Justia Constitutional Law Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment as to plaintiff's excessive force claim against Deputy Sheriff Daniel Hallock. The court held that, based on the circumstances Hallock confronted upon arriving at the 101 Bar & Grill, his use of the arm-bar technique fell short of the level of force required to constitute a constitutional violation. In this case, Hallock was dispatched to that location in response to a report that a man had threatened to stab several patrons with a knife. Although plaintiff neither visibly possessed a weapon nor attempted to resist arrest prior to the takedown, a variety of factors suggested that the amount of force Hallock employed was reasonable under the circumstances. View "Vester v. Hallock" on Justia Law

Plaintiff filed suit against defendants for constitutional violations resulting from an encounter between Officer Wilson and Johnson. The Eighth Circuit affirmed the district court's denial of defendants' motion to dismiss based on qualified immunity. The court held that plaintiff sufficiently alleged that he was seized; that there was a violation of a constitutional right; and, at the time of the incident in this case, that the law was sufficiently clear to inform a reasonable officer that it was unlawful to use deadly force against nonviolent, suspected misdemeanants who were not fleeing or resisting arrest, posed little or no threat to the officer or public, did not receive verbal commands to stop, and whose only action was to stop walking when a police car blocked their path. Therefore, a reasonable officer in Officer Wilson's position would not have shot his gun and the district court correctly denied qualified immunity to Officer Wilson. Furthermore, the district court did not err by denying Chief Jackson qualified immunity and the court did not have jurisdiction to review the City's liability. The court dismissed the rest of the appeal for lack of jurisdiction. View "Johnson v. City of Ferguson" on Justia Law

Plaintiff filed suit against her former employer, alleging claims of discrimination and retaliation leading to wrongful termination. The Eighth Circuit rejected plaintiff's claim that the district court failed to consider her status as a pro se litigant; sovereign immunity barred plaintiff's claims under the Americans with Disabilities Act, the Age Discrimination in Employment Act; and 42 U.S.C. 1981 and 83; assuming that plaintiff met her burden of establishing a prima facie case of race and gender discrimination under Title VII, the university has offered a legitimate, nondiscriminatory reason for terminating her (failure to report for work and the need to fill her position); and plaintiff's claim of discrimination was rejected. Accordingly, the court affirmed the judgment of the district court. View "Bunch v. University of AR Board of Trustees" on Justia Law

Plaintiff filed suit against the school district, alleging that the district and others violated his due process rights by declining to renew his coaching contract solely on the basis of parental complaints. The Eighth Circuit affirmed the district court's grant of defendants' motion for judgment on the pleadings and dismissed the due process claims. The court held that the 2013 amendment to Minnesota Statue 122A.33 did not grant plaintiff a property interest in the renewal of his coaching contract. View "McGuire v. Independent School District No. 833" on Justia Law

Plaintiff, a former jail administrator, filed suit under 42 U.S.C. 1983 and the Peace Officer Discipline Procedures Act (PODPA), alleging claims related to his termination. The Eighth Circuit affirmed the district court's grant of summary judgment to the County and held that, regardless of whether plaintiff held a constitutionally protected interest in his employment, the process surrounding his termination satisfied the Due Process Clause. The court also held that plaintiff was not entitled to the additional protections of PODPA given his actual duties as Assistant Jail Administrator and given the fact that the County neither charged him with the duties of general law enforcement nor utilized his services for those purposes. View "Pena v. Kindler" on Justia Law

Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law

Plaintiff, an African American farmer, filed suit against the USDA and others, alleging racial discrimination, retaliation, and conspiracy regarding his loan applications, servicing requests, and the application of administrative offsets to collect on a defaulted loan. The district court dismissed the complaint with prejudice. The Eighth Circuit reversed the district court's conclusions that plaintiff's Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691 et seq., claims were barred by res judicata and collateral estoppel because the Office of the Assistant Secretary for Civil Rights could not bar subsequent federal litigation; the individual defendants have not demonstrated that plaintiff failed to state an ECOA claim against them where the complaint included sufficient allegations from which one could plausibly infer that the individual defendants qualified as creditors under the ECOA; the district court erred in dismissing plaintiff's Bivens claims against the individual defendants in their individual capacities because his constitutional claims were not barred by a comprehensive remedial scheme; and plaintiff failed to state a claim for conspiracy against the individual defendants. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Johnson v. Perdue" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity and dismissal of the City's appeal for lack of jurisdiction in an action alleging violation of plaintiff's civil rights after she was arrested for possession of methamphetamine. The court held that Officer Cotton violated no constitutional right by arresting plaintiff and was entitled to qualified immunity for the arrest; Officer Delezene was not entitled to qualified immunity because plaintiff's allegations were based on disputed material facts and thus summary judgment was not appropriate in this case; and the court lacked jurisdiction to hear the City's appeal. View "Manning v. Cotton" on Justia Law

Plaintiffs Combs and Williams, on behalf of themselves individually and others similarly situated, filed a race discrimination suit against several entities with the District. Plaintiffs alleged that defendants engaged in a pattern and practice of racial discrimination that interfered with the ability of African American men to patronize bar and restaurant establishments in the District. The district court granted summary judgment to all defendants. The Eighth Circuit held that Combs was not judicially estopped from certain claims because they had not been listed as assets in his bankruptcy petition, and thus the district court abused its discretion by applying judicial estoppel to claims involving Defendants Mosaic and Tango. On the merits, there was insufficient evidence to support a rabbit scheme at Maker's Mark and LiveBlock. Furthermore, summary judgment was properly granted to Defendant First Response because plaintiffs failed to establish that First Response employed the security guards who escorted Combs out of the LiveBlock. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Combs v. The Cordish Companies, Inc." on Justia Law

Plaintiff filed suit against Nebraska and others, alleging negligence, unlawful taking of property for public use under Nebraska law, and a deprivation of federal rights under 42 U.S.C. 1983, after his true name and picture mistakenly appeared on the Nebraska State Patrol's online sex offender registry. The Eighth Circuit held that even if plaintiff's pleading was sufficient to state a claim of negligence against defendants, his claim was barred by the two-year statute of limitations of the Nebraska State Tort Claims Act; plaintiff's claim of unlawful takings failed because he did not allege that any property was taken or damaged for public use; the district court properly dismissed under Rule 12(b)(1) the official-capacity claims and the claim against the State as they were pleaded; and the district court properly dismissed the section 1983 claims against the state employees in their individual capacities because a mistake or lack of due care by state employees in a particular circumstance did not establish invidious or irrational treatment that could violate the Equal Protection Clause. Accordingly, the court affirmed the judgment. View "Roe v. Nebraska" on Justia Law