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

After enduring physical and sexual abuse while in the care of James and Susan McLaurie as a young child, the plaintiff obtained a $150 million judgment against both individuals in Missouri state court. Seeking to collect on this judgment, the plaintiff subsequently filed a new action in state court against the McLauries and their homeowner’s insurer, Liberty Mutual, asserting equitable garnishment claims against all three and additional claims, including bad faith and breach of contract, against Liberty Mutual.Liberty Mutual removed the action to the United States District Court for the Eastern District of Missouri, invoking diversity jurisdiction. At the time of removal, James McLaurie had not yet been served but later entered an appearance. The plaintiff moved to remand, arguing a lack of complete diversity, and James McLaurie joined this motion, expressly refusing to consent to removal. The district court disagreed that diversity was lacking but found that the absence of consent from all defendants rendered removal procedurally defective under the requirement of unanimity in 28 U.S.C. § 1446(b)(2)(A). The court granted remand on this procedural ground.On appeal, the United States Court of Appeals for the Eighth Circuit examined whether it had jurisdiction to review the district court’s remand order. The appellate court held that, under 28 U.S.C. § 1447(d), remand orders based on procedural defects—such as a lack of unanimity among defendants—are not reviewable, so long as the district court’s basis was at least “colorably” procedural. The court determined that the district court’s characterization of its order as resting on a procedural defect was colorable. Accordingly, the Eighth Circuit dismissed the appeal for lack of jurisdiction. View "G.T. v. Liberty Mutual Fire Insurance Company" on Justia Law

After receiving reports that Tyler Denby threatened several individuals in Alliance, Nebraska, law enforcement located him sitting in his vehicle. Upon observing a marijuana pipe in his pocket, officers searched Denby and his vehicle, finding various electronic devices, children’s items, and a collection of girls’ underwear. This discovery led investigators to obtain a warrant to search Denby’s SD cards, which contained child pornography. Denby subsequently confessed to possessing and transporting child pornography across state lines.The United States District Court for the District of Nebraska presided over Denby’s trial. Denby moved to suppress the evidence from his vehicle and his confessions, but the court denied the motion. He also sought to reopen the suppression hearing based on new evidence, which was denied as untimely and futile by a magistrate judge. Denby filed motions in limine to exclude certain evidence, which the court granted in part and denied in part. A jury convicted Denby of transporting and possessing prepubescent child pornography, and the district court sentenced him to 262 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit addressed Denby’s claims regarding his competency, the suppression motion, evidentiary rulings, and the reasonableness of his sentence. The court held that the district court did not abuse its discretion by not ordering a competency evaluation or by admitting certain evidence, including the girls’ underwear, for non-propensity purposes under Rule 404(b)(2). The appellate court found no error in denying suppression or reopening the hearing and concluded that the sentence was substantively reasonable. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Denby" on Justia Law

In August 2020, Joshua Brooks, accompanied by several friends, went to confront a family in Fargo, North Dakota, believing they had stolen from him. One member of the group, Jesse Burnett, fired a gun at the family, resulting in the death of a man. The investigation into the shooting stalled until 2022, when Andeus Smith, involved in a separate federal firearms case, provided information that reopened the case and led to Brooks’s arrest on state murder charges. Brooks agreed to cooperate with federal and state law enforcement, providing details that led to Burnett’s arrest. Both Brooks and Burnett were subsequently held at the Cass County Jail, where Shaquiel Mendez was also incarcerated. Mendez, who interacted with both Brooks and Burnett, facilitated the sharing of discovery materials within the jail. After receiving these materials, Brooks was confronted and assaulted by another inmate, Daniel Cisse, while Mendez and others acted as lookouts.Following these events, Mendez was indicted in the United States District Court for the District of North Dakota on one count of conspiracy to tamper with a witness, in violation of 18 U.S.C. § 1512(k). A jury found Mendez guilty. On appeal to the United States Court of Appeals for the Eighth Circuit, Mendez argued that the government had not provided sufficient evidence to establish the necessary federal nexus for conviction under the statute.The Eighth Circuit reviewed whether the government proved it was reasonably likely that Brooks would communicate with federal law enforcement officers regarding a federal offense, as required by § 1512(a)(2)(C), referencing the Supreme Court’s decision in Fowler v. United States. The court found that, given Brooks’s previous cooperation with federal authorities and the ongoing nature of the investigation, it was reasonably likely such communication would occur. Thus, the court affirmed Mendez’s conviction, concluding that the government had met its burden to establish the required federal nexus. View "United States v. Mendez" on Justia Law

The defendant pleaded guilty in 2016 to conspiring to distribute and possess with intent to distribute cocaine base and was sentenced to 292 months in prison, followed by eight years of supervised release. In January 2025, the President granted him executive clemency, resulting in his early release from prison in July 2025, at which point he began supervised release. The district court modified his supervised release conditions to require up to 120 days at a residential reentry center. Within two weeks of his release, he was terminated from the reentry center for violating rules and was later found to have violated another condition by traveling more than fifty miles from his residence without notifying his probation officer. He declined a modification offer, leading the Probation Office to initiate revocation proceedings.The United States District Court for the Western District of Missouri held a revocation hearing, found two Grade C violations, revoked his supervised release, and sentenced him to 14 months in prison, at the top of the recommended guidelines range, with additional supervised release to follow. The court reimposed the same employment and potential community service conditions as before. The defendant appealed, arguing that his revocation sentence improperly considered retributive factors barred by the Supreme Court’s decision in Esteras v. United States, and that the community service condition impermissibly authorized more than 400 hours without justification, contrary to circuit precedent.The United States Court of Appeals for the Eighth Circuit held that the district court did not violate Esteras because it did not rely on forbidden retributive considerations under 18 U.S.C. § 3553(a)(2)(A) in imposing the revocation sentence. The appellate court affirmed the sentence of imprisonment and revocation. However, it remanded the case for the district court to consider whether to modify the community service condition in light of policy guidance that generally limits such service to 400 hours and to provide an explanation for its decision. View "United States v. Redmon" on Justia Law

In this case, a man was involved in a fight between rival gangs in downtown Des Moines, Iowa. Law enforcement broke up the fight, but it resumed later, leading to a chase. During the pursuit, a bystander informed officers that the man had a gun. When confronted, he fled but was quickly apprehended. Officers found a loaded pistol and marijuana on him, and subsequent testing confirmed drug use. He was indicted for possessing a firearm as an unlawful drug user under federal law.Previously, the United States District Court for the Southern District of Iowa denied his motion to dismiss the indictment, in which he argued that the statute violated his Second Amendment rights and was unconstitutionally vague. He entered a conditional guilty plea, preserving his right to appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s ruling on the vagueness issue but found the record insufficient to resolve the as-applied Second Amendment challenge, remanding for further proceedings. On remand, the district court held a bench trial on stipulated facts, found him guilty, conducted an evidentiary hearing, and again denied his motion to dismiss, concluding that the statute did not violate the Second Amendment as applied to him.The United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to dismiss de novo and affirmed. The court held that the government bears the burden of showing, by a preponderance of the evidence, that the application of the statute is consistent with this nation’s historical tradition of firearm regulation. The court concluded that the man’s conduct—chronic drug use, gang involvement, and aggressive behavior while armed—was sufficiently analogous to conduct historically prohibited under Founding-era “going armed to terrorize” laws. Thus, the statute was constitutional as applied to him, and the district court’s denial of the motion to dismiss was affirmed. View "United States v. Baxter" on Justia Law

Several local iron workers unions and their associated trust fund boards sued a Tennessee-based company, alleging that the company failed to make required contributions for work performed by its employees within the unions’ territorial jurisdiction. The plaintiffs claimed the company was obligated to make these contributions under collective bargaining agreements with the unions, and they sought to recover the amounts they alleged were owed, including interest and damages.The United States District Court for the Eastern District of Missouri handled the case. During discovery, the defendant company moved to exclude the testimony of the plaintiffs’ witness, Bradley Soderstrom, arguing he was an undisclosed expert and his damages calculations were speculative. The district court agreed, excluding Soderstrom’s expert opinions and associated audit reports because the plaintiffs had not disclosed him as an expert and his calculations relied on unsupported assumptions. The district court granted summary judgment in favor of the company on one claim after finding the company was not a party to the relevant agreement, and on the remaining claims due to lack of admissible evidence of damages. The court also awarded attorneys’ fees to the company but did not set an amount. Plaintiffs appealed, challenging the exclusion of Soderstrom’s testimony, the grant of summary judgment, and the award of attorneys’ fees.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s exclusion of Soderstrom’s testimony, noting that plaintiffs failed to contest the finding that his damages model was speculative. The appellate court also affirmed summary judgment for the company because plaintiffs had no admissible evidence of damages without Soderstrom’s expert analysis. The court dismissed the appeal regarding attorneys’ fees, finding it was not ripe since the district court had not yet determined the fee amount. View "Iron Workers STL Pension Fund v. Barnhart Crane & Rigging Co." on Justia Law

Jackie Lackie owned property adjacent to Greers Ferry Lake, a federally managed lake in Arkansas. In January 2022, park rangers discovered sixty-nine trees had been cut down on government land between Lackie’s property and the lake. The Army Corps of Engineers identified Lackie as responsible, filed a notice of trespass, and sent Lackie a letter offering to settle the violation if he paid for the tree damage. The letter also indicated the Corps was recommending revocation of his shoreline use permit for a boat dock. Enclosed was a settlement agreement stating the parties intended to settle “all known disputes” regarding the public lands. Lackie signed the agreement and paid the requested sum, but the Corps subsequently revoked his shoreline use permit.Lackie challenged the revocation in the United States District Court for the Eastern District of Arkansas, seeking judicial review under the Administrative Procedure Act. He argued the Corps’s action breached the settlement agreement, which he contended had resolved all disputes, including the permit issue. The district court affirmed the Corps’s decision, reasoning that the letter accompanying the settlement made clear that the permit revocation was not resolved by the agreement, so the Corps did not violate the agreement by revoking the permit.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The court held that under the applicable federal common law, guided by Arkansas law, the unambiguous language of the settlement agreement encompassed “all known disputes,” including the dispute over Lackie’s permit. The Eighth Circuit concluded that the Corps’s revocation of Lackie’s permit contravened the settlement agreement and constituted unlawful agency action. The court reversed the district court’s judgment, remanding with instructions to set aside the Corps’s permit revocation. View "Lackie v. Noe" on Justia Law

On February 23, 2023, Cedar Rapids police, acting on information from a confidential informant, surveilled Robert Lee Drayton, Jr., who was suspected of packaging and distributing methamphetamine. Officers observed Drayton engage in several brief encounters consistent with drug transactions throughout the day. They conducted an initial traffic stop, discovering a firearm, MDMA pills, and methamphetamine, but did not detain Drayton. Later, after observing what appeared to be a delivery of a bag to Drayton’s vehicle, police initiated a second traffic stop after observing Drayton’s car hit the fog line multiple times and change lanes without signaling. During this stop, a canine unit alerted to the presence of drugs, leading to the discovery of a duffel bag containing several kilograms of methamphetamine and another firearm. Drayton was arrested, and subsequent searches of his home and cellphones yielded additional drugs, firearms, cash, and evidence of drug transactions.Drayton moved to suppress the evidence from the second stop, his stationhouse statements, the search of his home, and drug tests, arguing the stop lacked probable cause or reasonable suspicion and was unlawfully prolonged for the canine sniff. The United States Magistrate Judge for the Northern District of Iowa conducted an evidentiary hearing and recommended denial of the motion, finding the officers credible and concluding the stop and subsequent searches were constitutional. The United States District Court for the Northern District of Iowa adopted the recommendation, and Drayton entered a conditional guilty plea.The United States Court of Appeals for the Eighth Circuit affirmed. The court held that the second traffic stop was supported by reasonable suspicion based on Drayton’s observed driving and collective law enforcement knowledge of his suspected drug activity. The canine sniff did not unlawfully prolong the stop, and there was probable cause for the vehicle search. All challenged evidence was lawfully seized, and Drayton’s constitutional rights were not violated. View "United States v. Drayton" on Justia Law

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