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

A high school student, who is a transgender girl but was assigned male at birth, played on a varsity girls’ softball team in Minnesota under a 2016 state athletic bylaw permitting students to participate in sporting activities consistent with their gender identity. Female Athletes United (FAU), an organization advocating for women’s sports, sued Minnesota officials and local school boards, alleging that permitting the student’s participation violated the rights of its members under Title IX by denying them effective accommodation and equal treatment. FAU claimed its members suffered various harms, such as lost athletic opportunities and emotional distress, and sought a preliminary injunction to prohibit “male athletes” from competing against its members in girls’ sports involving contact or competitive skill.The United States District Court for the District of Minnesota found that FAU had standing because one member’s team was scheduled to play against the transgender athlete’s team. However, the district court denied the preliminary injunction on two grounds: first, that FAU lacked a private right of action for its Title IX claims, because they were based on a disparate impact (rather than intentional discrimination) theory, and second, that FAU failed to satisfy the requirements for preliminary injunctive relief.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court agreed that, under Title IX and controlling Supreme Court precedents, there is only a private right of action for claims of intentional discrimination, not for disparate impact. It found FAU’s claims were based on allegations of negative effects rather than intentional disparate treatment or deliberate indifference. The court concluded that FAU’s allegations did not support a claim of intentional discrimination. Thus, the Eighth Circuit affirmed the denial of the preliminary injunction, holding that FAU lacked a private right of action for its Title IX claims. View "Female Athletes United v. Keith Ellison" on Justia Law

Law enforcement conducted an investigation into drug trafficking activities involving Paul Parrow after a confidential informant, N.G., made several controlled purchases of various drugs from him. Surveillance linked Parrow to a residence where drugs and related paraphernalia were later found during a warranted search. At trial, multiple co-conspirators and customers testified to Parrow’s ongoing distribution of methamphetamine, heroin, and fentanyl. The defense sought to introduce the drug convictions of Clemmie Kirk, co-owner of the searched residence, to suggest Kirk’s opportunity and knowledge regarding the drugs found there, but these convictions were admitted only for impeachment, not for the purpose of establishing opportunity or knowledge under Rule 404(b).The United States District Court for the Southern District of Iowa excluded the convictions as reverse Rule 404(b) evidence and instructed the jury they could only consider them for credibility assessment. The court also addressed a discovery issue when the government failed to disclose that a witness, D.B., was the “concerned citizen” referenced in police notes. As a sanction, the court struck D.B.’s undisclosed testimony about Parrow’s drug trafficking but denied the defense’s motion for a mistrial. Parrow was found guilty by a jury of conspiracy to distribute and possession with intent to distribute controlled substances, and he received concurrent 300-month prison sentences.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court’s exclusion of Kirk’s prior convictions as reverse Rule 404(b) evidence was an abuse of discretion regarding the possession charge because the convictions were relevant to the issue of who possessed the drugs and their exclusion was not harmless. The conviction for possession with intent to distribute was vacated and remanded for a new trial. The court affirmed the district court’s judgment on all other issues, including the handling of the discovery sanction. View "United States v. Parrow" on Justia Law

An inmate at an Arkansas state prison injured his right pinky finger while playing basketball, resulting in a dislocation. He was treated initially by infirmary staff with a splint and pain medication, and an x-ray was ordered. The x-ray showed no fracture but confirmed the dislocation. After a week, a doctor and a nurse attempted to realign the finger but were unsuccessful, so they provided additional pain management and referred him to an orthopedic surgeon. The finger was reset by a specialist over a month after the original injury. The inmate followed the prison grievance process, complaining about pain, the delay in seeing a provider, and subsequent delays in receiving further care.The United States District Court for the Eastern District of Arkansas reviewed the inmate’s claims. The court dismissed the claims related to delay in care for failure to exhaust administrative remedies, as the inmate did not specifically name the doctor and nurse responsible for the alleged delay in his grievances. The district court granted summary judgment to the doctor and nurse on the remaining claim regarding their care on May 19, finding no deliberate indifference.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the inmate did not properly exhaust his administrative remedies against the doctor and nurse for claims of delayed care, since he failed to name them as required by prison policy. Further, the appellate court agreed with the district court that the care provided on May 19 did not constitute deliberate indifference under the Eighth Amendment. The court concluded that no reasonable jury could find that the medical staff acted with deliberate indifference, and thus affirmed the district court’s dismissal and grant of summary judgment. View "Nuuh Na'im v. Beck" on Justia Law

Police investigated an armed carjacking in St. Louis County after using an electronic tracking feature to follow stolen AirPods, which appeared to be located at a residence on Wylin Court. Based on this information, Detective Joseph Percich applied for a search warrant and submitted an affidavit outlining the investigation and his belief that evidence related to the crime would be found at the address. A county judge issued a no-knock search warrant. The county’s SWAT team executed the warrant, forcibly entered the home, and detained the family living there, who had no connection to the carjacking. The AirPods were ultimately found in the street outside the house.The family sued St. Louis County and Detective Percich in the United States District Court for the Eastern District of Missouri. Their complaint included claims under 42 U.S.C. § 1983 for an alleged Franks v. Delaware violation (claiming the affidavit contained misstatements and omissions), excessive force in the use and conduct of the SWAT team, unreasonable seizure, municipal liability for an unconstitutional SWAT policy, and a state law claim under Missouri’s Sunshine Law. The district court dismissed all of the federal claims, granting Detective Percich qualified immunity and finding that the plaintiffs failed to state viable claims. The court also declined to exercise supplemental jurisdiction over the state law claim.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The appellate court held that the plaintiffs did not adequately allege that Detective Percich knowingly or recklessly included false statements or omitted material information in his affidavit, so no Franks violation occurred. The court also affirmed the finding of qualified immunity for Detective Percich on the excessive force and seizure claims. The court concluded there was no sufficient allegation of an unconstitutional county policy. Finally, it upheld the district court’s decision to decline jurisdiction over the Sunshine Law claim, affirming the judgment in its entirety. View "Briscoe v. St. Louis County" on Justia Law

Jessie Farmer pleaded guilty in 2016 to two counts of using a communication facility to distribute methamphetamine, for which he received the statutory maximum sentence of 96 months’ imprisonment and one year of supervised release. After completing his prison term, Farmer began supervised release in 2024. The probation office later alleged that Farmer committed multiple violations of his release conditions, including missing drug tests and testing positive for drugs. The government petitioned to revoke his supervised release based on these violations.The United States District Court for the Western District of Arkansas reviewed the petition. Farmer argued that because he had already served the statutory maximum prison term for his offense, any additional imprisonment after revocation would violate his Fifth and Sixth Amendment rights unless a jury found the violations beyond a reasonable doubt. The district court denied Farmer’s motion to dismiss, found by a preponderance of the evidence that he committed ten violations, revoked his supervised release, and imposed a new prison sentence of twelve months, the statutory maximum for his supervised release violation.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether Farmer’s revocation sentence under 18 U.S.C. §§ 3583(e) and 3583(g) violated his constitutional rights to due process and trial by jury. The court concluded that the relevant Supreme Court guidance, particularly the controlling concurrence in United States v. Haymond, does not require application of the Apprendi line of cases to supervised release revocations under these sections. The Eighth Circuit held that the district court’s revocation and sentence did not violate Farmer’s constitutional rights, because the statutes did not require punishment for a new offense, preserved judicial discretion, and limited the sentence to the original statutory maximum. The judgment of the district court was affirmed. View "United States v. Farmer" on Justia Law

Jason Schmit, a truck driver for Trimac Transportation, Inc., was diagnosed with Parkinson’s disease in 2018. Following his diagnosis, Trimac provided informal accommodations, allowing Schmit to perform tasks that avoided climbing, pulling hoses, or making certain connections, and adjusting his work schedule to end earlier in the day. In 2021, after a new terminal manager was hired, Schmit was asked to formalize his accommodation requests, which Trimac largely approved. However, Schmit encountered difficulties, including changes in internal shop procedures that affected his ability to perform required tasks, disputes about hauling heavy loads, and disciplinary actions for job violations. Schmit complained to Human Resources about alleged harassment and difficulties related to his disability, but Trimac concluded its policies were being properly enforced. In August 2021, following a dispute, Schmit left work and Trimac treated his departure as a resignation. Schmit later applied for and received Social Security disability benefits, representing that his condition made it impossible for him to work.The United States District Court for the District of South Dakota dismissed Schmit’s state law claims for failure to exhaust administrative remedies and granted summary judgment to Trimac on the remaining claims. The district court found genuine disputes existed regarding whether Schmit resigned or was fired and whether there was discriminatory intent, but determined that Schmit’s statements to the Social Security Administration prevented him from showing that he was a “qualified individual” under the ADA.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that Schmit failed to adequately explain the contradiction between his representations to the Social Security Administration and his litigation position, barring his ADA claim. The court also concluded that Schmit failed to establish a hostile work environment, retaliation, or wrongful termination under South Dakota law. The judgment of the district court was affirmed. View "Schmit v. Trimac Transportation, Inc." on Justia Law

Law enforcement officers in Cedar Rapids, Iowa, observed activity consistent with drug transactions in the parking lot of Jim’s Foods, a location known for narcotics activity. Officers saw a man leave a nearby house, interact with vehicles, and enter the back seat of a Chevrolet Cruze, with Antonio Clarence Robertson in the front seat. After further observation, including witnessing a hand-to-hand transaction, officers noticed the Chevy leave its parking spot and exit the lot without coming to a complete stop before entering the roadway. The officers initiated a traffic stop for violation of Iowa Code § 321.353, which requires vehicles emerging from private driveways to stop before entering public roads. A search, conducted with the driver’s consent, uncovered prescription pills and marijuana on Robertson, leading to his charge for possession with intent to distribute.The United States District Court for the Northern District of Iowa heard Robertson’s motion to suppress the evidence obtained during the stop, which he argued was unlawful because the parking lot did not qualify as a “private driveway” under Iowa law. The district court found the officers’ testimony credible regarding the private nature of the lot and concluded the stop was lawful. Robertson pled guilty but reserved his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court held that the officers had an objectively reasonable basis to believe a traffic violation occurred, as the lot was not open to the public as a matter of right and thus was a “private driveway” within the meaning of Iowa law. The court affirmed the district court’s denial of the motion to suppress and upheld the conviction. View "United States v. Robertson" on Justia Law

After law enforcement officers found six grams of heroin and 453 grams of methamphetamine in Edgar Mejia’s car outside a casino, Mejia informed them he also owned a trailer. Upon searching the trailer, officers discovered a hidden compartment containing two firearms and 541 grams of heroin. Mejia attempted to have Gregory Johnson, his alleged co-conspirator, remove the drugs and guns before police could find them, but Johnson was unsuccessful. Recorded jailhouse calls captured Mejia instructing Johnson on accessing the compartment and discussing the contents and their value. Mejia faced four federal charges, pleaded guilty to possession with intent to distribute heroin and being a felon in possession of a firearm, and was tried and convicted by a jury on conspiracy to distribute heroin and possessing a firearm in furtherance of drug trafficking.The United States District Court for the Western District of Missouri sentenced Mejia to 322 months in prison and imposed supervised release conditions, including work or community service requirements. Mejia appealed, challenging the sufficiency of the evidence for his conspiracy conviction and two aspects of his sentencing: the inclusion of an expunged marijuana conviction in his criminal history calculation and the community service condition of his supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that there was sufficient evidence to support the conspiracy conviction, as the jailhouse calls and circumstances supported a reasonable inference that Mejia and at least one other person agreed to distribute heroin. The court also concluded that any error in counting the expunged conviction was harmless because the district court made clear that the sentence would be the same regardless. The appellate court dismissed Mejia’s challenge to the community service condition as unripe, since it would not take effect for decades and was contingent on future events. The judgment of the district court was otherwise affirmed. View "United States v. Mejia" on Justia Law

An individual was injured while working in a farm shop operated by two defendants, allegedly due to carbon monoxide exposure from a portable heater. The farm’s liability insurance policy, issued by an insurer, covered bodily injuries occurring on the property but contained a pollution exclusion provision. The injured party filed suit in state court, claiming serious injuries caused by the carbon monoxide emission. The insurer then brought a declaratory judgment action in federal district court, seeking a determination that it was not obligated to defend or indemnify the insured farm operators for the state court suit, arguing that the pollution exclusion applied because carbon monoxide is a “pollutant” as defined by the policy.The United States District Court for the District of North Dakota granted summary judgment for the insurer. It found that the pollution exclusion in the insurance policy unambiguously barred coverage for the injuries alleged, because carbon monoxide is a gaseous contaminant and therefore a “pollutant” under the policy’s definition. The court declared that the insurer had neither a duty to defend nor indemnify the insured farm operators in the underlying state court action.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether North Dakota law required a different interpretation of the pollution exclusion and whether the question should be certified to the North Dakota Supreme Court. The court declined to certify, finding that North Dakota insurance contract law was sufficiently clear. Reviewing the summary judgment ruling de novo, the court held that the policy’s pollution exclusion unambiguously excluded coverage for injuries resulting from carbon monoxide discharge and affirmed the district court’s judgment. The Eighth Circuit thus held that the insurer had no duty to defend or indemnify the insured farm operators for the injury claim arising from carbon monoxide exposure. View "North Star Mutual Ins. Co. v. Rodin" on Justia Law

Several educators, parents, students, and a nonprofit organization challenged two provisions of an Iowa law affecting public schools. The law restricts classroom instruction on gender identity and sexual orientation for students in kindergarten through sixth grade and requires school officials to notify parents if a student requests accommodations affirming their gender identity, such as using a different pronoun. The plaintiffs, asserting facial constitutional challenges, argued the provisions were overbroad and vague, infringing on First Amendment and due process rights.Previously, the United States District Court for the Southern District of Iowa granted a preliminary injunction against these provisions. The district court found that the terms “program” and “promotion” in the instruction restriction were overly broad and infringed on protected speech, and determined that the parental notification law was impermissibly vague due to the undefined use of “accommodation.” The district court severed what it considered unconstitutional portions of the statutes and enjoined their enforcement.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. It held that the statutes, when read with the canon of constitutional avoidance, could reasonably be interpreted in a way that avoided constitutional problems and that the statutory language was sufficiently clear. The appellate court found the plaintiffs did not demonstrate that unconstitutional applications of the laws substantially outweighed constitutional ones in their facial challenge. It further determined that the term “accommodation” was not unconstitutionally vague. The Eighth Circuit concluded that the district court abused its discretion in granting the preliminary injunction and vacated that injunction as to all challenged provisions, remanding the case for further proceedings on the merits. View "Iowa Safe Schools v. Reynolds" on Justia Law