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

Jacqusyn Grubb was charged with unlawful possession of a firearm as an unlawful user of a controlled substance under 18 U.S.C. § 922(g)(3). Grubb moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights, particularly as he was a user of marijuana, not a more dangerous controlled substance. The government contended that Grubb's challenge was premature due to undeveloped facts.The United States District Court for the Northern District of Iowa denied Grubb's motion to dismiss, ruling that the statute was constitutional on its face but held Grubb's as-applied challenge pending trial. The court rejected Grubb's request for an evidentiary hearing, stating it would amount to unauthorized discovery. Grubb then entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The district court later reconsidered and requested supplemental briefing but ultimately denied the motion to dismiss, concluding the statute was constitutional as applied to Grubb.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a trial on the merits was necessary to resolve Grubb's pretrial motion to dismiss the indictment. The court emphasized that there is no summary judgment procedure in federal criminal cases and that the government is not required to present all its evidence before trial. The court concluded that the district court should have deferred ruling on the as-applied challenge until trial. Consequently, the Eighth Circuit reversed the district court's order, vacated the judgment, and remanded the case for further proceedings, allowing Grubb to choose whether to adhere to his guilty plea or proceed to trial. View "United States v. Grubb" on Justia Law

Mario Mancini, an inmate at FCI Sandstone, sued the United States under the Federal Tort Claims Act (FTCA) for medical malpractice. Mancini alleged that the government caused him permanent injury by negligently delaying necessary medical care. He experienced neck and back pain from a prior workplace injury, which worsened in 2017. Despite reporting increasing pain and numbness, his MRI and subsequent surgery were delayed. Mancini claimed these delays resulted in permanent nerve damage, loss of strength, muscle atrophy, numbness, and pain.The United States District Court for the District of Minnesota dismissed Mancini's FTCA claim. The court found that Mancini's expert affidavit, provided by Dr. Gary Wyard, failed to meet the requirements of Minn. Stat. § 145.682. The affidavit did not adequately define the standard of care, explain how the government deviated from that standard, or establish a causal connection between the delays and Mancini's injuries. The court also excluded Dr. Wyard's testimony under Rule 702 and Daubert, citing factual errors and a lack of methodology in his affidavit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Dr. Wyard's affidavit did not satisfy the statutory requirements of Minn. Stat. § 145.682. The affidavit lacked specific details about the standard of care and failed to outline a chain of causation between the government's actions and Mancini's injuries. The court also upheld the exclusion of Dr. Wyard's testimony under Rule 702 and Daubert. The court concluded that the district court did not abuse its discretion in dismissing the case with prejudice, as Mancini did not correct the deficiencies in the affidavit within the provided safe-harbor period. View "Mancini v. United States" on Justia Law

Tayvin Galanakis sued Officers Nathan Winters and Christopher Wing under 42 U.S.C. § 1983 and Iowa law, alleging they arrested him without probable cause. He also brought federal and state claims against the City of Newton, Iowa. The district court denied summary judgment in part, determining that the officers were not entitled to qualified immunity or state statutory immunity, and the City was subject to vicarious liability on a surviving state-law claim.The United States District Court for the Southern District of Iowa denied summary judgment with respect to the § 1983 and false arrest claims against Winters and Wing, as well as the respondeat superior claim against the City predicated on Galanakis’s false arrest claim. The defendants appealed, arguing that qualified immunity and state statutory immunity protected the officers—and, as to the false arrest claim, the City—from suit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on Galanakis’s Fourth Amendment claim, concluding that no objectively reasonable officer could have concluded that there was a substantial chance Galanakis had driven while under the influence of marijuana. The court found that Galanakis evinced almost no indicia of intoxication and that his behavior during the stop did not suggest impairment. The court also dismissed the interlocutory appeal as to the state-law claims, noting that without clarification that resolution of the qualified immunity claim necessarily resolves the pendent claims, it declined to exercise jurisdiction. View "Galanakis v. City of Newton, Iowa" on Justia Law

Ashley Chacon pled guilty to possession with intent to distribute 50 grams or more of methamphetamine. Emiliano Nava Munoz and Valentin Nava Munoz pled guilty to conspiracy to distribute and distribution of 50 grams or more of methamphetamine. The district court sentenced Chacon to 60 months, Emiliano to 280 months, and Valentin to 180 months in prison. They appealed their sentences.The United States District Court for the Southern District of Iowa denied Chacon's motion to suppress evidence from a car search. Chacon argued that the traffic stop was impermissibly extended and that the drug-detection dog's contact with the car was an unlawful trespass. The district court found that the stop was not prolonged beyond the time reasonably required to complete the original purpose of the stop and that the dog's contact with the car did not violate the Fourth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the officer's questions during the traffic stop were ordinary inquiries and that the stop was not impermissibly extended. The court also held that the drug-detection dog's contact with the car did not violate the Fourth Amendment because the dog acted instinctively. The court affirmed the district court's denial of Chacon's motion to suppress.Emiliano challenged the enhancements to his sentence for maintaining drug premises and for his role as a manager or supervisor. The court found that Emiliano used his residence and another property for substantial drug-trafficking activities and that he had control over the premises. The court also found that Emiliano was a manager or supervisor of the criminal activity. Valentin challenged his role enhancement, but the court found that he directed transactions and recruited others into the offense. The court affirmed the sentences for Emiliano and Valentin. The judgments were affirmed. View "United States v. Munoz" on Justia Law

Armando Angel Cheshier was convicted of distributing a controlled substance resulting in serious bodily injury and possession of a controlled substance with intent to distribute. He was sentenced to 252 months for the first count and 240 months for the second and third counts, to run concurrently. Cheshier appealed his conviction, arguing that the district court erred in rejecting his guilty plea and in instructing the jury on intentional distribution of a controlled substance.The United States District Court for the District of South Dakota rejected Cheshier's guilty plea because he explicitly denied distributing fentanyl to the victim during the plea hearing. Cheshier also challenged the jury instructions, but the district court found that the instructions accurately reflected the law, including the requirement that the government prove he knowingly or intentionally distributed the controlled substance.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not plainly err in rejecting Cheshier's guilty plea, as he denied the factual basis for the plea. The appellate court also found that the district court did not abuse its discretion in instructing the jury, as the instructions were a correct statement of the law. Additionally, the court determined that there was sufficient evidence for a reasonable jury to conclude that Cheshier knowingly or intentionally distributed fentanyl to the victim and that the victim's death resulted from the fentanyl.The Eighth Circuit affirmed the judgment of the district court, upholding Cheshier's conviction and sentence. View "United States v. Cheshier" on Justia Law

Jan Kuklenski was terminated by Medtronic USA, Inc. and subsequently filed a lawsuit in federal court, claiming that her termination violated the Minnesota Human Rights Act (MHRA) due to her disability. Kuklenski had worked for Medtronic since 1999 but had not resided in Minnesota. She occasionally traveled to Minnesota for work until the COVID-19 pandemic, after which she worked remotely. She went on medical leave in June 2021, and after her initial three-month leave expired, Medtronic filled her position and formally terminated her in December 2021.The United States District Court for the District of Minnesota granted summary judgment in favor of Medtronic, concluding that Kuklenski could not bring claims under the MHRA because she did not meet the statutory definition of an “employee,” which requires either residency or physical presence in Minnesota. The court found that Kuklenski had not been physically present in Minnesota for almost two years before her termination.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s grant of summary judgment, agreeing that the MHRA’s definition of “employee” requires some degree of physical presence in Minnesota. The court found that the statutory language was clear and unambiguous, requiring that an individual must either reside or work within the physical limits of Minnesota to be protected under the MHRA. The court also denied Kuklenski’s request to certify the question to the Minnesota Supreme Court, noting that the case did not present a close question of state law and that certification was not appropriate given the circumstances.The Eighth Circuit held that the MHRA’s definition of “employee” necessitates physical presence in Minnesota, and since Kuklenski had not been physically present in the state for nearly two years, she did not qualify as an employee under the Act. View "Kuklenski v. Medtronic USA, Inc." on Justia Law

Inmate Travis Dantzler filed a lawsuit under 42 U.S.C. § 1983, claiming that Dr. Tonia Baldwin, a physician at the Clarinda Correctional Facility (CCF), was deliberately indifferent to his knee pain by delaying an MRI and orthopedic referral for nonmedical reasons, specifically his parole eligibility. Dr. Baldwin sought summary judgment based on qualified immunity, arguing she was not deliberately indifferent and that the law was not clearly established. The district court denied her motion, finding a genuine issue of material fact regarding her deliberate indifference.The United States District Court for the Southern District of Iowa reviewed the case and concluded that Dantzler had created a material fact issue as to whether Dr. Baldwin was deliberately indifferent by delaying the MRI and orthopedic referral based on his parole eligibility. The court also determined that Dr. Baldwin was not entitled to qualified immunity, as it was clearly established that delaying medical care for nonmedical reasons could violate the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Dantzler had shown an objectively serious medical need and produced verifying medical evidence that the delay in treatment adversely affected his condition. The court also found that Dr. Baldwin's delay in scheduling the MRI for a nonmedical reason (parole eligibility) could support a finding of deliberate indifference. The court concluded that the law was clearly established, and Dr. Baldwin was on notice that delaying medical treatment for nonmedical reasons could constitute deliberate indifference. View "Dantzler v. Baldwin" on Justia Law

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law

Ronald E. Byers owes the United States for unpaid income taxes, interest, and penalties. The government filed a suit to enforce its federal tax liens through the judicial sale of Ronald’s home, which he solely owns but shares with his wife, Deanna L. Byers. The Byerses agreed to the sale but argued that Deanna is entitled to half of the proceeds because the property is their marital homestead. The district court granted the government’s motion for summary judgment, ruling that Deanna lacked a property interest in the home and was not entitled to any sale proceeds.The United States District Court for the District of Minnesota found that Deanna did not have a property interest in the home under Minnesota law, which only provides a contingent interest that vests upon the owner's death. The court concluded that Deanna’s interest did not rise to the level of a property right requiring compensation under federal law. The court ordered that Ronald is liable for the tax debt, the government’s liens are valid, and the property can be sold with proceeds applied to Ronald’s tax liabilities.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Minnesota’s homestead laws do not provide Deanna with a vested property interest in the home that would entitle her to compensation from the sale proceeds. The court distinguished this case from United States v. Rodgers, noting that Minnesota law does not afford the same level of property rights to a non-owner spouse as Texas law does. Therefore, the court upheld the summary judgment in favor of the government, allowing the sale of the property to satisfy Ronald’s tax debt. View "United States v. Byers" on Justia Law

Quincy Martez Chambers was convicted by a jury for possession of ammunition by a felon, violating 18 U.S.C. §§ 922(g)(1) and 924(e). The incident involved the shooting of Nairobi Anderson, the mother of Chambers's child, by a masked man. Anderson was shot in the chest and struck in the head. Chambers was sentenced to 360 months in prison by the district court, which found the object of his offense to be first-degree murder, applying relevant sentencing enhancements.The United States District Court for the Eastern District of Arkansas sentenced Chambers, applying a base offense level of 33, with additional enhancements for Anderson's injuries and obstruction of justice. Chambers was also classified as an Armed Career Criminal under 18 U.S.C. § 924(e), leading to a statutory range of 15 years to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Chambers challenged the sufficiency of the evidence, the admission of certain evidence, and the application of sentencing enhancements. The appellate court found sufficient evidence to support the jury's verdict, including Anderson's initial identifications and other corroborating evidence. The court also upheld the admission of text messages and video stills as relevant to Anderson's credibility and motive for recanting her identification. The court found no plain error in their admission.The appellate court affirmed the district court's application of the cross-reference to attempted first-degree murder, the enhancements for the severity of Anderson's injuries, and obstruction of justice. The court also upheld Chambers's classification as an Armed Career Criminal, finding his nolo contendere plea to domestic battery constituted a violent felony under the ACCA. The judgment of the district court was affirmed. View "United States v. Chambers" on Justia Law