Wilbert Glover v. Matt Bostrom, No. 20-2884 (8th Cir. 2022)
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Plaintiff alleges that while he was detained at a detention center, officers subjected him to severe racial harassment, including the use of racial epithets, multiple times per day. He filed several internal grievances, but each was rejected. Plaintiff alleges the grievances were rejected because of his race. Plaintiff challenges the district court’s grant of summary judgment to Defendants. He also argues that the court should have construed his pleadings to include claims for retaliation and violations of the Minnesota Human Rights Act.
Plaintiff argues that his summary judgment evidence and other evidence available in the record was sufficient to establish a genuine dispute of material fact. Plaintiff identifies three “buckets” of relevant evidence: (1) his counter-affidavits; (2) the internal grievance forms filed with the adult detention center; and (3) other non-summary judgment evidence available in the record.
The court found that the evidence does not raise a genuine dispute that either officer was personally involved in racial harassment or discrimination at the detention center. Plaintiff's statement fails to identify any direct or circumstantial evidence that would demonstrate the denial was racially motivated. Further, Plaintiff failed to obtain sworn testimony or documentary evidence asserting specific facts to help prove his claim. The court held that Plaintiff’s summary judgment evidence is insufficient to establish a genuine dispute of material fact that Defendants were personally involved in racial discrimination or harassment. Thus, Plaintiff cannot demonstrate that either officer’s conduct violated his Fourteenth Amendment rights, and both are entitled to qualified immunity
Court Description: [Kobes, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Civil case - Civil rights. In action alleging the two defendants violated plaintiff's civil rights by subjecting him to racial harassment and by denying his grievances dealing with other racial harassment he claimed he suffered while he was detained at the Ramsey County Detention Center, the district court did not err in finding the defendants were entitled to summary judgment; plaintiff's summary judgment evidence was insufficient to establish a genuine issue of material fact that either defendant was personally involved in racial discrimination or harassment at the detention center; as a result, plaintiff cannot establish that either officer's conduct violated his Fourteenth Amendment rights, and they are both entitled to qualified immunity; the district court did not address plaintiff's claims for retaliation and violation of the Minnesota Human Rights Act, and the matter is remanded for further development of those claims.
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