Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

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Plaintiff and eight others filed a class action against Anheuser-Busch under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs are participants in the Anheuser-Busch salaried employee pension plan and claim that they are entitled to enhanced pension benefits. At issue is the interpretation of Section 19.11(f) of the plan. Determining that it has jurisdiction over the appeal, the court concluded that Section 19.11(f) is unambiguous and agreed with the district court's adoption of the reasoning in the Sixth Circuit's case, Adams v. Anheuser-Busch Cos., that Section 19.11(f) entitled plaintiffs to enhanced benefits. Although the court affirmed on the merits, the court agreed with plaintiffs that the decision still must be reversed and remanded because the district court failed to make individual calculations of enhanced benefits owed to individual members of the class. Therefore, the court reversed and remanded with instructions to reconsider plaintiffs' prayer for relief and, to the extent requested and provable, calculate and award the benefits owed to plaintiffs by applying Section 19.11(f). The court noted that, upon remand, the district court may reconsider whether certain records will assist in its calculation of the requested benefits. View "Knowlton v. Anheuser-Busch" on Justia Law
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Defendant appealed his conviction for multiple crimes related to child pornography. The court concluded that the district court properly denied defendant's motion to suppress where law enforcement officials had probable cause to search defendant's residence because there was a fair probability that they would unearth evidence of the completed crime in defendant's possession at the time of the search; the district court did not abuse its discretion in admitting "downthemall" exhibits because the evidence was probative of the charged crimes where it indicated that plaintiff's knowledge of the Tor network and specifically how it could be utilized to access hidden child pornography websites; likewise, the district court did not abuse its discretion in admitting the Onion Pedo Video Archive evidence; the evidence was sufficient to support the jury's verdicts that he knowingly received, accessed with intent to view, and possessed child pornography; and the district court did not abuse its discretion in denying defendant's motion for a new trial. Accordingly, the court affirmed the judgment. View "United States v. Huyck" on Justia Law
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Defendant was civilly committed under 18 U.S.C. 4243 after he was found not guilty by reason of insanity of false personation of a federal officer. On appeal, defendant challenged the district court's order denying him discharge from a psychiatric hospital. The court concluded that the district court did not clearly err in determining that the proposed conditions of discharge did not sufficiently address the substantial risk that defendant would stop taking his medications, decompensate, and cause bodily harm or property damage. Accordingly, the court affirmed the judgment. View "United States v. Mikawa" on Justia Law
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Defendant pleaded guilty to one count of bank fraud and one count of money laundering. On appeal, the government challenged defendant's sentence of twelve months and one day of imprisonment on each count, to run concurrently. The court concluded that defendant violated the parties' plea agreement by arguing for a sentence below the range calculated under the Sentencing Guidelines. Because the breach was material, prejudicial, and not harmless, the court vacated and remanded for resentencing before a different judge. View "United States v. Swisshelm" on Justia Law
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Defendant pled guilty to possession of a firearm and was sentenced to 60 months in prison, followed by three years of supervised release. The court concluded that defendant's sentence was substantively reasonable where the district court considered the 18 U.S.C. 3553(a) factors. In this case, the district court carefully considered whether defendant had made an effort to improve his respect for the law given his criminal history, whether a sentence of imprisonment within the advisory Guidelines range would promote respect for the law, and whether a sentence of imprisonment within the advisory Guidelines range would adequately protect the public from defendant's future offenses. Accordingly, the court affirmed the judgment. View "United States v. Bacon" on Justia Law
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Defendant appealed the revocation of his supervised release and commitment to the Bureau of Prisons for 8 months followed by one year of supervised release. Defendant, while on a previous term of supervised release, left a voice mail soliciting his daughter to commit an assault on his behalf. The court concluded that the district court did not clearly err in finding these facts, taken together, show by a preponderance of the evidence that defendant violated a condition of his supervised release. Furthermore, defendant's 8 month term of imprisonment was substantively reasonable where the district court explicitly considered the 18 U.S.C. 3553(a) factors. Accordingly, the court affirmed the judgment. View "United States v. Petersen" on Justia Law
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Ramon Mendoza, a naturalized United States citizen, challenged the district court's grant of summary judgment for ICE agent Justin Osterberg, the County, the County employees, and Sheriff Davis on numerous claims based on an improper immigration detainer that was issued and later withdrawn. The detainer was withdrawn once Osterberg confirmed that Mendoza was not in fact Ramon Mendoza-Gutierrez, an aggravated felon. The court concluded that Osterberg had arguable probable cause to issue the ICE detainer and was entitled to qualified immunity on plaintiff's Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics claim; the sheriff was entitled to qualified immunity because he had no direct participation in the alleged violations; there was no violation of Mendoza's constitutional rights and the County employees are entitled to qualified immunity; the district court properly granted summary judgment for Sheriff Davis and the County on plaintiff's claims of supervisory and municipal liability under 42 U.S.C. 1983 where employees received instructive memorandum and on-the-job training; the actions in this case cannot reasonably be attributed to a defective governmental policy or custom; even if there were no policies or training on how to handle ICE detainers, there was no constitutional violation; there was no Fifth Amendment due process violation; and there was no evidence of defendants' conspiracy in violation of section 1984(3). Accordingly, the court affirmed the judgment. View "Mendoza v. Davis" on Justia Law

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Defendant was convicted of production of child pornography and was sentenced to 354 months in prison. On appeal, defendant challenged the denial of his motion to suppress the evidence and the district court's application of a sentencing enhancement under USSG 2251 based on his prior conviction for criminal sexual conduct in the fifth degree. The court concluded that the information used to establish probable cause was not stale where the warrant, issued eleven months after defendant took the photos of the victim, was not based on stale information; even if the affidavit was insufficient to establish probable cause, the Leon good-faith exception prevents suppression of the seized evidence; and the Government met its burden to show any error by the district court in applying the sentencing enhancement was harmless. Accordingly, the court affirmed the judgment. View "United States v. Johnson" on Justia Law
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Debtor challenges the district court's affirmance of the dismissal of its small business Chapter 11 bankruptcy. The court explained that the bankruptcy court's feasibility concerns would have existed even had debtor succeeded on its impairment-of-collateral argument. Even giving debtor the benefit of the impairment-of-collateral issue, the court found a sufficient basis in the record to defer to the bankruptcy court's "broad discretion" in determining whether a Chapter 11 case should be dismissed. In this case, the bankruptcy court noted primarily the issue of feasibility, that debtor's case had been pending for three years, and its failure to present a confirmable plan imposed substantial and continuing losses on its creditors. Accordingly, the court affirmed the judgment. View "Diwan, LLC v. Maha-Vishnu Corp." on Justia Law
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Plaintiff and his corporate entity, Marken, Inc., filed suit alleging that FedEx breached contractual duties, engaged in fraud, and violated North Dakota's Franchise Investment Law, N.D.C.C. 51-19-02(5)(a), and Racketeer Influenced and Corrupt Organizations (RICO) Act, N.D.C.C. 12.1-06.1-05. The district court dismissed the amended complaint. Determining that Pennsylvania law governs the construction of the Standard Operating Agreement (SOA) at issue, the court concluded that dismissal as to the first breach-of-contract claim was proper because the SOA had expired and the Independent Service Provider (ISP) Agreement governed the relationship between the parties. Furthermore, the plain text of the SOA foreclosed the claim. The court also concluded that plaintiff's second breach-of-contract claim was properly dismissed and rejected plaintiff's reading of the Background Statement of the SOA because plaintiff's reading ignores context and would lead to an absurd result. The court also concluded that plaintiff's fraud claims were properly dismissed because he failed to plead fraud with the specificity required by Rule 9(b); the district court properly dismissed the Franchise Investment Law claim because the amended complaint failed to plausibly allege that plaintiff was granted the right to offer or distribute services to customers; and plaintiff's state RICO claim was also properly dismissed because he failed to sufficiently plead facts for his fraud claims and Franchise Investment Law claim. Accordingly, the court affirmed the judgment. View "Neubauer v. FedEx" on Justia Law
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