Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against three state officials to challenge provisions of Missouri law that authorize roving stops of certain vehicles for inspection without suspicion. The Eighth Circuit held that plaintiff had standing to sue the superintendent, and his claims against her for injunctive and declaratory relief were not barred by the Eleventh Amendment; claims against the governor and the attorney general were properly dismissed, because there was no case or controversy between plaintiff and those officials; Mo. Rev. Stat. 304.230.1, .2, and .7 can be applied constitutionally to participants in the commercial trucking industry under New York v. Burger, 482 U.S. 691 (1987), and the provisions were not unconstitutional on their face; but it was error for the district court to dismiss plaintiff's as-applied claims against the superintendent for declaratory and injunctive relief based on the meaning of "person" under 42 U.S.C. 1983. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Calzone v. Hawley" on Justia Law

After her son was shot approximately 10 times and killed by the police, plaintiff filed suit against defendants, alleging excessive force and wrongful death under state law. The Eighth Circuit reversed the dismissal of the excessive force claims against the officers, holding that plaintiff demonstrated that there were at least two genuine disputes of material fact: (1) whether the officers saw plaintiff's son throw his gun and therefore knew he was unarmed, and (2) whether he was turning around to the officers with his hands raised to surrender. The court held, however, that there was insufficient evidence for a rational jury to conclude the officers acted with malice or in bad faith. Therefore, the court affirmed the grant of summary judgment and dismissal as to the wrongful death claims. The court reversed in all other respects and remanded. View "Wealot v. Brooks" on Justia Law

After the City revoked his rental licenses, plaintiff filed suit alleging that the City violated 42 U.S.C. 1983 by subjecting plaintiff to the deprivation of his rights, privileges, or immunities under the Fourth and Fourteenth Amendments to the United States Constitution. The Eighth Circuit affirmed the district court's grant of the City's motion for summary judgment on the Fourth and Fourteenth Amendment claims. The court held that plaintiff had not demonstrated, as a matter of law, that the City violated his substantive-due-process rights under the Fourteenth Amendment. The court also held that the City's conduct was not arbitrary, oppressive, and shocking to the conscience, and there was no genuine dispute of material fact regarding whether the City violated plaintiff's Fourth Amendment rights. In this case, plaintiff did not have a reasonable expectation of privacy in the common spaces entered by the City's police officers, and any argument that the police officers may have physically intruded on constitutionally protected areas by trespassing in his buildings to search for incriminating evidence was waived. View "Azam v. City of Columbia Heights" on Justia Law

North Dakota may enforce the suspend-and-reimburse provisions of N.D.C.C. 65-05-05(2). The Eighth Circuit held that the reimbursement provision readily passed rational basis scrutiny and was not subject to equal protection or substantive due process challenges. Furthermore, the cost and difficulty of recovering benefits paid during the suspension period were a rational basis for the suspension provision. The court also held that the suspension provision did not violate North Dakota's constitutional obligation to provide full faith and credit to Colorado's death benefits provision. Accordingly, the court affirmed the district court's judgment on the pleadings for WSI. View "DeCrow v. North Dakota Workforce Safety & Insurance Fund" on Justia Law

The State appealed the district court's grant of a preliminary injunction preventing the enforcement of an Arkansas statute requiring medication-abortion providers to contract with a physician who has hospital admitting privileges. The Eighth Circuit vacated the preliminary injunction, holding that the district court failed to make factual findings estimating the number of women burdened by the statute. On remand, the district court should conduct fact finding concerning the number of women unduly burdened by the contract-physician requirement and determine whether that number constitutes a "large fraction." View "Planned Parenthood of Arkansas & Eastern Oklahoma v. Jegley" on Justia Law

Plaintiff, Kenny Gurley's mother, filed suit alleging numerous federal and state law causes of action after Gurley was involved in a physical altercation with two officers and died. On appeal, the officers and the Board sought interlocutory review of the district court's grant in part and denial in part of summary judgment on the basis of state and federal immunity. The Eighth Circuit held that the officers were not entitled to qualified immunity on the 42 U.S.C. 1983 claims where the officers violated Gurley's constitutional right to be free from excessive force and the officers' actions were objectively unreasonable at the time. Furthermore, the officers were not entitled to official immunity on the state law claims where a jury could find that the officers acted with bad faith and malice. With respect to the Board, the court held that it was not entitled to qualified immunity on plaintiff's section 1983 claim. However, the Board was protected by sovereign immunity on the wrongful death claim. Accordingly, the court affirmed in part and reversed in part. View "Lancaster v. Board of Police Commissioners" on Justia Law

Plaintiff filed suit on behalf of her son, alleging that VICC's race-based, school-transfer policy violated the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff lacked standing because the mention of magnet schools and the generalized grievance about VICC's transfer policy for them was insufficient to allege an injury in fact. In this case, VICC had no administrative or supervisory authority over charter schools, which are independent public schools, governed by the state. Even if VICC's policy applied to charter schools, VICC still would not cause the son's injury because VICC does not make or adopt rules or regulations for charter schools. Because the son's injury was not fairly traceable to VICC, he lacked standing. View "E.L. v. Voluntary Interdistrict Choice Corporation" on Justia Law

Plaintiff, a commercial photographer, filed suit against the Village for injunctive and declaratory relief after the Village passed a municipal ordinance prohibiting all commercial activity in its neighborhood park without a permit. The Eighth Circuit affirmed the district court's denial of her Free Speech rights claims, holding that the ordinance met constitutional scrutiny as applied to plaintiff because it was content neutral, was narrowly tailored to serve the Village's significant government interests, left ample alternatives for her to communicate her message, and did not provide the Village with unbridled discretion. View "Josephine Havlak Photographer, Inc. v. Village of Twin Oaks" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against a former police officer, alleging that the officer violated plaintiff's constitutional rights by deliberately or recklessly giving partially inaccurate testimony in a probable cause hearing. After two prior remands, the district court found that the officer was entitled to qualified immunity. The Eighth Circuit held that, although a reasonable officer would know that it was unlawful to use deliberate or reckless falsehoods in a probable cause hearing, the officer here was entitled to qualified immunity. In this case, ample facts supported the issuance of the arrest warrant for plaintiff without the officer's inaccuracies. Accordingly, the court affirmed summary judgment and dismissal in favor of the officer. View "Odom v. Kaizer" on Justia Law

Plaintiff filed suit against five police officers, three prosecutors, the city of Columbia, and Boone County, alleging numerous violations of his constitutional rights arising from his encounters with police. The Eighth Circuit rejected defendant's argument that the district court erred by failing to transfer his recusal motions to another judge for decision; the district court did not err by denying the recusal motions on the merits because none of the facts singly or in combination would provide an objective, knowledgeable member of the public with a reasonable basis for doubting the judge's impartiality; and the district court did not err, in its thorough and well reasoned opinions, by granting motions to dismiss and summary judgment by defendants and denying plaintiff's motion for partial summary judgment. View "Akins v. Knight" on Justia Law