Justia Constitutional Law Opinion Summaries

Plaintiff filed suit alleging that the union had violated the Missouri Human Rights Act (MHRA) by failing to accommodate his disability, by discriminating against him based on his disability, and by retaliating against him for reporting his disability and seeking accommodation. The district court determined that the claims were preempted under section 301(a) of the Labor Management Relations Act (LMRA) and section 9(a) of the National Labor Relations Act (NLRA), and that the statute of limitations had expired on those federal claims. The Eighth Circuit held that, because plaintiff's state-law claims were not completely preempted by section 301(a) of the LMRA or section 9(a) of the NLRA, the district court lacked removal jurisdiction over this case. Accordingly, the court vacated and remanded. View "Markham v. Wertin" on Justia Law

Minnesota state law grants a child attending a nonpublic school the right to a free appropriate education (FAPE), as well as the right to dispute the provisions of special education services in an impartial due process hearing. In this case, R.M.M. and her parents have a right, under both state and federal law, to an impartial due process hearing to dispute the provision of a FAPE by MPS. Accordingly, the court affirmed the district court's judgment. View "Special School District No. 1 v. R.M.M." on Justia Law

The Eighth Circuit reversed the district court's adverse grant of summary judgment on plaintiff's employment claim alleging retaliatory termination. The court held that a reasonable jury could conclude that her protected action was the but-for cause of her termination. In this case, it was undisputed that plaintiff's letter complaining of unequal pay based on her sex was a protected act and that she suffered an adverse employment action. View "Donathan v. Oakley Grain, Inc." on Justia Law

Plaintiffs filed suits against Hiland Dairy, alleging race discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and Nebraska law. The Eighth Circuit held that, because plaintiffs failed to produce direct evidence of discrimination, the court must apply the McDonnell Douglas burden-shifting framework. Applying the framework, the court held that Hiland Dairy satisfied its burden by articulating and presenting evidence of a legitimate and indiscriminatory reason for firing them. In this case, Hiland Dairy cited "theft of time" and dishonest conduct as reasons for termination. The court rejected plaintiffs' claim that they were disciplined more severely than similarly-situated white employees because the reasons Hiland Dairy gave were significant and sufficient distinctions making the situations not similarly situated in all relevant respects. The court rejected plaintiffs' remaining contentions and affirmed the judgment. View "Edwards v. Hiland Roberts Dairy" on Justia Law

Plaintiffs filed suit challenging the City's heightened enforcement of housing and rental standards, arguing that there was a disparate impact on the availability of housing for individuals protected under the Fair Housing Act (FHA), 42 U.S.C. 3604(a). The Eighth Circuit held that plaintiffs failed to plead a prima facie case of disparate impact under the FHA. In this case, pursuant to Texas Department of Housing & Community Affairs v. Inclusive Communities Project, Inc., 135 S.Ct. 2507 (2015), plaintiff failed to, at the very least, point to an artificial, arbitrary, and unnecessary policy causing the problematic disparity. Accordingly, the court affirmed the district court's grant of the City's motion for judgment on the pleadings. View "Ellis v. City of Minneapolis" on Justia Law

Plaintiff, a former detainee at a detention center, filed suit against a former correctional officer, alleging that the officer violated plaintiff's constitutional rights by failing to protect him from a violent attack while he was detained. The Eighth Circuit held that the district court did not abuse its discretion by failing to admit evidence regarding the officer's resignation from the Center in lieu of accepting termination of his employment. The officer resigned after he was accused of passing a cigarette to an inmate in violation of institutional policy. In this case, plaintiff did not identify a permissible purpose for the resignation evidence under Federal Rule of Evidence 404(b) and the district court properly declined to allow inquiry about the incident under Rule 608(b). Accordingly, the court affirmed the judgment. View "Glaze v. Childs" on Justia Law

Plaintiffs filed suit against department of correction officers under 42 U.S.C. 1983 after their son died while in custody. In this appeal, defendants challenged a jury verdict in favor of plaintiffs. The Eighth Circuit affirmed the district court's denial of judgment as a matter of law, holding that the evidence was sufficient to support a reasonable inference sustaining the award of damages for pain and suffering. The court affirmed the denial of plaintiffs' motion for a new trial, holding that the close-observation policy in this case was ministerial and defendants were not entitled to official immunity; evidence of what medical staff thought but did not disclose was irrelevant and inadmissable; and defendants waived further evidentiary arguments. View "Letterman v. Lammers" on Justia Law

The Eighth Circuit affirmed the district court's application of a tort-reform act, the Nebraska Hospital Medical Liability Act, to reduce the verdict by 90% in a case where a jury awarded $17 million to a child born with severe brain damage. The court held that notice was not a requirement for qualification under the Act, but rather a requirement imposed on those already qualified; Bellevue did not lose the Act's protections even if it failed to properly post notice; and Nebraska's cap did not violate the Seventh Amendment right to a jury trial nor the Fifth Amendment; the child failed to show a denial of access to the courts; the Act did not violate the child's right to equal protection of the laws; and the district court did not err in rejecting the child's substantive due process challenge. The court affirmed the district court's denial of Bellevue's motion for a new trial and rejected Bellevue's challenges to the district court's jury instructions and verdict. View "S.S. v. Bellevue Medical Center" on Justia Law

Plaintiff filed suit against his former employer, Skybridge, alleging claims under federal and state law based on Skybridge's denial of a promotion and ultimate termination of plaintiff based on his age. The Eighth Circuit affirmed the district court's grant of summary judgment for Skybridge, holding that the CEO's statement that the company was looking for a "New Face" was facially and contextually neutral when made to plaintiff. Under the McDonnell Douglas burden-shifting analysis, Skybridge articulated legitimate, nondiscriminatory reasons for selecting another person over plaintiff for the CTO position and for ultimately terminating plaintiff. In this case, plaintiff's position as IT director of fulfillment became superfluous. The court rejected plaintiff's two remaining claims of intentional misrepresentation and negligent misrepresentation. View "Aulick v. Skybridge Americas, Inc." on Justia Law

The Brossarts filed suit against Deputy Sheriff Braathen, his supervisor, Sheriff Kelly Janke, and Nelson County, asserting federal claims under 42 U.S.C. 1983. The charges stemmed from confrontations at the Brossart family farmstead that extended over two days. The Eighth Circuit affirmed the grant of qualified immunity to Braathen and Janke on Rodney Brossart's excessive force claim where there was no Fourth Amendment violation, and even if Braathen's repeated use of a taser was unreasonable, it did not violate clearly established law; affirmed the dismissal of plaintiffs' claims that Deputy Braathen used constitutionally excessive force in tasing Rodney and Thomas Brossart; and rejected plaintiffs' claim for supervisory liability against Janke. The court also held that plaintiffs' failure to train claim against Nelson County was foreclosed by the court's conclusion that Braathen's tasing of Rodney and Thomas did not constitute excessive force; the absence of prior complaints to Nelson County of improper taser use meant there was no pattern of constitutional violations; and the state law claims were properly dismissed. Accordingly, the court affirmed the judgment in its entirety. View "Brossart v. Janke" on Justia Law