Notable Opinions: Week of April 6, 2026

Excessive Force

Plaintiff appealed summary judgment for defendants after being struck by a foam projectile while observing a protest. When protesters threw objects at officers, an officer fired into the crowd but could not see plaintiff, who was obstructed from view. Plaintiff sued under §1983, alleging excessive force and First Amendment retaliation. The district court held that no reasonable jury could find the officer intended to shoot or restrain plaintiff. Because the officer never saw plaintiff, the Fourth Amendment claim failed, and plaintiff could not show his protected activity was the but‑for cause of the use of force. The judgment was affirmed.

Leask v. City of Minneapolis (8th Circuit)

Public School Libraries

Defendants appealed a preliminary injunction blocking enforcement of an Iowa law requiring public school libraries to remove books containing descriptions or depictions of sex acts. The district court held that no single First Amendment standard governed school restrictions and applied the obscenity and substantial government interest tests, finding plaintiffs likely to succeed. It nevertheless acknowledged that under the standard allowing restrictions reasonably related to legitimate pedagogical concerns, legislators could prohibit sexual content. Because school libraries are part of the curriculum, the appellate court held that the district court applied the wrong standard. The law addressed legitimate pedagogical concerns and sufficiently defined restricted materials. The judgment was vacated and remanded.

Penguin Random House, LLC v. Robbins (8th Circuit)

Vulnerable Adult

Appellant challenged a district court order affirming a DHS commissioner’s decision disqualifying her from certain employment for seven years after finding that she seriously maltreated a vulnerable adult. Appellant argued the determination violated her procedural due process rights because it relied on hearsay and lacked substantial evidence. The Court of Appeals rejected these arguments, concluding that DHS’s failure to subpoena a coworker did not deny appellant an opportunity to cross‑examine witnesses. The commissioner did not abuse discretion by relying in part on hearsay evidence. Appellant failed to show any due process violation. The decision was affirmed.

Reynolds v. Gandhi (Court of Appeals)

See all of the week’s Opinion Digests for the Minnesota Supreme Court, Court of Appeals and the 8th Circuit here.