Braun v. Burke, No. 19-2961 (8th Cir. 2020)
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After Cassandra Braun was killed in a high-speed police pursuit of a speeding vehicle, her mother filed a 42 U.S.C. 1983 action, alleging constitutional violations against the officer involved in the accident and his supervisor.
The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that the officer believed he was responding to an emergency, triggering the intent-to-harm standard. In this case, plaintiff failed to argue, much less present any evidence, that the officer intended to harm anyone. Therefore, the district court correctly granted summary judgment for the officer on plaintiff's substantive due process claim because she failed to establish a constitutional violation. Furthermore, the district court also rightly granted summary judgment for the supervisor where plaintiff's failure-to-train-or-supervise claim requires an underlying constitutional violation.
Court Description: [Gruender, Author, with Colloton and Grasz, Circuit Judges] Civil case - Civil rights. The state trooper involved in the crash with plaintiffs' decedent believed he was responding to a public safety emergency, thereby triggering the requirement that plaintiff must show intent to harm in order to establish liability; plaintiff did nor argue or present any evidence that the trooper intended to harm anyone, and the district court correctly granted summary judgment for the trooper on plaintiff's substantive due process claim because she failed to establish a constitutional violation; as a result, plaintiff's failure-to-train-or-supervise claim against defendant Director Bryant must also fail. Judge Colloton, concurring. Judge Grasz, concurring.
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