed motion to amend the complaint to include individual-capacity claims against him, that a formal motion to so amend the complaint was not necessary, and that the complaint was correspondingly amended. View "Stephens v. Jessup" on Justia Law

Russell Bucklew was sentenced to death after being convicted of murder, kidnapping, and rape. At issue on appeal was whether the Eighth and Fourteenth Amendments, as applied, barred Missouri officials from employing a procedure that was authorized by Missouri statute to execute Bucklew. The Eighth Circuit held that the summary judgment record contained no basis to conclude that Bucklew's risk of severe pain would be substantially reduced by use of nitrogen hypoxia instead of lethal injection as the method of execution. Therefore, Bucklew failed to establish the second prong of the Glossip/Baze standard. In this case, Bucklew failed to establish that lethal injection, as applied to him, constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments. Finally, the district court did not err in denying Bucklew's requests for discovery relating to two members of the lethal injection execution team. View "Bucklew v. Precythe" on Justia Law

Russell Bucklew was sentenced to death after being convicted of murder, kidnapping, and rape. At issue on appeal was whether the Eighth and Fourteenth Amendments, as applied, barred Missouri officials from employing a procedure that was authorized by Missouri statute to execute Bucklew. The Eighth Circuit held that the summary judgment record contained no basis to conclude that Bucklew's risk of severe pain would be substantially reduced by use of nitrogen hypoxia instead of lethal injection as the method of execution. Therefore, Bucklew failed to establish the second prong of the Glossip/Baze standard. In this case, Bucklew failed to establish that lethal injection, as applied to him, constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments. Finally, the district court did not err in denying Bucklew's requests for discovery relating to two members of the lethal injection execution team. View "Bucklew v. Precythe" on Justia Law