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

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

A group of plaintiffs, including publishers, authors, educators, and a parent of a student, challenged provisions of an Iowa law (Senate File 496) requiring public school libraries to remove books containing “descriptions or visual depictions of a sex act.” The law also imposed penalties on educators who failed to comply. The plaintiffs argued that these provisions violated their First Amendment rights, both as to students’ access to information and as to the right of authors and publishers to communicate with their intended audience.The United States District Court for the Southern District of Iowa initially granted a preliminary injunction, preventing enforcement of the challenged provisions. The court concluded that the plaintiffs were likely to prevail, holding that the unconstitutional applications of the law substantially outweighed constitutional ones. It declined to apply the standard set out in Hazelwood School District v. Kuhlmeier, instead relying on the obscenity standard from Ginsberg v. State of New York and the “substantial and reasonable government interest” test from the plurality in Board of Education, Island Trees Union Free School District No. 26 v. Pico.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The Eighth Circuit held that the Hazelwood standard—whether the restrictions are “reasonably related to legitimate pedagogical concerns”—applies to school library curation. The court determined that the Iowa law’s book restrictions addressed legitimate pedagogical concerns and were neither amorphous nor unreasonable. Because the plaintiffs could not show a likelihood of success on the merits under the correct standard, the Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings on the merits. View "Penguin Random House, LLC v. Robbins" on Justia Law

Alvin Boyer developed a relationship with Shayla Tilton, whose estranged husband, Freddie Tilton, confronted Boyer via threatening messages. Over several days, Boyer communicated with both Shayla and Freddie, ultimately sharing with Freddie the details of his plans to meet Shayla at a motel. At Freddie’s direction, Boyer made arrangements for Shayla to enter the motel room, unaware to Shayla that Freddie would be present. When Shayla arrived, Freddie assaulted her with a firearm and other weapons. After the incident, Boyer and Freddie exchanged messages indicating Boyer’s concern for his own safety but also referencing his role in facilitating the meeting.The case was tried in the United States District Court for the Western District of Missouri, where Boyer was charged with kidnapping and conspiracy to commit kidnapping. At trial, Boyer argued he lacked knowledge of Freddie’s intent to assault Shayla. The government introduced evidence of Boyer’s pending assault charges in Arkansas, over his objection. The jury found Boyer guilty on both counts. At sentencing, the district court imposed two concurrent 20-year sentences, below the advisory Guidelines range after considering all arguments.The United States Court of Appeals for the Eighth Circuit reviewed Boyer’s appeal, which challenged the admission of the pending charges evidence, the denial of his motion for judgment of acquittal, and the reasonableness of his sentence. The appellate court held that any error in admitting the pending charges was harmless, as the evidence of Boyer’s knowledge and involvement was substantial. The court found the evidence sufficient for a reasonable jury to convict on conspiracy. Regarding the sentence, the court concluded the district court did not abuse its discretion. The Eighth Circuit affirmed the convictions and sentence. View "United States v. Boyer" on Justia Law

A group of farmers and farming entities brought suit against several manufacturers, wholesalers, and retailers of seeds and crop-protection chemicals, alleging that these defendants conspired to obscure pricing data for these “crop inputs.” The plaintiffs claimed that this conspiracy, which included a group boycott of electronic sales platforms and price-fixing activities, forced them to pay artificially high prices. They sought to represent a class of individuals who had purchased crop inputs from the defendants or their authorized retailers dating back to January 1, 2014. The plaintiffs asserted violations of the Sherman Act, the Racketeer Influenced and Corrupt Organizations Act (RICO), and various state laws, seeking both damages and injunctive relief.After the cases were consolidated in the United States District Court for the Eastern District of Missouri, the defendants moved to dismiss the consolidated amended complaint. The district court granted the motion, finding that the plaintiffs failed to state a claim under the Sherman Act because they did not adequately allege parallel conduct among the defendants. The RICO claims were also dismissed with prejudice, and the court declined to exercise supplemental jurisdiction over the state law claims. The district court dismissed the antitrust claim with prejudice, noting that the plaintiffs had prior notice of the deficiencies and had multiple opportunities to amend.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiffs failed to adequately plead parallel conduct or provide sufficient factual detail connecting specific defendants to particular acts. It concluded that the complaint’s group pleading and conclusory allegations did not meet the plausibility standard required to survive a motion to dismiss. The court also ruled that the dismissal with prejudice was proper given the plaintiffs’ repeated failures to cure the deficiencies. View "Duncan v. Bayer CropScience LP" on Justia Law

A sheriff’s deputy found Robert Wilburn asleep in the driver’s seat of a Chevrolet Camaro that was parked partially off a roadway with its hazard lights flashing. An open beer can was visible in the center cup holder, and the deputy smelled alcohol and marijuana on Wilburn. Upon searching the Camaro, the deputy found a loaded handgun next to the center console, a box of ammunition, and an extra magazine. The vehicle was registered to Samira Swift, who had purchased the firearm eleven days earlier. Wilburn, a twice-convicted felon, was on parole at the time, having been released from home confinement the day before Swift purchased the firearm.Wilburn was indicted for unlawful possession of a firearm and ammunition as a felon. The United States District Court for the Eastern District of Arkansas admitted evidence of Wilburn’s 2021 conviction for the same offense under Federal Rule of Evidence 404(b), as well as evidence that Wilburn had been released on parole shortly before the firearm’s purchase. At trial, the jury found Wilburn guilty, and the court sentenced him to 100 months in prison.On appeal to the United States Court of Appeals for the Eighth Circuit, Wilburn challenged the district court’s evidentiary rulings and argued that the evidence was insufficient to support his conviction. The Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sufficiency of the evidence de novo. The court held that admitting Wilburn’s prior conviction and the parole release evidence was not an abuse of discretion, as both were relevant to knowledge and intent, and their probative value was not substantially outweighed by unfair prejudice. The court also concluded that the evidence was sufficient to sustain the conviction. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Wilburn" on Justia Law

After Jet Midwest International Co., Ltd. made a $6.5 million loan to Jet Midwest Group, LLC (JMG) for the purchase of a Boeing 737-700, JMG defaulted on repayment. Jet Midwest sued for breach of contract, and when it could not collect on its judgment due to JMG’s lack of funds, Jet Midwest brought claims under the Missouri Fraudulent Transfer Act against several individuals and entities (the Ohadi/Woolley defendants), alleging the improper transfer of assets to avoid payment. Following a bench trial, Jet Midwest prevailed on its claims, and the district court awarded money damages, interest, and set a schedule for further motions on attorney’s fees and costs.Previously, the United States District Court for the Western District of Missouri awarded Jet Midwest over $6.5 million in attorney’s fees and costs. The United States Court of Appeals for the Eighth Circuit vacated this award, finding the district court had not properly performed a lodestar calculation for attorney’s fees and had not analyzed which costs were recoverable under federal law. On remand, Jet Midwest reduced its fee request but sought a multiplier; the district court ultimately awarded $5.8 million in attorney’s fees, granted prejudgment interest at 14 percent, and included expert witness fees and other litigation costs. Both sides appealed aspects of this award.The United States Court of Appeals for the Eighth Circuit held that the district court properly calculated and awarded $5.8 million in attorney’s fees but erred in awarding expert witness fees as part of attorney’s fees, as Jet Midwest failed to provide sufficient evidence that such fees were recoverable under the relevant standards. The Eighth Circuit also held that the district court erred in applying a 14 percent prejudgment interest rate and ordered that Missouri’s statutory rate of nine percent should apply. Additionally, the court clarified that, after August 6, 2020, the federal postjudgment interest rate under 28 U.S.C. § 1961(a) governs. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with these rulings. View "Jet Midwest International Co., Ltd v. Ohadi" on Justia Law

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

A mother and her minor daughter, both citizens of El Salvador, entered the United States in 2017 without valid entry documents. The mother applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming that a criminal gang in El Salvador had repeatedly threatened her family with violence and kidnapping in attempts to extort money. Although her family partially complied with the gang’s demands and was not physically harmed, she asserted that returning to El Salvador would put her and her children at risk, as the gang had widespread influence and the Salvadoran government could not protect them.An immigration judge found the mother's testimony not credible due to inconsistencies and determined that, even if her testimony were credible, the threats did not amount to past persecution, the alleged social groups were not cognizable, and she could relocate within El Salvador. The judge denied all claims for relief. The Board of Immigration Appeals (BIA) affirmed, concluding that she had not established past persecution or a well-founded fear of future persecution. The BIA also determined that her argument that the immigration judge was biased was waived because she raised it only in a conclusory manner and abandoned it in her appellate brief.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s decision as the final agency action. The court held that the BIA properly applied its waiver rule and did not err in finding the due process claim waived, as the argument was inadequately raised and not meaningfully pursued. The court also concluded it lacked jurisdiction to review the Department of Homeland Security’s exercise of prosecutorial discretion regarding enforcement priorities. The petition for review was denied. View "Quijano-Duran v. Bondi" on Justia Law