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

A man named Austen May died by suicide while incarcerated at a Missouri Department of Corrections (MODOC) facility in July 2021, following a prior suicide attempt and ongoing mental health treatment. Correctional officers and a supervising sergeant failed to perform required periodic checks of May’s cell for nearly three hours, during which May obscured the cell window. When officers eventually entered, May was found deceased. Kristine Williams, May’s mother, filed suit against MODOC and several employees, alleging state law wrongful death and federal constitutional claims, including deliberate indifference to a suicide risk.The United States District Court for the Eastern District of Missouri denied motions to dismiss brought by MODOC, Loflin, Yount, and Noisworthy. The court held that MODOC was not entitled to sovereign immunity because Williams plausibly alleged a dangerous condition exception under Missouri law. It also found that the correctional officers and sergeant were not entitled to qualified immunity on the constitutional claim, reasoning that Williams sufficiently alleged they knew of May’s suicide risk and were deliberately indifferent. Additionally, the court denied official immunity for the state wrongful death claim, concluding that the required checks were ministerial duties and thus not protected, and found the public duty doctrine did not bar the claim.Reviewing the case, the United States Court of Appeals for the Eighth Circuit reversed the district court’s rulings. The appellate court held that Williams’s allegations did not plausibly establish a dangerous condition under Missouri law, so MODOC was entitled to sovereign immunity. It also found Williams failed to allege that the officers had actual knowledge of May’s suicide risk, entitling them to qualified immunity. Lastly, the court determined the duties in question were discretionary, not ministerial, so official immunity applied. The case was remanded for further proceedings. View "Williams v. MO Department of Corrections" on Justia Law

A lawful permanent resident, originally from the Philippines, was admitted to the United States in 1982. In 2013 and 2015, he pleaded guilty in California state court to receiving stolen property and possession of methamphetamine, respectively. Based on these convictions, the Department of Homeland Security initiated removal proceedings in 2024, charging him with inadmissibility as having committed a crime involving moral turpitude and a controlled substance offense. An Immigration Judge found both charges supported by the convictions and ordered his removal to the Philippines.The resident appealed this removal order to the Board of Immigration Appeals, challenging the finding that his property offense was a crime involving moral turpitude. The Board dismissed the appeal, agreeing with the Immigration Judge’s analysis, and declined to address the controlled substance conviction, finding the property offense alone sufficient to sustain removal. After being removed from the country, the resident moved to reopen his proceedings, arguing that his convictions had since been vacated by a California court. The Board denied this motion, relying on the “departure bar” regulation, which prohibits motions to reopen after removal, and concluded it lacked jurisdiction.The United States Court of Appeals for the Eighth Circuit reviewed both the Board’s dismissal of the appeal and the denial of the motion to reopen. The court held that the “departure bar” regulation, which prevents noncitizens from filing motions to reopen after removal, is invalid because it conflicts with the governing statute, which imposes no such geographic limitation. The court granted the petition as to the statutory motion to reopen, denied review regarding sua sponte reopening, and remanded the case to the Board for further proceedings. The main holding is that the Board cannot refuse to consider a statutory motion to reopen on the basis of the “departure bar” when the statute does not impose such a restriction. View "Lacsina v. Blanche" on Justia Law

Todd Sutton, Jr. was arrested in Iowa for driving with a suspended license, an aggravated misdemeanor. He was taken to the Cerro Gordo County Jail, where officials intended to place him in a communal intake dormitory with other detainees due to his cooperative behavior. Prior to being housed in the dormitory, jail policy required a visual strip search for detainees arrested for at least a serious misdemeanor. During this search, officials discovered a plastic bag containing methamphetamine concealed beneath Sutton’s genitals. Sutton was subsequently indicted for possession of methamphetamine with intent to distribute.Sutton moved to suppress the evidence found during the strip search, arguing it was an illegal search under the Fourth Amendment. The motion was first reviewed by a magistrate judge, who recommended denial. The United States District Court for the Northern District of Iowa adopted the magistrate’s recommendation over Sutton’s objection. Sutton then entered a conditional guilty plea, reserving his right to appeal the denial of his suppression motion.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to suppress, applying a clear error standard for factual findings and de novo review for legal conclusions. The Eighth Circuit held that, under the Supreme Court’s decision in Florence v. Board of Chosen Freeholders of County of Burlington, jail officials may conduct strip searches of detainees who will be housed with others, even absent reasonable suspicion or probable cause, unless substantial evidence shows the search was unnecessary or unjustified. The court found no such evidence in Sutton’s case and affirmed the district court’s denial of the motion to suppress, concluding the strip search did not violate Sutton’s Fourth Amendment rights. View "United States v. Sutton" on Justia Law

Thomas Riles, who suffers from Gardner syndrome and requires regular medical intervention using a Barnett Continent Intestinal Reservoir (BCIR), was arrested for speeding while urgently seeking a restroom to drain his BCIR. During his arrest and subsequent detention at Carroll County Detention Center (CCDC), Riles alleged that officers failed to provide him with necessary medical supplies and assistance, despite his repeated requests and clear communication about his medical needs. As a result, Riles experienced complications, including permanent damage to his BCIR, leading to a significant alteration in his lifestyle and employment capabilities.Riles filed a lawsuit in the United States District Court for the Western District of Arkansas, asserting claims under 42 U.S.C. § 1983 for deliberate indifference to his serious medical needs against several defendants, including Officer Laralyn Koster. The district court granted summary judgment in favor of most defendants but denied it as to Koster on the deliberate indifference claim, concluding that a reasonable jury could find, based on the evidence, that Koster was aware of and disregarded Riles’s substantial risk of serious harm. Koster appealed this denial, arguing she was entitled to qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the interlocutory appeal. The court determined it lacked jurisdiction to consider the appeal because the issues raised involved disputed facts and credibility determinations, which are not within the scope of interlocutory review under the collateral order doctrine. The court held that its authority extends only to abstract legal questions and not to factual disputes that a jury must resolve. Accordingly, the Eighth Circuit dismissed Koster’s appeal for lack of jurisdiction. View "Riles v. Koster" on Justia Law

In 2018, BAPTKO, Inc., wholly owned by Robert Kupper, agreed to sell two car dealerships in North Dakota to Foundation Automotive Corp. The agreement included provisions regarding inventory management prior to closing, contingent earnout payments based on dealership performance, and an attorney’s fees clause for prevailing parties in disputes. Foundation Automotive Corp. later assigned its interests to two LLCs connected to each dealership. After the sale, relations deteriorated: the LLCs sued Kupper and related entities for breach of non-compete and tortious interference, while BAPTKO counterclaimed for unpaid earnout payments, asserting the performance targets had been met.The United States District Court for the District of North Dakota consolidated the actions. It granted partial summary judgment for the Kupper parties, holding that the Foundation parties were obligated to make the earnout payments. The district court denied summary judgment on the amount of damages, finding factual disputes. The Foundation parties conceded nonpayment but argued they were excused due to BAPTKO’s alleged prior breaches, particularly regarding inventory management. The district court rejected this argument, determining that any such breaches did not excuse performance but might affect the damages offset. At trial, the jury found BAPTKO had not breached the agreement. The district court also awarded attorney’s fees to BAPTKO, including amounts spent defending Kupper personally, and denied the Foundation parties’ post-trial motions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that the district court properly granted partial summary judgment, concluding that no reasonable jury could find BAPTKO’s alleged breaches defeated the object of the agreement. The appellate court also held that limitations on expert testimony and jury instructions were not abuses of discretion, and that the attorney’s fee award, including amounts for Kupper’s defense, was supported by the agreement and not an abuse of discretion. View "FA ND Chev, LLC v. BAPTKO, Inc." on Justia Law

Northland Management & Construction, LLC developed four lots in a Missouri subdivision, including Lot 9. The City of Parkville had approved the subdivision’s Sixth Plat, which contemplated grading Lot 9 at a continuous slope to its southern property line. During construction, Northland filled in an existing swale, installed piers to stabilize the home, and created a new swale that diverted stormwater runoff to both Lot 9 and neighboring Lot 3. The City became concerned about erosion and water flow, ultimately requiring Northland to seek a grading permit under Section 520 of the municipal code. Northland refused, believing the permit was unnecessary due to the approved plat. The City denied a final Certificate of Occupancy (CO), prompting Northland to file suit for the CO and damages for the inability to sell Lot 9 at full value.The United States District Court for the Western District of Missouri held a bench trial, where it ruled in favor of Northland on its Missouri state law inverse condemnation and equal protection claims. The court ordered the City to issue a final CO and awarded damages based on the difference in the lot’s value with and without a CO. The City complied with the order but appealed, challenging both the legal and factual bases for the district court’s rulings and the calculation of damages.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s findings that Northland graded Lot 9 consistent with the approved plat and accepted practice, and that the City’s application of Section 520 was unreasonable. The appellate court also upheld the equal protection claim, finding Northland was treated differently from similarly situated property owners without rational basis. However, the court reversed the damages award, holding that compensation must reflect only the temporary diminution in value during the period the CO was withheld, and remanded for recalculation of damages. View "Northland Management & Construction, LLC v. City of Parkville" on Justia Law

The plaintiff, a Hasidic Jewish inmate formerly housed at Iowa State Penitentiary, submitted numerous grievances and a religious accommodation request, alleging that the Iowa Department of Corrections and its officials interfered with his religious practice. The grievances included issues such as access to a mikveh, use of candles with open flames, and use of religious funds for attorney fees. Under the Iowa Department of Corrections’ policy, these grievances were reviewed by a religious coordinator and could be appealed to a statewide committee. Several grievances were denied, others were marked as untimely or improper, and the plaintiff claimed he attempted to appeal all adverse decisions but often encountered obstacles.After discovery, defendants moved for summary judgment in the United States District Court for the Southern District of Iowa. A magistrate judge recommended dismissing all claims, finding that sovereign immunity barred claims against Iowa and its Department of Corrections; most claims were barred for failure to exhaust administrative remedies; prospective-relief claims were mooted by the plaintiff’s transfer to another prison; some damages claims were time barred; and remaining claims lacked merit. The district court adopted the magistrate’s report and granted summary judgment against the plaintiff.The United States Court of Appeals for the Eighth Circuit reviewed the summary judgment de novo. The court held that Iowa had consented to suit under RLUIPA, so sovereign immunity did not bar the plaintiff’s RLUIPA claims for prospective relief against the Department of Corrections. The court determined that the district court improperly disregarded the plaintiff’s declaration regarding exhaustion of administrative remedies and reversed the dismissal of claims relating to several grievances and the accommodation request. The court also found that some prospective-relief claims against statewide officials were not moot. It reversed in part, affirmed in part, and remanded for further proceedings consistent with its opinion. View "Hamby v. State of Iowa" on Justia Law

Owners of mineral interests in Arkansas leased their interests to various oil and gas companies through private agreements. These leases required the companies to pay royalties based on gross proceeds, meaning royalties should be calculated without deducting post-production costs. In 2019, Flywheel, the operator for these leases, began deducting post-production costs from the first 1/8 royalty payment, relying on Ark. Code Ann. § 15-72-305, which refers to “net proceeds.” This change reduced the royalty amounts paid to the lessors, who then filed suit alleging breach of lease obligations.The United States District Court for the Eastern District of Arkansas reviewed the claims and granted summary judgment in favor of the oil and gas companies. The district court interpreted Ark. Code Ann. § 15-72-305 to permit deductions of post-production expenses from the first 1/8 royalty, regardless of lease terms. It relied on its own prior rulings and declined to follow an Arkansas Court of Appeals decision stating that the statute does not require deduction of post-production expenses. The district court also considered but ultimately rejected the impact of a legislative amendment, Act 1024, passed during the appeal, which clarified the meaning of “net proceeds.”The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of Arkansas law de novo. The appellate court held that Ark. Code Ann. § 15-72-305(a)(3) is ambiguous regarding permissible deductions and determined, based on legislative clarification and the Arkansas Court of Appeals’ interpretation, that deductions from the royalty are not allowed beyond those specifically permitted by the lease. The court concluded that Act 1024 clarified the original legislative intent. It reversed the district court’s summary judgment and remanded for further proceedings consistent with its interpretation. View "Pennington v. BHP Billiton Petrol" on Justia Law

The dispute centers on allegations by a Minnesota-based health insurer that several related pharmaceutical companies carried out an unlawful scheme involving the distribution and sale of repackaged and adulterated oncology drugs. The scheme allegedly involved breaking sterile seals on medication vials, pooling overfill amounts—which were not intended for patient use—and creating pre-filled syringes that were then sold to healthcare providers. These syringes were ultimately administered to cancer patients, including many insured under programs operated by the plaintiff. The defendants did not themselves submit claims for reimbursement, but the plaintiff asserts it paid for treatments using these adulterated drugs, unaware of their compromised quality.Prior to this lawsuit, the scheme was the subject of other civil actions and federal investigations, including qui tam actions and a federal criminal prosecution. The defendants disclosed these investigations in annual reports filed with the Securities and Exchange Commission and the events received media attention beginning in 2012. In 2017, a related company pleaded guilty to federal charges, admitting to the repackaging scheme, and paid significant fines and settlements. The plaintiff filed suit in 2023, asserting claims for common-law fraud, unjust enrichment, and violations of several Minnesota consumer protection statutes. The United States District Court for the District of Minnesota dismissed the complaint, finding the claims were barred by the applicable six-year statute of limitations, and that the plaintiff had failed to sufficiently plead fraudulent concealment to toll the limitations period.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It concluded that publicly available disclosures and the plaintiff’s own allegations established that the plaintiff should have discovered its causes of action no later than 2016. Because the plaintiff did not file suit until 2023, its claims were untimely. The court affirmed the district court’s judgment, holding that all claims were barred by the statute of limitations. View "United HealthCare Services, Inc. v. AmerisourceBergen Corporation" on Justia Law

Shelly Ketcher was employed as a bookkeeper for South Delta Aviation (SDA) and also managed the personal affairs of the owner, D.R. Over a five-year period, she embezzled about $2.7 million from SDA and D.R. by forging more than a thousand checks, making them payable to herself, family, and friends. Ketcher concealed her extensive criminal history of prior fraud and embezzlement convictions when she was hired. The embezzlement was discovered after D.R. found he was delinquent on property taxes and confronted Ketcher, who attempted to cover up her actions with forged documents.The United States District Court for the Western District of Arkansas handled Ketcher’s guilty plea to one count of money laundering and one count of filing a false federal income tax return. The Presentence Investigation Report calculated an advisory guidelines range of 92 to 115 months. At sentencing, after hearing victim impact statements and arguments from both sides, the court imposed an upward variance, sentencing Ketcher to a total of 156 months in prison—120 months for money laundering and a consecutive 36 months for the tax offense. The court cited the egregiousness of the offense and Ketcher’s repeated similar crimes as aggravating factors, outweighing her mitigating circumstances.On appeal to the United States Court of Appeals for the Eighth Circuit, Ketcher argued that her sentence was substantively unreasonable, asserting that the district court gave insufficient weight to mitigating factors, imposed a harsher sentence than similarly situated defendants, and was motivated by personal animosity. The Eighth Circuit held that the district court did not abuse its discretion in imposing the upward variance, found the court’s reasoning and weighing of factors appropriate, and affirmed the judgment. View "United States v. Ketcher" on Justia Law