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

Morgan Fitch, a brakeman working for BNSF Railway Company, was injured in an emergency train stop in North Dakota, suffering a shoulder injury and claiming mild traumatic brain injury. Fitch asserted these injuries prevented her from returning to meaningful employment. BNSF admitted liability for the accident but contested the extent of Fitch’s injuries and her inability to work, offering alternatives to her conductor position. Fitch declined to pursue alternative employment, and the dispute proceeded to a jury trial focusing solely on damages.The United States District Court for the District of North Dakota presided over a six-day jury trial. Both parties presented expert testimony regarding Fitch’s injuries and her ability to work. Fitch requested substantial damages based on permanent disability, while BNSF argued her injuries had healed and she could return to work. The jury ultimately awarded Fitch significant compensation for past earnings and medical expenses but nothing for lost future earnings or benefits, along with reduced non-economic damages. Fitch moved for a new trial, asserting the jury’s finding of no lost future earnings was unsupported by the evidence. The district court denied her motion, finding sufficient evidence for the jury’s verdict and declining to substitute its judgment for the jury’s.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, applying a doubly deferential standard. The appellate court concluded that the district court did not abuse its discretion in denying Fitch’s motion for a new trial, as there was ample evidence to support the jury’s findings, including conflicting expert testimony. The court held that this case did not present an exceptional circumstance requiring intervention, and affirmed the district court’s denial of the motion for a new trial. View "Fitch v. BNSF Railway Company" on Justia Law

A student enrolled in a distance doctor of pharmacy program at a university suffered a concussion, resulting in various symptoms including headaches, fatigue, vision issues, and difficulty hearing. She requested accommodations such as extended time on assignments and tests, blue light filtering glasses, and closed captioning for lectures. The university provided most requested accommodations, but denied some, including closed captioning due to lack of medical documentation, and did not allow rescheduling of certain exams or extra time for an oral presentation, citing academic policy. The student refused to update her medical documentation as requested by the university. Subsequently, she missed a required skills experience, failed to communicate adequately with faculty, and received several citations for unprofessional conduct. After accumulating four citations, the faculty voted to dismiss her from the program. She declined to pursue internal appeals and instead filed a lawsuit alleging disability discrimination and retaliation under the Americans with Disabilities Act and the Rehabilitation Act.The United States District Court for the District of Nebraska granted partial summary judgment and judgment as a matter of law in favor of the university on the discrimination claims. The court found that the university had provided reasonable accommodations and that the adverse actions taken, including dismissal, were based on unprofessional conduct and refusal to comply with academic and procedural requirements, not disability discrimination. A jury subsequently found for the university on the remaining retaliation claim.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the university had not failed to accommodate the student’s disability, as she did not sufficiently connect her requests to her disability or provide necessary documentation. The court also found no evidence of disparate treatment or retaliation based on disability. The judgment in favor of the university was affirmed. View "Florek v. Creighton University" on Justia Law

Jeremy Phillips, a convicted felon on probation, was observed by law enforcement in Waterloo, Iowa, displaying a firearm and marijuana on social media. When an officer attempted to stop Phillips as he rode his bicycle, he fled, first on the bike and then on foot, dropping a loaded firearm in a residential street before being apprehended. A search of his residence revealed additional ammunition. Phillips was charged in federal court with Possession of a Firearm and Ammunition by a Felon, to which he pleaded guilty. State charges were dismissed.The United States District Court for the Northern District of Iowa, following a Presentence Investigation Report, initially calculated a base offense level of 20 and an advisory guideline range of 30 to 37 months. The government objected, seeking a four-level enhancement under USSG § 2K2.1(b)(6)(B) for use of the firearm in connection with another felony—Interference with Official Acts under Iowa Code § 719.1(1)(a) and (f)—and a two-level enhancement under § 3C1.2 for discarding a loaded firearm. The district court applied only the four-level enhancement, raising the advisory range to 46-57 months, and imposed a 57 month sentence, citing aggravating factors.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the district court correctly applied the four-level enhancement under § 2K2.1(b)(6)(B), since Phillips’s armed flight constituted “Interference with Official Acts,” and his possession of the firearm had the potential to facilitate the offense. The appellate court also rejected Phillips’s argument that the enhancement created unconstitutional sentencing disparities under 18 U.S.C. § 3553(a)(6), finding the claim unpreserved and unsupported by concrete examples. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Phillips" on Justia Law

During the COVID-19 pandemic, Dr. Scott Jensen, a physician and former Minnesota state senator, publicly voiced opposition to vaccine mandates and business closures. As a Republican candidate for governor in 2022, he became the subject of 18 complaints alleging he spread misinformation and endangered public health. The Minnesota Board of Medical Practice initiated four investigations, each requiring Jensen to respond and cooperate fully, including providing documents and hiring legal counsel. One investigation lasted over a year and demanded an in-person conference. Jensen claims these investigations caused him to spend substantial time and money, self-censor his public statements, and decline speaking engagements due to fear of professional repercussions.The United States District Court for the District of Minnesota dismissed Jensen’s amended complaint for lack of standing, finding his allegations “too conclusory” and lacking specific instances of chilled speech or imminent enforcement threats. The court determined he did not demonstrate injury sufficient to invoke federal jurisdiction, thus preventing further review of his constitutional claims seeking damages and injunctive relief.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal. It found that Jensen’s general factual allegations of time, money spent, and self-censorship—the chilling effect—were sufficient to establish standing at the pleading stage. The court concluded that both monetary harms and reasonable self-censorship due to credible threats of enforcement constituted concrete and particularized injuries. The appellate court held that Jensen had standing to pursue his claims for damages and injunctive relief. The judgment of the district court was reversed and the case remanded for further proceedings on the merits. View "Jensen v. Minn. Bd. of Medical Practice" on Justia Law

Law enforcement attempted to stop a vehicle driven by Jeremy Martin for speeding. Martin fled both in his vehicle and on foot before being apprehended. Upon his arrest, officers discovered a pistol, ammunition, and methamphetamine in his possession. Martin, a convicted felon, was charged with being a felon in possession of a firearm under federal law and pleaded guilty to that offense. His criminal record included several recent state convictions, among them multiple drug offenses and a conviction for unlawful betting, where he had used someone else’s identification at a casino, allegedly to avoid paying a $44,000 debt to the State of Iowa. He also owed over $60,000 in child support.The United States District Court for the Northern District of Iowa calculated Martin’s advisory sentencing range at 110-137 months and imposed a sentence of 126 months, to be served consecutively to his outstanding state sentences. The court considered Martin’s criminal history, including the unlawful betting conviction, as aggravating factors. It also discussed his significant child support arrears and inferred that his attempt to use a fake name at the casino was motivated by a desire to avoid paying child support. Martin did not object to these factual statements at sentencing.On appeal, Martin argued to the United States Court of Appeals for the Eighth Circuit that the district court’s inference about his motivation for the unlawful betting offense was based on clearly erroneous facts, specifically conflating his child support debt with his other obligations to the state. The Eighth Circuit reviewed for plain error and held that the district court’s inference was a reasonable one based on undisputed facts in the presentence report. Even if the inference was mistaken, the court found that it was not a principal basis for the sentence and did not affect Martin’s substantial rights. The appellate court affirmed the sentence. View "United States v. Martin" on Justia Law

The defendant was convicted by a jury in 2015 of being a felon in possession of a firearm and ammunition. At sentencing, the United States District Court for the District of Minnesota applied an Armed Career Criminal Act (ACCA) enhancement, relying on four prior convictions, including two 1996 drug conspiracy offenses charged in the same indictment but found to be committed on separate occasions. As a result, the defendant received a 280-month sentence. Subsequent appeals and post-conviction motions challenged whether the prior offenses qualified under the ACCA, but the original sentence was largely upheld, with courts determining that the necessary number of qualifying convictions existed.The defendant later sought a sentence reduction through multiple motions for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that changes in law and sentencing policy, including a recent Sentencing Commission amendment, warranted relief. Earlier motions were denied on procedural and substantive grounds. After the Supreme Court’s decision in Erlinger v. United States, which clarified that a jury must determine whether ACCA predicate offenses occurred on different occasions, the defendant argued his sentence was now grossly disparate. The case was remanded, and the District Court again denied relief, finding any error in the original ACCA determination was harmless because no reasonable jury would have found the offenses occurred on the same occasion.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the District Court’s denial. The court held that any error in the application of the ACCA was harmless, as the record demonstrated the offenses were committed on separate occasions. Additionally, the court noted that under recent Supreme Court and Eighth Circuit precedent, nonretroactive changes in law cannot qualify as “extraordinary and compelling reasons” for sentence reduction under § 3582(c)(1)(A). The denial of compassionate release was affirmed. View "United States v. Faulkner" on Justia Law

A hailstorm caused damage to the roofs of nine condominium units owned by a homeowners’ association in Minnesota. The damage was mainly to roof-valley metals, which required the replacement of surrounding shingles. The association and its insurer, State Farm, agreed that repairs were necessary, but disagreed on whether available replacement shingles met the policy requirement of being of “like kind and quality.” This determination would affect whether State Farm needed to pay for full roof replacement or just repairs to the damaged sections.To resolve the dispute, the association invoked the insurance policy’s appraisal provision. A three-member panel was formed, consisting of appraisers selected by each party and an umpire. The panel inspected the site and evaluated the replacement shingles. By a two-to-one vote, it awarded $52,482.81 as the total replacement cost, rejecting a more expensive full reroofing. The panel’s answers to clarification questions about the appearance of the shingles caused confusion, but further clarification revealed that all the replacement shingles were the same, with differences in appearance attributed to factors like shading or fading.The United States District Court for the District of Minnesota reviewed the appraisal award, sought clarification from the panel, and ultimately granted summary judgment in favor of State Farm, confirming the award. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under Minnesota law, appraisal awards are given every presumption of validity and are binding unless ambiguous. The panel’s award was clear and not ambiguous, and the panel had settled the dispute over whether the replacement shingles were of “like kind and quality.” The Eighth Circuit affirmed the district court’s judgment, confirming the appraisal award and rejecting further review of the adequacy of the amount. View "Jamestown Villas v. State Farm" on Justia Law

A former applicant for the position of police commissioner in St. Louis alleged that after a competitive selection process, he and another white male candidate were certified as the only eligible finalists. The mayor publicly stated she did not want to select either finalist because both were white males, emphasizing the city’s diversity. The city then abandoned the original selection process, reopened the search with lower minimum qualifications, and ultimately hired a different white male candidate after two Black finalists withdrew. The plaintiff, who was ranked first and asserted he was entitled to the position under civil service rules, claimed the process was reopened solely due to the race of the finalists.The United States District Court for the Eastern District of Missouri denied the defendants’ motion to dismiss on the grounds of failure to state a claim and qualified immunity. The court found that the plaintiff had plausibly alleged an adverse employment action and a violation of clearly established equal protection rights, relying on the Supreme Court’s decision in Ricci v. DeStefano, which prohibits invalidating a selection process based on race. The defendants argued that the plaintiff suffered no adverse employment action since a white male was ultimately selected and asserted that the plaintiff had no entitlement to the promotion.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed only the denial of qualified immunity. The appellate court held that, accepting the allegations as true, the complaint sufficiently alleged that the defendants’ actions violated the plaintiff’s clearly established right to equal protection by reopening the hiring process for racial reasons and denying him promotion. The court also found the complaint adequately alleged personal involvement by each defendant. The Eighth Circuit affirmed the district court’s order denying qualified immunity and left the underlying claims to be resolved in further proceedings. View "Sack v. City of St. Louis" on Justia Law

Three men, including Dubray, went to a woman’s home in South Dakota intending to confront another individual about an alleged assault earlier that day. One of Dubray’s companions kicked open the locked door, and two entered the house while Dubray remained outside. After an altercation inside, Dubray allegedly kicked the homeowner in the face as she tried to close the door. Dubray, along with the others, was charged with first degree burglary, two counts of assault with a dangerous weapon, and witness tampering. At trial, Dubray was convicted on the burglary and assault counts but acquitted of witness tampering.The United States District Court for the District of South Dakota presided over Dubray’s trial, where he challenged various evidentiary rulings and jury instructions. The district court excluded testimony about 911 calls made from the home, denied Dubray’s proposed jury instruction regarding the “open to the public” status of the home, admitted photographs of the crime scene, and denied motions for judgment of acquittal and for a new trial. Dubray appealed these decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in excluding the sheriff’s testimony about 911 calls, as it was not probative of the home’s public status and risked confusing the jury. The district court properly refused Dubray’s proposed jury instruction, given the lack of evidentiary support and reliance on inapplicable law. The appellate court concluded that the photographs and related testimony were properly admitted, and any speculative testimony was prompted by Dubray’s own questioning. The court found sufficient evidence to support the jury’s verdict and affirmed the district court’s denial of Dubray’s motions for judgment of acquittal and for a new trial. The Eighth Circuit affirmed Dubray’s conviction and sentence. View "United States v. Dubray" on Justia Law

WPX Energy, a non-Indian oil and gas company, obtained rights-of-way from the Bureau of Indian Affairs to access land owned by members of the Three Affiliated Tribes on the Fort Berthold Reservation. The Fettigs, tribal members and landowners, consented to the grants and also entered into side letter agreements with WPX Energy, imposing conditions such as prohibiting smoking and hunting, and specifying fines for violations. In 2020, the Fettigs filed suit in the Three Affiliated Tribes District Court, alleging WPX Energy violated the no-smoking provision. WPX Energy argued that the tribal court lacked jurisdiction, as it is a non-Indian entity, but the tribal district court, through Judge Jones, found it had jurisdiction under the Montana consensual relationship exception. The Fettigs also pursued an administrative claim with the Bureau, which was denied on the basis that the side letter agreements were not incorporated into the grants.WPX Energy sought a preliminary injunction in the United States District Court for the District of North Dakota, claiming the tribal court lacked jurisdiction. The district court granted the injunction, but the United States Court of Appeals for the Eighth Circuit previously vacated it, requiring exhaustion of tribal remedies. After the Three Affiliated Tribes Supreme Court affirmed tribal jurisdiction, WPX Energy again sought relief in federal court, which again granted a preliminary injunction. Judge Jones appealed this second grant.On review, the United States Court of Appeals for the Eighth Circuit held that the tribal court had jurisdiction under the first Montana exception because the dispute arose from a commercial relationship created by the side letter agreements, which were independently negotiated and not governed by federal law. The court also found that normal litigation costs did not constitute irreparable harm. The Eighth Circuit vacated the preliminary injunction and remanded for further proceedings. View "WPX Energy Williston, LLC v. Jones" on Justia Law