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

Two individuals, both former members of several Missouri limited liability companies operating as a commercial insurance brokerage, entered into contracts with their company containing Missouri choice-of-law and forum-selection clauses, as well as customer non-solicitation covenants. The agreements required members to follow certain operating agreements, which included a provision allowing termination of membership interests upon 30 days’ notice. Despite this, both individuals resigned “effective immediately” and began working for a competitor. The company sued them in federal court in Missouri to enforce the contractual terms, while the former members filed lawsuits in California state court seeking to void the agreements.The United States District Court for the Western District of Missouri granted summary judgment for the company on the enforceability of the Missouri forum-selection and choice-of-law clauses, finding the individuals breached the forum-selection clauses by suing in California. The court also found the customer non-solicitation covenants enforceable to the extent the company sought to enforce them. However, it granted summary judgment to the former members on claims that they breached the notice provision and related fiduciary duties, and on certain other contract and tort claims. The court awarded the company attorneys’ fees for the Missouri litigation but only nominal damages for the forum-selection clause breaches, declining to award fees incurred in the California actions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings on the enforceability of the choice-of-law and forum-selection clauses, as well as the customer non-solicitation covenants. It reversed the findings on the notice provision and fiduciary duty, holding these were breached, and directed entry of judgment for the company on those claims. The court vacated the nominal damages for the forum-selection clause breaches, instructing the district court to determine actual damages, and affirmed the attorneys’ fee awards to the company. The case was remanded for further proceedings consistent with these holdings. View "West Series of Lockton Companies, LLC v. Kaufman" on Justia Law

During an Alcoholics Anonymous meeting in Sikeston, Missouri, George Holland experienced a severe mental health crisis, displaying incoherent speech and ultimately brandishing a small pistol, which he placed in his mouth. The other attendees exited safely, leaving Holland alone and armed inside. Police responded and engaged with Holland from a concealed position outside an open door, repeatedly commanding him to drop his weapon. For most of the encounter, Holland neither pointed the firearm at officers nor threatened them directly. After about fifteen minutes, Holland moved into clear view, holding the gun to his temple. In a sudden motion, he lowered the firearm and shifted his left arm toward it, prompting Officer Martin Simmerman to fire. Holland retreated, and Simmerman, followed by other officers, pursued him into the corridor, firing additional shots. Simmerman discharged fifteen rounds in total, striking Holland at least six times, resulting in Holland’s death.The Holland family brought suit against Simmerman and the City of Sikeston in the United States District Court for the Eastern District of Missouri, alleging excessive force under 42 U.S.C. § 1983, wrongful death, battery, and Monell claims. The defendants moved to dismiss, providing body camera footage. The district court found that the video evidence contradicted key allegations in the complaint, concluded that Simmerman was entitled to qualified and official immunity, and dismissed all claims with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit found that while the video evidence contradicted the allegation that Holland took no menacing action before the first volley of shots, it did not conclusively show the events during the subsequent volleys. The court held that Simmerman was entitled to qualified immunity for the initial shots but not for the later volleys, as the complaint plausibly alleged excessive force as to those shots. The appellate court reversed the dismissal of the excessive force claim, remanded for reconsideration of the related state-law and Monell claims, and affirmed in all other respects. View "Holland v. Simmerman" on Justia Law

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital.The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions.The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

Darius Carter, a convicted felon, and his girlfriend, Sarah Mason, sought to obtain firearms but were ineligible to purchase them themselves. They recruited Carter’s mother to serve as a “straw buyer,” who purchased two guns from a pawn shop after Carter and Mason made most of the payments. She falsely certified on federal forms that she was the actual buyer. Months later, Mason was found dead from a gunshot wound to the head, which led investigators to uncover the gun-buying scheme. Carter was subsequently charged with making and conspiring to make false statements in connection with acquiring firearms.The United States District Court for the Eastern District of Missouri allowed the government at trial to present evidence that Mason died under suspicious circumstances, over Carter’s objection that this testimony was irrelevant and prejudicial. Carter was convicted on both counts by a jury. At sentencing, the government presented further evidence implicating Carter in Mason’s murder, arguing for a significant sentence enhancement on the basis that he used one of the illegally purchased firearms to commit the killing. The district court found by a preponderance of the evidence that Carter had committed first-degree murder with one of the guns, applying a sentencing guideline cross-reference that dramatically increased his advisory sentencing range. Carter was sentenced to 180 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit held that although the district court abused its discretion by admitting irrelevant evidence regarding the suspicious nature of Mason’s death, the error was harmless given the overwhelming evidence of Carter’s guilt. The court also found no clear error in the district court’s factual findings at sentencing and held that applying the homicide cross-reference under the Sentencing Guidelines was proper. Accordingly, the appellate court affirmed the district court’s judgment. View "United States v. Carter" on Justia Law

Two children, John and Jane, lived primarily with their maternal grandfather under an informal arrangement, while their parents, Nicole Roy and Harrison Dudley, Sr., retained responsibility for their medical care. Medical professionals discovered severe health issues: Jane, age two, suffered from life-threatening anemia and a scalp infection, while John, age six, had significant developmental delays and both children had untreated head lice. Roy and Dudley repeatedly failed to follow through with prescribed treatments, missed follow-up appointments, and did not address the children's medical and hygiene needs, despite receiving explicit instructions and assistance from healthcare providers.A grand jury indicted Roy and Dudley for felony child neglect and felony child endangerment under the Major Crimes Act, alleging the offenses occurred on the Red Lake Indian Reservation. After a trial in the United States District Court for the District of Minnesota, a jury convicted both defendants on all counts. The district court sentenced Roy to twelve months and one day and Dudley to four months of imprisonment, with both receiving three years of supervised release and special assessments. Roy’s appeal became moot due to her death, while Dudley appealed, challenging the sufficiency of the evidence and the legality of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that sufficient evidence supported Dudley’s convictions, finding that a rational jury could conclude he willfully deprived the children of necessary care and recklessly endangered their health. The court also held that Dudley’s term of supervised release and the imposition of special federal assessments were lawful under the Major Crimes Act and relevant federal statutes. The Eighth Circuit affirmed the judgment as to Dudley and vacated the judgment as to Roy, remanding with instructions to dismiss her indictment. View "United States v. Roy" on Justia Law

After Missouri legalized recreational marijuana in 2022, local governments were permitted to impose an additional sales tax on dispensaries selling recreational marijuana. Dispensaries passed this tax on to their customers. However, the Missouri Supreme Court later ruled that counties could not levy this additional tax on dispensaries located within incorporated areas such as cities or towns. Following this ruling, a class of customers sued several dispensaries, alleging that the dispensaries unlawfully retained the collected county tax and sought restitution.The dispensaries removed the action to the United States District Court for the Western District of Missouri under the Class Action Fairness Act (CAFA). The plaintiffs then amended their complaint to limit the class to Missouri citizens and moved to remand the case to state court, arguing that the Local Controversy Exception to CAFA applied. The district court initially found that three of the four required elements for the exception were met but that the class had not sufficiently shown that more than two-thirds of its members were Missouri citizens. After a second amendment explicitly limited the class to Missouri citizens, the district court found all requirements met and remanded the case to state court.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the operative pleading for determining CAFA jurisdiction was the first or second amended complaint. The court, relying on the Supreme Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger, held that the most recent amended complaint governs jurisdiction. The Eighth Circuit also agreed that the Local Controversy Exception was satisfied and affirmed the district court’s remand order, holding that federal jurisdiction no longer existed once the class was limited to Missouri citizens. View "Vick v. Vertical Enterprise, LLC" on Justia Law

Several individuals and a nonprofit organization in Minnesota, focused on election integrity, wished to publicly advocate their interpretation that certain felons—specifically those still on supervised release—are constitutionally ineligible to vote in Minnesota. State law, however, allows felons to vote once released from incarceration, regardless of whether they are on parole or probation. Concerned about possible prosecution under a Minnesota statute that criminalizes knowingly false statements about voter eligibility made within 60 days of an election, the plaintiffs sought to continue their advocacy without facing criminal or civil penalties.After the Minnesota Supreme Court held that the group lacked standing to challenge the felon voting law in state court, the plaintiffs filed suit in the United States District Court for the District of Minnesota. They sought declaratory and injunctive relief against the enforcement of the election disinformation statute, arguing it violated the First Amendment. In response, the Anoka County Attorney filed a counterclaim, seeking to restrain the plaintiffs from violating the law and to obtain damages. The district court dismissed the plaintiffs’ complaint and denied a preliminary injunction, concluding that the law could constitutionally restrict their speech. The plaintiffs appealed the denial of a preliminary injunction while the counterclaim remained pending.The United States Court of Appeals for the Eighth Circuit reviewed the denial of preliminary injunctive relief and found that the plaintiffs had standing due to both actual and imminent injuries. The court held that the statute at issue regulated protected political speech based on its content and was therefore subject to strict scrutiny. The court determined that Minnesota’s law was not narrowly tailored to serve a compelling state interest, as it both overreached and underreached in its restriction of speech, and also authorized unconstitutional prior restraints. The Eighth Circuit reversed the denial of a preliminary injunction in part, affirmed in part, and remanded for entry of a preliminary injunction in favor of the plaintiffs. View "Minnesota Voters Alliance v. Ellison" on Justia Law

In this case, two individuals, after forming a close association in Kansas City, Missouri, participated in a series of criminal acts. These included the theft of an AR-15 rifle, armed robberies targeting drug dealers, and two fatal shootings—one at a restaurant parking lot and another involving a resident of their apartment complex who had tipped off the police about their involvement in the first murder. The defendants also engaged in acts of witness tampering, evidence tampering, and intimidation, including efforts to recover the murder weapon and threats against potential witnesses. Law enforcement ultimately apprehended the perpetrators, and a federal grand jury indicted them on multiple counts, including drug conspiracy, firearm offenses, murder, robbery, and tampering-related charges.The United States District Court for the Western District of Missouri denied the defendants’ motions to sever their trials and allowed certain grand jury testimony into evidence. A jury found both defendants guilty on nearly all counts. The district court subsequently sentenced one defendant to four consecutive life sentences and the other to five. The government dismissed two counts for double jeopardy concerns after the Supreme Court’s decision in Lora v. United States, and both defendants appealed, raising challenges related to the severance denial, evidentiary rulings, sufficiency of the evidence, jury instructions, and sentencing.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the denial of the severance motion was not an abuse of discretion, the evidence was sufficient to support all challenged convictions, and the admission of grand jury testimony was proper under Federal Rule of Evidence 801(d)(1)(a). The jury instructions on Hobbs Act robbery were found to be consistent with Supreme Court precedent. The court declined to review the reasonableness of the sentences for one count under the concurrent sentence doctrine, as the defendants were already serving multiple consecutive life sentences. View "United States v. Nesbitt" on Justia Law

In December 1995, Holsey Ellingburg, Jr. robbed a bank. He was convicted by a jury in August 1996 and sentenced in November 1996 by the United States District Court for the Western District of Missouri, which ordered him to pay $7,567.25 in restitution. At the time of his offense, the Victim and Witness Protection Act of 1982 (VWPA) governed restitution, limiting liability to twenty years after judgment. However, the Mandatory Victim Restitution Act (MVRA), enacted after his offense but before his conviction, extended the government’s ability to collect restitution to the later of twenty years after judgment or twenty years after release from imprisonment, and made interest awards mandatory unless the defendant was unable to pay. After his release in 2022, Ellingburg challenged the continued enforcement of his restitution order, arguing that retroactive application of the MVRA violated the Ex Post Facto Clause.The district court held that the MVRA’s extended liability period did not increase Ellingburg’s punishment and rejected his petition. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, reasoning that MVRA restitution was not criminal punishment and therefore did not implicate the Ex Post Facto Clause. Ellingburg sought review in the Supreme Court, which reversed, holding that MVRA restitution is criminal punishment under the Ex Post Facto Clause, and remanded for further proceedings on whether the MVRA’s extended liability period increased his punishment.On remand, the United States Court of Appeals for the Eighth Circuit determined that the MVRA applied to Ellingburg because he was convicted after its enactment. The court held that retroactive application of the MVRA’s extended liability period increased Ellingburg’s punishment by prolonging his restitution liability well beyond what the law permitted at the time of his offense. The court therefore concluded that applying the MVRA to Ellingburg violated the Ex Post Facto Clause, vacated the district court’s judgment, and remanded for further proceedings. View "United States v. Ellingburg" on Justia Law