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

Betty Grooms, a Missouri clerk of court, filed a lawsuit under 42 U.S.C. § 1983 against Alice Bell and Judge Steven Privette, alleging violations of her First Amendment rights through discrimination and retaliation, and violations of her substantive due process rights. Grooms, a Republican, had defeated Bell, a Democrat, in an election for Circuit Clerk. Bell, who retained her job under Grooms, later married Privette, a Republican judge. Tensions arose when Bell and Privette were uncooperative with Grooms, leading to Bell's resignation and announcement to run for Circuit Clerk. Privette ordered Grooms to prepare detailed spreadsheets, which he repeatedly rejected, and initiated a contempt prosecution against her, which was eventually dismissed by the Missouri Supreme Court.The United States District Court for the Western District of Missouri dismissed Grooms's claims, ruling that the defendants did not violate her clearly established First Amendment rights and did not violate her substantive due process rights. The court found that the defendants' actions did not constitute adverse employment actions under clearly established law and that Grooms did not suffer a serious deprivation of a protected interest.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 Bell and Privette were entitled to qualified immunity on the First Amendment claim, as Grooms failed to show that their actions constituted adverse employment actions under clearly established law. Additionally, the court found that Grooms's substantive due process claim was inadequate, as she did not demonstrate a serious deprivation of a protected interest. The court concluded that the defendants' conduct did not shock the conscience and did not violate Grooms's substantive due process rights. View "Grooms v. Privette" on Justia Law

Wesley T. Vavra was charged with one count of attempted coercion and enticement of a minor after he arrived at a meeting place with items intended for a minor, believing he was meeting a father and his 8-year-old daughter, "Emma." The "father" was an undercover officer, and "Emma" did not exist. Vavra had engaged in explicit communications with the officer, expressing interest in meeting and engaging in sexual activities with the fictitious child.The United States District Court for the District of Nebraska held a jury trial, during which Vavra's motion for a judgment of acquittal was denied. The jury found Vavra guilty, and the district court sentenced him to 235 months in prison. Vavra appealed the conviction and sentence, arguing insufficient evidence and entrapment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Vavra guilty of attempted coercion and enticement of a minor, as he took substantial steps toward committing the crime, including reinitiating contact and planning a meeting. The court also found that Vavra was not entrapped, as he showed predisposition and was not coerced by the undercover officer. The court affirmed the district court's denial of Vavra's motion for a judgment of acquittal.Regarding the sentence, the Eighth Circuit reviewed for procedural and substantive reasonableness. The court found no procedural errors and held that the district court did not abuse its discretion in sentencing Vavra to 235 months, considering the nature of the offense and Vavra's actions. The court affirmed the judgment, concluding that the sentence was reasonable and appropriate given the circumstances. View "United States v. Vavra" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Deshonte Antwon Dickson was charged with conspiracy to distribute heroin and methamphetamine. At his trial, witnesses testified that Dickson supplied methamphetamine and heroin from California to North Dakota. The jury convicted him of conspiring to distribute heroin and between 50 and 500 grams of methamphetamine. The Presentence Investigation Report (PSR) calculated a base offense level of 26, resulting in an advisory guidelines range of 63 to 78 months imprisonment. However, the district court varied upward and sentenced Dickson to 120 months, finding him to be an essential participant in the conspiracy.The United States District Court for the District of North Dakota initially sentenced Dickson to 120 months imprisonment, but the Eighth Circuit Court of Appeals remanded for resentencing due to procedural errors. The district court had varied upward from the guidelines range without providing adequate notice. On remand, the district court gave notice of its intent to vary upward again and reimposed the 120-month sentence, citing Dickson's significant role in the conspiracy.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no procedural error in the district court's resentencing, as it had provided proper notice and based its decision on the trial evidence. The court also found the sentence substantively reasonable, noting that the district court had considered the statutory sentencing factors and the nature of Dickson's involvement in the conspiracy. The Eighth Circuit affirmed the district court's judgment, upholding the 120-month sentence. View "United States v. Dickson" on Justia Law

Curtis Temple, a cattle rancher and member of the Oglala Sioux Indian Tribe (OST), had his grazing permits on the Pine Ridge Indian Reservation expire on October 31, 2012. He reapplied for new permits, but another OST member, Donald Buffington, also applied. The OST allocation committee found Temple had over 1,600 cattle, exceeding the 300 animal unit limit, making Buffington the eligible applicant. Temple's permits were awarded to Buffington, and Temple's appeals to the OST executive committee and the Bureau of Indian Affairs (BIA) were unsuccessful. Temple continued to graze his cattle on the land allocated to Buffington, leading to multiple trespass notices and eventual impoundment of his cattle by the BIA.Temple filed a lawsuit in the District of South Dakota in August 2015, seeking a temporary restraining order (TRO) and contesting the permit allocation. The district court denied the TRO and dismissed Temple's permit allocation claims, requiring him to exhaust administrative remedies. Temple's due process claims regarding the impoundment of his cattle proceeded, but the district court found that the written notices of trespass provided to Temple were sufficient and did not violate his due process rights. Temple's motion to continue the trial was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Temple was provided due process through the written notices of trespass and had ample opportunity to contest the trespass determinations. The court also affirmed the dismissal of Temple's permit allocation claims for failure to exhaust tribal remedies, as he did not appeal the tribal court's decision. Lastly, the court found no abuse of discretion in the district court's denial of Temple's motion to continue the trial. The judgment of the district court was affirmed. View "Curtis Temple v. Roberts" on Justia Law

Devin Nunes, a former Member of Congress, along with NuStar Farms, LLC, and its owners, sued journalist Ryan Lizza and Hearst Magazine Media, Inc., for defamation. The lawsuit stemmed from an article published by Esquire, which implied that Nunes and his family were hiding the fact that NuStar Farms employed undocumented labor. The plaintiffs alleged both express defamation and defamation by implication.The United States District Court for the Northern District of Iowa initially dismissed Nunes's express defamation claim but allowed the defamation by implication claim to proceed. On remand, Nunes filed an amended complaint focusing solely on defamation by implication. NuStar Farms and its owners also filed a new lawsuit alleging both express defamation and defamation by implication. The district court consolidated the cases and ultimately granted summary judgment for the defendants, ruling that the plaintiffs failed to create a genuine dispute of material fact on certain elements of their defamation claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that Nunes did not present sufficient evidence to prove special damages, which are required under California law for defamation claims when general and exemplary damages are not recoverable due to failure to comply with the notice and demand statute. Nunes's claims of impaired career opportunities and diminished fundraising ability were unsupported by evidence.For the NuStar plaintiffs, the court applied Iowa law and found insufficient evidence of economic harm or reputational damage. The plaintiffs failed to demonstrate a preexisting good reputation that could have been damaged by the article. Consequently, the Eighth Circuit affirmed the district court's summary judgment in favor of the defendants. View "Nunes v. Ryan" on Justia Law

Iowa enacted Senate File 2340, which criminalizes the presence of aliens who have illegally reentered the United States within its boundaries. The Act mandates that aliens violating it must return to the country they reentered from and prohibits judges from abating state prosecutions due to pending or possible federal determinations of the alien’s immigration status. The United States sought a preliminary injunction against the enforcement of the Act, which the district court granted. Iowa appealed the decision.The United States District Court for the Southern District of Iowa ruled that the United States had standing to sue and could state a cause of action to enjoin the Act. The court found that the United States established a likelihood of success on the merits, showing that federal immigration law preempts the Act under both conflict and field preemption. The court also found that irreparable harm would occur if the Act went into effect and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, examining factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s decision, holding that the United States had standing and an equitable cause of action to enjoin the Act. The court found that the Act likely conflicts with federal immigration law, as it obstructs the discretion of federal officials and creates a parallel enforcement scheme. The court also agreed that the United States demonstrated irreparable harm and that the balance of equities and public interest favored the injunction. The preliminary injunction against the enforcement of the Act was affirmed. View "United States v. State of Iowa" on Justia Law

CEZ Prior, LLC ("CEZ") entered into a purchase agreement with 755 N Prior Ave., LLC ("Prior") to buy a property for $26 million. The agreement required Prior to cooperate in obtaining tenant estoppel certificates. Errors in square footage measurements led to rent discrepancies, prompting an amendment to reduce the purchase price to $15.1 million and the cash required at closing to $3.8 million. CEZ later requested to delay closing due to financial issues, but Prior did not agree. Prior sent estoppel certificates that did not address rate increases, and CEZ proposed edits that Prior rejected. CEZ demanded satisfactory certificates on the closing date, but Prior terminated the agreement, alleging CEZ failed to tender cash.CEZ sued Prior for breach of contract in Minnesota state court and sought to enjoin the termination. Prior removed the case to federal court and counterclaimed for breach of contract. The district court stayed the matter and later denied CEZ's motion for a preliminary injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court's denial of the preliminary injunction. The court found that CEZ was unlikely to succeed on the merits of its breach of contract claim, as Prior had reasonably cooperated in obtaining the estoppel certificates. The balance of harms favored Prior, given CEZ's insufficient evidence of its ability to pay. The public interest did not favor CEZ due to its low probability of success on the merits.The court also addressed CEZ's argument under Minnesota law, finding that the district court's stay order was not an injunction and did not extend statutory deadlines. Consequently, CEZ was not entitled to additional time to close under Minnesota statutes. The Eighth Circuit affirmed the district court's judgment. View "CEZ Prior, LLC v. 755 N Prior Ave. LLC" on Justia Law

John Doe filed a putative class action against SSM Health Care Corporation in Missouri state court, alleging that SSM shared private health information with third-party marketing services without authorization, violating Missouri law. Doe claimed that SSM's MyChart patient portal transmitted personal health data to third-party websites like Facebook. The lawsuit included nine state law claims, such as violations of the Missouri Wiretap Statute and the Computer Tampering Act.SSM removed the case to federal court, citing the federal officer removal statute and the Class Action Fairness Act (CAFA). Doe moved to remand the case to state court. The United States District Court for the Eastern District of Missouri rejected SSM's arguments, ruling that SSM was not "acting under" a federal officer and that Doe's proposed class was limited to Missouri citizens, thus lacking the minimal diversity required under CAFA. The district court remanded the case to state court.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that SSM did not meet the criteria for federal officer removal because it was not acting under the direction of a federal officer. The court also held that the proposed class was limited to Missouri citizens, which destroyed the minimal diversity necessary for CAFA jurisdiction. Consequently, the Eighth Circuit affirmed the district court's remand order. View "Doe v. SSM Health Care Corporation" on Justia Law

Monsanto Company, Pharmacia, LLC, and Solutia, Inc. (collectively, "Monsanto") filed a lawsuit in St. Louis County Circuit Court in Missouri against Magnetek, Inc., General Electric Co. ("GE"), Paramount Global, KYOCERA AVX Components Corporation, Cornell Dubilier Electronics, Inc., and The Gillette Company LLC (collectively, "Defendants"). Monsanto alleged that it continues to incur substantial costs to defend against PCB lawsuits that should be borne by Defendants and sought to enforce written agreements obligating Defendants to defend, indemnify, and hold Monsanto harmless in all currently pending and future PCB lawsuits.GE removed the action to federal court, asserting jurisdiction under the federal officer removal statute, 28 U.S.C. § 1442(a)(1). The United States District Court for the Eastern District of Missouri granted Monsanto’s motion to remand, finding that GE's removal was untimely. GE appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the parties had waived Missouri Supreme Court Rule 54.13(c)’s personal service provision and expressly agreed that January 31, 2023, was the effective date for service of process. The court determined that the 30-day removal period began on the agreed effective date of service, not when GE signed the acknowledgment and waiver of service of process or when Monsanto filed the document. Consequently, GE's notice of removal was filed within the 30-day period, making the removal timely.The Eighth Circuit vacated the district court’s order of remand and remanded the case for further proceedings consistent with its opinion. The court declined to address whether GE satisfies the government contractor requirement of 28 U.S.C. § 1442(a)(1), as this issue was not addressed by the district court. View "Monsanto Company v. General Electric Co." on Justia Law