Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against defendants, alleging claims under 42 U.S.C. 1983 for use of excessive force, unreasonable search and seizure based on his arrest, failure to protect, conspiracy to deprive him of constitutional rights, unconstitutional policy, procedure, or widespread practice, and danger creation. The Eighth Circuit affirmed the district court's order granting the motion to dismiss by individual defendants where plaintiff made no allegations that these defendants had knowledge of unconstitutional acts by subordinates nor did he make any allegations from which such knowledge could be inferred. Furthermore, the district court previously dismissed the same claims on the grounds that they were conclusory and not supported by factual allegations. The court also held that the district court did not err in granting summary judgment to other defendants, named only in their official capacities, and in concluding the record lacked sufficient facts necessary to impose liability on a municipality. View "Mick v. Raines" on Justia Law

The guardian of John Raines IV's estate filed suit against defendants after Raines was shot at twenty-one times and became paralyzed from his gunshot injuries. The Eighth Circuit dismissed defendants' appeal from the district court's denial of summary judgment based on qualified immunity. The court held that, while it had jurisdiction to determine whether conduct constituted a violation of clearly established law, it lacked jurisdiction to determine whether evidence could support a finding that a particular conduct occurred at all. In this case, whether the officers reasonably believed Raines posed a sufficient threat depended on what occurred, and the district court was unable to make this determination based on the evidence presented. Therefore, the court lacked jurisdiction to determine the key factual question about whether Raines advanced on the officer just before being shot. View "Raines v. Burningham" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to defendant with respect to his Arkansas arson conviction. The court found that trial counsel's choice not to challenge a fire investigator's testimony regarding whether defendant was a suspect in a home fire investigation did not render counsel's performance deficient. In this case, the fire marshal did not testify that defendant caused the fire, but rather that he developed defendant as a suspect based on his investigation. The court explained that the testimony was not unfounded speculation nor did it improperly usurp the providence of the jury. Furthermore, even if counsel's performance were deficient, defendant failed to establish prejudice. View "Booth v. Kelley" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint that alleged claims related to his termination from the police department. The court held that plaintiff's retaliation claim, on its face, was outside the bounds of the Title VII statute; nothing in plaintiff's complaint or his deposition testimony indicated that he was pursuing a Title VII claim encompassing race-based discrimination and thus he could not submit a claim via an affidavit at the summary judgment stage; and the district court correctly dismissed plaintiff's contract claim where the strain of public policy that plaintiff sought to invoke was simply inapposite to the facts in this case. View "Winfrey v. Forrest City, Arkansas" on Justia Law

The Eighth Circuit reversed the district court's order denying defendant's motion for summary judgment based on qualified immunity. The court held that defendant, a building inspector, did not need probable cause to enter a building in search of building code violations because he received voluntary consent to enter. Therefore, a reasonable official in defendant's position would have not have known that he was violating the constitution when he searched plaintiffs' house after receiving signed consent to do so in the particular circumstances. View "Estate of Leon Walker, Jr. v. Wallace" on Justia Law

The Eighth Circuit vacated the district court's order determining that petitioner's one-year statute of limitations for his habeas petition should be equitably tolled. As a preliminary matter, the court held that the district court's decision was final and appealable. On the merits, the court held that petitioner was not entitled to equitable tolling because he did not demonstrate reasonable diligence during the limitations period. The court reasoned that, even assuming that discussion at the hearing in April 2008 might have led petitioner to believe that an appellate court would appoint counsel for him, a reasonably diligent prisoner should have done something thereafter to protect his rights. View "Burks v. Kelley" on Justia Law

The Eighth Circuit vacated the district court's order determining that petitioner's one-year statute of limitations for his habeas petition should be equitably tolled. As a preliminary matter, the court held that the district court's decision was final and appealable. On the merits, the court held that petitioner was not entitled to equitable tolling because he did not demonstrate reasonable diligence during the limitations period. The court reasoned that, even assuming that discussion at the hearing in April 2008 might have led petitioner to believe that an appellate court would appoint counsel for him, a reasonably diligent prisoner should have done something thereafter to protect his rights. View "Burks v. Kelley" on Justia Law

A public employee cannot be terminated for making protected statements during a campaign for public office where that speech has no demonstrated impact on the efficiency of office operations. The Eighth Circuit affirmed defendant's motion for summary judgment based on qualified immunity in an action alleging that defendant terminated plaintiff's employment as a deputy in the Sheriff's Office for statements plaintiff made during an election campaign. The court held that plaintiff's statements were made as a citizen on matters of public concern; defendant failed to show an adequate justification for his actions, and thus plaintiff's speech was protected by the First Amendment; and defendant was not entitled to qualified immunity where defendant's termination of plaintiff violated a right secured by the First Amendment and that right was clearly established at the time of the termination. View "Morgan v. Robinson" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's application for a writ of habeas corpus. Assuming that petitioner enjoyed a constitutional right to choose counsel whom his parents could afford to retain, and that clearly established law precluded an arbitrary denial of a motion to continue that was designed to facilitate that choice of counsel, petitioner could not demonstrate that he was entitled to relief. In this case, the decision of the Arkansas courts was within the range of reasonableness. The court explained that without an identified counsel of choice and a proposed trial date, the benefits of a continuance were too speculative to show the denial of a clearly established right. View "Daniels v. Kelley" on Justia Law

Plaintiffs filed suit against the superintendent of the school district under Section 504 of the Rehabilitation Act, 29 U.S.C. 794, after their son committed suicide, alleging that the school had discriminated against their son on the basis of disability by failing to adequately protect him from being bullied by other students. The Eighth Circuit affirmed the district court's grant of summary judgment for defendant, holding that there was nothing in the record to establish that school officials knew of any specific instance of bullying before the son's death, aside from an October 7 altercation, which the school district responded to immediately and there were no further issues. Even crediting the evidence discovered after the son's death that he was being harassed at school, there was no evidence that the school district knew or even should have known about it. The court further held that, even under the deliberate indifference standard, plaintiffs failed to meet the standard articulated by the Supreme Court in Davis v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (1999). Finally, there was no authority for plaintiffs' claim that a school district can discriminate against a disabled student in violation of Section 504 after his death by failing to investigate harassment that might have occurred before he died. View "Barnwell v. Watson" on Justia Law