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

The defendant was charged with conspiracy to possess with intent to distribute and distribute 500 grams or more of methamphetamine, a violation of federal law. He entered into a written plea agreement, in which he acknowledged understanding the nature and elements of the charge, agreed he was guilty, and specifically waived his right to appeal except for limited circumstances. During the plea colloquy, the district court confirmed the defendant’s understanding of the plea and the appeal waiver, and reviewed the drug quantity at issue. The defendant and his counsel reserved the right to object to specific drug amounts attributable to him, but agreed there was a sufficient factual basis for the essential elements of the crime, including responsibility for at least 500 grams of methamphetamine.After entering his plea, and nearly a year later, the defendant moved to withdraw his guilty plea in the United States District Court for the District of North Dakota. He claimed that the court failed to establish an adequate factual basis for the drug quantity element, that he did not understand the nature of his offense, and that his plea was not voluntary. The district court denied the motion, finding that the record established an adequate factual basis for the drug quantity, that the defendant was aware of the nature of the offense, and that the plea was knowing and voluntary.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the defendant’s plea and appeal waiver were entered knowingly and voluntarily, and whether enforcing the waiver would result in a miscarriage of justice. The court held that the record showed the defendant understood the charge, including the drug quantity element, and knowingly and voluntarily entered his plea and waiver. The court found no grounds for applying the miscarriage-of-justice exception. As a result, the Eighth Circuit enforced the appeal waiver and dismissed the appeal. View "United States v. Caster" on Justia Law

Two individuals were convicted of armed robberies and related firearms offenses in separate incidents, resulting in lengthy prison sentences due to mandatory minimums under 18 U.S.C. § 924(c). Years after their sentencing, Congress passed the First Step Act of 2018, which reduced mandatory penalties for repeat § 924(c) violations, but did not make these changes retroactive. Both individuals argued that, had they been sentenced under the amended law, their sentences would be significantly shorter. They sought sentence reductions under the compassionate release statute, 18 U.S.C. § 3582(c)(1)(A), asserting that the disparity created by the nonretroactive change constituted “extraordinary and compelling reasons” for release.The United States District Court for the Northern District of Iowa and the United States District Court for the Southern District of Iowa both rejected these arguments, relying on the Eighth Circuit’s prior decision in United States v. Crandall, which held that nonretroactive sentencing changes do not qualify as extraordinary and compelling reasons for compassionate release. Although the United States Sentencing Commission subsequently amended its policy statement to allow consideration of nonretroactive legal changes in some circumstances, the district courts concluded that Crandall remained controlling law in the Eighth Circuit and that the Commission’s policy statement was inconsistent with the statute.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district courts’ decisions. The Eighth Circuit held that, in light of the Supreme Court’s recent decision in Rutherford v. United States, nonretroactive sentencing amendments—standing alone or in combination with other insufficient factors—cannot constitute “extraordinary and compelling reasons” to reduce a sentence under § 3582(c)(1)(A), even if the Sentencing Commission’s policy statement suggests otherwise. The court affirmed the orders denying compassionate release. View "United States v. Loggins" on Justia Law

The plaintiff, a federally recognized Indian tribe, entered into self-determination contracts with the federal government under the Tribally Controlled Schools Act (TCSA), receiving funds to operate tribal schools. From 2012 to 2019, the tribe used some of these funds for non-school tribal operations, resulting in unearned revenue deficits. After conducting annual audits as required, the Bureau of Indian Affairs (BIA) found, in reports covering fiscal years 2016, 2017, and 2018, that the tribe owed millions in disallowed costs. The government began recouping these sums by offsetting other federal payments to the tribe. Although each report notified the tribe of its right to administratively appeal the findings, the tribe did not file any timely administrative or judicial appeals regarding these determinations.The United States District Court for the District of South Dakota dismissed the tribe’s initial complaint as untimely, finding the claims barred by the one-year limitations period set by the Indian Self-Determination and Education Assistance Act (ISDEAA) and the Contract Disputes Act (CDA). The district court allowed the tribe to amend its complaint to assert an overcollection claim concerning the FY 2017 debt. The government moved for summary judgment on this claim, which the district court granted, concluding the tribe had not presented evidence or legal authority to support its position and that the claim was foreclosed by statutory finality rules.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s dismissal and grant of summary judgment. The Eighth Circuit held that the tribe’s failure to exhaust its administrative remedies and timely pursue judicial review deprived the courts of subject matter jurisdiction over its claims. The court also held that the government’s collection actions were lawful, since the BIA’s determinations became final and binding when not timely appealed, and rejected the tribe’s arguments regarding overcollection and technical assistance. View "Lower Brule Sioux Tribe v. U.S. Dept. of Interior" on Justia Law

Police, acting on a tip that drugs and firearms were present and sold at a particular Omaha residence, began an investigation. They corroborated the tip by conducting a lawful search of the home’s trash, finding marijuana residue, a ziplock bag piece, and unfired bullets. This led to a search warrant, and a SWAT team later found drugs, firearms, and related paraphernalia in the home, which was occupied by Baling N. Dat, Dilang N. Dat, Jany Jock, and others. The police also discovered incriminating text messages, images, and search histories on the defendants’ phones, showing ongoing illegal possession and transfer of firearms. Each defendant was charged under various federal firearm and drug statutes.The United States District Court for the District of Nebraska denied Baling’s motions to suppress evidence from the search and for severance of his trial. The jury convicted Baling of drug and firearm offenses, Dilang of being a felon in possession, and Jock of unlawfully supplying a firearm to a felon. The district court sentenced each to prison and denied Dilang’s and Jock’s motions for acquittal. The district court also admitted summary phone evidence and gang-related testimony over defendants’ objections.The United States Court of Appeals for the Eighth Circuit reviewed the convictions and sentences. It held that the search warrant was supported by probable cause, the district court did not abuse its discretion in denying severance, and the summary phone evidence was properly admitted. The court found that the admission of co-conspirator statements and gang-related evidence was not erroneous or, where not properly objected to, did not amount to plain error. The evidence was sufficient to support the convictions. The sentences, including upward variances, were not substantively unreasonable, and the district court adequately explained its decisions. The Court of Appeals affirmed the judgments and sentences in all respects. View "United States v. Dat" on Justia Law

The case concerns disputes between two groups of North Dakota surface landowners and an oil and gas company with rights to drill on their land. After the company gave statutory notice and commenced drilling, the landowners and the company were unable to reach an agreement on compensation for damages to the land, as required by North Dakota’s Oil and Gas Production Damage Compensation Act. Both sets of landowners, represented by the same law firm, filed separate lawsuits in federal court seeking compensation for damages. The cases involved substantial litigation over discovery, scheduling, expert witnesses, and attorneys’ fees, with mediation attempts failing. Eventually, the parties reached stipulated judgments settling the claims for monetary amounts.After settlement, the landowners sought attorneys’ fees under North Dakota law, submitting discounted requests and supporting invoices. The company objected, arguing that the requests were excessive given the simplicity of the dispute and raising concerns such as alleged excessive billing, duplicative work, and poor documentation. The company also requested an in-person hearing on the fee motions, which was denied.The United States District Court for the District of North Dakota applied the lodestar method to determine reasonable attorneys’ fees, starting with the actual fees incurred, then reducing the amounts based on factors such as poor documentation and litigation conduct. The court awarded the landowners more than they requested, after finding the hourly rates and the time expended reasonable, but applying a 10% reduction for documentation issues and delays. The court also denied the company’s motion for oral argument.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that the district court did not abuse its discretion in its fee award calculations, its consideration of relevant factors, or in denying an oral argument. The court found that the district court’s approach and reductions were consistent with precedent and North Dakota law. View "Murphy v. Continental Resources, Inc." on Justia Law

The case centers on Ellery Zephier, Sr., who was charged with two counts of assault with a dangerous weapon, assault resulting in serious bodily injury, and kidnapping, all arising from conduct toward his ex-girlfriend, Kristy Selwyn, over several days in July 2024. The evidence included testimony from the victim, medical personnel verifying her injuries, and law enforcement officers who corroborated aspects of her account, including finding blood and bloodstained clothing at the scene. The government also presented evidence under Federal Rule of Evidence 404(b) regarding a 2023 incident in which Zephier allegedly assaulted and kidnapped another former girlfriend, Angelique Drapeau.The United States District Court for the District of South Dakota, presided over by Chief Judge Roberto A. Lange, conducted the trial. The district court excluded evidence relating to a 2022 incident with another woman, A.K., but ultimately admitted evidence of the 2023 incident with Drapeau, offering a limiting instruction to the jury. The court also restricted the defense’s cross-examination of Drapeau to prevent introduction of prejudicial and speculative testimony regarding A.K.’s death. The jury acquitted Zephier of assault with a dangerous weapon but convicted him of kidnapping and assault resulting in serious bodily injury.On appeal, Zephier challenged the district court’s admission of the 404(b) evidence, the limits placed on his cross-examination of Drapeau, and the sufficiency of the evidence for both convictions. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the Rule 404(b) evidence was properly admitted, the limitation on cross-examination did not violate the Sixth Amendment, and that sufficient evidence supported both the kidnapping and assault convictions. Thus, the convictions and sentences were upheld. View "United States v. Zephier" on Justia Law

Four former employees of an agricultural products and services company resigned and soon after began working for a competitor. The company alleged that these employees breached their duty of loyalty, misappropriated trade secrets in violation of federal and state law, and tortiously interfered with its business relationships. The employees were paid by both companies for a two-week period during the transition. In total, at least eleven employees moved from the plaintiff company to the competitor during the same period.After the company filed suit in the United States District Court for the District of Nebraska, several discovery disputes arose. The magistrate judge and the district court denied the company’s attempts to obtain discovery from the competitor before seeking discovery from the employees and found the company’s identification of trade secrets to be overly broad and nonspecific. The company’s subsequent motion to compel discovery from the employees was denied on procedural grounds for failing to follow court-ordered procedures, and the district court affirmed this decision. The company also unsuccessfully requested a stay of summary judgment, which the district court denied as untimely.On summary judgment, the district court dismissed most of the company’s claims, finding insufficient evidence to support the trade secrets, tortious interference, and most duty of loyalty claims, but allowed a limited claim regarding dual employment during the two-week period to proceed. The parties later stipulated to dismiss this remaining claim without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s orders in full. The appellate court held that the district court did not abuse its discretion in its discovery rulings or in denying a stay. It further held that summary judgment was properly granted for the employees on all claims due to the company’s failure to identify specific trade secrets, provide admissible evidence of breach, or substantiate tortious interference. View "Wilbur-Ellis Company v. Gompert" on Justia Law

The case centers on Keith Carnes, who was convicted of first-degree murder and armed criminal action for the killing of Larry White in Kansas City, Missouri, in 2005. The prosecution relied primarily on eyewitness testimony from Lorianne Morrow and Wendy Lockett, which conflicted with physical evidence. Carnes was sentenced to life in prison and served eighteen years. In 2022, the Supreme Court of Missouri granted Carnes habeas relief, finding the state had violated Brady v. Maryland by failing to disclose material evidence, and Carnes was released. The state dismissed the charges.Carnes subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Missouri. He alleged that certain detectives and a prosecutor had violated his constitutional rights through the fabrication of evidence, suppression of exculpatory evidence, and a reckless investigation. He also brought claims for malicious prosecution and unlawful pretrial detention. The district court granted summary judgment for most defendants but denied summary judgment for Detectives Robert Blehm and Avery Williamson on the reckless investigation claim, and for Blehm on the suppression of evidence claim. Prosecutor Amy McGowan’s motion for summary judgment on qualified immunity, prosecutorial immunity, and official immunity was also denied.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment. The court held that a reasonable factfinder could determine the detectives acted recklessly by relying on witness testimony that contradicted physical evidence and by failing to pursue alternative suspects, thus violating Carnes’s right to fair criminal proceedings. It further held that Prosecutor McGowan was not entitled to absolute immunity or qualified immunity where a genuine dispute existed about whether she coerced a witness and suppressed evidence before probable cause. The court affirmed the district court’s denial of summary judgment. View "Carnes v. Blehm" on Justia Law

Minnesota State Troopers stopped Ricky Cobb, II during the early morning hours for driving without headlights. Shortly after the stop, Trooper Seide learned Cobb was wanted for a felony violation of a protective order. Seide, along with Trooper Londregan and another officer, received instructions from the Ramsey County Sheriff’s Office to arrest Cobb. When the troopers attempted to take Cobb into custody, he refused to exit his vehicle and shifted his car into drive, causing the vehicle to move forward with one trooper partially inside. In response, Trooper Londregan shot Cobb, who then drove a short distance before his car was stopped by the troopers. Cobb was removed from the vehicle and died at the scene.The United States District Court for the District of Minnesota reviewed the case after Nyra Miller-Fields, representing Cobb’s estate, brought a lawsuit under 42 U.S.C. § 1983. The suit alleged that the troopers’ actions constituted an unreasonable seizure and excessive force in violation of the Fourth and Fourteenth Amendments. The district court considered body and dash camera evidence and granted the troopers’ motion to dismiss on the basis of qualified immunity, concluding that the troopers’ conduct did not violate clearly established constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The court held that the troopers had reasonable suspicion to extend the stop and probable cause for Cobb’s arrest based on the protective order violation. It further held that the use of deadly force by Trooper Londregan did not violate a clearly established constitutional right in the specific context of this case, given the immediate risk to officer safety. The Eighth Circuit concluded that the troopers were entitled to qualified immunity and affirmed the dismissal of the claims. View "Miller-Fields v. Londregan" on Justia Law

Compeer, a group of federally chartered farm credit associations, entered into a master participation agreement with Corporate America Lending, Inc. (CAL), under which Compeer paid CAL $58 million in exchange for the right to receive all payments due on a set of agricultural loans CAL had originated to Famoso Hills Ranch in California. Under the agreement, CAL was to promptly remit any payments or proceeds received on these loans to Compeer. When Famoso refinanced its loans and paid off the balance to CAL, CAL failed to notify Compeer or transfer the payoff proceeds as required and instead concealed receipt of the funds and withheld them as a negotiation tactic, eventually claiming a right to offset based on alleged damages suffered.Arbitration proceedings commenced, resulting in an award in favor of Compeer, finding it was unconditionally entitled to the payoff proceeds and that CAL had no legal basis to withhold them. The arbitration panel found for Compeer on its claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment. Compeer moved in the United States District Court for the District of Minnesota to confirm the award and appoint a receiver to secure the funds. The district court confirmed the arbitration award, finding it final and enforceable, and appointed a receiver due to CAL’s repeated noncompliance and attempts to dissipate the funds. CAL appealed, arguing the award was nonfinal, violated public policy, and the receivership was improper due to a forum-selection clause and lack of necessity.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The court held that the arbitration award was final and confirmable, the public policy exception to vacatur under the Federal Arbitration Act did not require setting aside the award given the alternative equitable bases for Compeer’s recovery, and the district court acted within its discretion in appointing a receiver due to CAL’s conduct and the inadequacy of alternative remedies. View "Compeer Financial, ACA v. Corp. Amer. Lending, Inc." on Justia Law