Business Leaders In Christ v. The University of Iowa, No. 19-1696 (8th Cir. 2021)
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Business Leaders in Christ filed suit against the University and others, alleging that the University defendants violated its First Amendment rights through the application of the University's Policy on Human Rights. This action arose from the University's investigation of Business Leaders' refusal to allow a gay member to become an officer in the religious organization. The district court held that the University defendants violated Business Leaders' First Amendment rights to free speech, expressive association, and free exercise of religion; granted Business Leaders permanent injunctive relief and thus prohibited the University defendants from enforcing the Policy against Business Leaders under certain conditions; but granted qualified immunity to the individual defendants on Business Leaders' money damages claims.
The Eighth Circuit affirmed in part, reversed in part, and remanded for further proceedings. The court held that the district court erred in granting qualified immunity to the individual defendants on Business Leaders' free-speech and expressive-association claims. In this case, the law was clearly established at the time the individual defendants acted that the University's recognition of registered student organizations constituted a limited public forum, that the university may not discriminate on the basis of viewpoint in a limited public forum, and that Business Leaders had a right not to be subjected to viewpoint discrimination while speaking in the University's limited public forum. However, the district court correctly granted qualified immunity to the individual defendants on Business Leaders' free-exercise claim, because the law was not clearly established at the time that the individual defendants' violated Business Leaders' free-exercise rights.
Court Description: [Smith, Author, with Benton and Kobes, Circuit Judges] Civil case - Civil rights. In action alleging defendants violated the plaintiff's constitutional rights through selective enforcement of the University's Human Rights Policy, the district court granted the plaintiff's motion for summary judgment on its free-speech, free-association, and free-exercise claims and entered a permanent injunction prohibiting the University defendants from enforcing the policy against plaintiff in certain conditions; the court granted qualified immunity to the individual defendants on plaintiff's money-damages claim, concluding that the law on on free speech, expressive association and free exercise of religion was not clearly established; plaintiff appeals. Held: the district court erred in granting qualified immunity to the individual defendants on plaintiff's free-speech and expressive-association claims; it correctly granted the individual defendants qualified immunity on plaintiff's free-exercise claim. Affirmed in part, reversed in part and remanded for further proceedings. Judge Kobes, concurring in part, and dissenting in part.
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