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

After the death of Dana Kleinsteuber, her husband, Charles Kleinsteuber, sought accidental death and dismemberment (AD&D) benefits under an ERISA-governed insurance plan administered and insured by Metropolitan Life Insurance Company (MetLife). Dana Kleinsteuber, who suffered from end-stage renal disease (ESRD) due to a long history of an eating disorder, was using home dialysis as treatment. On the day of her death, she apparently failed to properly close her chest port after a dialysis session, resulting in severe blood loss and subsequent cardiac arrest. Emergency responders stopped the bleeding, but she died shortly after.MetLife initially denied the claim on the basis that Dana’s death resulted from natural causes related to her ESRD, and that an exclusion in the plan applied for losses caused or contributed to by illness or its treatment. Following an extensive administrative appeal submitted by Mr. Kleinsteuber, which included evidence from Dana’s doctor and other records, MetLife reconsidered and acknowledged the death was accidental. However, it maintained the exclusion applied because the death was caused or contributed to by the treatment for her ESRD. After Mr. Kleinsteuber exhausted his administrative remedies, he filed suit in the United States District Court for the District of Minnesota. The district court granted summary judgment for MetLife, finding the exclusion applicable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that MetLife provided a full and fair review and that its conflict of interest deserved little weight. The court interpreted the plan exclusion de novo, finding that the ordinary meaning of “caused or contributed to” included Dana’s death under these circumstances. Applying an abuse-of-discretion standard to MetLife’s ultimate decision, the court found substantial evidence supported the denial. As a result, the Eighth Circuit affirmed the district court’s judgment, upholding MetLife’s denial of benefits. View "Kleinsteuber v. Metropolitan Life Ins. Co." on Justia Law

Elisa Lopez-Vasquez, a native and citizen of Guatemala, entered the United States illegally in 2004 and lived in Carthage, Missouri for about twenty years. She is the mother of six children who are U.S. citizens and married a Guatemalan citizen in 2021. In August 2024, the Department of Homeland Security charged her with being present in the United States without admission or parole. Lopez-Vasquez conceded removability and sought cancellation of removal, citing hardship to her children, and also requested voluntary departure.The Immigration Judge in Kansas City, Missouri, denied both requests. The judge found Lopez-Vasquez ineligible for cancellation of removal due to a prior Missouri conviction for a crime of child abuse and concluded she had not proven that her removal would cause her children “exceptional and extremely unusual hardship.” The judge also denied voluntary departure for lack of valid travel documents. Lopez-Vasquez appealed to the Board of Immigration Appeals, which affirmed the denial based on insufficient hardship and the absence of travel documents for voluntary departure. The Board also denied her motion to remand for consideration of new hardship evidence, finding the evidence neither material nor previously unavailable.Lopez-Vasquez then petitioned the United States Court of Appeals for the Eighth Circuit for review, arguing violations of due process and misapplication of the legal standards. The Eighth Circuit held that because cancellation of removal is a discretionary form of relief, Lopez-Vasquez had no constitutionally protected liberty interest in it, so her due process claims failed. The court further found that substantial evidence supported the Board’s hardship determination, and that the Board did not abuse its discretion in denying the motion to remand. The court dismissed as moot her voluntary departure claim, as she had already been removed to Guatemala, and ultimately denied her petition for review. View "Lopez-Vasquez v. Bondi" on Justia Law

Michelle Lee Marr was charged after the death of her boyfriend, Jesse Gilpin, who was found unresponsive and later died from injuries. After Marr called 911, medical personnel observed bruises on Gilpin concealed with makeup. Marr made conflicting statements about who applied the makeup. Law enforcement conducted three interviews with Marr at her home or her mother’s home, during which she voluntarily provided her cell phone and, days later, signed a written consent for a search of the device. At trial, the government introduced her statements from the interviews and photographic evidence from her phone depicting Gilpin’s injuries.The United States District Court for the District of Nebraska denied Marr’s motions to suppress her statements and the cell phone evidence, finding she was not in custody during the interviews and consented voluntarily to the phone search. The court also admitted limited evidence under Federal Rule of Evidence 404(b) of prior violent acts Marr had committed against Gilpin, concluding that the probative value was not substantially outweighed by prejudice. Marr was convicted by a jury of second-degree murder and tampering with documents or proceedings and sentenced to 300 months for murder and 240 months for tampering, to be served concurrently.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings and judgment. The court held that Marr was not “in custody” for Miranda purposes during any interview, so warnings were not required; her consent to the phone search was knowing and voluntary; and the admission of prior violent acts was not an abuse of discretion. The court determined that sufficient evidence supported both convictions and that the sentence imposed was substantively reasonable. The judgment of the district court was affirmed. View "United States v. Marr" on Justia Law

While detained at the McLean County Detention Center, Dirk Alan Christianson developed a severe leg infection that ultimately resulted in the amputation of his leg above the knee. During his incarceration, Christianson sought medical attention several times and was treated both within and outside the jail, including being evaluated by a jail nurse and a family nurse practitioner. After displaying symptoms such as fever and pain, Christianson was transported to an outside clinic where he was evaluated, tested, and given instructions for follow-up. His condition deteriorated over the next several days, leading to hospitalization, a diagnosis of necrotizing fasciitis, and amputation.Christianson brought suit in the United States District Court for the District of North Dakota against McLean County, jail officials, medical staff, and the outside clinic, asserting claims under 42 U.S.C. § 1983 for deliberate indifference to serious medical needs, Monell municipal liability, and state law medical malpractice. The district court dismissed the Monell and medical malpractice claims, granted summary judgment to all defendants on the deliberate indifference claims, and denied Christianson’s motion to amend his complaint to identify and add John Doe defendants.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that Christianson failed to allege facts sufficient to support municipal liability under Monell, as the complaint did not set forth a specific policy or widespread custom causing constitutional harm. The court also determined that the evidence did not support claims of deliberate indifference by the sheriff, jail nurse, or family nurse practitioner, finding no facts showing that these individuals knew of and disregarded a serious medical need. Additionally, the court ruled that Christianson’s motion to amend was untimely and properly denied, and that dismissal of the John Doe defendants was appropriate. Finally, the court affirmed dismissal of the state law medical malpractice claim, concluding that the required expert affidavit was not timely served. View "Christianson v. McLean County" on Justia Law

General Electric Company (GE) was assessed withdrawal liability by the Boilermaker-Blacksmith National Pension Trust (the Fund) under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which amended the Employee Retirement Income Security Act (ERISA). The Fund claimed that GE partially withdrew from the plan based on a 70% decline in contribution base units (CBUs) and the closure of a manufacturing facility in Chattanooga, resulting in liability assessments totaling over $227 million. GE disputed these assessments, arguing that it qualified for the “building and construction industry” (BCI) exception, which exempts certain employers from withdrawal liability if substantially all their covered employees perform work in the building and construction industry.An arbitrator considered the dispute and found in favor of GE, concluding that it met the requirements for the BCI exception. Both parties sought review in the United States District Court for the Western District of Missouri, which affirmed the arbitrator’s decision. The district court determined that the statutory language was ambiguous regarding how to count employees for the purpose of the BCI exemption and adopted GE’s cumulative headcount method rather than the Fund’s preferred monthly headcount method.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and examined the ambiguity in the statutory language. The Court held that, of the two methods presented, the cumulative headcount approach advanced by GE was more consistent with the purpose and legislative intent of the statute, which was designed to accommodate the fluctuating nature of employment in the building and construction industry. The Court affirmed the district court’s judgment, holding that GE qualified for the building and construction industry exemption and was not liable for withdrawal assessments. View "General Electric Company v. Boilermaker-Blacksmith National Pension Trust" on Justia Law

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials.The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

On November 18, 2022, a confrontation took place in downtown Waterloo, Iowa, involving members of two rival gangs. Quintorey Kemp, associated with the "Only the Brothers" gang, had previously displayed a firearm at a barbershop during an encounter with members of the "All About Action" gang, including Andrew Spates and Keivon Anderson. Laindrell Cooper, also affiliated with "All About Action," arrived at the scene dressed in all black and wearing a mask, having been dropped off nearby. Surveillance footage captured Cooper approaching the barbershop, walking past waiting vehicles, and ultimately pursuing Kemp, firing multiple shots at him as Kemp fled.Cooper was charged in the United States District Court for the Northern District of Iowa with possession of a firearm by a prohibited person and possession of ammunition by a felon. He pleaded guilty to the ammunition charge. During sentencing, the district court applied the attempted murder cross-reference in the Sentencing Guidelines, concluding by a preponderance of the evidence that Cooper had attempted to murder Kemp. The district court rejected Cooper's arguments that he acted in self-defense or imperfect self-defense, finding no credible evidence that Cooper reasonably believed he or others were in imminent danger, and instead determined Cooper was the aggressor.The United States Court of Appeals for the Eighth Circuit reviewed Cooper’s appeal. The court held that Cooper’s constitutional challenge to 18 U.S.C. § 922(g)(1) was foreclosed by binding Eighth Circuit precedent. The court further held that the district court did not clearly err in its factual findings regarding Cooper's intent and the lack of justification for self-defense or imperfect self-defense, and properly applied the cross-reference for attempted murder in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Cooper" on Justia Law

On September 15, 2022, a woman named Nyvelle Quick Bear was fatally shot while inside Justin Bradford’s house. Initially, Bradford told authorities the shooting was accidental and involved a .22 caliber revolver. However, forensic evidence showed that Quick Bear was killed by a .45 caliber bullet fired from outside the house. Surveillance footage and witness testimony identified Clayton Fire Thunder as the person who approached Bradford’s house with a gun after having been drinking heavily. Testimony and forensic evidence indicated that Fire Thunder fired the shot that killed Quick Bear. Fire Thunder later denied possessing a gun during two separate interviews with law enforcement.Fire Thunder was indicted in the United States District Court for the District of South Dakota on charges of involuntary manslaughter and making false statements to federal law enforcement. At trial, the jury found him guilty on all counts. The district court determined the offense levels for the convictions, applied a three-level enhancement for substantial interference with the administration of justice regarding the false statement convictions, and grouped the offenses under the Sentencing Guidelines. Ultimately, the court imposed a total sentence of 96 months, which included upward variance to the statutory maximums.On appeal to the United States Court of Appeals for the Eighth Circuit, Fire Thunder challenged the sentencing enhancement, the substantive reasonableness of his sentence, and the sufficiency of the evidence. The Eighth Circuit held that any error in applying the enhancement was harmless because it did not affect the Guideline range or the sentence imposed. The court also found no abuse of discretion in the upward variance and statutory maximum sentence, concluding that the district court reasonably considered aggravating factors. Finally, the appellate court held that sufficient evidence supported each conviction. The judgment of the district court was affirmed. View "United States v. Thunder" on Justia Law

On January 9, 2022, Sam Sando was involved in two significant events. Early that morning, he had a domestic dispute with Asatu Abalo, during which he allegedly threatened her with a firearm and warned her that there would be gunfire the next day. Later that evening, Sando and his cousin arranged to meet Andrew Meyer, who had earlier tried to sell Sando fake marijuana. When Meyer and two companions arrived at the meeting point, Sando and his cousin approached the vehicle with guns drawn and fired at them, resulting in the death of one occupant. Both Sando and his cousin fled but were arrested a week later. Although Sando was acquitted of first-degree murder in state court, he was subsequently prosecuted in federal court on charges related to attempted robbery, drug trafficking, and firearm use.At the United States District Court for the Southern District of Iowa, the government dismissed one count before trial, and a jury found Sando guilty on three remaining counts: attempted interference with commerce by robbery, attempted possession with intent to distribute a controlled substance, and carrying a firearm during and in relation to a drug trafficking crime. Sando challenged several of the district court’s evidentiary decisions, including the exclusion of Abalo’s state court deposition, the exclusion of a portion of another witness’s prior testimony, limitations on impeachment of a government witness, and the admission of evidence related to the domestic dispute.The United States Court of Appeals for the Eighth Circuit reviewed each of Sando’s claims for abuse of discretion. The court held that the district court did not abuse its discretion in excluding the deposition and prior testimony, limiting impeachment, or admitting evidence of the domestic dispute, either because the evidence was inadmissible under the rules or any error was harmless. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Sando" on Justia Law

A police officer in Williston, North Dakota, stopped a driver after observing an illegal turn late at night on New Year’s Eve. Noticing signs of alcohol intoxication, the officer conducted field-sobriety tests. During a subsequent interaction, the driver became argumentative and declined to answer whether he would agree to an additional alcohol screening. At that point, according to the complaint, the officers forcefully grabbed the driver without warning, commanded him to put his hands behind his back, and—assisted by a second officer—took him to the ground and handcuffed him. The driver alleges he suffered physical injuries and emotional harm as a result and sued both officers for using excessive force in violation of his Fourth Amendment rights.The United States District Court for the District of North Dakota granted the officers’ motion to dismiss, holding that their use of force was de minimis and, in the alternative, that it was objectively reasonable. The district court relied on dash-camera and body-camera footage, finding the videos consistent with the pleadings.Reviewing the case on appeal, the United States Court of Appeals for the Eighth Circuit applied a de novo standard to the motion to dismiss. The appellate court found that the video evidence did not conclusively contradict the plaintiff’s allegations regarding the severity of force or the absence of resistance. The court further held that, under clearly established law, force is least justified against nonviolent misdemeanants who do not actively resist arrest or pose a threat. Since the complaint alleged facts that, if true, would constitute a violation of clearly established rights, and the video evidence did not refute those allegations, the Eighth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Young v. Keyes" on Justia Law