Kroupa v. Nielsen, et al., No. 12-2843 (8th Cir. 2013)
Annotate this CaseAfter 15-year-old B.K. was barred from showing livestock at 4-H exhibitions, B.K.'s father filed suit under 42 U.S.C. 1983 against the unincorporated 4-H Association and two 4-H officials. The district court granted preliminary injunctive relief from the claimed denial of B.K.'s constitutional right to procedural due process. The court inferred that 4-H membership and participation was a "right or status" open to all South Dakota children interested in a career in agriculture, subject to reasonable, non-discriminatory terms; the record clearly demonstrated that the ban deprived B.K. of the opportunity to participate in a public program that was important to her education and career development and from which she obtained significant personal income; and, therefore, the district court did not abuse its discretion in concluding that B.K. had a fair chance of proving that defendants published a defamatory ruling that deprived her of a right or status conferred by state law and that she was entitled to the constitutional protection of the Due Process Clause. Further, B.K. was not afforded minimal procedural due process protection; there was a sufficient showing of the threat of irreparable injury; and the balance of the equities and the public interest supported the issuance of the injunction. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Injunctions. In action alleging defendants violated plaintiff's daughter's civil rights by barring her from further showing of livestock at 4-H exhibitions based on a decision that she had misrepresented the ownership of her winning swine entry at the 2011 South Dakota State Fair, the district court did not err in granting plaintiff injunctive relief as plaintiff established: (1) a likelihood of the success on the merits of the claim that the daughter had a protected liberty or property interest in protecting her reputation, her immediate interest in training livestock and winning prizes and her future interest in a career in agriculture and (2)that defendants' actions had deprived her of those interests without due process; further, the district court did not err in finding a threat of irreparable injury, particularly to the girl's reputation, and that the balance of the equities and the public interest both supported the issuance of the injunction. Judge Bye, dissenting.
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